Rock Dam

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An Upstream Invitation: COME VISIT; THEN PLEASE SUE US!

Posted by on 21 May 2020 | Tagged as: American shad, bascule gates, Bellows Falls VT, blueback herring, Connecticut River, Connecticut River migratory fisheries restoration, Connecticut River shortnose sturgeon, Dead Reach, Deerfield River, Dr. Boyd Kynard, endangerd shortnose sturgeon, False attraction, Federal Energy Regulatory Commission, FERC, FERC license, fish passage, Greenfield, Holyoke Fish Lift, MA Division of Fish and Wildlife, Massachusetts Division of Fish & Wildlife, migratory delay, New Hampshire, Rock Dam, shad fishing, The Dead Reach, Turners Falls, Turners Falls dam, Turners Falls power canal, US Geological Survey's Conte Fish Lab

THIS GREAT AND BROKEN RIVER V

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 5, An Upstream Invitation: COME VISIT; THEN PLEASE SUE US!

Dear Vermont and New Hampshire (and northern MA):

Our Connecticut River–as grimly battered by diversions and reversing industrial currents as it is down here in Massachusetts, is way better than yours upstream. That’s not very neighborly to say, but it’s true. Your states probably should’ve sued our Commonwealth years back for depriving you of a living river. It’s what’s been owed you. Down here we have a spring river with at least a credible ocean connection stretching all the way from Long Island Sound to just past the mouth of the Deerfield River. It really isn’t fair you don’t…


Just a single bascule gate open with thin spill at Turners Falls Dam, May 20, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrow to return to text)

Case in point: as of May 20, 2020, Holyoke Dam had passed some 130,000 American shad upstream. Enough federal and state fisheries data from studies has been produced to safely estimate that as many as 100,000 may have arrived at Turners Falls, just 36 miles distant, still heading upstream. The only data from Turners Falls Dam was reported as of May 8, 2020, showing a total of 38 shad successfully passing that site…

In the interest of good relations, I’d like to invite you downstream to experience what you’re missing. After all, everyone has a right to a living Connecticut River. Some of us just have a little more right, while others—living upstream, have forever had almost none at all. Ironically, that none even includes Bay State residents living in the towns of Greenfield, Gill, Turners Falls, Erving, and Northfield. An ocean connection for them is barely perceptible as well.

But for the rest of you far northerners, whether you live in Vernon, Brattleboro, Dummerston, Putney, Westminster or Bellows Falls VT–or Walpole, Westmoreland, Chesterfield, or Hinsdale NH, please come visit your river where it at least still remains partly tethered to its ancient ocean connection. It’s worth the trip.

And, why not bring along fishing pole?—because, truth is, we’ve been hanging on to your fish here for decades. Most of the hundreds of thousands of migrating shad, blueback herring and sea lamprey here annually never get past the Turners Falls Dam—becoming mired in the 2-1/2 mile long Dead Reach and canal diversion leading up to that ponderous obstruction. Turners Falls is where your living river connection with the ocean, ends. Thus, including all three states, 15 towns have been robbed.

Really, come down and experience what us “haves”, have. Meet us at the cull de sac of the Connecticut here, and we’ll show you where your thousands of fish are foundering. They were promised you way back in 1967, but you never received them. This is a peek at the river your kids should be experiencing at up at home today, and the one that’s the birth right of their grand kids decades into the future. Somebody should’ve stood up long ago. There should have been a lawsuit.

BTW: there’s even a free fishing weekend down here on June 6 and 7, where you don’t even need a license to toss in a line. Come! There should still be good numbers of shad and lamprey fighting the good fight upstream–right up to the dead end dam in this largely impassible reach. You need not come far; your ocean connection ends abruptly here in Turners Falls.


The ponderous–difficult for shad to find and access, fish ladder below Turners Falls Dam, May 20, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge)

If you don’t feel like waiting, and want to catch the peak of the run here in the next week or so, just grab a short term fishing license at the MA Wildlife website. Honestly though, I’m not sure they deserve your business. Massachusetts Division of Fish & Wildlife was the only entity with specific rights to intervene over the last 50 years in the federal (FERC) license governing fish passage conditions at Turners Falls if conditions changed. In the first decade of this century, the long-paltry (6-7%) fish passage success beyond that dam evaporated down to less than 1% percent in some years. That plunge began right after Massachusetts deregulated its electricity generating markets. Those were your fish! That was your last remaining thread of an ocean connection. MDFW did nothing. Like I said, there should’ve been a lawsuit. They sat on their hands. We let you down.

For that reason alone, please come and visit. Come fish. Pop on a shad dart. We’ll be happy to social distance with you.Try your luck where your fish are stuck!

And if you don’t happen to be an angler–but just want to experience what the remains of an ocean- connected ecosystem look like, bring a folding chair and just enjoy the spectacle. A living river can be quite inspiring. And witnessing sleek, healthy fish that have travelled thousands of ocean-going miles and then 120 miles upstream here to their ancient spawning grounds, might just encourage you to take action. You deserve this. And, we know exactly where your lost fish are trapped today—the same places they’ve been spinning their upstream migratory wheels and energies for decades.

The best way to locate the nearest ocean connection on the Connecticut here is to go where the currents are—go where there is still flow in the riverbed. That’s where the agitated shad will be, trying to discover and fight their way through promising upstream currents. They want to go into the flow, but that’s the bit tricky down here–as the power company is constantly jacking the currents up, down, and all around. That’s why its the river’s dead-end. Those see-saw currents and flow diversions are tricking the shad into alien industrial flows producing endless streams of what’s called “false attraction.”

Some sites, as you will see at the company’s Station # 1 outflow into the river adjacent to the Turners Falls Power Canal, dump their industrial effluent, back into the river while creating just a few small amount of hydro power.. That false upstream signal to migrating shad essentially traps them there–for hours or days on end, spending energy in that false current as they await an open upstream path that never comes.

For anglers not tied to anything like a natural setting, the Station #1site teems with scores and scores of tricked shad, ripe for the hooking. It’s a supremely ironic dead end for the fish and run—nosing for hours into a nowhere current. But, for fish-in-a-barrel anglers, this sad site can be a slam dunk.

Other sites are rather more “scenic,” but the same waffling, insufficient flows ultimately lead to dead-end routes for the vast majority of the fish run. Less than 1 fish in 10 annually ever make emerge out of the Turners Falls Power Canal–which all must pass through before popping out beyond that dam toward your Vermont and New Hampshire doorsteps. Most just give up.

Anyway, here are some visit/witnessing recommendations from my personal investigations on May 20, 2020:

Ocean Dead End Stop # 1: Turners Falls Dam, Turners Falls. Take I-91 south to Rt. 2 East. Rt. 2 E to the second set of lights, where you turn left over the Turners Falls Bridge. Park just over the bridge near the Great Falls Discover Center and find your way across the little power canal bridge and down to the river. Note that the paltry flow is unlikely to be drawing any shad upstream to the dam and fish ladder.

Lone, disappointed shad angler in low flows below dam: look far left at center, adjacent to the bend in fish ladder. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Ocean Dead End Stop # 2: Station # 1, your false attraction fishing hole. Follow the above directions—crossing the bridge into Turners Falls. Make an immediate right after passing the Great Falls Discover Center. Continue straight after the stop sign, and then make the second right, going over the SECOND, one-way bridge there. Continue along until you see the brick outline of Station # 1 on the right, adjacent to the river. If they are dumping good current here, the fish will be stacked up like sardines, nosing into the flow that will not allow them a path upstream. Anglers fish both sides of this outflow. You’ll find the paths. An exhausting dead end, for your share of the shad run. The two gents here landed 3 shad in the 10 minutes I lingered there.

Station # 1, exhausting attraction flow leading…nowhere. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Station # 1, fish-in-a-barrel fishing! Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Station # 1, bring on the net! Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Ocean Dead End Stop # 3: the Rock Dam. Continue with the above directions and go along past Station # 1, winding around until you come to G Street. Go right and continue south on G Street—do not recross the canal, or you’ll be off track. Continue down G Street to the end, where it becomes, rather ironically, “Migratory Way,” beyond the sign for the US Geological Services Silvio O. Conte Anadramous Fish Research Center. Follow this route down to the parking turnouts adjacent to the canal, and walk down the path there leading to Cabot Woods.

