Turners Falls

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

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

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Copyright © 2016 by Karl Meyer

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

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

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

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

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

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

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

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

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

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

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

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

No “Springtime for Sturgeon in Holyoke…”

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

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

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

Copyright © 2016 by Karl Meyer

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

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

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

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

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

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

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

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

INFORMATION BLACK HOLE on the Connecticut

Posted by on 05 May 2016 | Tagged as: American shad, Connecticut River, federal trust fish, FirstLight, GDF-Suez FirstLight, Greenfield Community College, Holyoke Community College, Holyoke Fish Lift, Jack Buckley, MA Division of Fish and Wildlife, New Hampshire, Northfield Mountain, shad, shad fishing, Station 1, teachers, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Walpole, Wendi Weber

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INFORMATION BLACK HOLE

Copyright © 2016 by Karl Meyer

On this May 5th, 2016, they have no idea in Sunderland–or in Deerfield for that matter. Nor do they know anything in Greenfield, Turners Falls, Gill, Northfield or Millers Falls. Upstream, Vermont folks in Vernon, Guilford, Brattleboro and Putney don’t have a clue. Across the river, New Hampshire people in Hinsdale, Chesterfield, Walpole and Charlestown remain in the dark.

What these towns all have in common is that nobody can tell them anything of the whereabouts of their share of the spring American shad run. The fish have been in the river and upstream of Holyoke for a full five weeks now, and there hasn’t been a single fish count provided from the Greenfield Community College students hired by GDF-Suez FirstLight to monitor fish passage at Turners Falls. An accounting of the public’s fish remains in the hands of a private company—and, as I’ve said before, many or most are likely struggling to survive a trip through their private power canal.

For a migrating shad, the 36 mile swim from Holyoke to Turners Falls is a walk in the park. It’s a day—maybe a day-and-a-half trip, ostensibly on the way to spawning habitats in Vermont and New Hampshire. But thousands of the public’s fish have gone missing on the Connecticut River this spring. And it seems no one can say exactly where they are. If you had to make an educated guess, you could surmise many are somewhere between Greenfield and Turners Falls, with many not in the actual river at all.

A significant number are fighting currents in the debased habitats of the Turners Falls power canal, where murky flows delay most by over a week before they even approach the site that could route them past the dam. Others are in the river, trying to find a path to the base of a fish ladder whose construction back in 1980 was based on Pacific salmon. And still others are sidetracked and stalled in the riverbed like sardines, expending precious migratory and spawning energy in front of the ramping outflows at a mini overflow power site known as Station 1. Wherever those fish may be, we do know that, on average over time, just 4% of those shad ever make it beyond Turners Falls Dam toward Vermont and New Hampshire. In the very few “good” years, one fish in ten wriggles upstream.

We also know that the first two American shad were lifted past Holyoke Dam five weeks ago. As of May 4, 2016, some 25,000 had been passed upstream at the Holyoke Fish Lift. What happened to them next is anyone’s guess. Once they pass Holyoke, accounting for them is left in the hands of a private power company—currently GDF-Suez FirstLight Hydro, now going under the corporate aegis Engie. These are the folks responsible for passing the public’s fish at Turners Falls Dam, and giving public accounts of fish passage for anglers, teachers, the general public, and the state and federal fish agencies.

It’s been documented that at least half of all the shad passing Holyoke will attempt to pass Turners Falls. It’s wholly possible the actual number is significantly higher. It matters little though, as all fish get diverted into the Turners Falls Power Canal once they attain this easy upstream reach, and only that average of 4% make it past the TF Dam. The rest simply go unaccounted for once they arrive and are tempted into that turbine-lined pit.

Five full weeks since fish have been heading upstream, and that includes sea lamprey as well. Yet we still do not have a single fish passage update at Turners Falls. What’s wrong here? Who is responsible?? Well, obviously FirstLight GDF-Suez is responsible. But, nobody is holding them to it. These fish, while moving through Massachusetts, are the responsibility of the US Fish & Wildlife Service. But, while here, they in large part fall under the responsibility of the MA Division of & Wildlife. Why aren’t they ensuring the public gets daily fish updates—like those that have been available at Holyoke Dam for years? Again, go fish…

At Holyoke Dam there are actually humans on-site that can witness real-time conditions, fish passage, and provide the needed public info in a timely manner. These come via students from Holyoke Community College. Not so at Turners Falls, where the Commonwealth has largely left responsibility for the chicken coop up to the fox. All monitoring is done remotely by video, with equipment provided by FirstLight. Prior years show repeated equipment failures. And then you have to wait—often many WEEKS, before those videos are handed off and analyzed by GCC interns. Its only then that we are treated to weeks-out-of-date info about where our fish are.

