Rock Dam

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AN INSENSITIVITY OF PLACE

Posted by on 29 May 2016 | Tagged as: 5-year FERC licensing process, AMC, American Whitewater, Appalachian Mountain Club, By Pass Reach, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, CRWC, Dead Reach, ecosystem, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC Comments, Gary Sanderson, Greenfield Recorder, New England FLOW, Northfield Mountain Pumped Storage Station, Rock Dam, Rock Dam Pool, Station 1, The Recorder, Turners Falls, Turners Falls dam, whitewater boating

An Insensitivity of Place

Copyright © 2016 by Karl Meyer (CLICK on any photo to ENLARGE)

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There’s a big difference between theory and practice. So too is there often a huge divide between what is said and what is done—and a giant gap between how you portray your intentions in writing, and how you actually carry yourself in the real world. The difference between those things is what most often turns out to be true.

At the Rock Dam, the endlessly-beleaguered and sole natural spawning site for the state- and federally-endangered shortnose sturgeon in the entire Connecticut River system, that difference came into high resolution last week. While I looked on four people in helmets and safety gear lumbered in a huge blue raft over the tiny, watered notch leading into that self-same shortnose sturgeon spawning pool. Four other decked-out compadres looked on admiringly from atop the low ledge that helped form this little ancient pool thousands of years back.

The “drop” for this joyride might have been a total of 4 feet at best, perhaps a third of the length of the giant boat. For any shortnose sturgeon that might have been using this unique ecological site to accomplish the most basic act of survival—spawning, it would’ve been the equivalent of the Starship Enterprise plopping down atop your kiddy pool party. Basically, party over. But hey, those fish are only the sole federally-endangered migratory species in the entire river. Hope you enjoyed the ridiculously short, half-second rush… Yahoo!

And the real kicker is, they were doing this within the known documented time-window at Rock Dam for shortnose sturgeon to be present and attempting to spawn successfully. This was a Sunday, but the previous Wednesday I’d seen rafts being trailered away from the site in the “Patch” section of Turners Falls. I didn’t quite put it together until Gary Sanderson’s column came out in The Recorder the next day, noting the obtuseness of rafters and kayakers he’d seen repeatedly making the same disrespectful maneuvers at Rock Dam earlier in the week.

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But here’s the theory and practice divide. During the current 5-year Federal Energy Regulatory Commission relicensing hearings for the Turners Falls and Northfield Mountain Pumped Storage projects, these whitewater groups have been at the table advocating for increased flows and access for the public on this short section of river. Chief among these have been American Whitewater and New England FLOW, with the Appalachian Mountain Club partnered with the Connecticut River Watershed Council submitting formal testimony in favor of whitewater boating interests here.

AMC and the Watershed Council in submitted testimony are advocating opening up this most-biologically-damaged stretch of the river for the last half century to increased access at three sites over a tiny reach that is just 2.7 miles long: “Improvements would need to be made to a put-in at the upstream end of the run downstream of Turners Falls dam, the take-out at Poplar Street, and access at No. 1 station and at the Rock Dam.” I wonder how many boats, rafts and cars per mile of river that constitutes.

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All groups in their statements and submitted testimony made reference to their concerns for the protection of aquatic habitats here, as well as adherence to the Clean Water Act in this Dead Reach stretch of the Connecticut that includes the extremely critical spawning habitat of the shortnose sturgeon—which consists solely of the small, semi-circular pool that forms below Rock Dam–along with its tiny little 4 foot drop. Shortnose congregate at Rock Dam for spawning from early April through the end of May. Let’s run giant rafts over them and invite crowds of kayakers to overwhelm the river and rocks here to demonstrate respect and concern for a river struggling for life here these last 50 years.

This is self-interested behavior only a little removed from that of the power companies, and, like the power companies, there is cash waiting in the wings for using the river in this most self-considered way. So, well done, whitewater boating interests! We at least now have a tiny picture of what your practice, rather than theory, might constitute. And, hey, did it ever cross your minds that some people actually consider the Rock Dam a sacred place..?