At the Cabot Woods site you will find a few picnic tables, but, most importantly, several severely eroded paths down to the Rock Dam. Flows to this site, critically important to endangered shortnose sturgeon, have already been tamped down enough to chase those ancient fish out of their spawning ground here. But, those same tamped-down flows weeks later here are keeping tricked shad into thinking the viable upstream flows through the notches here will somehow magically return, giving them a viable route. Sadly, they are not going anywhere. Again, some pretty good fishing here this day. These 5 anglers grabbed three in the 25 minutes I stayed along shore.

Fishing in the oft cul-de-sac attraction flow at the Rock Dam.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Note: there are far more shad struggling just downstream–attracted by the outflow of the Cabot Station hydro site. But there’s no good fishing access to these flows, some of which are designed to lead the shad into what’s been described as the “world’s longest ladder for shad,” by fisheries biologist Dr. Boyd Kynard. It’s a brutal exercise–fishladder 66 steps to fight through, which dumps them into the alien flows and environments of the power canal…

So, that’s where your fish are. Down here, where the ocean connection breaks. Come and visit! Then, take us to court to get what you deserve. It’s your river too!

Issue # 3: The River Emptied at Spring

Posted by on 13 May 2020 | Tagged as: American shad, Bellows Falls VT, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC, FERC license, FirstLight, Greenfield Recorder, Holyoke Dam, Holyoke Fish Lift, migratory fish, Narragansett, Nipmuck, Northfield Mountain, Norwottuck, Pocumtuck, Rock Dam, Rock Dam Pool, shad, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turner Falls Massacre, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont, Walpole

THIS GREAT AND BROKEN RIVER III

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 3: The River Emptied at Spring

Dismal Mother’s Day flow at Turner’s Falls Dam and Fishway Copyright © 2020 by Karl Meyer (Click X 3 for closeup, click back arrow to return to text)

It was a grim Mother’s Day weekend for the Connecticut River in Massachusetts. The only current left in the riverbed below Turners Falls Dam amounted to little more than a thin, spreading soup winding a shallow path around successive ridges of drying ledge as it threaded together a downstream path along it’s ancient, impoverished bed. Anyone with a pair of rubber boots could’ve easily walked across the Connecticut just a few hundred feet below that dam without much risk of getting wet to the knees–smack in the middle of fish migration and spawning season in the heart of the Silvio O. Conte Connecticut River National Fish and Wildlife Refuge.

There’s something soulless in starving a river of its flow—particularly in the spring when the shadbush is in bloom, the columbine have sprouted, and the fish are in the river. This year, with the corona virus draining spirits and sapping energy during March and April, the presence of a living river in Western New England’s back yard was something to anticipate come May. The light returned, the trees were in flower, birds were making music, and energy use was in its usual seasonal retreat—demand being down ever since a warmer than normal winter.


Days Earlier Flow over Turners Falls Dam May 5, 2020 Copyright © 2020 by Karl Meyer (Click X 3, back arrow to return to text)

This should have been a promising early May on New England’s Great River. But no–not here in northern Massachusetts–not this Mother’s Day weekend. For migrating American shad seeking a route upstream here, the river was literally a road to nowhere. As of Monday, May 11th, though some 18,000 shad had passed upstream at the Holyoke Fishway, 36 river miles to the south, not a single shad had been tallied managing to pass beyond the grim maze of a power canal and several ladders to emerge above Turners Falls Dam. By Monday not a single migrant from the ocean had been tallied passing that dam–thus none were present moving upstream to open Vermont, New Hampshire and northern Massachusetts habitats. The public has no access to the fishway this year, and FirstLight has not provided a simple video feed for people to see their fish. At Turners Falls, the power company alone, is left to monitor itself and report on the public’s fish.


Shad Anglers below Holyoke Dam May 7, 2020 Copyright © 2020 by Karl Meyer

But, most grimly again this May, river conditions on Mother’s Day were altogether devastating for federally-endangered Connecticut River shortnose sturgeon attempting to spawn and nurture young in the currents at their ancient Rock Dam spawning pool–a mile and a half downstream of the dam. Vital river flows at a natural basalt, in-stream formation known as Rock Dam–which had been accommodating for spawning sturgeon just a week before, were shut down to the point where the cobble shoals that shelter eggs and developing young were now visible along a receded shoreline.

Hopeful shad anglers from the adjacent USGS Conte Lab and nearby US Fish & Wildlife Service in Sunderland were present to witness the impacts. This year’s potential progeny–at the sturgeon’s only documented natural spawning site in the ecosystem, were once more left to desiccate–starved of life-giving, oxygenating water as the sun warmed the prematurely exposed, rocky shallows. Though not fishing on this Mother’s Day morning, one of the leaders of the local Nolumbeka Project stopped to inquired of me if the sturgeon had been able to successfully spawn this year. I had to tell him no.

For the second year running FirstLight Power had squeezed the bascule gates closed at Turners Fall Dam, leaving just a curtain of a few hundred cubic feet per second (cfs) of flow entering the starved riverbed below Turners Falls Dam. The Federal Energy Regulatory license for FL’s Turners Falls and Northfield Mountain operations expired two years back on April 30, 2018. . Conditions in a new license would have hopefully increased that dribbling flow at the dam by a factor of 20. Grimly, the starving of this Great River is occurring at the exact site where women, children and elders of the Nipmuck, Pocumtuck, Norwottuck and Narragensett People were set upon and slaughtered in their pre-dawn sleep in the Turners Falls Massacre on May 19, 1676.

But FERC stepped in on FirstLight’s behalf, and has now offered two years of license extensions to this Canadian-owned, Delaware-registered company, allowing these grim impacts to continue. In doing so it has now green-lighted these conditions for three consecutive spawning seasons–allowing crippling industrial practices put in place 52 years back to choke the life out of four-state migratory fish runs, and crushing the spawning prospects for those sturgeon–literally the Connecticut’s only federally endangered migratory fish species. This, in an ecosystem that should have had connected and sustaining flows and fish passage upstream to Bellows Falls VT and Walpole NH long ago.

The flows present in the river on Mother’s Day are flows that force endangered sturgeon to default downstream to attempt spawning in the pulsing industrial flows churning out of the Cabot Station powerhouse a half mile downstream. There, any spawned and developing young-of-the-year will have no defense against the scouring-out hydro surges pulsing canal water back into the riverbed below once fertilized young are dispersed in the flows to shelter in rocky shallows .

Those tamped-down Mother’s Day flows from the dam also create conditions that keep American shad in an endless Groundhog Day cycling at Rock Dam–circling and re-circling in the depleted currents at a pool where depths become too shallow to find a flow offering a negotiable upstream path. Anglers sometimes do quite well at this migratory cull-de-sac where agitated, circling shad snap at darts while wasting hours and energy in this suspended-migration.

But those same tamped down flows diverted at TF Dam also cause just-arriving American shad from Holyoke to be led directly to the false upstream currents exiting the power canal at Cabot Station. Sensing that upstream attraction flow, those unlucky fish get drawn into a ponderous and exhausting fish ladder there. There they are diverted entirely out of the riverbed and into a concrete chute where they must attempt to better an impossible series of steps, twists, and turns that will ultimately dump them into the alien and un-river-like environs of the Turners Falls power canal. Once they enter that industrial habitat, many end their upstream migrations altogether, spending weeks in the labyrinth of that walled corridor without finding a way out and upstream.

Grimly, this year was nearly a carbon copy of the brutal conditions visited below Turners Falls the week of Mother’s Day 2019. Last year at this time researchers tallied the largest-ever catch of spawning-run endangered sturgeon gathered at their Rock Dam nursery pool, corralling 48 fish in a morning survey of a biologist’s net. Days later, at the height of shortnose spawning season, FirstLight abruptly cut off life giving flows to the site. Those same banks and cobbles were exposed, and the spawning run sturgeon were sent packing—forced to abandon the site, with any embryos and young that might have proved viable left withering in the shallows.