This privatization needs to change. Wendi Weber, Region 5 Director at the USFWS might be able to help. Or MA Division of Fish & Wildlife Director Jack Buckley. Or, perhaps, MADFW’s Caleb Slater, Anadramous Fish Passage Project Director. The guy at FirstLight responsible if Bob Stira.

As a side note: many other states have actuarial tables that put specific monetary values on migratory and resident fish. Then, if they are killed in project operations, or fish do not reach their spawning grounds, the public is reimbursed for the ecological damages.

Updated HOLYOKE fish counts can be accessed at:
www.fws.gov/r5crc under Recreation.

Missing camera in missing river

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

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

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

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

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

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

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

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Connecticut River Dead Reach Update: April 29, 2016

Posted by on 29 Apr 2016 | Tagged as: American shad, Connecticut River, federally-endangered Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FirstLight, Holyoke Fish Lift, National Marine Fisheries Service, National Marine Fisheries Service, Turners Falls, Turners Falls dam, Turners Falls power canal

Connecticut River Dead Reach Update: April 29, 2016

SHAD PASSAGE UPDATE: Holyoke Fish Lift passed its first American shad upstream on April 1, 2016. Normally, that would signal the opening of the fish ladders upstream at Turners Falls Dam.

Migrating shad take less than 2 days to swim the 36 miles up to Turners Falls Dam, the next barrier on the Connecticut as they attempt to head to northern MA, VT and NH.

Unfortunately there is so little water left in the riverbed when they arrive at the 2.7 mile Dead Reach between Greenfield and Turners Falls, that the vast majority never make it past that dam.

As of April 24, some 7,100 shad had passed Holyoke.

This year, due to lack of maintenance by FirstLight, the fish ladder at Turners Falls Dam was not working until April 22, a full three weeks after shad were arriving at that site. That kept thousands of those shad treading water and wasting their migration energy in the miserable conditions below Turners Falls.

SHORTNOSE STURGEON UPDATE: Shortnose sturgeon begin arriving in the Dead Reach at the Rock Dam site in Turners Falls in mid-April. On April 14th there was virtually no water be released into the riverbed where those sturgeon arrive to spawn, and those shad arrive to continue on to upstream spawning habitats.4-28-16 dribbling Dead Reach Flow

Above: flow dribbling down the DEAD REACH, April 28, 2016.(Click to enlarge)

On April 27th, the day sturgeon studies show that spawning at Rock Dam commences, the flow released into the Dead Reach and running downstream to the Rock Dam spawning site was so withered that spawning at the site would’ve been rendered impossible. Thus chased out by insufficient flows, another year of shortnose sturgeon spawning failure has occurred at its only documented natural spawning site in the entire ecosystem.

FURTHER, despite much touted improvements for moving the hundreds of sturgeon trapped below Holyoke Dam upstream, all FOUR shortnose sturgeon that made have made it into the fish lift there have been unceremoniously plopped back DOWNSTREAM. Call it bureaucratic interuptus… Or, agency failure.

Thus, for yet another year, there will be no improvement for the genetic prospects of the Connecticut River’s only federally endangered migratory fish. The agencies, chief among them the National Marine Fisheries Service have failed this fish and this river once again—as well as the so-called watchdog groups.

FERC Stakeholder comments: Turner Falls Canal ultrasound study

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

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

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

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

Dear Secretary Bose,

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you,
Karl Meyer, Fish & Aquatics Study Team

New comments to the Federal Energy Regulatory Commission

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

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

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

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

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

Dear Secretary Bose,

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

3.3.2 Evaluate Upstream and Downstream Passage of American Shad

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Redeem the promise at Great Falls

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, bald eagle, canal shad, Captain William Turner, Connecticut River, Connecticut River ecosystem, Connecticut River Refuge, Connecticut River shortnose sturgeon, Conte, Conte National Fish & Wildlife Refuge, Daily Hampshire Gazette, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC license, FERC licensing process, Greenfield Recorder, Holyoke Fish Lift, New Hampshire, Northfield Mountain Pumped Storage Station, Relicensing, Rock Dam, Rock Dam Pool, shad, shad fishing, shortnose sturgeon, The Greenfield Recorder, The Recorder, Turners Falls, Turners Falls dam, Turners Falls power canal, USFWS, Vermont, Vermont Yankee, wildlife refuge

