Silvio O. Conte Connecticut River National Fish and Wildlife Refuge

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ENDGAME LOOMS FOR NEW ENGLAND’S GREAT RIVER

Posted by on 10 Sep 2020 | Tagged as: American shad, Anadromous Fish Conservation Act, Atlantic salmon, blueback herring, climate-destroying, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, endangerd shortnose sturgeon, Endangered Species Act, ESA, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power Resources, Fish and Aquatics Study Team, GHG, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, pumped storage, right-to-know, Rock Dam, shad, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Revelator, The Society of Environmental Journalists, Turners Falls, Turners Falls dam, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, USFWS, Vermont

Endgame Looms for England’s Great River Copyright © 2020 by Karl Meyer


The impoverished Connecticut River looking downstream to Turners Falls Dam. The run stops here. Photo Copyright © 2020 by Karl Meyer All Rights Reserved. (CLICK x 3 to enlarge)

NOTE: The following piece first appeared as an Op-Ed in The Revelator, an initiative of the Center for Biological Diversity on August 26, 2020. www.therevelator.org

FURTHER NOTE: * On September 1, 2020, after this piece first appeared, FirstLight petitioned FERC for an open-ended date to extend the filing of their Final License Applications citing a need for new test data to respond to the USF&WS. If FERC agrees, that would add another 4 months and possibly another full year, to this endless process–without any long-awaited relief for a flow starved Connecticut River. It’s time for FERC to wrap this up.

After a half-century of failures, the recovery of the Connecticut River ecosystem hangs in the balance. Will authorities finally act to save it?

Rivers should not die in the dark.

On Aug. 31 FirstLight Power Resources is expected to file its final license applications with the Federal Energy Regulatory Commission to continue operating three hydro facilities profiting off massive water diversions from the Connecticut River in Massachusetts. The conditions written into FERC licenses can last up to 50 years.

These applications signal the beginning of the final chapter in determining the future of the four-state river at the heart of the Silvio O. Conte National Fish and Wildlife Refuge, founded to protect a 7.2-million-acre watershed. Their rendering will decide the future of migratory fish, river flows and a host of embattled ecosystem conditions on New England’s longest river, some running counter to laws in place since 1872.

When decisions affecting a river for decades are being made, the public has a right to know of the stakes, the players and the key decision makers. In this case the public knows little of issues potentially affecting 2.4 million people in a sprawling watershed.

One of the failed fish ladders sending all spring migrants into the Turners Falls power canal maize. Across 45 years just 5 shad in 100 have succeeded in passing the Turners Falls Dam–leaving 50 miles of spawning habitat in 3 states largely empty. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife have been at the table in this FERC license-determining process since 2012. But three years back, all parties signed nondisclosure agreements with FirstLight — ostensibly to facilitate settlement discussions on flows, habitat, dismal fish passage and endless mortality cycles at these Massachusetts hydro sites. Those NDAs have kept these issues largely out of the media, even as initial settlement talks broke off a year and a half ago.

*Since 2012 I’ve been a FERC-recognized intervener in the relicensing process. I chose not to sign the company’s confidentiality agreement in order to preserve the right to address and highlight the critical, long-term decisions being made about the Connecticut River in a process that remains largely out of public view.

FirstLight is part of the giant Canadian investment outfit PSP Investments, which arrived in Massachusetts four years back to buy up these facilities from GDF Suez. In 2018 it quickly reregistered the facilities as limited liability tax shelters in Delaware. Regardless of their state of incorporation, the licenses they now vie for will each be subject to current federal and state environmental laws, under terms mandated by the fish agencies and FERC.

Entranceway to the “Great Falls Discovery Center” where, most days out of the year, there are literally no great falls running here at all… The sprawling rocky riverbed is an emptied bowl. Photo Copyright © 2020 by Karl Meyer.

Of more than 500 U.S. refuges, Conte is one of just three with “fish” in its name. Today hopes for the long-term protections of its fish and the river comprising its central artery rest heavily in the hands of the U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife. They have “conditioning authority” in these relicensings — mandates to protect the life in this river system. FERC, the ultimate relicensing umpire here, is also mandated to ensure compliance with environmental laws. For the fish agencies this is their one chance to redeem some far-reaching mistakes made by their predecessors.

Forty-five years ago these agencies — operating on limited information and pursuing dreams of reprising a salmon not seen on this river since 1809 — signed agreements with different owners of these facilities. That hobbled, for generations, a four-state migratory fisheries restoration for American shad and river herring and a recovery for federally endangered shortnose sturgeon. They sanctioned the daily use of the massive river-reversing pumped storage facility still chewing through generations of migratory and resident fish today. Concurrently they left two miles of the river emptied downstream, its flow diverted into a turbine-lined power canal that all migrants must negotiate in order to access the next 50 miles of open spawning habitat. Just 5 shad in 100 have ever succeeded. Perhaps worse, the river’s only documented natural spawning habitat for the endangered shortnose sturgeon was left without life-sustaining flow.

A Tale of Two Salmon, a River Without Fish

The last wild salmon run on the Connecticut River was recorded in 1809.

Science later revealed the salmons’ end was likely a combination of warming temperatures following the unusually cold period known as the Little Ice Age coupled with modern dam building.

For 165 years there were no salmon. Then, in 1974, a single fish arrived at Holyoke Dam. Far from being a native of the Connecticut River, this was a new hybrid — a returning fish produced at one of several federal hatcheries completed five years prior. This salmon’s genes, like the genes of all the fish that would return in subsequent years, were cobbled together using salmon from several still-surviving runs in northern New England.

This past June 30 marked a different milestone on the river. It ended the first season in 46 years when not a single hatchery-derived Atlantic salmon returned past Massachusetts’ Holyoke Dam.

That unnatural history event passed with little fanfare. Its silent-spring absence marked the end of a half-century-old program that consumed hundreds of millions of dollars and ate up far too much room in a badly broken ecosystem. The U.S. Fish and Wildlife Service abandoned its hatchery program at the end of the 2012 migration season, but across its 43 years — which saw the annual release of millions of fry and smolts to tributaries in Connecticut, Massachusetts, Vermont and New Hampshire — so few adults returned that no one was ever allowed to catch one.