FL’s Locked Entrance at Cabot Woods & Rock Dam mid-afternoon May 5, 2020 Copyright © 2020 by Karl Meyer

You might have expected more from FirstLight this year. This is a Canadian shareholder company seeking a new federal license to operate these facilities on the Connecticut River in Massachusetts after recently re-registering them in Delaware as tax shelters. But, now that FERC continues to allow them to profit off the grim and antiquated tenets of a license written under the Federal Power Commission 52 years ago, they seem in no particular hurry to become relicensed neighbors operating for profit on a four-state US river that is the centerpiece of a National Fish and Wildlife Refuge.

These ongoing grim flow regimes fly in the face of mandates long-ago included in the Endangered Species Act and the Anadramous Fish Conservation Act, here, in the most biologically important and critical habitat in the entire Connecticut River ecosystem. They also feel like a thumbing of the nose at Massachusetts taxpayers—as well as all the deserving citizens in the three states from Montague MA to Walpole NH, who also pay taxes and are certainly entitled to a living river. It is a form of public theft.

As the Connecticut River is left starved, its ancient fish runs foundering, there is no movement to bring to a close the Federal Energy Regulatory Commission’s “5-year” relicensing process—begun here in 2012 and lingering on, laughably unfinished. The power company continues to pocket profits, while the FERC is led by a stilted and hand-picked majority happy to feed the corporations what they want, to the benefit of foreign shareholders far from New England. Sadly, there is no state or federal environmental agency that appears willing to challenge this endless delay. And, as noted here before—this four-state river lacks a true NGO watchdog with a mission-mandate and staff lawyers protecting it. See The Greenfield Recorder: https://www.recorder.com/New-England-s-great-river-without-a-watchdog-33291778

THIS GREAT AND BROKEN RIVER

Posted by on 28 Apr 2020 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls VT, blueback herring, Canada, climate-heating, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, ecosystem, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, FirstLight Power, Holyoke Dam, Holyoke Fish Lift, Holyoke Gas & Electric, Massachusetts Division of Fish & Wildlife, Micah Kieffer, migratory fish, National Marine Fisheries Service, New Hampshire, Northfield Mountain, Northfield Mountain Pumped Storage Project, pumped storage, Rock Dam, Rock Dam Pool, shad, shortnose sturgeon, State of Delaware, The Great Eddy, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, Vermont, Vermont Yankee

THIS GREAT AND BROKEN RIVER

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 1, First Daylight for an Embattled Run

The tiniest spark of life reentered New England’s Great River on Tuesday, April 21, 2020. According to Ken Sprankle, Connecticut River Project Leader for the US Fish & Wildlife Service, the fish lifts began operating that morning at the Holyoke Dam, 82 miles from the sea. And on that day the first two migrating American shad of the spawning season were lifted upstream.


Holyoke Dam. Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x3.

I got that fragile bit of good news on Earth Day, and it was truly a bright spot in what seems a very distant and fragile time for people, ecosystems, and our beleaguered planet. And during this Covid pandemic, while our warming atmosphere is experiencing a brief respite from the particulate pummeling of jets and cars, the Connecticut is being brutalized as catch basin for all the chemicals, chlorine and antibiotics that are currently being flushing out into–and right through, our sewage treatment plants to the River… As such, the Connecticut had little to celebrate on the 50th Anniversary of Earth Day.

Nonetheless those two fish meant there would at least be some vestige of the spring run that once fed river communities for hundreds of miles along this central artery for untold centuries into the past.

It’s the public’s river, and these are the public’s fish. Those are the facts that I always keep in mind whenever I write or speak about the Connecticut. But there’s also this basic tenet for me: a river is a living system; it exists of its own right and its right to survive and thrive should thus be an unquestioned part of its existence. We humans have a moral obligation to protect the life of rivers, just as they have nourished, protected and supported the very ecosystems we’ve relied on for time immemorial.

For me, to kill a river is an immoral act. To flaunt any part of the legal framework that federal and state law has put in place protecting them is both criminal and repugnant. But maybe that’s just me…

Holyoke Dam looking toward Fish Lifts. Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x3.

Now two shad aren’t much in many minds, I’ll admit. But what those two shad—likely early males meant, was that the Connecticut had actually become a living river once more. At least a part of it. That tenuous little reconnection was completed when one fat, industrial bucket of river water was pulled from the downstream side of Holyoke Dam and dumped on the upstream side. Two living, blue-green American shad swam out into 35 miles of upstream river that all downstream fish are denied access to for some six months out of every year. That’s way less than a half-living river.

But what that tiny spark meant, more than symbolically was that—on the most basic level, the Connecticut was reopened along a tiny stretch as a true river–a TWO-WAY highway where migrating and resident fish can move both upstream and down as part of this ancient ecosystem highway.

The Holyoke Dam is historic for two reasons: First, it is the barrier at the center of the 1872 landmark US Supreme Court decision in Holyoke Company v. Lyman that established that dam owners and operators must provide passage for migratory fish—both upstream, and downstream, of their barriers. Second, though imperfect and of the simplest most basic design—i.e. upstream, in-river attraction flows leading migrating fish to be corralled in a closeable, industrial bucket and lifted over the dam–those Holyoke Fish lifts have remained the most successful fish passage on the entire East Coast since 1955.

For the next few months Holyoke’s industrial buckets will facilitate a stuttering recreation of the former Connecticut as a living, 2-way river while American shad, sea lamprey, shortnose sturgeon and blueback herring attempt to access ancient spawning grounds. For many that open habitat reaches all the way to the dam between Bellows Falls VT and Walpole NH–nearly 90 miles upriver. That ancient destination, however, remains a cruel impossibility for all but a fortunate few migrants…

The Great Eddy at Bellows Falls Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x 3.

Once again this spring the vast majority of those hundreds of thousands of fish passing upstream at Holyoke will be thwarted from reaching the wide open spawning habitat anywhere above the Turners Falls Dam. That dam sits just 35 miles upstream of the Holyoke lifts. It’s an easy swim for most– just a day, maybe two.

But once they approach that river reach and barrier there won’t be accommodating riverbed flows or any lifts offering suitable passage upstream. They’ll encounter vacillating, confused flows and a series of obstacle-filled fish ladders that funnel all migrants into the grim habitats of the Turners Falls power canal before any get an outside chance to squeeze past the dam itself. Most never do. Perhaps one fish in ten will succeed–leaving the next 68 miles of Connecticut River habitat impoverished and all but empty of its ancient migrants.

And for shortnose sturgeon, one of this river’s most ancient species and the only federally-endangered migrant in this ecosystem, prospects are yet more dire. With the actual riverbed in the 2 miles below Turners Falls Dam sporadically deluged and emptied of suitable natural current, these fish are all vulnerable to being again robbed of what should be an annual, slam-dunk spawning aggregation at their only documented natural spawning site in the ecosystem–the Rock Dam in Turners Falls. Another season will go by without life-giving mandated flows to this critical habitat due an absence of enforcement protection and license requirements.

Of course, that was to have changed two years back.

The Federal Energy Regulatory Commission licenses for operation of the Turners Falls/Cabot Station hydro sites and the Northfield Mountain Pumped Storage Project expired two years back on April 30, 2018. New flows and fish passage requirements should have been re-nourishing the endlessly pummeled and impoverished river in the beleaguered miles above and below Turners Falls Dam since that time. However, for the crippled run here, there is literally nothing new. Fish at Turners Falls today are almost as effectively blocked from moving upstream into Vermont, New Hampshire and northern Massachusetts waters as they were when the first dam across the Connecticut there blocked these runs beginning in 1798.

Today, the crushing suck-and-surge impacts of Northfield Mountain’s net-energy-loss, peak-price/peak-demand operations continue brutalizing the grimmest 10 miles in the entire ecosystem–cannibalizing the river’s fish runs and chewing through young-of-the-year. Pumped storage is not renewable energy, nor is it anything like the conventional river hydropower much of the public thinks it generates. Northfield Mountain consume vast amounts of virgin electricity from the grid here—most if it generated through imported natural gas, to pump the Connecticut backwards and a mile uphill. NMPS is in reality an energy consumer. It’s massive pull off the grid gets tallied in negative megawatts.