HOLYOKE HOISTS RECORD SHAD NOS; TURNERS FALLS FOUNDERING ON ALL FRONTS

Posted by on 13 May 2016 | Tagged as: American shad, Connecticut River, federally-endangered shortnose sturgeon, GDF-Suez FirstLight, Greenfield Community College, Holyoke Fish Lift, National Marine Fisheries Service, New Hampshire, NOAA, Rock Dam, salmon, shad, shad fishing, shortnose sturgeon, Test flows, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

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Copyright © 2016 by Karl Meyer

According to USFWS Connecticut River Coordinator Ken Sprankle on Thursday, May 12, 2016, the Holyoke Fishway lifted more fish—specifically 54,006 American shad, than on any single day in the fish lift’s 61 years of operation. In 1955, something simple and sensible came into being on the Connecticut. It was a fish passage set-up that brought shad directly upstream in the riverbed via upstream attraction flows, and drew them into an elevator that gave them a lift directly above South Hadley Falls. Once there they could head upstream toward open spawning habitat in Vermont and New Hampshire. For three generations, Holyoke has been the single largest fish passage success site and story for American shad on the entire East Coast.

Sadly, just 36 miles upstream, those shad met with the fish passage restoration boondoggle-disaster of all-time—a three-ladder fish passage puzzle that forced all fish into a 2.7 mile long power canal at Turners Falls. Steered out of the river, and forced to negotiate a turbine lined canal in order to make it upstream beyond the Turners Falls Dam, the average annual success rate was 4 fish out of 100. To focus in a bit more on the present, what Holyoke passed yesterday was nearly the equivalent of all the shad that made it past Turners Falls Dam last year: 58,000.

The Turners Falls Power Canal remains the dead end, adjacent to the Connecticut River’s Dead Reach, where the federal/state Connecticut River migratory fisheries program has lingered in a comatose—nearly frozen state, since those ladders were built in 1980.

Given the brief nature of spring spawning conditions, it’s likely—at minimum, 25,000 of yesterday’s shad from Holyoke will be attempting that torturous labyrinth in Turners Falls by midday today (Friday). Most won’t make it past, and most will expend over a week of their precious spawning energies in the attempt. A high, though poorly studied or documented percentage, will ultimately be cut up in the turbines of the Turners Falls Power Canal.

Such is the legacy of non-intervention on behalf of the public’s fish, and the 45 year focus on creating a hatchery strain of salmon on a river system where the species had been extinct since 1809. So, again, Vermont, New Hampshire, and northern Massachusetts—sorry, but your fish are stuck down here in the miseries of a power canal and the Connecticut’s Dead Reach lacking suitable flows and fish passage.

On that note: it’s now six weeks since we had the first fish passage numbers reported from Holyoke Dam. Here at Turners Falls, we have nothing from GDF-Suez FirstLight and the Greenfield Community College students hired to tally them. The public’s fish, and the information as to their whereabouts, remains in private hands—most of it in the murky environs of a private power canal.

I’ll give you an on-the-ground update from my visits. At Rock Dam, just after midday on Tuesday, three anglers were working the site for shad. Curiously, there was a very clear “tide” line in the sand at the site—which is also the natural spawning ground for endangered shortnose sturgeon. The very recent high water mark was between 10 and 25 feet wide leading down to the water’s edge. It indicated a recent and significant change in flow there. One of the gentlemen said the drop came quickly, and had only happened “fifteen minutes ago.” Such “ramping” up and down of flows by the power company has huge implications for migrating and spawning fish. In fact, ramping at this site is one of the key reasons for spawning failure for endangered sturgeon. But, who’s watching?

Anyway, the three anglers reported that the shad were running here before the flow drop—there were several in two buckets, but they had disappeared once flow conditions changed.

I returned to Rock Dam on Wednesday, and there was just a lone guy and his dog present. His name was Shawn, and he’s lived nearby for the past year, but this was his first outing for shad. He looked to be in his early 20s.

There must’ve been plenty of shad trying to pass upstream at Rock Dam—with extra “test” flow water being released at the dam for federal relicensing studies. It wasn’t a minute after I clambered up the rocks to speak with him that he hooked his first fish. I obliged and took his photo with it. While there, I also took a minute to explain that shad don’t survive handling well, and they do best if handled very gently and while right in the water at the shore line.

I only tarried only for five more minutes–in which time Shawn landed two more fish, and four new anglers had scrambled down to join the shad run at the Rock Dam.

