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FirstLight Power AGAIN GREEN-WASHED in Greenfield Public Schools

Posted by on 20 Jun 2022 | Tagged as: Connecticut River, Connecticut River ecosystem, Extinction Rebellion, FERC license, FirstLight Power, Greening Greenfield, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, Nolumbeka, Northfield Mountain Pumped Storage Station, public trust, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Greenfield Recorder, US Fish & Wildlife Service

FirstLight Power is again being green-washed in the Greenfield Public School system

Extinction Rebellion activists calling for the immediate shutdown of FirstLight’s Northfield Mountain Pumped Storage Station, June 1, 2022. Photo Copyright © 2022 by Karl Meyer

THE FOLLOWING was a rather unfortunate and transparent attempt to entice truth-tellers away from the facts about sponsoring the deadliness of FirstLight’s grim venture capital cash cow–the Northfield Mountain Pumped Storage Station and its monstrous impacts on the strangled Connecticut River here in Franklin County for the last half century. They were seeking to shunt away any controversy and gloss over FirstLight’s unending carnage–in a corporate-funded, green-washed sponsorship ploy, set to take place in a Greenfield public school. Apparently embarrassed, they sought to co-opt and pull others under FirstLight’s sullied public relations blanket…

“June 2, 2022 June 23rd, Robin Kimmerer

hi Karl and _____,
Last night Greening Greenfield agreed to partner with Nolembeka Project in hosting Robin at Greenfield High School. Discussion included possible protests because the event is being financed by a grant of $50,000 (!) from First Light. So we talked about offering your groups (river flow and preserving forests – is that yours ____ or is it someone else?) the option to have tables at the event in the hall outside the auditorium. If you are interested, get in touch with Diane Dix with Nolumbeka (If i can find her email i’ll forward it).
Sandra Boston”

You might see why I found it’s subtle trickery inappropriate and unworthy of a response. I don’t really know Sandra Boston. We’ve never corresponded. I didn’t reply.

It had arrived on the morning of June 2, 2022, the day after my blog post describing the actions of over half a dozen Extinction Rebellion Activists challenging the unconscionable, deadly, daily extinguishment of the Connecticut River’s life and ecosystem functions by FirstLight’s 50 year old Northfield Mountain Pumped Storage Station, It was also addressed to one other person, and others are mentioned whose names I’ve left off to respect their privacy.

What seems readily apparent is these sponsorships seek to keep the company’s grim ecosystem record and carnage quiet, they don’t want their relationship with the company and it’s death machine revealed while accepting the fruits of it’s poisoned tree.

At center it concerns the “free,” “public” program to be presented at the Greenfield High School this Thursday, June 23rd, sponsored by–and made possible via a big chunka-change (note the $50K!!) from FirstLight Power(now-Delaware tax-sheltered and parent-owned by Canadian global venture capital giant Public Sector Pension Investments), gifted to the Nolumbeka Project, and now–by extension, Greening Greenfield. As someone who has spent two decades writing about Northfield Mountain’s abject river brutality, it was a most unwelcome and insulting ploy. Here is the last piece I wrote on the subject in The Recorder, just a month prior:

https://www.recorder.com/my-turn-Meyer-Don-t-Take-FirstLight-for-Granted-46104531

What also seems quite likely is that the distinguished and celebrated author coming to present at Greenfield High School has little understanding of FirstLight’s grim plans for river-killing and profiteering out of the very soul of the Connecticut River for the coming half century. There was much misdirection apparent here. Any of the leaders of these entities could have reached out to me directly.

A week later–carrying water and working in the shadows for the program’s presenting sponsors, Nolumbeka and Greening Greenfield, there came this follow-up email from Ms.Boston:

“June 7, 2022, Robin Wall Kimmerer June 23

hi _____ and Karl
I told Diane Dix I had contacted you about a table at the event at GHS on the 23rd and she called me today wanting to know if I had heard from you. If you are interested could you please contact Diane at nolumbekaproject@gmail.com and let her know? thanks.and _____, would you mention this to _____ in case the _____ committee would like to have a table at the event? they would be welcome too. Greening Greenfield is going to have a table too.
thanks
sandra
ps let me know if you are not interested by replying to this email and i’ll let diane know.

The Auditorium entrance of Greenfield High School. Photo Copyright © 2022 by Karl Meyer

After giving it a bit more thought, I decided I wanted to be clear that I wanted nothing whatsoever to do with this sorry bit of green-washing–particularly at the grim time when the future of a living Connecticut River ecosystem is at stake.

The following, line-by-line, is my reply. I hope they’ve now noted I will ALWAYS stand with the River and its People:

“I do not have a “group,” but find your solicitation rather creepy.

I can’t figure out exactly on who’s behalf you are “green washing”: venture capital giant PSP Investments and FirstLight, or Nolumbeka, or Greening Greenfield?

Anyway, as a journalist, citizen and stakeholder I’m always ready to offer my voice and knowledge on behalf of a living Connecticut River and a life-sustaining ecosystem. But not under the aegis of a sponsor capitalizing on killing them.

FirstLight’s monstrous machine is a continuing assault on both, and being asked to collaborate under their money-tent is particularly insulting.

Conversely, would’ve loved to explain river-crushing pumped storage from the stage!

Hey, perhaps its time to reconsider that creepy sponsorship?

I do hope the author fully understands whose tent she’ll be speaking under…

Karl”

A river without a watchdog:The Connecticut River on Juneteenth/Father’s Day, water-starved and failing in Franklin County for 50 years due to the monstrous suck-and-surge appetite of the Northfield Mountain Pumped Storage Station. FirstLight’s FERC license to operate Northfield expired on April 30, 2018, yet FERC and the responsible agencies let the killing continue. Photo Copyright © 2022 by Karl Meyer.

FirstLight deserves no honor; and certainly no place in our Public Schools. They have starved the river for profit, and taken their profits to Delaware. Attempts to quash facts and public engagement and protests are not honorable stances in a democratic society. The public has a right to know, but sitting under a FirstLight banner at a Greenfield public school sits in direct opposition to honoring the facts and democratic values.

These are things I believe Robin Kimmerer would agree with. I hope they’ve been honest with her regarding the facts of her sponsored appearance…

STARVED: Our river has rights!