Today, the revival and protection of those long-ago, lawfully mandated runs remains stuck at Turners Falls and Northfield Mountain. The so-called FERC 5-year Integrated Licensing Process(ILP) that should have given them their two basic necessities for survival—water, and a safe, timely route upstream and down, actually began in the fall of 2012. It drags on to this day.

The day after FirstLight at long-last submits its final license application for examination to FERC–and the federal fisheries agencies with conditioning authority on the Connecticut, it will be September. September signals the beginning of the 9th year this supposed stream-lined FERC ILP has been malingering on this river system. FirstLight left off negotiations over a year ago with the US Fish & Wildlife Service, National Marine Fisheries Service, and the Massachusetts Division of Fisheries & Wildlife for required new river conditions and construction of fish lifts. There has been no movement since that time.

Any delay in the construction of a fish lift at Turners Falls, and the requirement for real, life-sustaining flows in the riverbed, benefits this recently-arrived power company. Their interest is in stakeholder and corporate profit—and this is a Canadian-owned outfit that re-registered all of these assets out of Massachusetts, chopping them into a series of tax sheltered Delaware LLCs in late-2018. FERC continues to allow FL “extensions of time” to make their license-required filings, delaying what have long-been federally required mandates for river and migratory fish protections.


The de-watered Rock Dam Pool where shortnose sturgeon attempt to spawn, just after 6:00 a.m., May 17, 2019. Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x 3.

FL is now citing that restructuring as another reason for delay in submitting their “final license application” until August 31, 2020—that’s two years and four months of operating and profiting from a destructive and river de- pauperizing extended license. The current extension still requires only 400 cubic feet per second to be released into the Connecticut River bed in the spring migration season through which shad attempt to move upstream in—and embattled,federally-endangered shortnose sturgeon attempt to spawn in. That’s the equivalent of substituting a small brook for a river. Sturgeon spawning fails at the Rock Dam site most years, often caused by the abrupt ratcheting of those spring flows down to little more than that trickle.

Studies and investigations by the federal fish agencies show that a massive increase in sustained spring flows are baseline requirements for a living river here. Last year n the first week of May spring flows of some 10,000 cubit feet per second were coursing down the Connecticut’s “dead reach” here–and right through the Rock Dam pool. Shad anglers were landing fish by the dozen. On May 10, 2019, USGS Conte Lab researcher Micah Kieffer put out a research net overnight in that pool. Then next morning he found 48 federally-endangered shortnose sturgeon weighing it down—the largest aggregation ever recorded there. Kieffer continued his successful sturgeon netting through the following week, until coming up empty on Friday, May 17, 2019. He got “skunked” that day after flows through the Rock Dam reach were abruptly cut by FL to a relative trickle, exposing the cobble-lined shores of that pool where embryos and young develop.

Clearly, those 10,000 cfs flows are what are necessary to restore life to this river. They are required and long overdue—at a season when electricity demand is at some of its lowest points in the year.

The first year license extension by FERC was allowed because of the shuttering of the Vermont Yankee nuclear plant upstream. VY’s excessive, night nuclear megawatts were the grim, 40 year engine that enabled Northfield Mountain to suck the river into reverse and pump it up into a 4 billion gallon reservoir to later re-create second-hand electricity at high prices.

Now restructured, FL appears in no hurry to move ahead with new licenses. Their study results have often been delayed in being handed over to the federal fisheries agencies and study teams in this relicensing–or handed in on the very last day the process requires. They seem happy to tread water and realize profits–while NMPS’s fish-eating, net-energy loss operations continue running along, largely fueled via the imported, climate-scorching, natural gas generated electricity now bloating the grid.

The longer you don’t have to put a shovel in the ground or give this US River its flows for federally-required fish passage, the more money you keep. It’s time FERC stopped letting them off the hook. Stop stringing this process along. It’s time this river was brought into compliance with 1872’s Holyoke Company v. Lyman; it’s time to comply with the federal Endangered Species Act of 1973. It is the public’s river; these are the public’s fish.

Addendum: on Friday, April 24th, USFWS’s Ken Sprankle sent a note that the Holyoke Gas & Electric had shut down its fish lifts due to accumulating debris in its assembly. They would not operate through the weekend, and a fix would be attempted on Monday. Thus, the Connecticut became a one-way stream again anywhere above South Hadley Falls, leaving the next 88 empty miles of river still in midst of an endless vigil–awaiting the migratory runs guaranteed by the Supreme Court 148 years ago. Hopefully, for those migrating shad—and perhaps other early migrants wasting another week’s precious spawning-energy reserves while knocking on Holyoke’s door, those lifts are again operating and in full motion today.

Connecticut River shortnose sturgeon: a spectacular failure to protect

Posted by on 26 Mar 2020 | Tagged as: Christopher Chaney, Christopher Cheney, Clean Water Act, Connecticut River, Connecticut River pollution, Connecticut River riverbank failure, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, Endangered Species Act, EnviroSho, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, FirstLight Power Resources, Kimberly D. Bose, MA Division of Fish and Wildlife, manganese pollution, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, NMFS, P-1889, Rock Dam, Secretary Kimberly Bose, Turners Falls, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, www.whmp.com

Connecticut River shortnose sturgeon: a spectacular failure to protect
Copyright © 2020, by Karl Meyer. All rights reserved.

Photo Copyright © 2020, by Karl Meyer (click X3 to enlarge)
Well over 4 months since I registered my October 9, 2019 Comments describing critical erosion and polluting impacts on the Connecticut River at fragile habitat at the Rock Dam in Turners Falls–the sole documented natural spawning site for the federally endangered shortnose sturgeon in this river FirstLight Power Resources received instructions from the Federal Energy Regulatory Commission’s Christopher Cheney at the Office of Hydro Compliance. On February 21, 2020, they included the following:

“Dear Mr. Traester:

On October 9, 2019, we received a complaint regarding erosion in the bypassed reach of the Turners Falls Project No. 1889. According to the complaint, releases from the dam caused erosion in the area known as the Rock Dam in the project’s bypassedreach. For us to complete our review of the of the complaint, please file the followinginformation within 30 days of the date of this letter:

1. Photographs and the location(s) and an estimate of the extent(s) (e.g., height, width, depth) of the erosion in the bypassed reach identified in the October 9, 2019complaint.”

Here are some key points, verbatim, from my October 9, 2019 letter, including impacts on this fragile endangered-species spawning site and habitat—and addressing as well, federal and state laws and license conditions:

“In recent weeks I have noted increasingly steady water leakage in the riverbanks above the Rock Dam site, leading to constant water flow intrusions along these banks. Less than 400 feet away sits the downstream, outer-right banking curve of the Turners Falls power canal, which is the apparent source of these increasing water intrusions.
Photo Copyright © 2020, by Karl Meyer.

In a visit to the Rock Dam site on October 8, 2019, I noted the dramatic collapses of a long section of riverbank adjacent to the Rock Dam. This collapse, of some 25 feet in width and dropping down between 5 – 10 feet toward the river, is apparent in my attached photo. Please note that the draped yellow jacket in the foreground is approximately 3-1/2 feet across. This new bank collapse is just south, by perhaps 30 feet, from an earlier recent collapse of a smaller scale of some 6 feet across, occurring at approximately the same bank level. At both of these sites there has been a serious leaching of manganese, the red colored flow toward the river and the sand and cobbles that constitute the shortnose sturgeon spawning site and egg/embryo nursery unique to this reach. Photo Copyright © 2020, by Karl Meyer. (click X3 to enlarge)

Please take action requiring immediate remedy to this situation, which appears to concern license and statute infractions that run afoul of the federal Endangered Species Act, the Clean Water Act, and Article 17 concerning erosion; Article 19, concerning construction and maintenance; Article 18 concerning fishing access; and Article 35 concerning State Historic Preservation under the current license for P-1889.”
Photo Copyright © 2020, by Karl Meyer (click x3 to enlarge)

FirstLight responded on March 20, 2020. They included an all-but-useless satellite shot for a federal agency that has exact information on this site, and pictures of boulder-rubble that connect directly to their dumped rubble that is currently tumbling from their ancient attempts to shore up the failing Connecticut River banks above and adjacent to the TF power canal.
This is evidence of the power company’s failure in decades past. They now attempt infer that the tumbled rocks here are the work of the public and fishermen, not the failed detritus of their ongoing neglect.