This second salmon ending highlights the fish agencies’ last shot at returning ancient ocean connections to the river’s still-viable, age-old runs of American shad, blueback herring and federally endangered shortnose sturgeon in three states.

All these species have been guaranteed safe passage on U.S. rivers, going back to the landmark Supreme Court decision in Holyoke Company v. Lyman in 1872. That finding centered on the dam in Holyoke, Massachusetts and held that private dam owners operating on U.S. rivers must provide for the free movement, upstream and down, of migratory fish past their facilities.

Looking west across the CT to the Holyoke Dam fish lift complex. Since 1955 it is one of the East Coast’s few fish passage successes. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Its implementation on New England’s river is now 148 years overdue.

A River Run in Reverse

What’s ultimately at issue here is flow.

Having taken a back seat for generations, wild runs of shad, herring and sturgeon remain in desperate need of passage and consistent, exponentially increased river flow in FirstLight’s hydro-complex dominated reach. It’s literally the weight of water that matters most to FirstLight. It’s money in the bank. And where flow diversion is concerned, it’s been pretty much a free ride for companies here for the past 50 years.

The 20 miles of river backed up into Vermont and New Hampshire behind Turners Falls Dam are massively suctioned for hours at up to 15,000 cubic feet per second to fill the 4-billion-gallon reservoir above the Northfield Mountain Pumped Storage Station.

Northfield’s suction is so violent it literally reverses the Connecticut’s current for up to a mile downstream at times, erasing the essence of a living river system. The station kills everything it sucks in, from tiny fish eggs to full-size eels. In pumping mode it suctions the equivalent of 3,600 seven-bedroom mansions, each filled with the aquatic life of a river, vaporized every hour, for hours on end. Agency studies on America shad show tens of millions of eggs and larvae extinguished at Northfield annually, plus the deaths of over 2 million juvenile shad sucked in on migrations back to the sea. Five migrant species are subjected to Northfield. In all 24 species live here, most unstudied.

Warning floats on the CT at the entranceway to Northfield Mountain Pumped Storage Station’s massive subsurface suctioning site. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Northfield’s operations are nothing like classic hydro, operating to produce virgin electricity via a dam in or adjacent to a river. It’s actually an electric appliance, built to take advantage of excess, unused megawatts produced nightly at the nearby Vermont Yankee nuclear station. Northfield burns electricity to pump water from the river a mile uphill to into its reservoir tank, which was created by blasting off the top of a mountain. The company’s original owners would buy up Vermont Yankee’s cheap electricity to power its giant, reversible turbines. Later, during peak energy times, that now-lifeless river water would get sent back through the turbines to generate hours-long pulses of energy at peak market prices.

It’s a buy-low, sell-high operation, still running at the expense of a river system six years after Vermont Yankee shut down.

Idle bulldozers sit in the emptied bed of the giant NMPS reservoir on June 27, 2010–the year they broke their giant appliance by fouling the pumps with muck and silt. Sanctioned by the EPA for a cover-up and massively dumping the muck from their mile-long intake tunnel directly into the river, Northfield didn’t operate for over half a year. Photo Copyright © 2020 by Karl Meyer. All Rights Reserved. (Click x3 to enlarge.)

Northfield is a net-loss energy machine — a giant underground appliance consuming massive amounts of grid electricity, half of it now generated by the climate-scorching natural gas that dominates New England’s power grid today. The station consumes 25% to 33% more juice than the secondhand megawatts it sends back by dumping deadened river water back through its turbines. It and a smaller pumped storage station in Connecticut are responsible for gobbling up 1.4% percent of the region’s energy in order to reproduce the few hours of secondhand juice they regenerate. According to grid operator ISO-New England, they are the only facilities whose operations flush out as negative input in the regional power mix.

Northfield has never generated a single watt of its own electricity. And though it may be fine as blunt instrument for use during the occasional power grid slump or rare emergency blackout, its endless, river-crippling, pump-and-purge cycle of regenerated megawatts is unnecessary for the daily operation of the New England grid. While its owners brag of being able to power a million homes for a few hours, they never mention having already burned through the energy of 1.25 million homes to do so. After its daily flush, Northfield is virtually dead in the water and must begin pulling from the grid and sucking life from the river all over.

Past mistakes not only allowed for this massive upstream disruption, they sanctioned diversion of nearly all flow, as well as all migrating fish, into a downstream power canal that on average just 5% of shad have ever successfully negotiated. That left another two miles of New England’s river dysfunctional, with the company providing just a dribble flow of 400 cubic feet per second in the riverbed in spring, when fish are moving upriver. That riverbed remains emptied of all flow more than half the other days of the year.

The most critical time for sustaining flows and the river’s migrants is April through June, when New England’s energy consumption is at its low annual ebb. But federal and state studies and in-river findings show that spring flows will need to be increased by a factor of 20, supplying 8,000 cfs rather than the current brook-like drizzle of 400 cfs. That’s what it will take to guide shad and blueback herring upstream in the river past Turners Falls Dam. That will also provide this river’s only endangered migrant the consistent flows required to successfully allow the shortnose sturgeon to spawn and ensure its larvae can develop in the cobbles at an ancient river pool in that impoverished reach.

Flow starved Connecticut River at the Rock Dam–critical shortnose sturgeon spawning and rearing site, May 13, 2018. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Back in 1967, when four New England states and these agencies signed the “Statement of Intent for the Cooperative Fishery Restoration Program for the Connecticut River Basin,” they projected some 38,000 salmon would return annually to this four-state ecosystem. For salmon, a pinnacle of sorts was reached in 1981, when 592 were tallied passing Holyoke. But for a hybrid fish whose wild prototype disappeared 160 years prior, it was downhill from there. Most years fewer than 100 salmon returned to the river.

That 1967 agreement also set annual run targets of one million American shad heading upstream, with 850,000 shad passing Turners Falls and 750,000 entering Vermont and New Hampshire habitats above Vernon Dam. The highest shad return saw 720,000 passing Holyoke in 1992. Sadly, they’ve never made it much farther.

The Run Stops in Massachusetts.

