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A Connecticut River return to the bad old days?

Posted by on 18 Oct 2020 | Tagged as: American shad, Cabot Woods, Clean Water Act, Connecticut River, Connecticut River Conservancy, Connecticut River riverbank failure, Connecticut River shortnose sturgeon, Endangered Species Act, Eversource, Farmington River, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FirstLight, FirstLight Power, Greenfield Community College, Northeast Utilities, Northfield Mountain Pumped Storage Project, pumped storage, Relicensing, Rock Dam, Rock Dam Pool, Society of Environmental Journalists, Source to Sea Cleanup, The Recorder, The Revelator, Turners Falls, Turners Falls dam, Turners Falls power canal, Uncategorized, US Geological Survey's Conte Fish Lab, Vermont Digger, Vernon Dam Fishway

The riverbanks at Rock Dam
Photo
Copyright © 2020 by Karl Meyer

Note: the following piece appeared recently in VTDigger, www.vtdigger.org, https://vtdigger.org/2020/10/18/karl-meyer-a-connecticut-river-return-to-the-bad-old-days/ and in the The Recorder, www.recorder.com, (no story link posted)

                        A Connecticut River return to the bad old days?

Copyright © 2020 by Karl Meyer All rights reserved

On September 1st, FirstLight Power petitioned the Federal Energy Regulatory Commission for a 3rd delay in submitting final license applications to run Northfield Mountain Pumped Storage Station and their Turners Falls hydro sites in Massachusetts. In a process now in its 9th year, the Canadian-owned company wants 4 more months to restudy NMPS’s water release impacts on endangered tiger beetles 30 miles downstream. It was bad news capping a dismal year for a Connecticut River that’s not seen any semblance of natural flows in the Bay State for half a century.

Despite recent on-air, print and social media stories of cleanup heroism, secret swimming holes, baby lamprey rescue and adult lamprey barbecues, our river seems headed back toward its time as “the nation’s best landscaped sewer.”

In August hundreds of thousands of gallons of raw sewage overflows enter its main stem, fouling it from Springfield to Middletown CT. In June, for the second time in a year, toxic PFAS entered waterways at Bradley Airport triggering fish consumption warnings and menacing water supplies on the Farmington all the way to its meeting with the Connecticut. A year ago–almost exactly 19 years after a factory spill killed thousands of North River fish, that grizzly Colrain kill was replicated when sulfuric acid again flowed from that site into that same tributary. 

In Vermont this year structural problems at Vernon Dam likely led to the big downturn in American shad reaching central New England. At Vernon this spring structural problems at that fishway likely led to the big downturn in American shad passing upstream there to central New England. The partial blockage might have been caught–and repaired, had two students downriver at Greenfield Community College fulfilled their weekly fish counting obligations. Important tallying, via downloaded video, just didn’t happen–leaving the problem at Vernon Dam undetected for a full migration season.

Meanwhile in Turners Falls riverbanks were collapsing—some oozing grim puss that’s leaching to the most endangered habitat in the ecosystem. The Rock Dam is an in-river ledge that’s provided refuge to federally endangered shortnose sturgeon for centuries. It’s their sole documented natural spawning site. Pink-orange slurry has been flushing from the banks there for a year–running into the river’s cobble bed where early life stage sturgeon shelter and develop.

A red slurry enters the Connecticut at the Rock Dam
Photo
Copyright © 2020 by Karl Meyer

Visitors to the river at Rock Dam off “Migratory Way” in Cabot Woods will see a 30 foot hemlock and saplings being eaten by a sinkhole now big enough for a Mini-Cooper. Banks there slump to a series of nasty, yards-wide, gashes—one with a dumped tire in its center. Slime squeezing from them sloughs in weeping riverlets that flow the final few yards to the river’s sturgeon nursery as a rusty precipitate of oxidizing iron, manganese and other unknown agents. In a drought year, the adjacent muck-choked canal is clearly the destabilizing water source.

Upriver failing FirstLight banks are threatening Millers Falls Road and houses on a buff there. Pipe failure is said to be a culprit. The town made expensive repairs, dumping rubble on that hillside at a sharp river curve called The Narrows. Failures at such nearby sites might merit closer examination. The Narrows is where current pushes against the outer riverbanks–a classic place for surging water to create erosional impact. Northfield Mountain creates big suck-and-surge cycles just 4 miles upstream–sending down powerful pulses that cause daily 3 foot “tides” at Turners Falls Dam. Some can reach 9 feet.