FirstLight also failed to address the requested measurements from FERC. And, as to my original complaint, they leave out any mention of manganese, the intrusions and water—and it’s leaching and crumbling connections to the Turners Falls power canal; as well as failure to protect and maintain critical shortnose sturgeon spawning habitat. Nor does FL address the ESA, Clean Water Act, and current FERC license conditions required at this site. Below are excerpts from FL’s response, and below that is a link that you may be able to use to access FirstLight’s full response to FERC:

“FirstLight cannot provide dimensions of the extent of the erosion because there is no evidence of any recent erosion in this natural river channel.”
Above photo taken March 25, 2020 w/sturgeon expert Dr. Boyd Kynard at right, on the failed banks adjacent to Rock Dam. (click X3 to enlarge) Photo Copyright © 2020, by Karl Meyer.

Further, FL states, “Photographs were taken on October 29, 2019, after the October 9, 2019 complaint letter. Note moss on the rocks located within the side channel in Photos Nos. 1 and 2, indicating the preexistenceof a wet environment. Note also a Photo No. 3 showing ~12” rocks placed across the side channel. This section of the bypass reach is frequented by the public in summer months. The rocks aligned across the side channel appear to have been placed by unknown members of the general public, possibly to form a barrier or walk path across the side channel, suggesting that the channel is frequently wetted.”

You may be able to access FirstLight’s full response to FERC by copying an pasting the link below:https://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20200318-5043

You may also want to Comment directly to the Federal Energy Regulatory Commission.
Here’s how:
Go to www.ferc.gov ; then to file E-Comment; from there to Documents and Filings; then to Hydro; then to Washington DC; then paste-in P-1889 for the Project # (you must have this), then check the little X Box; then address your comments to “Secretary Kimberly D. Bose” and comment away! Make sure to include your own contact information.

AND, from FERC Hydro Compliance: Christopher.Chaney@ferc.gov

Also, you may want to contact your agency representatives negotiating on the public’s behalf in the current FERC relicensing. They will assuredly forward your message to their Department Chiefs who are responsible for the CURRENT license and river conditions and enforcement:

For the National Marine Fisheries Service: julie.crocker@noaa.gov
For US Fish & Wildlife Service: ken_sprankle@fws.gov ; melissa_grader@fws.gov
For MA Div. of Fish & Wildlife: caleb.slater@state.ma.us

There’s also your federal and state/local reps: Warren, McGovern, Comerford, etc., all represent you! And, you can write to the local media—this effects all at the ground level, and into the future.

Also, a few recent radio spots addressing this issue, below, with thanks to Bob, d.o., and Glen!

The Enviro Show

The Shortnose Sturgeon are Coming to Spawn –in THIS?

FERC orders Canada’s FirstLight to investigate ITSELF on ESA impacts

Posted by on 27 Feb 2020 | Tagged as: Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, ESA, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, FERC Secretary Kimberly D. Bose, FirstLight, Kimberly D. Bose, MA Division of Fish and Wildlife, National Marine Fisheries Service, Rock Dam, Rock Dam Pool, Secretary Kimberly Bose, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS

Photo Copyright © 2020, by Karl Meyer.
NOTE: the above photo was taken on 2/25/20 at the Rock Dam pool in Turners Falls. This is the ONLY documented natural spawning site for the federally endangered shortnose sturgeon on the Connecticut River. NOTICE: the Connecticut River shortnose sturgeon is the ONLY federally-endangered migratory fish in the entire ecosystem. Shortnose sturgeon will be returning to the grim conditions in this ancient spawning pool in just 7 weeks.(Click, then click twice more to enlarge)

I sent the Federal Energy Regulatory Commission the following letter in October of 2019.

Karl Meyer, M.S. Environmental Science October 9, 2019
91 Smith Street
Greenfield, MA, 01301
karlmeyer1809@verizon.net

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

ILP COMMENTS re: Turners Falls Hydroelectric Project P- 1889, and Northfield Mountain Pumped Storage Project P-2485.

Dear Secretary Bose,

These comments are made with respect to immediate concerns respecting P-1889 and operations of the Turners Falls Dam and power canal impacting the riverbanks and the spawning habitat of the federally-endangered Connecticut River shortnose sturgeon at the Rock Dam, this species’ only documented natural spawning site in the Connecticut River ecosystem. I have been a participating Stakeholder in the FERC relicensing process for P-1889 and P-2485 since 2012. I serve on the Fish and Aquatics Studies Team for both these projects.

In recent weeks I have noted increasingly steady water leakage in the riverbanks above the Rock Dam site, leading to constant water flow intrusions along these banks. Less than 400 feet away sits the downstream, outer-right banking curve of the Turners Falls power canal, which is the apparent source of these increasing water intrusions.

In a visit to the Rock Dam site on October 8, 2019, I noted the dramatic collapses of a long section of riverbank adjacent to the Rock Dam. This collapse, of some 25 feet in width and dropping down between 5 – 10 feet toward the river, is apparent in my attached photo. Please note that the draped yellow jacket in the foreground is approximately 3-1/2 feet across. This new bank collapse is just south, by perhaps 30 feet, from an earlier recent collapse of a smaller scale of some 6 feet across, occurring at approximately the same bank level. At both of these sites there has been a serious leaching of manganese, the red colored flow toward the river and the sand and cobbles that constitute the shortnose sturgeon spawning site and egg/embryo nursery unique to this reach.

Of most import in the licensing and management of this critical habitat is the damaging, new eroded channel flowing around the Rock Dam site on river left that has grown from a trickle in the mostly rain-free months of this year’s late summer and early fall—until, by yesterday, October 8, 2019, it had grown to torrent of new water coursing through a new channel adjacent to those collapsing river banks. The corresponding connection to this dramatically increasing damage appears to stem from the increased flows currently being released from Turners Falls dam to facilitate the week-long dewatering of the Turners Falls canal, currently in progress. See attached photo of TF dam release on that day. This new channel presents an immediate threat, through deposition and erosion and pollution, to the spawning and early life stage development of shortnose sturgeon in the rock, sand, and cobble habitats at the Rock Dam pool, immediately downstream and adjacent.

Immediate action appears to be necessitated by these developments. This riverbank and traditional fishing access has been neglected and poorly maintained through the last decade. A cursory look would find neglected concrete pilings where steps were to be built, as well as literal sink holes in at least two sites in areas above these collapsed banks, where small hemlock trees are now sunk to the depth of 4 feet.

Please take action requiring immediate remedy to this situation, which appears to concern license and statute infractions that run afoul of the federal Endangered Species Act, the Clean Water Act, and Article 17 concerning erosion; Article 19, concerning construction and maintenance; Article 18 concerning fishing access; and Article 35 concerning State Historic Preservation under the current license for P-1889.

Thank you for your careful review of these matters; they are of immediate import.

Sincerely,
Karl Meyer

Cc:
Doug Bennett, FirstLight
Julie Crocker, NMFS/NOAA
Ken Spankle, USFWS
Melissa Grader, USFWS
Caleb Slater, MA Div. of Fish & Wildlife,
Rich Holschuh, Elnu-Abenaki”

Photo Copyright © 2020, by Karl Meyer.