Just 36 miles upstream of Holyoke, all semblance of a successful restoration ends when the annual shad run reaches Turners Falls Dam. Of the 537,000 shad that passed Holyoke in 2017, just 48,000 — a mere 9% — squeezed back into the river beyond Turners Falls.

Vernon Dam between Vernon VT and Hinsdale NH, March 2020. Photo Copyright © 2020 by Karl Meyer

The annual inversion at the next upstream dam in Vermont illustrates the perils on this broken river. In 2017 29,000 or 59% of the shad that survived the miseries of Turners Falls were subsequently counted passing Vernon Dam, 20 miles upriver. That inverted interstate ratio has been the case since 1975, with few shad managing to break out beyond the brutal ecosystem conditions in Massachusetts.

Why the Restoration Failed

The current restoration, congressionally authorized in 1967 and still operating today under the moniker of the Connecticut River Atlantic Salmon Commission, made their biggest blunder in 1975 when they signed off on new license requirements for upstream fish passage. They ultimately chose a design based on hydro project fish ladders on Washington State’s giant Columbia River, known for huge Pacific salmon runs. What got built was a three-ladder fish passage that forced all migrants out of their ancient river highway and into the byzantine maze of the company’s power canal, while leaving two miles of riverbed all but emptied of flow.

Scaled down and put in place at Turners Falls, it worked fine for the program’s few successfully returning hybrid salmon but failed immediately for 95% of the hundreds of thousands of migrating shad. No big run has ever passed that site, leaving three states without their promised bounties. Vermont and New Hampshire remain this river’s shad deserts today.

The Prescription

It’s now 2020. At this late date, corporate re-registrations can’t hide what’s legally required and a half-century overdue on New England’s river. The last opportunity to undo those festering mistakes for the Connecticut now rest in the hands of the National Marine Fisheries Service, U.S. Fish and Wildlife Service and Massachusetts Division of Fish and Wildlife. They are the people’s gatekeepers, mandated to guard the public trust — agencies with the authority to change to the generations-old crippling conditions here in Massachusetts.

Across 45 years of tracking fish runs passing upstream at successive dams on the Connecticut, shad counts have averaged 315,369 at Holyoke, 17,579 at Turners Falls, and just 9,299 at the Vernon Dam in Vermont. But recently long-term federal and state studies on passage and juvenile survival for American shad have led to new minimum benchmarks for fish passage at each dam to ensure the long-term survival of the river’s runs.

Using those findings, the Atlantic States Marine Fisheries Commission, National Marine Fisheries Service, U.S. Fish and Wildlife Service and the four states have formally adopted new Connecticut River fish passage goals. They include annual minimums of 687,000 shad passing Holyoke, 297,000 passing Turners Falls, and 227,000 at Vernon Dam annually. Those federal and state targets are now part of the public record in the current FERC relicensings. Their implementation would also ensure the endangered shortnose sturgeon gets the flows needed to begin its recovery here.

It’s time to return flow to the Connecticut River below Turners Falls. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The time has come for facilities operating and profiting off the life of New England’s river to come into compliance with the laws of the land, including the Supreme Court’s 1872 finding in Holyoke Company v. Lyman, the Anadromous Fish Conservation Act of 1965, the Endangered Species Act of 1973 and a host of others. For the fisheries agencies charged with protecting a river’s bounty, standing up for their implementation is the sole prescription for success in a four-state restoration undertaken when back Lyndon Johnson was president.

By law, by right and by the public trust, the Connecticut River’s time has come.

Karl Meyer has been a member of the Fish & Aquatics Studies Team and an intervener in the Federal Energy Regulatory Commission relicensing process for three Massachusetts facilities on the Connecticut River since 2012. He lives in Greenfield, Massachusetts. Meyer is a member of The Society of Environmental Journalists.

* * FINAL NOTE from the author: if all this history is new and troubling to you it must be considered that: this is the only river in the Northeast with several federal designations that has remained the only major waterway without an independent and effective watchdog–one with a full legal team on staff, and a mandate to investigate, enforce, and go to court. The generations-long mistakes and brutal conditions that have existed here would’ve long ago been challenged in court had there been an effective organization protecting the integrity of this river system. If the Connecticut River is to have a future as a living ecosystem, a new model will have to come into being.

IS IT CLEAN? Connecticut River at its most Critical Habitat

Posted by on 27 Jul 2020 | Tagged as: American shad, Cabot Woods, Connecticut River, Connecticut River riverbank failure, critical habitat, Endangered Species Act, federally-endangered Connecticut River shortnose sturgeon, FirstLight, FISH and Wildlife Refuge??, manganese pollution, Rock Dam, Rock Dam Pool, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turners Falls power canal

IS IT CLEAN? Connecticut River at its most Critical Habitat
Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

THIS LITTLE PHOTO ESSAY WAS taken in the early morning hours of July 26, 2020, on the Connecticut River at the Rock Dam. This would be another brutal 90 degree day in this fragile site on a largely dewatered river. This is the Connecticut River at the Rock Dam pool, which is the critical spawning site for the endangered shortnose sturgeon. American shad also spawn here. Also, it may well be the last refuge in this river section for the state-endangered yellow lampmussel.

The photos begin by showing the Connecticut River looking upstream at the Rock Dam, and then trace the grim soup entering the site from the failing riverbanks of FirstLight’s Cabot Woods area, adjacent to the Turners Falls Power Canal. Basically, it walk you back along the manganese and iron muck trail heading up the riverbank along FirstLight’s eroded and crumbling access, and then takes you up top–looking back down on the failing sludge slumping down to the river, and then to their scoured-out, wood chipped picnic area, before the added in pictures of the adjacent canal/swamp–the obvious source water for the seeping sludge pollution.