Posted by on 31 May 2022 | Tagged as: Connecticut River, Connecticut River ecosystem, Conte National Fish & Wildlife Refuge, Death-Sewer, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, Holyoke Co. v Lyman, migratory fish, Nation's best landscaped sewer, Northfield Mountain, Northfield Mountain Pumped Storage Station, Peskeomscut, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Supreme Court, Vermont Digger

Our River has Rights


Controlled from 5 miles upstream by operators inside Northfield Mountain, FirstLight’s impoverished river spill at Turners Falls Dam: its now five, full, grim spawning seasons since FL’s Federal Energy Regulatory Commission license expired, April 30, 2018. Photo Copyright © 2022 by Karl Meyer

NOTE: text below published in www.vtdigger.org on May 18, 2022.
https://vtdigger.org/letters_to_editor/our-connecticut-river-has-rights/>

In Turners Falls Massachusetts on Saturday May 14th just a small wash of current folded through two bedrock notches in the Connecticut River at a basin known as the Rock Dam pool. It was peak spawning time at critical spawning habitat for the federally endangered shortnose sturgeon. Upriver just a thin spill entered the riverbed via a single open gate at Turners Falls dam, controlled by FirstLight operators at the Northfield Mountain Pumped Storage Station, 5-miles away. The Connecticut’s giant chasm at the place known to Algonquian Peoples as Peskeomscutt was mostly dry bedrock, with just thin braids of dam flow washing downstream.


The listless, calf-deep shallows at the ancient chasm known as Peskeomscutt below Turners Falls Dam. For a living river the trickling flow from the dam into this basin should be 20x times what you see in this baking riverbed landscape. Photo Copyright © 2022 by Karl Meyer

That lack of flow had assuredly chased the ancient sturgeon from their age old spawning site again. Five years and 5 seasons after FirstLight’s license on the river expired on April 30, 2018, there is still no water for the river or its fish. Why? After a decade of endless Federal Energy Regulatory Commission relicensing procedures, why are hundreds of thousands of American shad lacking river flows needed to reach and pass the dam blocking them from spawning habitat in three New England states since 1798?


The grim “bakers” field of exposed cobbles and starved shoreline at the Rock Dam on the Connecticut–critical spawning and sheltering habitat for federally endangered shortnose sturgeon, and an impoverished upstream roadblock to shad attempting to reach Vermont and New Hampshire habitats. Photo Copyright © 2022 by Karl Meyer

The river and its fish are a public trust. Shad should be feeding us. FirstLight’s little dam spillage is some 20 times less than a basic flow needed to support a living river ecosystem here–one allowing sturgeon to spawn and shad to reach Vermont and New Hampshire.


Reconstruction work being done at the giant sucking intake of FirstLight’s Northfield Mountain Pumped Storage Project–essentially a deadly, energy-wasting, river-sucking, gas-powered machine that extinguishes the life of everything its consumed for over a half century. Since 1972 there has never been a more direct-deadly contraption operating on New England’s Great River. Here at Northfield Massachusetts is where an ecosystem is literally pulled apart by suctioning the four-state Connecticut River backward and uphill for hours at a massive 15,000 cubic feet per second. It’s really exploited as the Connecticut River’s Death-Sewer. Photo Copyright © 2022 by Karl Meyer

In 1872 the US Supreme Court made safe fish passage on the Connecticut the law of the land. Canadian-owned FirstLight is exploiting our river for millions, while laws and requirements go listlessly unenforced by agencies and so-called watchdogs. The Connecticut in Massachusetts has been an environmental disaster since Northfield Mountain began its massive suck and surge operations in 1972. By whose right?

CONNECTICUT RIVER CASUAL TRAGIC HISTORY HIKE: Sat., May 14th

Posted by on 06 May 2022 | Tagged as: America's best landscaped sewer, Andrew Fisk, Connecticut River, Connecticut River Day of Mourning, Connecticut River ecosystem, Conte National Fish & Wildlife Refuge, Federal Conte Anadromous Fish Research Center, federally-endangered Connecticut River shortnose sturgeion, Great Falls, Jesse Leddick, Julie Crocker, Landmark Supreme Court Decision 1872, Mark Tisa, Martin Suuberg, migratory fish, Nation's best landscaped sewer, National Marine Fisheries Service, net-loss power, no license to kill, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, public trust, Rock Dam, shad, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Recorder, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Wendi Weber

THE CONNECTICUT RIVER CASUAL TRAGIC HISTORY HIKE:
Saturday, May 14, 2022, 9:30 – 11:00 a.m..

The April 2, 2022, Connecticut River Day of Mourning. Photo courtesy of John Bos.

Trip meets 9:30 in the courtyard of the Great Falls Discovery Center and continues onto the Rail Trail. Photo Copyright © 2022 by Karl Meyer

I hope some folks are able join this long and casual history walk. * * Please be aware that it will be close to 5 miles–with the return to Great Falls to be done on your own. As noted, a bike or even a 2nd car-pool, relay-car can be left near the walk’s end and return point. Bikes can be locked near Conte Lab–also, relay cars could be parked in the public lot at the end of G-Street, where “Migratory Way” continues along the canal heading the last 1/2 mile to Rock Dam. (I’ll be on my bike.)

The April 2nd Connecticut River Day of Mourning. Photo courtesy of John Bos.

The Connecticut River casual, tragic history hike
Saturday, May 14, 2022, 9:30 a.m. – 11:00 a.m.
Meet: Great Falls Discovery Center courtyard, Avenue A, Turners Falls
Free. No pre-registration required. * * Rain cancels.

Join journalist Karl Meyer for this 2-1/2 mile (one-way) unnatural history walk, starting at the Great Falls Discovery Center and Turners Falls dam’s failed salmon ladder. This casual hike partly follows the Rail Trail’s 200 year old transportation and power canal. We’ll cross it on a one-way bridge, pass a 1906 generating station; then head to G Street and down “Migratory Way” to unprotected sturgeon habitat at the river’s Rock Dam near the USGS Conte Fish Lab. We end above the failed fish ladder adjacent to Cabot hydro station. NOTE: * * Participants responsible for returning to Great Falls on their own (total: 5-mile round trip). It’s possible to pre-stash a locked bike near Conte Lab along Migratory Way, then cycle back via the Rail Trail.

DEAD American shad at the Rock Dam, May 2021: a public trust migratory fish guaranteed safe passage to VT and NH waters by the US Supreme Court back in 1872. Photo Copyright © 2021 by Karl Meyer

*** OH, and here are a few LINKS, the first two comprising defense of an undefended river by citizens; the last three are where foreign vultures are spending the ill-gotten spoils from our massively broken river–far from our Valley ecosystem:

https://www.recorder.com/my-turn-Meyer-Don-t-Take-FirstLight-for-Granted-46104531

https://www.recorder.com/ltr-Ogden-FirstLight-s-Lack-of-Urgency-Threatening-Shortnose-Sturgeon-46144862

https://energycentral.com/news/invenergy-and-energyre-secure-offshore-wind-lease-award-and-announce-formation-investor

https://www.bizjournals.com/pittsburgh/news/2022/05/02/hydro-electric-firstlight-allegheny-8-9.html

https://apnews.com/press-release/business-wire/business-new-york-pennsylvania-ca11a3273cfb45eeb0e7181075ebe2df

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

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

A CONNECTICUT RIVER DAY OF MOURNING:

NO RIVER SHOULD EVER DIE IN THE DARK!