The latest Connecticut River shortnose sturgeon count at Holyoke Dam: 15 fish—ostensibly on spawning runs to that self-same Rock Dam spawning haven, have been lifted in the fish ladder this spring–and stopped abruptly once reaching the top floor. Every one of them has been slapped on the nose with a newspaper, told “NO!” and been dropped back in the drink below the dam. “Wait till next year..!” Hey, National Marine Fisheries Service: that is award-worthy endangered species protection through genetic deprivation! Kind of makes you miss David Letterman and his Stupid Pet Tricks…

DEAD REACH REPORT: the BLACK HOLE continues…

Posted by on 09 May 2016 | Tagged as: American shad, blueback herring, Connecticut River, Dead Reach, federal trust fish, federally-endangered shortnose sturgeon, FirstLight, GDF-Suez FirstLight, Greenfield Community College, Holyoke Community College, Holyoke Fish Lift, MA Division of Fish and Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, Rock Dam, Rock Dam Pool, sea lamprey, shad, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Vernon Dam Fishway

DEAD REACH REPORT: the BLACK HOLE continues…

Copyright © 2016 by Karl Meyer
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Forty-one days after the first fish were reported being lifted at Holyoke Dam, we still have not a shred of information on fish passage in the Connecticut River’s Dead Reach at Turners Falls. That’s the beleaguered, half-emptied, 2.7 miles of riverbed that all migrating American shad, sea lamprey, and blueback herring must pass in order to make progress toward Vermont and New Hampshire spawning grounds. Within that Dead Reach is the Rock Dam, the only documented natural spawning site for endangered shortnose sturgeon in this river system.

Thus, again, GDF-Suez FirstLight continues in sole control and possession of information on the public’s federal trust migratory fish—every one of which, in trying to reach upstream sites, gets diverted into their turbine-lined power canal. Once corralled and essentially privatized in that miles-long trench, very few ever emerge alive beyond Turners Falls Dam.

Holyoke Fish Lift numbers have been handed off daily to Ken Sprankle, USFWS’s Connecticut River Coordinator, for weeks now. Students from Holyoke Community College are staffing that site, overseen by the MA Division of Fisheries & Wildlife. MA Fish & Wildlife is responsible for those shad, lamprey and herring while they are traversing the Commonwealth’s reach on the Connecticut. They’re responsible for getting the public’s fish counted as well. That role up at Turners Falls is clearly not working or being taken seriously. We have no information from there whatsoever–with the video-counting apparatus controlled by FirstLight, and the review, tallies, and the hand-off of that public information left in the hands of Greenfield Community College students.

None of this speaks well for any safeguarding of the public trust.

Nevertheless, USFWS’s Ken Sprankle did provide these updates from Holyoke Dam this morning. Fish counts there as of Sunday, May 8, 2016 are: 32,937 American shad; 239 sea lamprey; and 14 federally-endangered shortnose sturgeon—all of which were brought to the top in the fish elevator, lifted out, and dropped back downstream. Virtually none of them will get an opportunity to spawn yet again this year.

To give you a sense of the miseries, one egg-laden female lifted up there had been tagged in the Dead Reach in Turners Falls 2004, as a female on a spawning site. This year, a dozen years after that tagging—she was apparently full of eggs and attempting to reach the Rock Dam for spawning once more. They plopped her back downstream on orders of the National Marine Fisheries Service. If that aging female dies over the winter, the genetic material in the hundreds of thousands of eggs she was carrying gets lost to eternity, and becomes yet another signpost on extinctions path.

Just what exactly is being accomplished by not letting these endangered fish spawn?

Meanwhile, here’s a tiny Dead Reach report of my own. I stopped by the TF Dam at mid-morning on Mother’s Day. It was drizzly, water was spilling from Bascule Gate 1(Turners Falls side), and no one was fishing at the site.

Downstream at 9:40 I met a lone angler exiting from the Rock Dam pool site at Cabot Woods. He said he’d had a few, earlier, but that it was slowing down. When I went out to the Rock Dam it was fairly quiet, with the water only moderately clear with the recent rain. Still, looking down from the rocks, schooling swirls of shad can sometimes be seen when the light is good. I saw nothing. Nor did I note any lamprey tails slapping the rock faces as they suctioned their way upstream through the notches.