I will let you judge for yourself as to: Is it CLEAN? And, more importantly, IS IT PROTECTED??
(CLICK ANY PHOTO X3 to ENLARGE)

Looking across and upstream on the river at Rock Dam. Endangered species habitat? Really??
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


A sneaker adds a bit of perspective.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


Connecticut River below Rock Dam, with the cobbled area in the background where shortnose sturgeon larvae are supposed to find shelter and protection to develop.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


Red pool feeding into base of Rock Dam habitat.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


Sludge close-up, going uphill from where the owners simply dumped rubble down the banks in years past. What Clean Water Act?
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


The grim red soup, looking up the slumping banks from Rock Dam to FirstLight’s Cabot Woods ‘picnic’ area…
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


The eroded, unmaintained “access” path leading down to Rock Dam, with abandoned stair pilings visible in background.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


From above, FirstLight’s failed banks leaching down to the Connecticut from above the Rock Dam.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


Looking down to Rock Dam over FirstLights failed riverbanks.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


This chipped-tree path of scoured out woods leading to Rock Dam.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED
What’s the activating source water for these failed Connecticut River banks? Humnnn…Just a few hundred feet away sits the TURNERS FALLS CANAL.
This picture is from 2009, the last time the canal swamp was mucked out.


This is TF Canal July 24, 2020. It is now more swamp than canal in its location adjacent to the Connecticut at Cabot Woods/Rock Dam
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


This is TF Canal July 24, 2020. This is a swamp.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

A RIVER in HEATSTROKE: A Photo Portrait on July’s Hottest Day

Posted by on 21 Jul 2020 | Tagged as: Clean Water Act, climate-destroying, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, endangerd shortnose sturgeon, Endangered Species Act, FirstLight, Great Falls, Peskeomscutt Island, Rock Dam, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turners Falls dam, Turners Falls power canal, US Geological Survey's Conte Fish Lab, Vermont

A RIVER in HEATSTROKE: A Photo Portrait on July’s Hottest Day
Story and pictures Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

The above photo of the “Great Falls” at Turners Falls was taken at approximately 6:45 am, on July 19, 2020, the hottest day on a boiling-out planet this year. The riverbed below was simply left to bake in this reach until just after 4 pm. (CLICK x 3 to enlarge; BACK ARROW to return)
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

I continued downstream on this, the most critical and imperiled reach in the entire Silvio O. Conte National Fish & Wildlife Refuge, through the two desperate miles of abused river channal, all the way to the Rock Dam, critical spawning site for the federally endangered Connecticut River shortnose sturgeon.

Locked-down river, starved in front of the “tainter gates” on the Gill side of the river. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


The stilled-water graveyard, just downstream of the TF Dam on the Gill side of the Connecticut. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

Starving, de-oxygenated river on the Turner Falls side, looking downstream, with Peskeomscutt Island–now, no longer an island, de-watered and attached by tilted shales to the land. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


The entire flow of the Connecticut (save for a dribble of 125 cubic feet per second mandated to enter from a chute 100 feet downstream of the dam to keep shortnose sturgeon from stranding and dying in the baking pools) is shunted into the muck and sludge accumulating Turners Falls power canal. Pictured here, the canal downstream adjacent to Cabot Woods, back in 2009, the last time it was mucked out by the heavy machinery pictured. (Click x3)
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


Here is the same area, pictured above, with the shunted Connecticut flow moving listlessly by the sludge-catching silt banks on the morning of July 19, 2020. This is the canal and just part of the grim habitats that ALL migratory fish must must face before emerging upstream of Turners Falls Dam. USGS Conte Fish Lab is visible in the background. Few fish ever manage to survive the puzzled and emerge to spawn in wide open upstream habitats stretching beyond Bellows Falls VT. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

Another look from a similar vantage with the Fish Lab in the background and a grim canal substituted for a living river. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


View from the opposite side–from the rail trail, July 19, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


And, lastly, just some of the Campbell’s Tomato Soup-looking sludge bleeding down FirstLight’s failing riverbanks at Cabot Woods–adjacent to their sludge-choked canal, and into the endangered shortnose sturgeon’s Rock Dam spawning site and nursery for developing young on July 19, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


A closer look, 07/19/2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


And another, 07/19/2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


And, just yards away, the slurry connection–where the grim soup enters the most critically endangered site in the entire river ecosystem: the Rock Dam, on July 19, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

That riverbank soup was already assaulting Rock Dam habitats back in September 2019. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

Ten months has passed since this photo was taken. The banks continue to fail, the site continues to be assaulted through pollution, and outright neglect and flaunting a ESA protections.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

SPRING: Private Profit; Public Loss

Posted by on 26 May 2020 | Tagged as: American shad, Connecticut River, Federal Energy Regulatory Commission, FERC, FirstLight, FirstLight Power, FISH CAM, fish passage, Holyoke Dam, Holyoke Fish Lift, Humor, ISO New England, migratory fish, Northfield Mountain, shad fishing, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Slim Shad Point, Turners Falls dam, Turners Falls power canal, USFWS

THIS GREAT AND BROKEN RIVER VI

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

SPRING: Private Profit; Public Loss

Despite the enormous and longstanding damages the Industrial Age visited upon the Connecticut River—the early clear-cutting of the north woods, the building of the main stem dams and canals, the profligate effluent pollution, the thermal heating from a pair of nuclear reactors, the eviscerating impacts of a massive, river-reversing pumped storage project, it somehow has survived into the 21st century with a relatively robust and still-restorable spring run of American shad in its lower reaches.


Fishing Slim Shad Pt. Holyoke Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge; back arrows to return)

The Connecticut is indeed rare in that respect—as well as for being host to the most successful fishway on the entire East Coast, with a lift first put in place at Holyoke Dam in 1955. That spurred a New England fisheries restoration effort begun here between federal and state fisheries agencies in 1967. It is why the Connecticut ultimately became the central artery of the 4-state Silvio O. Conte National Fish and Wildlife Refuge in 1997. But by that time the river’s migratory fisheries restoration had already stalled and foundered in Massachusetts just 36 miles upstream of Holyoke, at the foot of the Turners Falls power canal and dam.


Shad Angler Wading at Holyoke Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge; back arrows to return)

The complex of fish ladders and canal routes chosen and installed there in 1980 were largely weighted toward passage of a new, mass-produced hatchery-hybrid salmon strain. They proved an obvious and instant failure for the hundreds of thousands of shad returning to pass that place as soon as all the concrete dried. Vermont, New Hampshire, northern Massachusetts—never received their promised bounty.