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

Greenwashing, or How Many Times Can You Sell a Dead River?

Posted by on 09 Mar 2022 | Tagged as: America's best landscaped sewer, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, Daily Hampshire Gazette, Federal Energy Regulatory Commission, FERC, FirstLight, FirstLight Power, fish kill, Greenfield Recorder, Julie Crocker, MA Division of Fish and Wildlife, Mark Tisa, Martin Suuberg, Martin Suuberg: Commissioner MA Department of Environmental Protection, Massachusetts DEP, Nation's best landscaped sewer, net-loss power, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, right-to-know, Rock Dam, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Recorder, The Springfield Republican, UMass, US Fish & Wildlife Service, Wendi Weber, Will Ryan

It’s like an old joke: HOW MANY TIMES CAN YOU SELL A DEAD RIVER? In the case of the Connecticut River and the Northfield Mountain Pumped Storage Project the answer is: Twice a Day for Fifty Years!

And the new answer to that old joke–if our federal and state leaders fail to step up again for this ecosystem: TWICE A DAY FOR 100 YEARS AND COUNTING!

Participants in a 2016 program at the fragile Rock Dam spawning habitat of the shortnose sturgeon that I did with Boyd Kynard.

Please, if you missed it in the Daily Hampshire Gazette or The Recorder, read BELOW the terrific op ed by Will Ryan, a UMass graduate and Northfield Mountain investigator, along with his colleagues. Will attended one of my river programs at the fragile Rock Dam spawning habitat of the federally endangered shortnose sturgeon. It sunk in–what a failed and unprotected ecosystem exists in Massachusetts, and that there really has never been a watchdog here to force the corporations or the agencies to comply with established law. It’s seen as merely a cash cow, run amok.

https://www.masslive.com/opinion/2022/03/firstlight-is-greenwashing-effects-on-health-of-connecticut-river-viewpoint.html

Joyriders descend on the fragile Rock Dam habitat, an ancient, starved and embattled place that many of us consider sacrosanct for its biological and cultural significance.

In a time when the very fabric of the Earth is rapidly fraying, it would be criminal of public officials to turn their back on the chance to revive the key living artery of our ecosystem. The US Fish & Wildlife Service, MA Dept. of Environmental Protection, MA Fisheries & Wildlife and NOAA’s National Marine Fisheries must step up now. The ugly scale of this antiquated scheme is to relicense the Northfield Mountain Pumped Storage Station to literally continue sucking away the life of the river for the next half century–re-marketing its deadened flow as twice-produced, net-loss megawatts to places as far away as New York, Pennsylvania, New Jersey and Maryland.

Right now leaders of those agencies are getting a second chance to do what’s morally and ethically required to assure there’s a Connecticut River legacy to pass on to future generations. Will they stand up, or will they bow to a short-sighted, long-term corporate cash scheme that trades an ecosystem for a net-loss, mega-scale power export configuration?

Predecessors of those four agencies failed disastrously 50 years ago by agreeing to allow that uninvestigated, brutal and lethally-disruptive machine to be installed on the Connecticut River. Today, that deadly contraption is being cleverly rebranded as clean, renewable and Earth-friendly–pedaled as the single best idea to accomplish energy storage for future generations here. In fact, its brutality has been unparalleled in this river’s natural history.

River-killing pumped storage is a 20th century crime, put forward in place of any number of energy storage and delivery configurations that should already be in place by 2022. It’s as if the only way to keep the lights on is to kill the very thing that has literally fed and sustained life in this Valley for millennia.

If you are lucky, you literally get one second-chance a century to conserve, protect and enforce the environmental protections left endlessly unattended on New England’s Great River. Like so many people in the Connecticut River Valley, I would never be the person who would turn their back on restoring this region’s critical ecosystem artery after a half century. That wholesale slaughter has come entirely at the hands of the Northfield Mountain Pumped Storage Project.

The Connecticut is a river without a bona fide protector, one with not even an NGO who can say they employ a single staff lawyer after 70 years of watershed council/conservancy window dressing. That’s what has left this ecosystem in tatters for generations. The corporations and the environmental agencies have never had a single thing to fear as the half century disaster rolled along….

Right now, the Connecticut River’s survival as this ecosystem’s most vital organ rests in their hands. It’s way past time our public trust agency leaders actually walked the talk. It’s time for them to stand up for the River’s life, and for those who come later. Here are their names. Use them, publicly. No river should die in the dark. They are being mentioned in Letters to the Editor, and No License to Kill filings with FERC:
Wendi Weber, Director Region 5 US Fish & Wildlife Service, wendi_weber@fws.gov; Martin Suuberg, Commissioner of MA Dept. of Environmental Protection; Mark Tisa, Director of the Division of Fisheries and Wildlife, mark.tisa@state.ma.us; Julie Crocker, NOAA/National Marine Fisheries ecosystems and energy branch chief, julie.crocker@noaa.gov,

And, finally, and once more–time is short in this relicensing process. FirstLight is again making claims they will have the fed/state agencies bought and sold in their secret, backroom license negotiations by March 15th. However unlikely, it is still time to keep up the pressure NOW! If you haven’t, or know someone who can, get them to take public action with FERC and the leaders noted above.

Again, here’s the NO License to Kill filing process for FERC–please share it, get someone to write, write a new letter yourself, NOW!

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

And thanks to all, or almost all–because this is hardly a complete list of those who have written FERC or op eds, or letters, or shown up on bridges and made signs. We’re still in the game! Think, if you can, of doing something NOW, a letter, asking a friend. Something that pushes this River’s life out of the backroom shadows and into the light. There is only NOW! RIGHT NOW!