The following piece, with edits, appeared in the Daily Hampshire Gazette and The Recorder on November 12, 2015 as: “Federal wildlife service must preserve the promise at Great Falls,” and “River restoration retreat”

The US Fish & Wildlife Service’s recent abandonment of their flagship Conte National Fish & Wildlife Refuge Visitor Center at Turners Falls defies all logic. In August they abruptly withdrew their on-site interpreter and funding for The Great Falls Discover Center. That center was located above the falls two decades back precisely because of the site’s importance as an ecological refuge—perched at a river crossroads critical to the success of their new “watershed-based” refuge.

Back then bald eagles had just returned to Turners Falls; it was once again the place that hundreds of thousands of migrating American shad surged to each spring. And just downstream was the sole natural site where the only federally-endangered migratory fish in the watershed–the ancient Connecticut River shortnose sturgeon, attempted to spawn each May. Known as the Rock Dam, its an ancient geological formation that remains a premiere retreat for spring shad anglers. For its biological and historic importance alone, Rock Dam should have long ago been offered the Refuge’s first “in-river” sanctuary designation.

Yet today, USFWS seems ready to walk away from its core mission and long history on the river at Turners Falls. Doing so would be no less an historic retreat than that of Captain Turner and his battalion after their pre-dawn attack on hundreds of Native American women, children and old men seeking refuge at that very site nearly 340 years ago. On May 19, 1676–having accomplished their grizzly goal with the loss of just one man, they were sent in reeling retreat when the first counter-attacking Native warriors arrived from a downstream island encampment opposite today’s Rock Dam. They’d been stationed there to intercept the teeming May shad runs to help feed their people. Turner and 37 of his troops died in the ensuing rout.

Today, Turners Falls remains the site of the US Fish & Wildlife’s biggest regional blunder in a mission to protect a nation’s fish and wildlife resources on New England’s Great River. In the late 1970s they signed off on the plan resulting in a series of fish ladders being built there. It forced all migratory fish out of the river and into the Turners Falls Power Canal. That resulted in a half century of failed fisheries and habitat restoration—largely drawing the curtain down on a spring ocean-connection for riverine habitats in Vermont, New Hampshire, and northern Massachusetts. That 1967 USFWS/four-state migratory fisheries restoration compact for the Connecticut River still founders at Turners Falls today.

That is why the recent USFW’s retreat from their ecologically and historically unique flagship perch remains inexplicable. Currently federal hydro-relicensing studies of dam and canal operations at Turners Falls are taking place. Their outcomes will determine environmental conditions governing the Connecticut River in this reach for two generations to come. The USFWS is playing a key role in these studies as the lead agency empowered to define and require changes at Turners respecting the protection and restoration of the public’s federal-trust and federally-endangered fish species there. In short, they’re at a crossroads. They are the key player able to restore past mistakes and make the Conte Connecticut River Watershed National Fish and Wildlife Refuge a true refuge for annual migrants passing from Connecticut to Massachusetts; then Vermont and New Hampshire.

That long-awaited success would occur at the doorstep of the Great Falls Discovery Center–replete with its life-sized displays of watershed fish and wildlife, and its accessible public auditorium. It’s a huge opportunity at a site virtually on the river, easily reachable by visitors from a broad swath of southern New England travelling the I-91/Route 2 Corridor. Great Falls is the only brick and mortar place for the public to regularly interact with USFW staff and a diversity of displays of characterizing watershed habitats for 80 miles in any direction. What’s more it’s the only publicly-funded flagship Refuge site where admission is free.

Without a touchstone site in this populous reach of the watershed, most citizens will remain unaware of the restoration and conservation work of the USFWS. They’ll be left to surmise instead that Conte is more a theoretical Refuge—a concept and an amorphous jumble of disparate parts lacking any true core.

In practice and in theory, Turners Falls and the Discovery Center site represent the best of opportunities for the US Fish & Wildlife Service to succeed in their core missions of conservation, restoration, public access and education. A second retreat at Turners Falls would be an historic failure. This fabulously rich reach of the Connecticut is uniquely situated to showcase the Service’s long-awaited success in river restoration on the public’s behalf. Many mistakes could be redeemed with the right decisions at this time. Don’t abandon the Great River at the Great Falls.