And so it is to this day. The Connecticut, still massively overworked and under-protected, remains without any new bona fide restoration success for migrating shad in 3 out of 4 of the states over its 410 mile reach over the last 30 years. Where have the fish successfully passed? You need not go far to identify the break point. Smack in the heart of this spring’s migration peak here’s a quick look at the stats for fish passage success up through Memorial Day weekend. As of May 25, 2020, some 274,370 shad had been lifted past Holyoke Dam according to USFWS Connecticut River Project Leader Ken Sprankle.

And at Turners Falls? Well, the last report offered included a total of 735 shad passing as of May 17, 2020. They don’t report regularly from Turners Falls. If FirstLight had just installed a simple Fish Cam the public would have had something this year—while all their license-required recreational access has been shut down tight this spring, including fish viewing, camping, even hiking trails. But, just to compare: as of that same date, May 17, 2020, Holyoke had already reported passing 51,000 shad upstream. It only takes the 1-1/2 – 2 foot long, blue-green migrants just a day or so to start knocking on the door at Turners Falls. But as the failed restoration numbers have grimly shown for decades, the river’s great run dies in the alternately starved and ramped-up industrial flows set in motion by gatehouse and dam operators at Turners Falls and Northfield Mountain.

Listless Riverbed at Turners Falls, May 14, 2020
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED
. (Click X 3 to enlarge; back arrows to return)

It’s now three migration seasons past the April 30, 2018 expiration date of the current Federal Energy Regulatory Commission license for FirstLight’s Turners Falls Dam, yet no legally-mandated fish passage–upstream and down, has been constructed. Literally nothing has been done. While citizens in three states—including fifteen cities, towns and villages, are yet to see their rightful share of the river’s fish.

As always, FERC and ISO-New England (in Holyoke) have both made sure to requisition and have available a glut of power for the sprawling Northeast power grid here (at public expense, but without public input of course) It’s way more than enough to easily exceed the grip of a summer heat wave. Climate emergency be damned… It does means big corporate profits. Meanwhile, it’s mid-spring. Power use is at a low annual ebb. Yet New England’s Great River here in the United States is currently starved of both its fish and life-giving flows at Turners Falls–while Canada’s shareholder-owned FirstLight Power exports its profits out of the region.

A living river is a public right here. Whose pockets are being lined?

Issue # 3: The River Emptied at Spring

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

THIS GREAT AND BROKEN RIVER III

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 3: The River Emptied at Spring

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

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

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


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

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


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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

Dear Secretary Bose,

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

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

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

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

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

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

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

Sincerely,
Karl Meyer

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

Photo Copyright © 2020, by Karl Meyer.

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

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

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

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

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

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

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

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

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

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

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

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

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

INSIDE A FERC LICENSING PROCESS: the Federal Energy Regulatory Commission and the State of the Connecticut River in Massachusetts

Posted by on 31 Jul 2019 | Tagged as: climate-heating, Connecticut River, Connecticut River shortnose sturgeon, Dr. John Waldman, Endangered Species Act, Federal Energy Regulatory Commission, FERC Commissioner Neil Chatterjee, MA Division of Fish and Wildlife, National Freshwater Marine Sanctuary, National Marine Fisheries Service, Northfield Mountain Pumped Storage Project, Riverkeeper, Scott Pruitt, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turners Falls dam, US Environmental Protection Agency, US Fish & Wildlife Service, USFWS

Inside a FERC Licensing Process: The Federal Energy Regulatory Commission and the State of the Connecticut River in Massachusetts

Copyright © 2019 by Karl Meyer All rights reserved.


The Connecticut River below Turners Falls Dam. Photo Copyright © 2019 by Karl Meyer All rights reserved. (NOTE: Click, then click twice more to enlarge.)

“River conditions miserable; relicensing progress, negligible. No end in sight.”

Note: the following is a long-form letter to Dr. John Waldman, CUNY Queens College professor of biology. John dropped a friendly note inquiring as to the state of affairs on the Connecticut River. I replied I would like get back to him in some detail, with a view toward publishing those extended thoughts. Besides his teaching, John is an award-winning author of several books. He has been a long-time advocate for the restoration of the Hudson River and its environs. We met some years back when I took him on a tour of the Connecticut River reaches I write about here. John was in the process of completing, RUNNING SILVER: Restoring Atlantic Rivers and Their Great Fish Migrations, published by Lyons Press (2013). He is an avid angler and a fierce defender of rivers.

Karl Meyer
Greenfield MA 01301 July 31, 2019

John Waldman, Professor of Biology
Queens College, CUNY
Queens, NY 11367

Hi John,

You asked me sometime back how things were going on the “mighty Connecticut?” Sorry it’s taken a while to get back to you.

As you know, the real news—as it were, is all bound up in the Federal Energy Regulatory Commission’s 5-year relicensing process for Northfield Mountain Pumped Storage Project, P-2485, and Turners Falls/Cabot Hydro Project, P-1889. That ponderous process for these tandemly-operated, peaking electric facilities, began way back in August of 2012. All the while some 10 miles of the Connecticut have been essentially strangled and broken here since 1972, when the Northfield Mountain Pumped Storage Station came on-line in concert with the now-shuttered Vermont Yankee Nuclear Plant, just upstream in Vermont. Overall, NMPS’s massive pump-and-purge water appetite impacts flows and habitat across 50 river miles in three New England states.

VY closed permanently in 2014. Instead of being pulled from daily service at that time and kept on as a reserve emergency power source for summer and winter grid-stress days, NMPS somehow has been allowed to soldier-on by importing giant surges of electricity from distant power sources, battering an ecosystem with deadly, pumped storage suction and creating artificial tides here daily, some 70 miles above the nearest reach of Long Island Sound tidal impacts at Hartford.

Of course NMPS has never produced, and will never produce, a single watt of its own virgin power. This is not renewable energy, and Northfield is not “hydro” power, as people think. It is recycled nuclear, natural gas, oil, coal, etc., power taken directly off the grid to do the unseemly work of suctioning a river backward. Pumped storage is the only category that shows up on regional power grids as turning in a negative percentage of power production. It’s a river-killing technology–a bulk power relay switch ferrying the climate-heating juice of a disastrously warming planet.

If I were to put into the fewest possible words how things are going on the mighty Connecticut it would read something like: “River conditions miserable; relicensing progress, negligible. No end in sight.”