Joseph W Stubblefield, Sanjay Arwade, Jonathan S Shefftz, Jamie Rowen, Michael Giles, William H. Pete, Nicholas Reich, James Lowenthal, Katharine Sims, William Daniels, Paige Wilder, Karl Meyer, Shayla G Freeland, Mary J Metzger, Robert Arbib, C Grecsek, Malcolm G Everett, Mike Cournyn, Robert Catlin, Don Ogden, William N. Ryan, Elizabeth Whitcomb, Judith Nietsche, Celt Grant, Susan Olmsted, David B. Keith, Glen Ayers, Virginia Hastings, Annie Chappell, James Seretta, Ron Barto, Robert Dickerman, Pamela Scott, Tanya Dragan, Lin Respess, Rebecca Tippens, Sigurd Nilsen, Peggy Matthews-Nilsen, Amy Rose, Steven Wilkinson, Stephen Kerr, Nancy Obertz, Dorothy McIver, Robert Sweener, Seth Wilpan, Norma Roche, Fergus Marshall, Louise P. Doud, Vicki Citron, John Nelson Jr., Jon Burgess, Robert F Porzio, Garrett D Connelly, Dave Dersham, Betsy Corner, Graham Hayward, Sid Siff, Paul Richmond, Betsy Browning, Rebecca Robbins, James Smethurst, Laura Doughty, Mary Hall, Laura Kaye, Frank Ribeiro, Andrew Hutchison, Mark Russo, Judith Phillips, Priscilla Lynch, Molly Freeland, John Hoffman, Roberta Murphy, Dodi Melnicoff, Ethel S. White.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sincerely,
Anne Naughton
Shelburne Falls, Massachusetts

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Alan Douglass
Regulatory Compliance Manager

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

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

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

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

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

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

Sincerely,
John L. Ragonese
FERC License Manager

The Connecticut River BUZZ: the NO LICENSE TO KILL podcast with WHMP host Buz Eisenberg, and the LATEST FERC citizen filings

Posted by on 30 Jan 2022 | Tagged as: Andrew Tittler, Buz Eisenberg, CommonWealth Magazine, Connecticut River, Connecticut River ecosystem, Connecticut River Refuge, Connecticut River shortnose sturgeon, CRC, crippled ecosystem, critical habitat, E-Comments, ecosystem, Endangered Species Act, ESA, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC license, FirstLight, Jesse Leddick, Kathleen Theoharides, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Martin Suuberg, Martin Suuberg: Commissioner MA Department of Environmental Protection, Mr. Jesse Leddick, Mr. Mark S. Tisa, Nation's best landscaped sewer, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, right-to-know, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service, USFWS, Wendi Weber, WHMP

The Connecticut River BUZZ: hear the NO LICENSE TO KILL podcast with WHMP host Buz Eisenberg, Greenfield Community College professor and attorney focused on civil liberties and human rights. Eisenberg represented detainees at Guantánamo Bay for 12 years beginning in 2004.

VALLEY CITIZENS CONTINUE TO HOLD OFF FirstLight’s plans in their fight for a living river; see their latest NO NEW NORTHFIELD FERC LICENSE on-the-record testimonies and the WHMP Afternoon Buz podcast link, BELOW:

1/27/2022: FirstLight’s crumbling, manganese-weeping Connecticut River banks adjacent to the Rock Dam river pool–beleaguered spawning and nursery site for the federally-endangered shortnose sturgeon.

* Legitimate watchdogs file INJUNCTIONS the second they find corporate infractions. They don’t look the other way in the face of ecosystem destruction for decades…

https://whmp.com/podcasts/the-afternoon-buzz-1-25-22/

Manganese-laced slurry directly entering critical habitat for the shortnose sturgeon. CRC refused to take water samples at this site, though they want to open it up to kayaks and rafts, and the attendant swimming that occurs here.

Document Accession #: 20220127-5119 Filed Date: 01/27/2022
Cynthia Lawton-Singer, Conway, MA.

“I strongly oppose the relicensing of the Northfield Mountain hydroelectric plant. The system requires more energy input to power itself than the energy that it will create. This contraption regularly disrupts and destroys the ecology of the river as it sucks every living organism out of the river and passes it through turbines. In doing this and then releasing the water from the mountain-top reservoir back into the river, the flow of the Connecticut River is reversed, once again disrupting the living creatures in the mile up and down stream from the outlet. The pump is powered by natural gas. A gas-powered pumping machine that seriously disrupts a MAJOR , four-state river’s ecology ( including endangered species, the Short-nosed Sturgeon), and is a net-energy CONSUMER, has no business calling itself a “green” or “sustainable.”

The damage done, in addition, to the river banks and to the aesthetic appeal of the Connecticut River leaves the Northfield community with a damaged and unappealing natural resource. The River should be an asset that will help the economy of the town bringing in tourists and sports-persons. Because of the disturbances on the river, none of the potential ecological or economic value of the Connecticut River is available to the Town of Northfield Massachusetts or to any of the upstream communities in Vermont and New Hampshire which would benefit from a return of the Short-nosed Sturgeon and a living river. We MUST not continue to make the mistake made 50 years ago and relicense this monstrosity. Another fifty years of this will seal the fates of countless species and deprive communities along the entire course of this river of a living beautiful, healthy Connecticut River. Again, PLEASE DO NOT relicense! Think of future generations. Thank you for your serious consideration of these objections.”
Any credible watchdog would have filed for an INJUNCTION for the deadly, suctioned and reversed river miles at Northfield Mountain, and the grim conditions for endangered sturgeon years ago. It would long-ago have been placed IN-THE-RECORD and prominent–as critical defense in this FERC relicensing. A poser would tell people that its fine to wait until AFTER federal and state agencies sign a secret 50-year settlement deal with FirstLight. A 70 year-old organization without a single staff lawyer would have people believe they can fix these little problems afterward

Document Accession #: 20220125-5000 Filed Date: 01/25/2022
Andy Rothschild, Greenfield, MA.

“Given the environmental challenges that our planet and its inhabitants face today and the increasing challenges that it will face over the next fifty years, it doesn’t make any sense to me to relicense the Northfield Station. The system requires more energy input to power itself than the energy that it will create. All the while, doing damage to the Connecticut River, its banks and the fish within it. Please think long and hard about the damage that would be done in the present and for the next crucial fifty years of our planet’s existence. Thank you.”

Document Accession #: 20220124-5001 Filed Date: 01/24/2022
Anna, Arlington, MA.

“I strongly oppose the relicensing of the Northfield Mountain hydroelectric plant. While shifting energy production to renewables is a pertinent step in battling the climate crisis, such a transition must be done in a manner that takes necessary precautions. This hydro plant reverses river flow and disrupts essential ecosystems of the Connecticut River. It is powered by natural gas. These two facts alone are reason enough to reconsider calling this project “green” or, even remotely sustainable. The Connecticut River, home to globally significant tidelands and 10 federally threatened aquatic species, is a watershed that spans four different states: VT, NH, MA, and CT. An estimated 2 million people live in the CR watershed. It is with utmost importance that we protect the river, not further degrade it’s well-being. The Northfield Mountain hydro plant should therefore be denied recertification.
Thank you.”