According to this angler who fishes the mouth of the Deerfield as well, Rock Dam fishing on Saturday was pretty decent: “I had a dozen shad,” he noted. Thus, it’s become fairly obvious these last two springs that when flow is left in the riverbed, Rock Dam is one of the finest shad fishing sites on the Connecticut.

So, American shad have been reaching Turners Falls for 5 weeks now, we just don’t know how many are passing upstream—and we have yet to get count information from TransCanada about numbers passing Vernon Fishway. Thus parts of Massachusetts and all of Vermont and New Hampshire remain in the dark as to the whereabouts of their share of the ocean’s spring bounty.

Holyoke Fishway opened last week. You can visit, Weds. – Sunday from 9 – 5. Its on the CT, where Rt. 116 crosses into Holyoke from South Hadley. The public fish viewing facilities at Turners Falls have yet to open.

No “Springtime for Sturgeon in Holyoke…”

Posted by on 06 May 2016 | Tagged as: Connecticut River, Connecticut River ecosystem, Endangered Species Act, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, Holyoke Fish Lift, Holyoke Gas & Electric, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Rock Dam Pool, shortnose sturgeon, Turners Falls, US Fish & Wildlife Service, USFWS

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HG&E’s Holyoke Dam with Mt. Tom in background(click to enlarge)

No “Springtime for Sturgeon in Holyoke…” Unenforced FERC License continues the woes for the Connecticut’s only federally endangered migratory fish

Copyright © 2016 by Karl Meyer

For endangered shortnose sturgeon on the Connecticut River this year has been the best thing and the worst thing to happen to them since 1849. In an infinitely promising development over a dozen sturgeon(13 thus far)have found their way into the retooled Holyoke Fish Lift this spring—and all were lifted 30 feet toward upstream spawning habitats at the facility. However, in a most ugly turn of events for a creature listed under the Endangered Species Act since 1967, every one of those sturgeon was subsequently dropped back downstream by humans working there. They literally gained ten yards… after 167 years. Sorry kids, wait ‘til next year–or maybe the one after that.

In 2002 Holyoke Gas and Electric was issued a FERC license under which they were required to complete construction of a fish lift providing up- and downstream access for endangered sturgeon by 2008. FERC, responsible for enforcing those license requirements as well as the tenets of the ESA, failed to enforce their requirements, leaving those improvements unconstructed, year after year. The National Marine Fisheries Service, US Fish & Wildlife Service, and MA Division of Fisheries & Wildlife sat on their hands respecting their responsibilities to act. Nor did any so-called “watchdog” group fulfill their role–to make the enforcers enforce.

This was just the latest failure in a foundering Connecticut River ecosystem steered by money and politics rather than legal obligations, science, and enforcement of the public trust. Just consider that one of the Connecticut River Watershed Council’s Board Members has worked for Holyoke Gas & Electric at their fish lift for a decade… Then consider the resounding silence on enforcement.

This year–a full 9 springs beyond their license obligations, HG&E finally completed that mandated construction at the Holyoke Fish Lift. That says a mouthful about FERC, their licensing process, private industry, and whether anyone is actually protecting the public’s fish and river.

Grimly this spring, when the most sturgeon embarking on upstream spawning runs since the building of the railroads made it to the top of those South Hadley Falls, all were captured and “released downstream” of Holyoke Dam. This bit of brilliance comes via the orders—or lack thereof, of NOAA’s National Marine Fisheries Service. Their failure to act again denies any new genetic input into the tiny upstream population keeping this species’ flickering spark alive across the centuries up at their sole natural spawning site, the Rock Dam in Turners Falls.

Below Holyoke, generation after generation of these long-lived fish have been relegated to simply growing to maturity, repeatedly attempting to return upstream, and ultimately expiring without ever having the chance to pass on their genes. That goes back to the time of President Zachery Taylor.

In one very cruel act of fate, any shortnose sturgeon finding themselves downstream of the newly constructed Holyoke Dam in 1849, were forever barred from reaching their sole natural spawning site in the river system—that ancient Rock Dam pool in Turners Falls. What that has meant is that hundreds upon hundreds of these fabulously evolved fish–across more than a century and a half, have been relegated to the status of “reproductive nulls,” unable to spawn in their natal river system.

Pick your favorite bad actor in this failed scenario–there are a half-dozen choices.