It all seems to work in favor of the corporation—which, if you try and look beneath all the legal paperwork permutations still is ultimately parent-owned by Canada–the country, to the detriment of a four-state US river and ecosystem, and dozens of communities in Massachusetts, Vermont and New Hampshire. The biological losers, besides the citizenry, include—among others, the federally-endangered shortnose sturgeon, and federal trust species including American shad and blueback herring.

Further below you’ll find part of the asset transfer paperwork entered into this FERC relicensing record on Wednesday, July 17th, via the company’s Washington law firm, a limited legal partnership. They’ve essentially split these intimately-integrated components—Northfield Mountain Pumped Storage and Turners Falls power canal/Cabot Station, into a handful of separate limited liability companies, all now registered as corporations in the state of Delaware.

As you know, these peaking/re-peaking projects have proven major stumbling blocks to river connectivity and real anadromous/diadromous fish restoration above Holyoke Dam into wide open Vermont and New Hampshire habitats. There has long-existed fifty-miles of essentially empty and infinitely-restorable river spawning and rearing habitat for shad, lamprey, bluebacks, etc., in those New England states.

But the Connecticut is sucked into reverse for up to a mile downstream via NMPS’s monstrous water appetite. Chewing through 15,000 cubic feet per second of CT River flow for hours when pumping, it extirpates virtually all the river life it inhales—fish, eels, eggs, etc. And, in grim concert, the riverbed below Turners Falls Dam is left all but an empty bedrock relic many months out of the year—as the flow from Northfield is re-peaked into their three-mile long power canal below that dam.

Today as I write, there are three miles of exposed rocky riverbed baking in the sun in 93F degree heat. The company is actually required to only dribble 125 cubic feet per second of water into this Dead Reach from a point just below the dam. The rest is corralled for Northfield’s huge appetite and for shunting into that canal. Thus, the Connecticut River itself is essentially broken at this point. And, no nourishing, connecting flow to make it a viable river and waterway will be required again until NEXT April, at the earliest. It just sits—baking, starved of water.

During this spring’s migration season just over 7% of the 315,000 shad that passed Holyoke Dam were tallied passing Turners Falls. Those numbers do not even approach the passage numbers achieved here mid-1980s. That’s absurd.

Plus, during peak shortnose sturgeon spawning season operators inside Northfield Mountain pinched off spawning flows at the key site known as Rock Dam during a period when investigations by USGS fish biologists had demonstrated that 4 dozen of members of that federally-endangered species were present. The ancient pool at the Rock Dam site is their only documented natural spawning site in the entire river ecosystem.

This occurred during a time when the power company was conducting their own test flows to potentially move tagged American shad upstream through that water-starved Dead Reach which includes Rock Dam. I witnessed and documented the flow cuts one morning, and another federal fisheries biologist witnessed the same brutal draw-down two days later.

An email confirmed those grim impacts on those spawning sturgeon were caused by the operators 7 miles upstream inside the Northfield Mountain Mountain Pumped Storage Station, who control the Turners Falls Dam. The company has long been fully apprized during this federal relicensing process that shortnose sturgeon spawn here from mid-April past the third week of May, yet they pinched the flows shut and egg-sheltering banks were dewatered. That’s deadly. It’s what’s known as a taking under the Endangered Species Act.

Days later, a commercial rafting company was documented making repeat runs over that single, tiny rapid at the Rock Dam, while repeatedly entering onto sensitive wetland habitats on the island adjacent in rerunning those very brief joy rides.

As you know, a single instance of interference with a federally-endangered shortnose sturgeon is subject to a fine of $49,000 and possible jail time. If this was an individual citizen destroying spawning habitat and crippling reproduction–rather than a “corporate” citizen, I’m sure they would’ve ended up in court, fined, and answering to the law. I think if there was a worthy watchdog on the Connecticut, the company would have been sued, and a judgment sought. If the judgement of a taking of say 20 endangered shortnose sturgeon was rendered, at $49k per fish, we are talking serious river protection money! Here? Nada. Due diligence? Any diligence??

Alas, we really have no enforcing non-profit watchdog here on the Connecticut like you have with Riverkeeper and its battery of lawyers on the Hudson. There’s no enforcement or taking the corporations to court here on our 4-state Connecticut. That’s certainly why conditions are so miserable, despite the presence of long-settled law, the ESA and CWA statutes. No NGO teeth.

Our resident NGO did change its name a year or so back, but not its mission and mandate. And what’s always been needed here is that promise to prosecute corporations and take government agencies to court when they fail to enforce environmental mandates and do their jobs. The one we have submits lots of “comments.”

OK, they also hold a big river clean-up—offering high PR visibility for questionable corporate sponsors who have a legacy of nuclear waste left in their wake here, and they do some water quality testing. They also plant trees with grant money, and pull aquatic weeds. But, since producing several guides for boaters on the Connecticut, some of their key constituencies are the promoters of recreational and commercial paddle sports here—kayakers, rafters, canoeists.

They are pushing to get these interests portage and river access to the long-abused, critical habitats immediately below Turners Falls Dam. I have stated publicly any number of times that in a just world this tiny reach would be designated a National Freshwater Marine Sanctuary, so critical is it to this ecosystem—upstream and down.

Given the fragile biological, historical and cultural nature of those three river-miles—recreational and commercial watercraft pursuits are the absolute last pursuits that should be allowed there. But, guess what? That little NGO just entered their for-the-record “comments” into this FERC relicensing for their vision of new recreation access in that fragile reach—where over a dozen state- and federally- listed species are struggling for survival. It reads more like a marketing and development plan: new parking spaces, a trail cut onto an island for repeat runs over the tiny Rock Dam and habitat of endangered sturgeon and what may be the last place in the reach where state-endangered yellow lampmussels were documented.

I really have no idea whether they have ever looked up the definition of conservancy.