HERE ARE THE RESPONSIBLE DEPARTMENT OFFICIALS AND THEIR NEGOTIATION REPRESENTATIVES who are meeting behind closed doors with FirstLight:

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

AGAIN, if you haven’t yet submitted testimony–or know of others who want to defend our River’s right to survive as a living system, here’s the FERC formula to share:

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

This is THE PUBLIC’S RIVER!

NOTE: River ecosystem protection is inextricably linked to uplands and forests: see this great piece from Commonwealth Magazine:
https://commonwealthmagazine.org/opinion/use-our-forests-to-fight-climate-change/

The Connecticut River NOW! Defenders are taking their case directly to FERC; here’s why!

Posted by on 23 Jan 2022 | Tagged as: Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, CRC, CRWC, Delaware LLC, Extinction, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC license, FirstLight, Jo Comerford, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Natalie Blais, Nation's best landscaped sewer, National Marine Fisheries Service, net-loss power, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Source to Sea Cleanup, US Environmental Protection Agency, US Fish & Wildlife Service, USFWS

DON’T BE DIVERTED: The Connecticut River NOW! Defenders taking their case directly to FERC; here’s why!

* * * POST UPDATE: letter from today’s (Tues. 1/25/22) Greenfield Recorder. It nicely outlines FirstLight/Northfield’s massive impacts on a SINGLE town: https://www.recorder.com/ltr-field-ConcernsAboutPumpingStation-44673061


Federal and state agency reps, plus CRC’s Andy Fisk at a meeting of the Connecticut River Atlantic Salmon Commission. The US Fish & Wildlife Service, MA Fisheries & Wildlife, and the Connecticut River Conservancy have all signed in FirstLight’s non-disclosure agreement as they meet in secret.

With scores of citizens stepping up to defend our ecosystem, FirstLight’s secret January deal plans for the river have been thwarted. And more are writing in… These are folks who understand that–while many of the planet’s ecosystems seem to be foundering, if you are offered ONE CHANCE to turn the light’s BACK ON after a half-century of a massively broken Connecticut River ecosystem at Northfield Massachusetts, you DO NOT SQUANDER THE OPPORTUNITY. Certainly not for those who come after…

* * * ALSO UPDATED: Please see the TWO latest FERC testimonies sent directly–and on-the-record to FERC, at the end of this post. * *

ALSO, tomorrow, TUESDAY, at 4 p.m., I speak with attorney Buz Eisenberg on: The Afternoon Buzz | Shows | WHMP 101.5 / 1240 & 1400 AM.


Some of my personal river heroes…

DON’T BE DIVERTED! A new, out-of-the-box, save our river “opportunity” is today being pedaled to the public by two non-profits–one of which has signed FirstLight’s non-disclosure agreement. It’s a vague, dangerous idea at this critical juncture–belatedly promising that a sleek state legal angle can magically be employed over the next year to rescue the Connecticut River at Northfield from another 50 years of ecosystem strangulation AFTER a FirstLight federal settlement deal has been sent along to FERC with state agency signatures.

Right now, the US Fish & Wildlife Service, Massachusetts Dept. of Environmental Protection, the National Marine Fisheries Service, and MA Div. Fisheries & Wildlife are meeting in secret negotiating sessions with Canadian-owned, Delaware LLC-registered FirstLight Power to try an ink a grizzly “settlment” agreement to relicense the deadly operation of the Northfield Mountain Pumped Storage Station for the next 50 years. They’d wanted to have a signed deal by now that they could forward to the Federal Energy Regulatory Commission for approval. But strident public protest to FERC appears to be keeping state and federal agents from caving-in to another half century of a strangled Connecticut River.

The people are denying FirstLight from getting its way here.

This just-launched, last minute, state-pressure ploy comes off as both ridiculous and self-serving. THIS HAS BEEN A DECADE-LONG FEDERAL PROCESS–the tail won’t be wagging the dog here in Massachusetts on this four-state river system.

Once the SECRET DEAL in this slogging 10 year FERC process is inked at the highest levels–there will be NO magic mechanism at the MA wetlands level that has a snowballs-prayer-in hell to retrieve this crippled river from another half century of venture-capital devastation at Northfield. New England’s Great River will continue on as the “nation’s best landscaped” DEADLY sewer” here in Massachusetts. MA Dept. of Environmental Protection is at the backroom table in this process! Let’s be honest here…

Believing the brutal disruption, chaos and massive aquatic killing by FirstLight’s Northfield Mountain can be legislated ONCE a closed-door settlement deal is signed with the federal/state agencies meeting with Firstlight, is irresponsible MAGICAL THINKING. Some are even clinging to the notion that FERC will make a ruling ordering that BILLIONS AND BILLIONS of dollars must be spent to site, engineer and build a whole new Northfield reservoir that would exclude the use of river water. Think about that! Who would do it? Who would pay? It’s just not possible–or true.

BUT ALAS! FL is being thwarted in their plans by citizen input sent directly to FERC, with new, on-the-record statements demanding no new license be issued for deadly operations at Northfield, not another half century wasting massive amounts of energy to pull our river into reverse–literally for miles, in a buy-low/sell high 50 year profit scheme here in the Massachusetts.

AGAIN, if you haven’t yet submitted testimony–or know of others who want to defend our River’s right to survive as a living system, here’s the FERC formula to share:

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

* * * HERE IS JUST THE LATEST citizen testimony entered into the record at the Federal Energy Regulatory Commission:

Document Accession #: 20220125-5000 Filed Date: 01/25/2022
Andy Rothschild, Greenfield, MA.

Given the environmental challenges that our planet and its inhabitants face today and the increasing challenges that it will face over the next fifty years, it doesn’t make any sense to me to relicense the Northfield Station. The system requires more energy input to power itself than the energy that it will create. All the while, doing damage to the Connecticut River, its banks, and the fish within it. Please think long and hard about the damage
that would be done in the present and for the next crucial fifty years of our planet’s existence. Thank you.

Document Accession #: 20220124-5001 Filed Date: 01/24/2022
Anna, Arlington, MA.

I strongly oppose the relicensing of the Northfield Mountain hydroelectric plant. While shifting energy production to renewables is a pertinent step in battling the climate crisis, such a transition must be done in a manner that takes necessary precautions. This hydro plant reverses river flow and disrupts essential ecosystems of the Connecticut River. It is powered by
natural gas. These two facts alone are reason enough to reconsider calling this project “green” or, even remotely sustainable. The Connecticut River, home to globally significant tidelands and 10 federally threatened aquatic species, is a watershed that spans four different states: VT, NH, MA, and CT. An estimated 2 million people live in the CR watershed. It is with utmost importance that we protect the river, not further degrade it’s well-being. The Northfield Mountain hydro plant should therefore be denied
recertification.
Thank you.