Missing camera in missing river

Posted by on 01 May 2016 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Dead Reach, endangerd shortnose sturgeon, federally-endangered shortnose sturgeon, Holyoke Fish Lift, New Hampshire, Rock Dam, Rock Dam Pool, shad, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont

I stopped along the Connecticut on the first bridge crossing downstream of Turners Falls Dam on Friday, April 29th. This is, of course, the alternately starved or inundated Dead Reach–the place where shortnose sturgeon can’t spawn, and migrating shad can’t pass upstream because of free-reign hydropower operations that choke off the Connecticut River ecosystem in these 2.7 miles of river. This is literally where the Connecticut River ends.

This day, as it had been for days prior, the riverbed was starved. Two thirds of it’s channel was simply exposed tilted and drying shale, with a shallow riffle of flow filling in the rest. I’d stopped to take a photo of the parching Dead Reach, just to have a record. Sadly, I was a bit rushed and didn’t use the camera strap. When I tried to reframe the picture to get a sweep of the ruined river, it slipped from my hands.

Had there been an actual river below, the camera would’ve splashed-in and sunk. Instead, in a true illustration of how starved this ecosystem has been these last decades, it tumbled end-over-end and banged onto the rocks, bouncing at last into a puddle leftover from when the Connecticut last saw some flow here.

Just downstream and out of view was the Rock Dam, where this same impoverished flow had chased spawning-ready shortnose sturgeon from their only documented natural spawning site over a week earlier. Also denied habitat just downstream were literally thousands of American shad–now many days past their lift upstream at the Holyoke Fishway. They too were being denied a river route upstream toward Vermont and New Hampshire spawning habitat. Instead, all were being tricked by flows at the Cabot Station fish ladder into the deadly power canal just a hundred yards east of where I stood.

Thus, the picture was lost, as was the camera. There was something final in watching it pitch downward. Oddly, I wasn’t devastated to see it go. Staring down, I realized this was the same photo of ecosystem misery I’d shot a half dozen times in a half dozen other years. Its a bit withering to witness it year after year.

Thus, as substitute, I’ll post here another photo, taken later in the season one of these last years. Its the exact same misery–just with a bit more late-season green on the riverbanks. It’s the Dead Reach in the dead Connecticut River at Turners Falls…(click to enlarge)

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Shortnose sturgeon: ignoring published research

Posted by on 04 Apr 2016 | Tagged as: Connecticut River shortnose sturgeon, Dr. Boyd Kynard, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC Comments, Jack Buckley, John Bullard, Julie Crocker, Kimberly D. Bose, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Rock Dam Pool, Secretary Kimberly Bose, shortnose sturgeon, US Fish & Wildlife Service, USFWS, Vince E. Yearick, Wendi Weber

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TOP: Rock Dam program, 4-23-16 (click to enlarge)

Bottom: The ROCK DAM: shortnose sturgeon spawning site (click to enlarge)

The following testimony was submitted on March 18, 2016, to the Federal Energy Regulatory Commission on behalf of the biological needs of the federally-endangered Connecticut River shortnose sturgeon at its sole documented natural spawning site in the Connecticut River ecosystem.

Karl Meyer, M.S.

85 School Street # 3

Greenfield, MA  01301                                       March 18, 2016

 

The Honorable Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, NE

Washington, DC  20426

 

SUPPLEMENTAL INFORMATION: RE: P-1889-081 and P-2485-063, and federally-endangered Connecticut River shortnose sturgeon, (Acipenser brevirostrum)

Attach to: PROTEST of FERC-sanctioned Revised Plan for Study 3.3.19, issued to FirstLight Power Resources, Inc, in a February 25, 2016 FERC letter to Mr. James P. Donohue of FirstLight, by Vince E. Yearick, FERC Director, Division of Hydropower Relicensing.

Dear Secretary Bose,

This additional information is being submitted subsequent to my receipt of a March 15, 2016 letter from Mr. Vince Yearick, Director, Division of Hydropower Licensing, restating FERC’s intention to sanction spring 2016 test flows that are documented to result in spawning failure and displacement of federally-endangered Connecticut River shortnose sturgeon(SNS), at their sole natural spawning site in this river system. Those findings come from 20 years of research conducted by government scientists from both the US Fish & Wildlife Service and the US Geological Survey.