They want three or four new accesses designed for this tiny reach, as well as a road cut for emergency vehicles and a ramp-slide for watercraft. Makes you wonder who is donating to them. This is a mostly-forgotten, fragile biological gem, adjacent to a tiny backwater neighborhood of old factory double-decker homes—and you can just see it being turned into something commercialized and soulless…

It’s a damned good thing they have no actual conditioning authority in this relicensing. I think USFWS, National Marine Fisheries, MA Natural Heritage, MA Historical Commission, and several federal- and state recognized Native American tribes will be looking at this with some shock. At the very least, that NGO’s director should step down as vice chair and MA public-sector representative on the Connecticut River Atlantic Salmon Commission. It’s been two years now, but it’s more like a sycophant position for the NGO–since they get channeled grant monies through the fed and state agencies that they should be watch-dogging over. So, it’s like a cheerleading slot. Before that, the MA public sector slot on CRASC sat empty for seven years, but at least it was a do-no-harm arrangement.

They really need to look up the definition of conservancy.

Unfortunately John, that’s the state of affairs in this critical section of the Connecticut, tottering on the brink between resurrection and conservation protections, and their vision of the river as an attraction for tide of tourist-joyriders with little regard for place, or species, or the intrinsic right for a river to just live and heal; as a life giving entity in its own right. It’s merely a fun-time commodity. Sad, that we have no legal team or NGO operating under the watchdog/enforcement mode here. Lacking that bedrock necessity, a Connecticut River with monitored–and enforced, protections and life-giving flows in the future seems a highly unlikely prospect, no matter what gets written into a new license.

Unless, another organization steps into the breach–bringing consistent enforcement and a willingness to drag crimes against this ecosystem into the courtroom every time they occur. We need an every-day enforcement presence like you have on the Hudson.

Howsoever, I will say that the US Fish & Wildlife Service’s goal for Turners Falls Dam in these proceedings–after gathering research from long-range studies and examining decades of passage data, is: 75% of all the fish that pass Holyoke will be required to pass TF safely. After four decades of failed fish passage here, they appear solid on that goal being met through this relicensing. That passage, upstream and down, is required via the 1872 landmark Supreme Court decision in Holyoke Company vs. Lyman, as you know—decided exactly a century before NMPS began swallowing the Connecticut River and all manner of its migratory and resident fish. Its full impacts have never been calculated nor compensated–to even the smallest measure.

There’s one other ember of good news here: for the second year in a row a SINGLE blueback herring passed Turners Falls Dam. They hadn’t been seen here in most of a decade, though thousands used to pass back in the 1980s. It’s a federal trust species with its back against the wall. Good to see even the tiniest biological thread holding on.

The other test the power company is currently conducting–of its own volition vis-à-vis this relicensing: little swaths of mesh net have been placed in front of the massive sucking mouth of Northfield Mountain—purportedly to prevent that gaping maw from feasting on millions of tiny, young-of-year shad each spring, as well as adult American eels on their way downstream. Early YOY study results from fish agencies hinting that the reach at Northfield is the least productive of this river’s dammed sections. Wonder why??

The absolute brilliance of this “trial”, is they are going to project how effective a 1,000-plus foot net across the intake might be for decades into the future—by staking out several test panels that are about the size of high school flags in front of that giant pipe, during various sucking flows. I’m sure that’s gonna prove an effective snapshot of how a ponderous mega-net might perform for decades to come! Ludington Pumped Storage and lake trout should be the cautionary tale…

Of course, as the Federal Energy Regulatory Commission let’s this bloated process go on, ad infinitum, we may all be dead before Vermont and New Hampshire get their long-deserved shad runs, and those shortnose sturgeon–which you assisted as a reviewer in their Federal Recovery Plan, receive flows that guarantee they actually can spawn and are able to begin the slow slog toward viable species-status.

Ok, just to give you a flavor of what rights and privileges a ten dollar (yes $10.00) tax shelter sale in this key reach in a 4-state ecosystem that is part-and-parcel of the Silvio O. Conte Connecticut River National Fish & Wildlife Refuge can offer, please see the included clauses below. THEY ARE HEART-BREAKING in the midst of a 5-year FERC relicensing process that is now set to begin its 8th year, if my math is correct. We began meeting in August 2012.

And, John, the company and its consultants do not seem in any hurry to bring this process to a close. The last negotiation with conditioning federal and state fisheries agencies took place in mid-winter. Basically, the parties all stated their positions; then walked away with no further meetings scheduled. This was, of course, after they made their surprise December 20, 2018 filing to break the company up into little, Delaware-registered, llc tax silos… Some ten agencies and stakeholder interests have filed protests with FERC and been granted Intervener status, myself included.

Here is an excerpt from that conveyance document:

“In consideration of the covenants and agreements contained herein and the payment of $10.00 and other good and valuable consideration, the receipt of which is hereby acknowledged by the Grantor, the Grantor and the Grantee hereby agree as follows:

The Grantor hereby grants, bargains, sells, and conveys to the Grantee, and its
successors and assigns, with Quitclaim Covenants, a perpetual nonexclusive right and easement for the purposes set forth below in, on, over, under, across and through the Property identified on Exhibit “A” attached hereto.

The rights and easements conferred hereby shall include, but not be limited to, the right, at any time and from time to time and without payment of damages or further consideration to:

1. Alter the level of the Connecticut River and of its tributaries to any extent by
withdrawing water from said River and returning the same water in whole or in part by
the use of structures now or hereafter forming part of the Northfield Mountain Pumped
Storage Project, FERC No. 2485;

2. Retard, accelerate, reverse, or divert the flow of said river and of said tributaries,thereby causing an increase or decrease in the percolation, seepage, or flowage of waterupon, over, and under or from the Premises described and identified in Exhibit A notwithstanding that by such percolation, seepage, or flowage damage may be caused directly or indirectly to the said Premises or to any one of them or to structures, personal property or trees or vegetation thereon;

3. To erect and maintain upon the Premises so subject suitable gauges to measure and
record the flow and level of the said river and said tributaries;

4. To enter upon said Premises for the aforesaid purposes and for the purpose of removing any trees or other vegetation which may be injured or destroyed by the flowage
aforesaid; and

5. As an incident of the foregoing, cause an increase or decrease in the flowage of water orice upon, over, or from said Premises, notwithstanding that portions thereof subject tothe aforesaid rights and easements may be washed away or added to by the action ofwater or ice and that damage may be caused thereto and to structures or vegetation thereon or adjacent thereto by flowage, seepage, percolation, erosion, accretion,interference with drainage, or otherwise.”