Document Accession #: 20220121-5069 Filed Date: 01/21/2022
Christopher “Monte” Belmonte, Turners Falls, MA.

I live between the mighty Connecticut River and the Turners Falls Power Canal in a little island neighborhood called “The Patch.” The canal runs right past my backyard. I am a big believer in creating clean, fossil-fuel-free energy and I know that some of what First Light is doing is toward that end.
But it is unconscionable how much water is drawn from the river to keep the canal flush. I watch it go from a gorgeous raging river to a trickle from one day to the next, creating an ecological disaster for the aquatic life in that river. Specifically, the federally endangered shortnose sturgeon. Down the street from my house on the river at the so-called â€oeRock Dam†is one of
the best known, if not only, spawning locations of this endangered fish. And yet First Light continues to interfere with the flow of the river, even during spawning season. They might wipe out an entire species. And yet there is little to no acknowledgement of their risking ruining spawning year after year.

And no clear plan to stop under the new proposed license.
Further, the ecological disaster known as the Northfield Pump Storage station, which literally sucks the river flow backwards up to a mile away as it pumps, is also decimating what fish do manage to make it over their currently ineffective Fish Ladder in Turners Falls. While I’m pleased there will be a new way for fish to pass over the dam, until Northfield Mountain’s facility becomes a closed circuit, rather than a river sucking, fish massacring machine, First Light should not be granted a new license.
We have one chance left to save the shortnose sturgeon. If First Light is granted this license, as it is written, it’s game over for that federally endangered fish. This is a federal license. There is a fundamental disconnect in not doing our utmost to protect a federally endangered fish. And the disconnect between what good Northfield claims it provides, contrasted with
the uncountable millions of fish it is killing there each year is more than we who love our river can bear. Please reconsider this current license. Please make sure First Light is held to account and changes course before it changes the course of our river and its watershed.

CONNECTICUT RIVER UPDATE: STAY THE COURSE; KEEP UP THE PRESSURE!

Posted by on 20 Jan 2022 | Tagged as: Anadromous Fish Conservation Act, Commonwealth of Massachusetts, Connecticut River, Connecticut River blog, Connecticut River ecosystem, conservancy, Conte National Fish & Wildlife Refuge, critical habitat, E-Comments, ecosystem, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC Comments, FERC license, FirstLight, Holyoke Co. v Lyman, Landmark Supreme Court Decision 1872, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, migratory fish, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, public trust, right-to-know, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service

A Connecticut River deluge of citizens “no License to kill” defense pours into the Federal Energy Regulatory Commission.

READ THOSE DEFENDERS NAMES in the list below…

STAY THE COURSE; KEEP UP THE PRESSURE!

* * Also: On Sunday, January 23 at 10:00 AM, on Occupy the Airwaves, I join Paki Wieland, Bob Gardner and Emikan Sudan, to speak about these critical weeks for the future of the Connecticut River as FirstLight Power tries to nail down secret negotiations to relicense the devastation of the Northfield Mountain Pumped Storage Station for another half century: https://www.facebook.com/VFROccupytheAirwaves/ I hope you can listen and TAKE ACTION! * *

Occupy the Airwaves can be heard every Sunday morning at 10:00 AM on Valley Free Radio, WXOJ-LP, 103.3 FM, in Northampton, MA. Shows are re-broadcast every Friday at 3:00 PM, and can be streamed at www.valleyfreeradio.org.

HERE IS THE LIST OF THE LATEST CITIZEN HEROES of Connecticut River DEFENSE. NOTE: Update continues further below:

Joseph W Stubblefield, Sanjay Arwade, Jonathan S Shefftz, Jamie Rowen, Michael Giles, William H. Pete, Nicholas Reich, James Lowenthal, Katharine Sims, William Daniels, Paige Wilder, Karl Meyer, Shayla G Freeland, Mary J Metzger, Robert Arbib, C Grecsek, Malcolm G Everett, Mike Cournyn, Robert Catlin, Don Ogden, William N. Ryan, Elizabeth Whitcomb, Judith Nietsche, Celt Grant, Susan Olmsted, David B. Keith, Glen Ayers, Virginia Hastings, Annie Chappell, James Seretta, Ron Barto, Robert Dickerman, Pamela Scott, Tanya Dragan, Lin Respess, Rebecca Tippens, Sigurd Nilsen, Peggy Matthews-Nilsen, Amy Rose, Steven Wilkinson, Stephen Kerr, Nancy Obertz, Dorothy McIver, Robert Sweener, Seth Wilpan, Norma Roche, Fergus Marshall, Louise P. Doud, Vicki Citron, John Nelson Jr., Jon Burgess, Robert F Porzio, Garrett D Connelly, Dave Dersham, Betsy Corner, Graham Hayward, Sid Siff, Paul Richmond, Betsy Browning, Rebecca Robbins, James Smethurst, Laura Doughty, Mary Hall, Laura Kaye, Frank Ribeiro, Andrew Hutchison, Mark Russo, Judith Phillips, Priscilla Lynch, Molly Freeland, John Hoffman, Roberta Murphy, Dodi Melnicoff, Ethel S. White.

These folks have gone on the record with FERC in recent weeks and months, stating no new license should be issued for the Northfield Mountain Pumped Storage Station. They are from up and down the Connecticut Valley, from the Bay State’s border with Connecticut, up to Putney VT. I hope I haven’t skipped any of these people who understand ecosystems and have had the courage to defend ours for those who come along after. Many have also made their defense stronger by posting it in the public press. Thank you all, and stay the course!

These River’s defenders have staved off FirstLight’s secret license-to-kill negotiated plans with US Fish & Wildlife, National Marine Fisheries, MA DEP and MA Fisheries & Wildlife. THEY ARE SUCCEEDING: * NO SECRET AGREEMENT has yet been signed!! *

Don’t get sidetracked: STAY THE COURSE; KEEP UP THE PRESSURE!

OF CRITICAL NOTE:

I’ve been forwarded some posts recently. They appear to be some watershed rhetoric claiming to have discovered a last-minute, secret mechanism that can change the trajectory of this federal process at the state-level–AFTER a negotiated deal has been signed by the big-dog players and forwarded to FERC for approval.