Just one small section of FirstLight’s collapsing riverbank and the pollution that runs into the Rock Dam pool just 40 feet away. This is just 250 yards away from the USGS S.O. Conte Anadromous Fish Research Center. (NOTE: Click, then click x2 to enlarge)

NOTE: Over 4 months later the Federal Energy Regulatory Commission finally took the bold action to order Canadian-owned, Delaware-registered FirstLight to investigate and report on their own impacts on this critical endangered species habitat on the Connecticut River. THE ORDERS ARE BELOW:

FEDERAL ENERGY REGULATORY COMMISSION
Washington, D. C. 20426
OFFICE OF ENERGY PROJECTS
Project No. 1889-090 – Massachusetts
Turners Falls Hydroelectric Project
FirstLight Hydro Generating Company
VIA FERC Service
February 21, 2020

Mr. Donald E. Traester
Manager, Regulatory Compliance
FirstLight Power Services, LLC
99 Millers Falls Road
Northfield, MA 01360
Subject: Complaint – Erosion

Dear Mr. Traester:
On October 9, 2019, we received a complaint regarding erosion in the bypassed
reach of the Turners Falls Project No. 1889. According to the complaint, releases fromthe dam caused erosion in the area known as the Rock Dam in the project’s bypassed reach. For us to complete our review of the of the complaint, please file the following information within 30 days of the date of this letter:

1. Photographs and the location(s) and an estimate of the extent(s) (e.g., height,
width, depth) of the erosion in the bypassed reach identified in the October 9, 2019complaint.

2. The dates and timing of the Turners Falls power canal drawdown, why it was
performed during this time, whether it was typical of past drawdowns, and what
measures you took to protect downstream resources and the public.

3. Flow data for the entire period identified in item 2, including releases from the Turners Falls dam.

4. A comparison of the flow releases into the bypassed reach during this drawdown
to historical releases into the bypassed reach (e.g., for maintenance purposes,
naturally occurring high flows, etc.)

5. Any additional information you believe is pertinent to the allegations raised in the October 9, 2019 complaint.

20200221-3033 FERC PDF (Unofficial) 02/21/2020
Project No. 1889-090 – 2 –

The Commission strongly encourages electronic filing. Please file the requested
information using the Commission’s eFiling system at http://www.ferc.gov/docsfiling/efiling.asp. For assistance, please contact FERC Online Support at
FERCOnlineSupport@ferc.gov, (866) 208-3676 (toll free), or (202) 502-8659 (TTY). In
lieu of electronic filing, please send a paper copy to: Secretary, Federal Energy
Regulatory Commission, 888 First Street NE, Washington, D.C. 20426. The first page of any filing related to this letter should include docket number P-1889-090.
If you have any questions regarding this letter, please contact me at (202) 502-
6778 or Christopher.Chaney@ferc.gov.

Sincerely,
Christopher Chaney, P.E.
Engineering Resources Branch
Division of Hydropower Administration
and Compliance

Intervening for the Connecticut River Ecosystem

Posted by on 13 Nov 2019 | Tagged as: Connecticut River ecosystem, Connecticut River shortnose sturgeon, Douglas Bennett, Dr. Boyd Kynard, Endangere Species Act, ESA, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, Federal Recovery Plan, federally-endangered Connecticut River shortnose sturgeion, FirstLight Power Resources, Kleinschmidt Associates, Micah Kieffer, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, Northfield Control Room, Northfield Mountain Pumped Storage Project, P-1889, P-2485, Recovery Plan for the Shortnose Sturgeon (Acipenser brevirostrum), Rock Dam, Secretary, Section 9–Prohibition of Take Section 9(a)(1), Steven Leach, Turners Falls dam, Uncategorized, US Fish & Wildlife Service, US Fish and Wildlife Coordination Act

NOTE: below, find photographic evidence and the text of my Request for Rehearing delivered to Federal Energy Regulatory Commission Secretary Kimberly D. Bose on August 11, 2019. My request was granted. I will update this posting when FERC delivers its decision on whether FirstLight can be approved for several Transfer of License applications while being out of compliance with current license requirements that have impacted the critical habitat and spawning of a federally-endangered migratory fish. Text begins below photos.

ALSO here: https://www.youtube.com/watch?v=WZVyFgoFYyA is a link to Episode 187 of Local Bias that I recorded with host Drew Hutchison at the studios of Greenfield Community Television. It is running throughout November on GCTV, and has been broadcast in Hadley, MA, HQ home of Region 5, US Fish & Wildlife Service.


PHOTO: dewatered shortnose sturgeon spawning pool at the Rock Dam in the early hours of May 17, 2019. (Click x3 to enlarge)
Photo Copyright © 2019 by Karl Meyer All rights reserved.


PHOTO: Closed bascule gates and cut-off flow to the main stem Connecticut River on the morning of May 17, 2019. (Click x3 to enlarge)
Photo Copyright © 2019 by Karl Meyer All rights reserved.

Karl Meyer, M.S. Environmental Science
91 Smith Street
Greenfield, MA, 01301
karlmeyer1809@verizon.net

August 11, 2019

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

Request for a Rehearing of Commission’s July 11, 2019 Order Approving Transfer of License and Substitution of Relicensing Applicant for P-2485-077, FirstLight Hydro Generating Company to Northfield Mountain LLC; and P-1889-088, FirstLight Hydro Generating Company to FirstLightMA Hydro LLC.

Specifically: the FirstLight Hydro Generating Company, Project No. 2485-077 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. 1889-088, FirstLight MA Hydro LLC ) APPLICATION FOR APPROVAL OF TRANSFER OF LICENSE, SUBSTITUTION OF APPLICANT, AND REQUEST FOR EXPEDITED CONSIDERATION

Dear Secretary Bose,

I request that the Commission rehear and review its expedited decision regarding P-2485 and P-1889. This request is being made in part because I believe the Commission erred when it stated in its approvals of the transfers under the Section D headings that “The Transferer is in Compliance with the License.”

FERC’s decision that FirstLight, in its Section 12 Discussion statements, “demonstrated this transfer is in the public Interest,” was made in error—particularly with respect to its Section 16 statements that, “Our review of the compliance history of the project shows that the licensee has been in compliance.” And further, in FERC’s Section 17 Discussion statements that, “In conclusion, we find that Northfield’s transfer application demonstrates that it is qualified to be the licensee for the project. In this case, the transferee has provided documentation showing its fitness to comply with the terms and conditions of the license.”

My request for a rehearing and withdrawal of the Commission’s July 11, 2019 decision granting these license transfers is that FirstLight was not in compliance of the terms and conditions of its license on May 17, 2019 respecting the federal Endangered Species Act, Section 9.(ESA section 9 makes it unlawful to take (harass, harm, kill, etc.) any endangered species.), as well as Article 45: “The operating of Project No. 2485 shall be coordinated with the operation of Project No. 1889.”

Section 9–Prohibition of Take Section 9(a)(1) makes it illegal to take²² an endangered species of fish or wildlife. The take prohibition has been applied to most threatened species by regulation. ²² *: Take–to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct (section 3 of the ESA–definitions). Harm means an act that actually kills or injures wildlife, and may include significant habitat modification or degradation where it actually kills or injures wildlife by significantly impairing essential behavioral patterns, including breeding, feeding, or sheltering (50 CFR § 17.3, § 222.102).

On May 9, 2019, US Geological Services Micah Kieffer, Research Fishery Biologist at the LSC Conte Anadromous Fish Laboratory detected a signal from a radio-tagged shortnose sturgeon at the Rock Dam, a documented natural SNS spawning site on the Connecticut River. Kieffer, a sturgeon specialist, set two nets in the river overnight, and returned early on the morning of May 10, 2019, to find 48 federally endangered shortnose sturgeon in those nets.

In turn, on May 13, 2019, Kieffer emailed a report of this finding in his ongoing work to biologists and various interested parties and SNS stakeholders, noting: “This past Thursday evening we dropped two gill-nets in the Rock Dam pool. Expecting to capture only a few fish, on Friday morning we instead landed 48 individuals: four females (two pre-spawning, one running, one spent) and 44 males (all running sperm) (pers. comm.)” Duly apprised of the presence and apparent spawning activity of that federal endangered species were two biologists working for FirstLight Power Resources–Steven Leach, Senior Fishery Biologist, FirstLight Power Resources, Inc., and Chris Tomichek, Senior Manager, Kleinschmidt Associates, working as a FL consultant.