Northfield Mountain Pumped Storage remains today the same ecosystem killer it was when it came on line in 1972. Absent in any of these proceedings has been its grim impacts on resident fish species across 4-1/2 decades. It is both an engine and enabler of climate change, as it sucks in 34% more natural gas- and nuclear-produced juice from the grid than it ever sends back as 2nd hand, peak-priced electricity.

FYI: the weakest partner with conditioning authority in all these years has been MA Division of Fish & Wildlife—the sole agency that has had authority to reopen the current license across all these decades concerning failed fish passage. They sat on their hands, mum, while anadromous fish passage nearly disappeared above Turners Falls Dam in the first decade of this century—dropping at times to 1% or less. It all adds up to what a massive taking has occurred here in Massachusetts across the decades via the operations of Northfield Mountain and Turners Falls. Vermont and New Hampshire have been hereby impoverished as well During these relicensing hearings MA Fish & Wildlife has shown little in the way of leadership. It’s an embarrassment for this Commonwealth.

I will, however, recognize that the MA Natural Heritage people and the Dept. of Environmental Protection have shown up and been active partners in environmental safeguarding during these proceedings.

Otherwise, the federal fish and environmental agencies—the people I sit with on the Fish and Aquatics Study Team, have ultimately shown great expertise and resolve in enforcing US statutory law and long-standing environmental mandates respecting a new license. I think the US Fish & Wildlife Service and the National Marine Fisheries Service recognize their responsibilities to get it right this time—and to protect this four-state New England River for the citizens of the United States as the heart of the US Silvio O. Conte Connecticut River Fish & Wildlife Refuge. They are proving forthright and honest brokers on behalf of the citizens they work for.

As you may know, I am the only recognized stakeholder/intervener in these proceedings who has not signed one of those grim non-disclosure agreements with the company. I have thus become a conduit for nearly all the relicensing information reaching the public on several platforms in this largely unseen process.

But as I write this I begin to wonder: since these intimately intertwined projects have now become a series of new LLC outfits–are all those agencies and towns still bound by non-disclosure agreements they signed years ago with a different company? The company’s behavior in that regard has been so snake-like that it hardly seems relevant or appropriate to hold back information from the public about their river at this time. It’s been like an in-your-face demonstration of the rootlessness and stark profit motives of the new “corporate citizenship.”

And, nowhere have I heard any hint that these newly-configured, on-paper companies are interested in coming to settlement terms any time soon.

With those actions driving the parties apart, why not just move it in front of FERC rather than watching and waiting for these venture capitalists’ next power move? Every year these proceedings drag on the Connecticut River ecosystem continues to fray and fracture along these miserable miles of broken river basin. And every year the company continues to profit from FERC’s extension of the current license. In the interim they’ve participated in helping change operational parameters for pumped storage payments and participation in ISO markets. The power companies sculpt the laws that FERC imposes.

And, of course, every year they do not have to put a shovel in the ground to construct mandatory fish passage is more money in the bank for them and their venture capital investors. The bulk power grid, FERC and ISO New England are some of the key engines of our climate crisis. Only distributed generation and micro-grid reorganization—stopping us from blithely consuming the glut of imported power that fuels our massive over-consumption, will offer us a way out of this emergency. Those new, localized power configurations would also guarantee routes around the looming threat of massive cyber attacks on this behemoth of a power grid.

Something called NEPOOL, a consortium of New England corporate power producers, really wags the dog that is ISO New England. And FERC generally rubber stamps their positions. And, FERC won’t even consider ruling on any given projects’ climate impacts or GHG emission contributions to an overheating planet. Not once. Seems they’ve never met a power project they didn’t embrace.

Hell, both NEPOOL and ISO ban the media outright from their meetings. They do not provide or disclose critical information needed for the public to understand and trust the decisions made about the grid, power production, energy sources, distribution and its import in the current climate crisis. It’s all backroom stuff. One of this company’s own executives testified in Washington hearings in support of continuing to ban the media from these critical, precedent-setting, energy meetings. As stakeholders we are denied data and information on what this power company pays for the glut of grid power it imports while it sells an ecosystem down the river, offering it back in deadened, second-hand, peak-priced juice.

There is speculation from folks I know who design and install solar projects and metering that this company may not actually be paying ANYTHING at times when the power grid is so bloated with excess juice at certain times and seasons. Bulk power producers pay to have it taken off their hands in what’s called “negative pricing”. How much money are they making? How much of a free ride is this boondoggle getting? Just a year and a half back the Federal Energy Regulatory Commission’s current chair Neil Chatterjee and now-disgraced former EPA chief Scott Pruitt made an all-but-secret visit to Northfield Mountain. No media; no witnesses. What does that tell you?

But then it’s always been pretty much at free ride at Northfield, having never paid for nearly a half century of unmeasured annual fisheries carnage. That’s been a taking on a massive scale: federal-trust migratory—and, resident fish, both.

The public really has no idea that this contraption can really only regenerate a few HOURS of dense, second hand juice, after which it is literally and completely dead in the water—and has to start hoovering-up endless juice from the grid once more, while sucking all manner of aquatic life through its deadly turbines. Its profits–and purchase price mechanisms are all shielded from the public in this FERC/ISO/NEPOOL process. It’s is an abomination of democracy.

Reregulating the energy market here presents the only open path to realigning our energy production, distribution and use with societal needs in the face of a climate crisis reaching a critical precipice. However, our governor here seems quite happy to farm-out our climate responsibilities and import-in massive amounts of what are termed green megawatts. Huge build-outs going on in Boston and elsewhere–casinos, luxury high-rise condos, giant, energy- sucking marijuana grow-houses. It’s all sleight of hand. Robbing Peter to pay Paul.

Rivers are the cooling arteries of this planet, and the Connecticut is the heart of an ecosystem stretching from the Quebec border to the estuary at Long Island Sound.

History will remember the inaction and misrepresentation of these corporate rogues and complicit bureaucrats in our time of climate crisis. Seems obvious that none of them have granddaughters or grandsons they worry for, in the draconian future they are helping engineer…

Well John, that’s plenty enough cheer from here.

BTW, how are things over on the mighty Hudson??

All best,
Karl