That Cinderella idea seems to be just more window dressing from those who’ve failed to engage openly with the public in this 10 year fight. There have been decades–and numerous opportunities for any bona fide watchdog to file lawsuits on any number of flow, critical habitat and wetlands infractions and flagrant ecosystem damage across half a century.

New England’s River has been left on life-support here in Massachusetts—reversed, comatose and massively-deadly at Northfield for the last half century. There have been no lawsuits; there have been no challenges—under the Clean Water Act, Rivers and Harbors Act, Endangered Species Act, the 1872 Supreme Court ruling in Holyoke Company v. Lyman. None stood up as responsible public trust agencies for decade upon decade as the river was left in ruins as the Nation’s best landscaped deadly sewer in the Commonwealth.

We’ve just never had a real watchdog here. If there had been one it would have sued federal and state agencies and taken on a power company long ago. Defenseless for 50 years… YOU DON’T STAND BY WATCHING THE HORSE LEAVE THE BARN!

At this time, in this top-down federal process where big-time forever decisions are being made beyond the public eye, the key place to put the pressure on the agencies charged with protecting our public trust is straight to the top: GOING ON THE RECORD WITH THE FEDERAL ENERGY REGULATORY COMMISSION. Every FERC entry these defenders made has also been seen and registered in the licensing files by MA DEP, US Fish & Wildlife, MA Fisheries and Wildlife, and National Marine Fisheries. These folks are getting a constituent earful.

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

It is pure fantasy that it will be possible to “save the river” and make key changes to a top-down negotiated federal deal AFTER these key agencies have signed some giant ecosystem compromise with venture capital FirstLight for the next 50 years. It’s pure fantasy, bravado, and soft-pedaling of the critical juncture we are at right NOW.

The only sensible, just and moral position to take with the future of an ecosystem that must be revived to support coming generations is simply: NO LICENSE TO KILL. That’s what’s at stake right now—telling our public agents there can be no deal sanctioning a half century of massive fish kills and river reversals here in Massachusetts, in the heart of the S.O. Conte Connecticut River National Fish & Wildlife Refuge. ONCE it’s signed, there will be little if anything left to re-bargain over. The time is NOW.

There is no sugarcoating what’s at stake RIGHT NOW in secret Connecticut River federal relicensing negotiations occurring behind closed doors between FirstLight and fed/state agencies. It’s no less than the future of a living Connecticut River ecosystem. Critically, what takes place and gets secretly-signed in that backroom closet between FirstLight’s venture capital lawyers, and federal and state environmental trust entities is likely to seal the life-or-death fate of a broken ecosystem here for what ‘s essentially its last chance at revival. There are many examples of terrific testimony and river defense in the other blog posts on this site.

AGAIN, if you haven’t yet submitted testimony–or know of others who want to defend our River’s right to survive as a living system, here’s the FERC formula to share:

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

This is THE PUBLIC’S RIVER!

More Connecticut River citizens’ defense

Posted by on 13 Jan 2022 | Tagged as: America's best landscaped sewer, American shad, Clean Water Act, Commonwealth of Massachusetts, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River blog, Connecticut River Conservancy, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River Watershed Council, Endangered Species Act, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, fish kill, Holyoke Co. v Lyman, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, migratory fish, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, NOAA, Northeast Utilities, Northfield Mountain, Northfield Mountain Pumped Storage Station, NU/WMECO, P-2485, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Source to Sea Cleanup, US Fish & Wildlife Service

THE CONNECTICUT RIVER’S CITIZEN DEFENSE continues:
While FirstLight’s secret January license “settlement” talks continue–centered around leaky net ideas and spit-and-glue window dressing at Northfield Mountain, the public is demanding that its 50 years of devastation cease.

https://www.youtube.com/watch?v=ybwy8MBiy9I
* * NOTE: ABOVE is a link to a Wilbraham Public Library ecology lecture series I was asked to take part in last November. The title of my presentation was: “LIVING RIVERS FLOW DOWNSTREAM.” IT IS A KEY HISTORIC PERSPECTIVE to understanding why we live in a broken ecosystem… * *

https://www.gazettenet.com/my-turn-meyer-LastLightCtRiver-44127152

FirstLight led closed-door bargaining with state and federal fish and environment agencies are continuing here in MA, while an ongoing flood of citizen testimony to end Northfield Mountain’s license to kill continues at the Federal Energy Regulatory Commission.

THOSE DEMANDS–from no less than 77 people since November 13th, are also sending a very clear signal to the MA Division of Fish & Wildlife, MA DEP, the US Fish & Wildlife, and National Marine Fisheries Service:

DON’T SELL OUT New England’s Great River for another half-century!

* Read the latest public testimony targeting Northfield lethal ecosystem destruction entered into the FERC record further below.*

BUT FOR THE LONG VIEW, HERE’S A LITTLE ILLUMINATING HISTORY:

Only living rivers flow downstream. But that’s not what you find on the Connecticut River in the Commonwealth of Massachusetts. Here, 150 years after the US Supreme Court guaranteed safe upstream and downstream passage of migratory fish to and from New Hampshire and Vermont—and a full half century after the enacting of the Clean Water Act and Endangered Species Act, the Northfield Mountain Pumped Storage Station continues to chew-through, reverse and obliterate the key living ecosystem functions of New England’s critical central artery here in northern Massachusetts.

The grim prospects of allowing Northfield to be built were widely known by federal and state agencies half a decade before it began its deadly, net-power loss, river-reversing ecosystem damage. Here, from the same agencies that are today’s MA Fish & Wildlife, US Fish & Wildlife Service, and the National Marine Fisheries Service (the entities still publicly responsible for environmental enforcement and river fish protection), are their words from a key, signed, 1967 document:

“Statement of Intent for a Cooperative Fishery Restoration Program for the Connecticut River Basin”

“Based on the present fragmentary data available on the Northfield Pump Storage Project, it appears that this project poses definite limitations to an anadromous fish restoration program. These limitations involve the physical loss of eggs, larvae, and young fish of both anadromous and resident species, and an orientation problem for both upstream and downstream migrants attributed to pumping large volumes of water. Studies, designed to minimize the potential adverse effects to fishery resources, should be undertaken in development of the design for the Northfield Pump Storage Project. In related studies, fish screens, barriers and deflectors, and flow regimen must be thoroughly investigated.”

Those agencies’ inaction, their failure to protect–while instead indulging in a massive frenzy to recreate an extirpated salmon hybrid in place of a fish not seen here since 1809, proved disastrous for the river’s still-living fish runs and species in this four-state ecosystem. Today, absurdly, a deadly Northfield Mountain soldiers on, while—50 years later those same agencies dicker with foreign owners over emplacing a new band-aid of a barrier net—one full of holes, upstream of that deadly, river-reversing suction.