Public comments are being accepted through November 13th on the USFWS’s plans for Conte Refuge priorities for the next 15 years at: www.fws.gov/refuge/silvio_o_conte/

Karl Meyer
Greenfield

From the Rutland Herald: Where our fish are trapped

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls, Connecticut River, Connecticut River migratory fisheries restoration, False attraction, Federal Energy Regulatory Commission, FERC licensing process, New Hampshire, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, Rutland Herald, shad, shad fishing, The Great Eddy, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont Yankee, Vernon Dam Fishway


The following piece, with edits, appeared in the Rutland Herald on November 12, 2015.

Dear Vermont and New Hampshire:

Sorry, but your fish are down here in Massachusetts. With Vermont Yankee’s heated discharges no longer clouding issues, that’s become clear. We’re talking hundreds of thousands annually. This year a quarter million might’ve reached Vernon and Hinsdale had we not corralled them. A hundred thousand in the Great Eddy at Bellows Falls might’ve been a possibility.

And these aren’t small fry. These are free-swimming American shad straight from the briny Atlantic—wild fish that snap at lures and offer anglers an honest fight. Fresh caught and sweet, they’re a homegrown harvest for anyone taking the time to debone them or put them in the slow roaster. You could’ve been enjoying all that.

Actually you were promised them by the US Fish & Wildlife Service and state fisheries agencies back in 1967. They’d arrive in the 1980s–when much-touted fish passage facilities got built downstream. Each successive dam would pass 75% of the fish passed by the dam below it. Yet only excuses arrived. You weren’t told your fish got caught in a trap—that the Turners fish ladder diversion was a disaster; that your shad run dies in a muck-filled power canal. That’s where your bounty is still driven from the river today—where fish get diverted into a last-chance canal from which few emerge upstream.

We’ve now had the first spring where VY’s discharge has not intercepted spring runs. It appears the nuke played a smaller role than long-rumored concerning dismal fish passage at Turners. Heated effluent ain’t great for any species–but fish deprived of a river are an unending ecosystem disaster.

The 2-1/2 miles below Turners Falls Dam are that disaster. Down here government agencies don’t require anything approaching sustaining nature-like flows in the Connecticut’s bed. It’s either deluge or desert—much of it produced by the mega-flushing and pumping flows Northfield Mountain Pumped Storage Station sends downstream. Part of that blistering regime gets re-diverted into the power canal 5 miles south—a trap each upstream migrant is funneled into.

That canal is where a great migration dies—where fish get delayed; fatigued, entrapped and eviscerated. Not one in ten shad have made it beyond Turners Falls across the decades. It’s not rocket science to understand–in fact, the math just got a little simpler.

The years 2013 and 2014 were the final years Vermont Yankee was heating the river. Of the 393,000 American shad passing Holyoke Dam in 2013, just 9% or 35,000 fish made it past Turners. Yet of those 35,000 fish, 18,000 or 51% swam safely past Vernon–20 miles upstream. Similarly in 2014 of the 371,000 shad passing Holyoke, just 40,000 or 11% were able to get through the canal past TF Dam. But of the 40,000 that made it, a full 28,000 or 69%, swam beyond Vernon toward upstream destinations.

Turners’ fishways opened in 1980; Vernon’s in-river fishway in 1981. Across the decades the annual average of shad passing Holyoke that make it past Turners is 4%. In the same span, Vernon averaged passage of 40% of the shad arriving from Turners. Passage at Turners hovered near 1% for the decade beginning in 2000 when deregulation began allowing Northfield Mountain to pump and profit from the river according to price peaks on the electricity “spot market.” Those peaking pulses decimate river habitats below Turners Falls.

Which is why 2015 proved interesting. This spring, with VY silent, the Federal Energy Regulatory Commission ordered a series of nature-like test flows to be sent through the gates at Turners Falls Dam into the impoverished riverbed–to gauge their impact on the public’s fish runs. It’s part of the 5-year FERC licensing process for Northfield and Turners. At Holyoke 413,000 shad passed upstream, while at Turners just 14% or 58,000 shad passed the dam. Yet 20 miles north, 69% or 40,000 of those fish, swam past Vernon Dam—an all-time record for shad passage there.

So here’s some math: Turners passed 9% in 2013; 11% in 2014, and 14% in 2015. Vernon passed 51% of their shad in 2013, 69% in 2014, and 68% in 2015. The difference between a year with VY’s heated effluent, and one without—was insignificant, a 1% change with shad passage actually dropping a fraction with Yankee silenced. Yet they still set a new shad passage record.