I am submitting an index and key chapters from this exhaustive body of shortnose sturgeon research published in LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEONS, 2012, by Boyd Kynard, Paolo Bronzi et al, World Sturgeon Conservation Society: Special Publication # 4. Chapter 3 directly addresses SNS spawning failure and displacement at the Rock Dam in the Connecticut’s By Passed Reach, and clearly indicates that test flows of 1500 cfs will not be protective of a species listed since 1967 under the federal Endangered Species Act.

From P. 107 (PDF-page numbers and numbers in the actual text are the same), “Spawning failure in unregulated rivers likely occurs, but it should be rare because females have adapted to natural fluctuations in the river discharge. Spawning failure (when fish were present) occurred at MontSR due to river regulation, but spawning did not fail due to peaking operations. Regulation created bottom velocities that were too low or exceeded the preference of females or created a low discharge that either prevented female access to the RockD or failed to attract them.”

Findings and data from pages 101 and 102 should provide further guidance to FERC in reexamining this decision. In his response Mr. Yearick argues that the low test flow of 1500 cfs put forth for Study 3.3.19 is somehow key in making correlations to last year’s American shad passage tests from Study 3.3.2. However, that is by no means clear (note–the 3.3.2 results have yet to be made available to Stakeholders) as that study also included tests flows of 1000 cfs and 6300 cfs—flows also not being included in order to make any useful correlation with Study 3.3.19.

Further, in regard to the failure or oversight in the protective responsibilities of the National Marine Fisheries Service to submit objections in this instance (as well as the USFWS and MA Division of Fisheries and Wildlife, who also have federal and state ESA mandates), those failures in no way release the FERC from its own responsibilities under the federal Endangered Species Act. In FERC’s own words, from: Hydropower Relicensing-Get Involved, A GUIDE FOR THE PUBLIC: “Is the Commission subject to other federal laws? Yes. The Commission must comply with a variety of federal laws, such as the Clean Water Act (to protect water quality), the Endangered Species Act (to protect threatened and endangered plant and animal species) and the National Historic Preservation Act (to protect culturally significant places and historic properties).”

Regarding Mr. Yearick’s citing of Article 34 as permitting the harming of protected species in the current license, he fails to note the following tenets included in that self-same Article regarding continuous minimum flows and modifications thereof: “These flows may be modified temporarily: (1) during and to the extent required by operating emergencies beyond the control of the Licensee; and (2) in the interest of recreation and protection of the fisheries resources, upon mutual agreement of the Licensees for Projects 1889 and 2485 and the Massachusetts Division of Fisheries and Wildlife.”

Please also note that, with the marked improvements shown in American shad passage at Turners Falls in 2015 which appear to correlate well with the significant increases in flow through the By Passed Reach, it is highly unlikely that any of the Stakeholder Agencies would consider requesting a Licensed flow of 1500 cfs when the biological needs and passage of both federal-trust and federally-endangered migratory fish require significantly more volume to fulfill their spawning requirements.

Lastly, 8 years in arrears of its license agreement signed in 2002 for FERC P-2004–to have completed upstream access for federally endangered Connecticut River shortnose sturgeon by 2008, Holyoke Gas & Electric has completed modifications to its fishway. That should allow SNS their first access and reintroduction to their natural spawning grounds in 168 years. In my mind, it would be patently criminal to greet these endangered fish on their first spawning trip upstream since 1849 with sanctioned flows guaranteed to displace them and cause spawning failure.

Thank you for your careful attention to this critical matter.

Sincerely,

Karl Meyer, Fish and Aquatics Study Team, P-2485 and P-1889

Please see attached chapters in PDF format, as well as included index and book cover.

Cc’d via email to:

Brandon Cherry, FERC

William Connelly, FERC

James Donohue, FirstLight

Julie Crocker, NOAA

Bjorn Lake, NOAA

John Warner, USFWS

Caleb Slater, MA Division of Fisheries & Wildlife

John Bullard, Regional Administrator, NOAA Fisheries Greater Atlantic Region

Wendi Weber, Director, USFWS Region 7

Jack Buckley, Director, Massachusetts Division of Fisheries & Wildlife

Dr. Boyd Kynard

Stakeholder PROTEST of FERC Revised Study Plan finding endangering Connecticut River shortnose sturgeon