In the “library” at the Connecticut River Watershed Council—today’s “Conservancy”, there is a boxed, mid-1960s promotional document from WMECO/Northeast Utilities. NU is today does business as Eversource, the perennial chief sponsor of the Conservancy’s Source to Sea Cleanup. That half-century old box contains a glossy booklet promoting the future construction of a Northfield Mountain Pumped Storage Station. The booklet includes several scenarios and options to premise how of its net-loss power pumping operations might be deployed.

One of them was a glaring red flag for the river, its fish, and an entire ecosystem…

The Watershed Council HQ has a private library within…

THAT SHUTDOWN OPTION, never implemented, was that Northfield’s impacts would be so detrimental to the river and life cycles of its migratory fish that it would have to be shut it down during fish migration season. But here again, no watchdog ever emerged to stand up and fight for a living Connecticut River in Massachusetts. Basically, the only protection ever offered was a net to protect their mythical, teeny, hatchery-bred baby salmon, leaving all the river’s other species to fend for themselves.

Thus Northfield’s gargantuan and lethal water and fish appetite still strangles New England’s four-state ecosystem today. And, half a century later, those same public agencies are allowing a power company to dangle the grim bait of temporary fish barrier net before them once more.

ABOVE IS AN EPA-ORDERED “silt barrier” mandated to be kept in place at FirstLight’s Northfield intake after they were caught flagrantly and clandestinely dumping a mountain of muck directly into the river for over 90 days straight in gross violation of the Clean Water Act. Looking closely, you can see it has FAILED, its anchors useless, and its floats flapping in the breeze along the shoreline downstream of Northfield’s sucking intake. Photo taken 10/2/2010.

Even two years after Northfield came on-line the Federal Power Commission–today’s FERC, still had not been given answers to information they’ requested of WMECO–today’s Eversource, including describing flows on a reversing river. This is a Xeroxed document from FERC:

20010120-0656 FERC PDF (Unofficial) 09/10/2014: January 22, 1974, from the Federal Power Commission to WMECO:

Robert E. Barrett, Jr.,President.
Western Massachusetts Electric Company
West Springfield, Massachusetts 01089

Dear Mr. Barrett:
The Commission staff is presently preparing the Draft Environmental Impact Statement for the Turners Falls Project (No. 1889) and requests the following information:
(1) In the revised Fxhibit W of the application (page 43, second paragraph), reference is made to the continuing resident fish study being conducted in Turners Falls Reservoir. Please provide a copy of the results obtained since the last Progress Report. If the study has not been completed, please indicate the date you expect a report to be available.

(2) In Exhibit W (pages 19, 20, and Figure 5), the conditions expected to produce flow reversals in the Turners Falls ‘Reservoir as a result of Northfield operation were set forth. Since the Northfield Mountain Project became operational, which of the conditions described have been observed to produce reverse flows? Based on operational experience, are there any observed or anticipated changes in the patterns, durations, or velocities of the flows described therein? Your early response in providing this information would be appreciated.
Very truly yours,
Secretary

On October 16, 1974, WMECO’s lawyers finally replied in the negative to the Federal Power Commission’s questions, stating they still had not implemented the required study which would offer answers to questions about the impacts of reversing the flow of the Connecticut:

“Staff also inquired whether the Company had a study on the effect of hydrology caused by the pumping of Northfield Mountain project this year. The Northfield Licensees have not made a formal study but are accumulating data with respect to Pond elevations, flows and other operating data.”

EVERYBODY KNEW 50 YEARS AGO: yet nobody came to the Connecticut’s rescue…

BUT TODAY CITIZENS are standing up for the living river owed future generations. SEE BELOW for the latest entries into the FERC public record…

BUT FIRST, here’s how it can be done:
Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

HERE ARE THE LATEST:

Document Accession #: 20220111-5033 Filed Date: 01/11/2022
Elizabeth J Erickson, Colrain, MA.

As a long time resident of Franklin County I have for a long time been very concerned about the environmental and ecosystem destruction at Northfield mountain because of the power generating plant there. I have been following the research about the decline in fish populations in the Connecticut River nearby because of the turbines and am strongly opposed to the reicensing of the First Light hydropower plant there. I’m actually shocked that the relicensing is even being considered given all that is now known about how destructive the plant is. Please deny any future license of power generation of Northfield Mountain.

thank you,
Elizabeth Erickson
Colrain, Massachusetts

Document Accession #: 20220111-5005 Filed Date: 01/11/2022
John Hoffman, Shelburne Falls, MA.

I am writing to ask that you deny a continuation of the license for FirstLight Hydro Generating Company. The project began as a way to make use of excess power from the Vernon Nuclear Power Plant. That plant is now closed. This license is now simply a vehicle for FirstLight to use its capitol to make a profit.

That profit comes at the expense of the Connecticut River, one of the glories of New England, and the source of outstanding agricultural soils in the Connecticut River valley. Now that we possess a vastly more sophisticated understanding of river ecology, the damage to the river is elaborately documented.

By sucking large volumes of water out of the river and then disgorging them back, the company erodes the river banks which in turn damages water quality. The turbines through which water is sucked destroy aquatic life, from adult fish, to their young and down to their eggs.

This is a primitive way to treat a river. No company in our present era should be allowed to inflict such damage. This river is a part of the commonwealth of Massachusetts. We the citizens ask you to protect the invaluable ecosystem of our preeminent river and deny FirstLight its license.
Future generations will thank you.

Document Accession #: 20220111-5004 Filed Date: 01/11/2022
Molly Freeland, Gill, MA.

To whom it may concern,
I am a resident of Gill Massachusetts and I request that you do not let Northfield Mountain Pump Station renew their license. The pump station is killing all life it sucks up from the river. Millions of fish are dyeing every year, including endangered short nose sturgeon. The pump station causes major erosion in the river banks which then spreads pollution. The pump station is escalating climate change when we need to be looking to renewable energy sources. Please say no to the pump station for our children, grandchildren, all life and the planet.
Sincerely,
Molly Freeland

Document Accession #: 20220111-5002 Filed Date: 01/11/2022
Irma Lorraine Pearson, Greenfield, MA.

If we, residing in the Democratic heart of our country, cannot save the only large river we have, and all the life in it, we are putting our imprimature on the destruction of our planet for the sake of building private fortunes.

The cautionary tale of Midas and his gold works very well here.
Let’s try another path, of freeing the rivers of dams and reversals, and saving 50% of our ecosystem as wilderness.

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