In an updating May 22, 2019 email that again included fishery and agency biologists and stakeholders, including myself and FL’s Steven Leach and Chris Tomichek, Kieffer noted:

“Greetings to all SNS stakeholders:
Here is an update on the monitoring of SNS spawning at Montague for 2019. Following the May 13 report, we set additional nets on three days (May 14, 16, and 17), mostly at Rock Dam, but a few at Cabot and the Deerfield River, all day-sets to avoid excessive captures like that we experienced on 5/10. These efforts resulted in the additional capture of 11 fish on 5/14 and another 11 on 5/16 (we got skunked on the 17th). Within these efforts, we captured an additional female running eggs that received an external tag, and we also internally tagged three males, two that we PIT-tagged 25 years ago!”

Having been apprised of SNS spawning activity having been observed at Rock Dam on May 10, 2019, I found the Rock Dam spawning and rearing site had had its flows cut and its banks dewatered just a week later, on the morning of Friday, May 17, 2019. That is the same morning when Kieffer later recorded getting “skunked” at Rock Dam. Upstream, FL had shut bascule gates 2, 3, and 4, while pinching down Bascule 1 to just a few hundred CFS. See photos attached. Flow at the Rock Dam had been ramped down to a shallow lick of whitewater, while robust flows have been documented as necessities for females to remain on that spawning ground. Further, the cobble banks had been dewatered, habitat where embryos shelter and develop. The practice is lethal.

In short, FL’s actions at the dam, controlled from upstream at the Northfield Mountain Pumped Storage Station, directly interfered and imperiled SNS spawning. They did this at a time when they were apprised of SNS presence and should have executed the utmost diligence—FL, of its own volition, was in the process of implementing its own test flows for the By Pass reach.

The presence and spawning activity requirements of shortnose sturgeon in the project areas–and within the influences of P-1889 and P-2485 has been known by the license holders for decades. Indeed, several studies were referenced in the PAD, before the beginning of the current relicensing:

From the Northfield Mountain/Turners Falls Pre-Application Document, October 2012, Section 6:

LITERATURE AND INFORMATION SOURCES CITED IN THE DESCRIPTIONS AND SUMMARIES OF EXISTING RESOURCE DATA (18 C.F.R. § 5.6 (c)(2)), pp. 297. – 301
Fish and Aquatic Resources, Sections 6-3, 6-4, 6-5.

Kieffer, Micah & Boyd Kynard. (2007). Effects of Water Manipulations by Turners Falls Dam Hydroelectric Complex Rearing Conditions for Connecticut River Shortnose Sturgeon Early Life Stages. S.O. Turners Falls. MA: Conte Anadromous Fish Research Center.

National Marine Fisheries Service (NMFS). (1998). Recovery Plan for the Shortnose Sturgeon (Acipenser brevirostrum). Prepared by the Shortnose Sturgeon Recovery Team for the National Marine Fisheries Service, Silver Spring, Maryland. 104 pages.

In an email to SNS stakeholders from FirstLight Manager Douglas Bennett, responding to an inquiry from US Fish & Wildlife Biologist Melissa Grader about see-sawing flows and bascule gate settings, Bennett noted that the FL settings impacting SNS spawning and habitat in the By Pass at Rock Dam in the P-1889 Project area had been implemented in the control room of NMPS, P-2485:

“On Friday morning at approximate 1000 the flows receded enough so that the 6500 cfs by-pass flows were initiated by discharging 4400 cfs over Bascules 1 and 4 and 2100 cfs at TF #1 Station.

The 6500 cfs by-pass flows were maintained until 2400 on Saturday evening when by-pass flows were dropped to 4400 cfs, discharging 2400over Bascule gate 1 and 2100 at TF #1 Station. This was an error on our part due to misinterpretation of conflicting schedules in the Northfield Control Room. Corrective actions have been taken to prevent this going forward.”

I witnessed the Rock Dam water-starved and bank-exposed at 5:30 a.m., and my photo of the listless spill with ONLY Bascule 1 open, was taken at 7:30 a.m. Mr. Bennett’s note states that flows had not come down enough to implement FL-initiated test flows until 1000 hrs. He did not mention the setting hours earlier that I documented. Thus, apparently, there had been a ramping down of the bascule from within the NMPS control room sometime in the early morning hours, with the result of further impacts on spawning SNS through a jumble of see-sawing gate settings.

The Commission notes in its granting of these Transfers that “Section 8 of the FPA requires “any successor or assign of the rights of such licensee . . . shall be subject to all the conditions of the license under which such rights are held by such licensee and also subject to all the provisions and conditions of [the FPA] to the same extent as though such successor as assign were the original licensee.”24. FirstLight, at a time when it was apprised of the presence of a federally endangered species did not meet its license requirements here—regarding the ESA Section 9, and the only federally-endangered migratory fish in the Connecticut River

The Commission further stated that, “Northfield is affiliated with companies in the operation and maintenance of hydroelectric projects and will have access to their expertise.” Their actions clearly demonstrate there was no expertise shown or relayed between P-2485 and P-1889 at this critical time.

The Commission noted, in their decision: “In conclusion, we find that Northfield’s transfer application demonstrates that it is qualified to be the licensee for the project. In this case, the transferee has provided documentation showing its fitness to comply with the terms and conditions of the license.”

Their actions clearly call the company’s fitness to operate these plants into question. Is FERC’s finding that these transfers are “in the public’s interest” valid? FL clearly did not coordinate operations between P-2485 and P-1889 at this critical time, which is clearly spelled out in Article 45 of their license. Those actions should have been updated with the Commission and investigated before a Transfer finding was granted. An investigation and exploration of impacts and penalties under Section 9 of the ESA should be undertaken by the Commission before these transfers are validated.

I therefore request that the Commission undertake a rehearing of these license transfers. The grantor and grantee need to demonstrate they can comply with federal regulations to operate these facilities. Please see attachments.

Thank you for your careful review of these matters.

Sincerely,
Karl Meyer

Who is protecting New England’s Great River??

Posted by on 15 Jul 2019 | Tagged as: Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, ecosystem, Endangered Species Act, Federal Energy Regulatory Commission, federal trust fish, federally-endangered Connecticut River shortnose sturgeion, FERC, FirstLight Power, Fish and Aquatics Study Team, limited liability corporation, LLC, Northfield Mountain Pumped Storage Station, Rock Dam, Rock Dam Pool, shortnose sturgeon, Society of Environmental Journalists, State of Delaware, The Daily Hampshire Gazette, The Greenfield Recorder, Treasury Board of Canada, Turners Falls dam, US Fish & Wildlife Service, US Geological Survey, US Geological Survey's Conte Fish Lab, USFWS

The following piece appeared in The Greenfield Recorder on June 27, 2019, and in the Daily Hampshire Gazette on July 17, 2019. The original title ran as “Sturgeon Revival on the Connecticut.” www.recorder.com, www.gazettenet.com .
Ruined Rock Dam spawning and nursery site on May 17, 2019. At upper left is one of the extremely sensitive island habitats that rafters repeatedly trammeled. NOTE: Click, then click twice more to enlarge. Photo Copyright © 2019 by Karl Meyer, All Rights Reserved.

Story, Copyright © 2019 by Karl Meyer. All Rights Reserved.

Something remarkable occurred below Turners Falls this May: four dozen federally-endangered Connecticut River shortnose sturgeon were discovered at their embattled spawning and nursery site–the largest documented aggregation since long-term research began there in 1992.

In the afternoon of May 8, 2019 when US Geological Services biologist Micah Kieffer walked down to the river near the Silvio O. Conte Anadromous Fish Research Center, he got a surprise “burp” on the receiver he carried. That meant just one thing: a radio-tagged sturgeon was nearby. Since early spring consistent high flows had coursed down the riverbed—a rarity in the oft-emptied, 3-mile reach below the Turners Falls Dam controlled by FirstLight Power. Kieffer hustled back to the USGS Lab, gathering armloads of equipment and securing a boat. By nightfall he’d set out nets, hoping to find a few sturgeon where they’ve likely spawned for thousands of years–a unique, cobble-bottomed pool downstream of the dam.