Posted by on 07 Mar 2016 | Tagged as: Connecticut River shortnose sturgeon, Dead Reach, Dr. Boyd Kynard, endangerd shortnose sturgeon, Endangered Species Act, ESA, Extinction, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, Fish and Aquatics Study Team, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Secretary Kimberly Bose, US Fish & Wildlife Service, USFWS

(The following Stakeholder testimony was submitted to FERC on March 4, 2016)

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 March 4, 2016

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

RE: P-1889 and P-2485, and federally-endangered Connecticut River shortnose sturgeon, (Acipenser brevirostrum)

PROTEST of FERC-sanctioned Revised Plan for Study 3.3.19, issued to FirstLight Power Resources, Inc, in a February 25, 2016 FERC letter to Mr. James P. Donohue of FirstLight, by Vince E. Yearick, FERC Director, Division of Hydropower Relicensing.

Dear Secretary Bose,

I protest the FERC finding issued on February 25, 2016 for P-2485 and P-1889 specifically because it sanctions test flows that are documented to cause spawning failure for the federally-endangered Connecticut River shortnose sturgeon (Acipenser brevirostrum) at its only documented natural spawning site, the Rock Dam, in the Connecticut River. FirstLight has proposed and FERC has accepted Study Plan test flows of 1500 cubic feet per second in the CT River’s By Pass Reach for April, May and June 2016. That low level of flow will displace and wipe out a full season’s spawning and rearing of Young of Year life stage SNS at their ancient Rock Dam nursery site.

Though my FERC Stakeholder comments of January 28, 2016 specifically addressed this ESA issue, FirstLight did not respond to the endangerment issue in its RSP revisions. Further, I had made this issue clear to FirstLight and its agents, FERC staff, and key stakeholder agencies in an email delivered on January 20, 2016. I again reiterated the endangered species impacts to those same parties in an email delivered on February 24, 2016. Madam Secretary, I again made my concerns about spawning interference and failure to you and for the FERC record in a letter delivered February 26, 2016. All are available for perusal in the FERC record for P-2485 and P-1889.

Shortnose sturgeon gather at this spawning and nursery site annually between April 22 and May 25 for pre-spawning and spawning. Further, the complex of key biological characteristics of flow, varying depths, and cobble/sand habitat provide SNS with protective options that nurture developing Young of the Year throughout June into July.

According to 17 years of published studies at that site documented by Dr. Boyd Kynard and research colleagues, a continuous minimum flow of 2500 cfs is required to protect sturgeon spawning and rearing at this site. Therefore, I PROTEST the findings of the FERC Revised Study Plan determination issued by FERC on February 25, 2016, and request that only continuous protective minimum flows of 2500 cfs be allowed in this study, and throughout the 2016 SNS spawning and rearing season, as well as all ensuing springs.

The following publication has been referenced in the FERC ILP for these projects by both federal and state stakeholder agencies, FERC, as well as FirstLight and their agents.

“LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEONS, 2012, by Boyd Kynard, Paolo Bronzi et al, World Sturgeon Conservation Society: Special Publication # 4

“Effect of hydroelectric operations on spawning”

Page 101, bottom: “During the 11 yr spawning failed (excluding the failed migration in 2002), when discharge levels were too low for 5 yr and too high for 4 yr. During one yr (2007), discharge during April was both to low and too high. When spawning failed at RockD due to low discharge during 4 yr (1995, 1998, 1999, and 2006)m discharge decreased to <70 m3 s-1 for at least 4 d by 30 April (Fig. 14), the earlier period of low discharge likely marked a threshold making the RockD unattractive to spawning fish.”

Further published data, tables, and required flows necessary in this reach appear on pages 101-102 of LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEIONS.

I would welcome a FERC hearing on this critical ESA issue and would make myself available for testimony. Thank you for your attention to this pressing matter.

Sincerely,
Karl Meyer
Fish and Aquatics Study Team, P-2485 and P-1889

Cc’d via email to:
Brandon Cherry, FERC
James Donohue, FirstLight
Julie Crocker, NOAA
John Warner, USFWS
Caleb Slater, MA Division of Fisheries & Wildlife

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

CASHING IN ON A CASH COW

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

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

CASHING IN ON A CASH COW

Copyright © 2015 by Karl Meyer

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

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

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

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

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

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

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

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

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

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

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

Got credit? Give a call!

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

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