NMPS was completed in 1972 by Northeast Utilities. Rebranded as Eversource and now expanding into natural gas, they are still New England’s grid monopoly and perennial major sponsor of the Source to Sea Cleanup. NMPS is a now 48 year-old FirstLight holding, but still sending its surges down the Narrows to that dam. There, they get shunted into the power canal, ultimately exerting pressure against its massively muck-choked outer bank–adjacent and just 400 feet from those dissolving banks at Rock Dam. Ironically, any flow the canal can’t swallow gets flushed over the dam in channel-ramping surges to the starved, oft-empty riverbed below. That parch-and-flood cycle further impacts Rock Dam’s shores; then heads to endangered Puritan tiger beetle habitat 30 miles away.

The muck-choked outer bank of the drawn-down Turner Falls power canal on Sept. 14, 2020 Photo Copyright © 2020 by Karl Meyer

The US Geological Survey’s Conte Anadromous Fish Research Center sits 250 yards from Rock Dam. Shortnose sturgeon and their critical Rock Dam pool were extensively studied by their researchers there for decades. Now debased and failing, it is ignored. What about the Endangered Species Act, the Clean Water Act? That lab sits on a bank opposite Greenfield, home to the 68 year-old, recently-rebranded Connecticut River Conservancy. Why isn’t CRC testing that Rock Dam slurry at their water lab? Have they sent any slime samples out for analysis? Where’s their Streambank Erosion Committee? Why would a federal lab abandon the long-term endangered species research site at its door?

As self-described champions of “Science for a Changing World” and “Healthy habitats,” neither has steered a reporter or video crew to that elephant in the room. Perhaps it’s their admission of powerlessness. CRC, dependent on various federal and state fish and environmental agencies for grant monies won’t likely be calling out their failures anytime soon. They have no enforcement mandate and employ no staff lawyers. Thus they never challenge the big dogs, and power companies know it.

If a river could talk I think it would say cleanups look nice, but they won’t save rivers. That requires an unencumbered 21st century organization—one with lawyers and an enforcement mandate corporations can’t ignore.

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.

PROFIT and PAYBACK on NEW ENGLAND’S RIVER

Posted by on 04 Aug 2020 | Tagged as: Uncategorized


(Click X3 to enlarge; back arrow to return)

A happy Northfield Mountain greeting. Nothing about net-loss power and an endless cycle of river predation. Photo Copyright © 2020 by Karl Meyer All Rights Reserved

NOTE: the following piece appeared in The Greenfield Recorder on August 1, 2020.
https://www.recorder.com/my-turn-meyer-profitandpayback-35485611

PROFIT and PAYBACK on NEW ENGLAND’S RIVER

Copyright © 2020 by Karl Meyer All Rights Reserved

Recorder readers may have been surprised to see pictures of FirstLight Power’s new CEO Alicia Barton and Board President Phil Giudice recently. Photos are nice. But their profiles may have left people with misconceptions–particularly about clean energy and describing the Northfield Mountain Pumped Storage Station as a “zero emissions energy storage facility.” FirstLight’s commitments to the Commonwealth and our 4-state Connecticut River are questionable. On December 20, 2018 they left us, re-registering all three facilities profiting off massive consumption of this river into a series of limited liability companies in Delaware.

FirstLight is largely a Canadian outfit, a subsidiary of the huge venture capital firm, PSP Investments. PSP arrived four years back to buy up the Northfield Mountain and the Turners Falls/Cabot hydro facilities from GDF Suez. And while they employ perhaps a hundred folks locally, the profits they mine from our river are largely exported to distant shareholders.

Readers should understand Northfield Mountain is a gas powered contraption, not a hydro-powered facility. It is a giant net-energy-loss operation. The massive amount of juice NMPS pulls from the grid daily is overwhelmingly generated from climate-burning natural gas—today’s main source of New England power. Grid operator ISO-New England, reported natural gas accounted for 48.5% of all energy consumed in the region in 2019, while nuclear dumped in 30.5% and hydro—mostly imported from Canada, chipped in 8.9%. At 2 p.m. this July 29, 2020, ISO-NE’s energy mix was 75% gas, 18% nuclear, 4% renewables, and 2% hydro–largely imported. And, while NMPS sucks life from the river at of the heart of the Conte National Fish & Wildlife Refuge, it’s never created a single watt of virgin electricity.

According to the Federal Energy Regulatory Commission in 2019 NMPS consumed 1.114 billion Gross Kilowatt Hours of electricity while reproducing just 828 million GKHs. In 2018 NMPS consumed 1.205 billion GKH pumping the river uphill, but later returned only 907 million GKH of peak-priced power. Some years it’s consumes a full 1/3 more juice than it regurgitates.