The big shock came first thing next morning. Weighing down the nets were 48 squirming, 2-3 foot long, endangered sturgeon–one female “running eggs”; the males all running sperm. Kieffer worked quickly to catalogue each fish; returning all to the current. Across a quarter century of intensive federal research started under Amherst’s Dr. Boyd Kynard and continuing under Kieffer, this was a critical discovery near a place called Rock Dam—which hosts a single, tiny rapid. That site is critical to the shortnose’ recovery—it’s a unique biological refuge, and their only documented natural spawning site in the ecosystem.

Life-giving spring flows have been rare below Turners Falls Dam for nearly a half century. Most years currents get violently see-sawed up and down and diverted in and out of the riverbed at that dam via computers operated from inside the 1972 Northfield Mountain Pumped Storage Station, seven miles upstream. Those disruptions help service the massive water and energy appetite of Northfield’s pumped storage electricity regeneration and resale regime. Most years spawning success for this 200 million year-old sturgeon species fails at Rock Dam. That flow chaos has also long-handicapped the stalled, four-state federal Connecticut River Cooperative Fisheries Restoration for shad and herring here.

But this year, nourishing high flow continued through that critical biological reach right into the height of shortnose spawning season—which extends to late May. Operating with minimal staff, Kieffer again managed to anchor “day-set” nets in the river on May 15th and 16th. He got 11sturgeon on each of those days. But when nets were set again on May 17th he suddenly found himself skunked.
Exposed, dewatered shoals in shortnose sturgeon spawning and nursery habitat below Rock Dam.
Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. Click x3 to ENLARGE>

At 7:30 on the morning of May 17th, just a single gate spilled a thin stream of water into the channel below Turners Falls Dam. Though river flows had been slowly subsiding, when FirstLight pinched those gates shut they were pulling the plug on spawning flows. According to Dr. Boyd Kynard in his 2012 book, Life History and Behavior of Connecticut River Shortnose and Other Sturgeons, “Flow reductions that occurred while fish were spawning at RockD caused SNS to leave the area, and after females left, they did not later return to RockD spawning habitat.” What’s worse, that abrupt tamp-down dewatered the cobble bottom and shoals below Rock Dam where spawned eggs and embryos shelter and develop through June. It’s deadly.

Later that morning two gates were opened, re-ramping currents in the river. Over the ensuing days US Fish & Wildlife Service representatives noted gates alternately waffling flows up and down in sturgeon spawning time—from two open, down to one; later up to three. Perhaps encouraged by those settings, on May 29th a rafting company was seen repeatedly sending loaded, lumbering rafts over Rock Dam and walking them up onto sensitive island habitats.

FirstLight and those commercial rafters have long been apprised and legally aware of the presence of endangered sturgeon—federal studies are part of the relicensing record here. Liability is spelled out under the Endangered Species Act. A single act of interference with a federally endangered sturgeon carries a penalty of $49,000 and possible jail time. Those dam settings resulted in grim biological conditions at a time FirstLight should have been exercising utmost care: this was in the midst of their providing experimental flows from the dam to fulfill license requirements for migrating shad while meeting sturgeon spawning needs.

This December, FirstLight reregistered their Northfield and Turners Falls facilities in a series of tax-sheltered, limited liability corporations in the State of Delaware. As a venture capital firm, parent-owned by the Treasury Board of Canada, they’re seeking a new federal license to operate on this U.S. River in our Commonwealth for decades to come. This critical reach should not become a cash-cow playground for corporate shareholders or joyriding rafters. It’s time to celebrate the shortnose sturgeon, and time to let a river heal.

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.

Why no FISH?, STILL???

Posted by on 30 Apr 2019 | Tagged as: American shad, Atlantic salmon, Bellows Falls Fishway, blueback herring, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River migratory fisheries restoration, Connecticut River Watershed Council, CRASC, Daily Hampshire Gazette, Dr. Boyd Kynard, Federal Energy Regulatory Commission, federal trust fish, FERC, FirstLight, Gary Sanderson, Greenfield Recorder, Holyoke Fish Lift, MA Division of Fish and Wildlife, Montague Reporter, National Marine Fisheries Service, National Marine Fisheries Service, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, Public Law 98-138, Rock Dam, shad, shortnose sturgeon, The Greenfield Recorder, The Recorder, Turners Falls, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, Vernon Dam Fishway

The disastrously-emptied Northfield Mountain Pumped Storage Reservoir, June 27, 2010. (CLICK, then Click several times more for FULLEST VIEW) Copyright © 2019 by Karl Meyer. All Rights Reserved.

WHY no FISH…
All photos and text Copyright © 2019 by Karl Meyer. All Rights Reserved.

By clicking on the blue link WHY no FISH… above, and then clicking it again on the following page, you will open an old PowerPoint presentation that I gave to the Pioneer Valley Chapter of Trout Unlimited in Holyoke in December 2010. It will take several minutes to load, but is then largely self-explanatory, with text available below photos, or by clicking the text tab.

On April 30, 2010 I embarked on a journey to the mouth of the Connecticut River by bicycle, to document the grim crippling of the river and its shad runs due to the lack of enforcement and engagement of fisheries agencies and river organizations. At the time, they were all still cheerleaders for a failed salmon program, ignoring the stark facts of the impacts of the Northfield Mountain Pumped Storage Project on American shad and federally endangered shortnose sturgeon.

At the time I was doing part-time work at the Connecticut River Watershed Council, but quit out of frustration and disappointment just a few months after.

Notably, just a year later, the US Fish & Wildlife Service cancelled its long-failed salmon hatchery and “restoration” program on the Connecticut. A year after that, the river conversation became about the impacts of flows in the Dead Reach of the Connecticut, and Dr. Boyd Kynard’s groundbreaking book focusing on federally endangered shortnose sturgeon at the Rock Dam was released–though only following an unconscionable 3-month embargo of his research data by the US Geological Service.

Nearly a decade later, Northfield Mountain remains the Connecticut River ecosystem’s deadliest machine, directly impacting riverine life and migratory fish abundance in three states.

The Connecticut River now has TWO “conservancies”, but not a single NGO that makes any claims for ENFORCEMENT being a chief (or really ANY) component of their mandate. And ENFORCEMENT is a requisite for any true ecosystem restoration and river protection outfit that means to carry out its mission. This is a four-state ecosystem without a legal team. The Connecticut remains a river unprotected.

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).

CONNECTICUT RIVER ALERT: FERC deadline looms

Posted by on 24 Jan 2019 | Tagged as: Canada, Connecticut River ecosystem, Connecticut River Refuge, Connecticut River shortnose sturgeon, Conservation Law Foundation, Endangere Species Act, Federal Energy Regulatory Commission, Federal Recovery Plan, federal trust fish, FERC, FERC Commissioner Neil Chatterjee, FERC licensing process, First Light Hydro Generating Company, FirstLight, Greenfield Community Television, ISO New England, MA Division of Fish and Wildlife, Maura Healey, Natalie Blais, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Project, Paul Mark, Public Comment period, public trust, Rock Dam, shad, Treasury Board of Canada, Turners Falls dam, USFWS, Vermont, Vermont Yankee, Yankee Rowe Nuclear Plant

While federal fisheries stakeholders from the US Fish & Wildlife Service and National Marine Fisheries Service are shut out of the FERC relicensing process by the government shutdown, Canada-owned FirstLight Hydro Generating Company has maneuvered to split its assets on the Connecticut River. This is a slick move, and a punch in the gut to all that have been working in good faith on the understanding throughout–since 2012,that these long-co-run plants were to be covered by a single new license: per the power company’s standing, 5 year-old request.

Copy and paste link directly below to see a half hour on this suspect 12th hour maneuver, filmed for later airing on Greenfield Community Television.

NOTE: FERC has extended the COMMENT, PROTEST, and INTERVENTION deadline for Stakeholder to file Motions with them until February 8, 2019. Go back to www.karlmeyerwriting.com/blog and see second blog post following this on this one on how to submit at FERC.gov on Ecomments.

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