It’s noteworthy the 34 year-old Vernon record was broken the first time more in-river flow was required below Turners Falls Dam, supplying a direct route upstream during FERC’s May-June test flows. It clearly spared some fish the energy costs of industrial entrapment and the dangers of weeks in a turbine-lined canal.

The problem is that canal, and a decimated river at Turners Falls. You’ve been owed fish totaling in the millions across the decades–and an ancient connection to the sea all kids should know. They’re not the power company’s fish, they’re yours. Demand federal and state fisheries directors sue for those fish—and for the Connecticut River refuge your grandkids deserve.

With apologies,
Karl Meyer, Greenfield, MA

Writer Karl Meyer is participating in the FERC hydro relicensing studies for MA facilities on the Connecticut River. He is a member of the Society of Environmental Journalists.

The Great Eddy at Bellows Falls

Posted by on 27 May 2015 | Tagged as: American shad, Bellows Falls, Bellows Falls Fishway, Cabot Station, Connecticut River, Connecticut River ecosystem, Dead Reach, GDF-Suez FirstLight, migratory delay, New Hampshire, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, power canal studies, Rock Dam, Rock Dam Pool, shad, shad fishing, Station 1, The Great Eddy, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Walpole

BFallsdam
May, 27, 2015. I happened to be at Bellows Falls High School yesterday, and I took a walk into town and over to the Connecticut River at the now-closed Vilas Bridge. Just downstream of here and pictured above is a place formerly known as the Great Eddy. Here, prior to the completion of the Turners Falls Dam in 1798–the first dam to span the entire Connecticut, historic accounts recall 1,200 shad being pulled from the river at a single haul of the net. This picture was taken a few years ago, my batteries proved exhausted as I stood looking downstream yesterday.

There were two young guys far below, fishing in the shadow of the bridge, just downstream of the Bellows Falls Dam. When I hollered down they said yes, the fishing was good, “A rainbow and some bass.” Thus, today, it is rare for a single shad to reach Bellows Falls, the upstream limit of their historic reach. It is harder still to imagine that this place was once a key part of an ecosystem connected to the OCEAN.

I got a note from John Howard, GDF-Suez FirstLight’s Director of Hydro Compliance on Monday. He assured me that those scores of American shad stalled by false attraction flows roaring down from Station 1 had been worked out and agreed to by the USFWS as part of a flexible test flow grid due to an absence of rain. He’d neglected to forward the new test flow schedule to the Fish and Aquatics Studies Team. I imagine those shad burning up their energies would’ve liked to have had a heads-up as well. Their destination–as is the professed destination of the Connecticut River anadromous fisheries restoration these last 48 years, has been to REACH Bellows Falls, VT, and Walpole, NH.

Head gate flow at the TF Dam today, Wednesday, was again lamb-gentle. Of all the years I’ve witnessed flows pouring out of those head gates in the midst of fish passage season, this is the quietest I’ve ever seen them. Canal head gate flow and power generation from the canal at Station 1 and Cabot Station will all need to be looked at carefully in these studies to tease out any biases. (Click to enlarge photo).P1000457

Meanwhile, there were still shad being taken at The Rock Dam Pool this afternoon. I was headed down the path about 3:30 pm and a guy was walking out with a pole and his two energetic labs. He cautioned the wet dogs to give me a wide birth and I asked how it had been. “Not bad,” he said, “Better this morning.” I took a second look at the gentlemen and said, “Hi Jake, how are you?” “Doing OK, how about you?” Jake was part of the maintenance and grounds crew up at Northfield Mountain under Northeast Utilities when I was working at the Visitor Center some dozen years back.

“You still writing letters?” he asked. “I’m doing what I can.” “Good,” Jake replied, “Give it to ’em. Good luck!” Funny, but I bump into many folks who used to work there and there seems to be little sympathy for the company–or lingering loyalty.

P1000460
When I get down to the Rock Dam Pool three people are angling. The guy here has a shad on the line. Another guy, just a bit upstream toward the dam hooks one two or three minutes later. I head out, continuing downstream by bike. (Click to enlarge)
P1000466
Looking upstream from the deck of the General Pierce Bridge in Montague City, much of the riverbed is exposed due to the low flows. At top, far right, is the outfall and attraction flow at Cabot Station, which is likely to be attracting and capturing a good slug of the migrating fish–steering them out of the river to the ladder that will dump them into the power canal. (Click to enlarge)

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