This is a river-killing water storage and relay contraption, suctioning hours-long loops of water and fish from an ecosystem. Northfield sucks the river at rates up to 15,000 cubic feet per second to their 4 billion gallon reservoir. That 15,000 cfs amounts to gulping in a 7 bedroom, 8 bathroom mansion–filled with aquatic life, every second. Picture one instantly imploded–all fish, eggs, animals and insects killed on a twice-through Northfield sleigh ride. Now, picture 60 per minute, 600 every 10 minutes–3,600 mansions vaporized an hour–for hours on end.

Meanwhile, FirstLight’s traditional hydro-power operations 5 miles downstream at Turners Falls reported producing 316 million Gross Kilowatt Hours in 2018. In 2019 those same operations totaled 357 million GKHs. A little math shows that the 398 million GKH Northfield-created pumping deficit in 2018 erased nearly all 316 million GKH of the actual hydropower produced at Turners Falls. In 2019, Northfield’s deficit of 286 million GKHs erased a full 75% percent of all its downstream hydro contributions—negating all but a mere 71 million GKH of the total 357 produced.

FirstLight brags it can power a million homes for several hours, but never states in doing so it’s already burned through the energy for over 1,250,000 million homes. That math may work to cover the occasional grid slump or extremely rare blackout (what Northfield was originally designed for), but its continued daily use is grim news for the climate, the ecosystem; and river. After dumping out their few hours of electricity each day, NMPS is literally dead. De-watered, it must begin that massive juice and river consumption all over.

Studies on American shad show tens of millions of eggs and larvae are vaporized by Northfield annually, and add to that the outright loss of over 2 million juvenile shad sucked up on migrations back to the ocean. Five migratory species are subjected to NMPS. In total, 24 species–nearly all unstudied, live here. It’s doubtful any proposed 1000 foot barrier net strung across its giant, subsurface mouth will effectively protect fish–or the rest of a river’s aquatic life from its year-round carnage.

Northfield is now operating on an extended 50-year old FERC license. The original expired April 30, 2018. FirstLight, of Delaware and Canada, continues its profitting–while seeming in no hurry to complete a FERC relicensing process now dragging into its 9th year. It’s time to pony up. Time to stop killing fish and starving an ecosystem. By law, hundreds of thousands of fish are entitled to a new fish lift at Turners Falls and safe passage at NMPS annually. And no years-in-the-future corporate promise of pairing grim river pumped storage with ocean turbines 150 miles away will ever make those net-loss megawatts “clean” or “renewable.” They’re just patently miserable.

Karl Meyer lives in Greenfield. He’s been a member of the Fish and Aquatics Study Team in the FERC relicensing for Northfield Mountain and Turners Falls projects since 2012. Meyer is a member of the Society of Environmental Journalists.

Waterkeeper Alliance to be featured on PBS’s The Visionaries

Posted by on 08 Jul 2020 | Tagged as: Uncategorized

Above: Delaware Waterkeeper telling it straight.

I walked into the Solar Store of Greenfield about two weeks back and noted this large sign propped up against the front desk. This is an organization that is now the umbrella for all the Riverkeeper, Baykeeper, and Waterkeeper organizations that have sprung up by the hundreds across the planet. As shown here, there is a chapter on the Delaware. These are strong, direct, hands-on river and water protection outfits that take enforcement of environmental laws to heart, and take the corporations exploiting resources and skirting public rights into the courtroom. They’ve won many victories against energy giants, including just west of here on the Hudson River, as Hudson Riverkeeper.

https://www.youtube.com/watch?v=Ek0Xq5zKgC4

The Waterkeeper Alliance is being featured throughout the summer on PBS for its courage, effectiveness, and as a leading model of environmental protection. The episode begins airing on July 9th. Those interested in an effective blueprint for protecting rivers here in New England can tune in and learn more on PBS when it runs locally, or simply use the link ABOVE to see it now.

REIMAGINING A RIVER, Part 2: Not Nearly Hydro Power; Not Renewable Energy

Posted by on 17 Jun 2020 | Tagged as: American shad, B. D. Taubert, Clean Water Act, climate-destroying, Connecticut River, Connecticut River Conservancy, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, Environmental Protection Agency, EPA, Federal Energy Regulatory Commission, FERC, FirstLight, Fracked Gas, GHG, Hudson Riverkeeper, ISO New England, ISO-NEW ENGLAND, Mike Dadswell, Natural Gas, Nepool, Nepool, Phil Glick, Sam Lovejoy, Turners Falls dam, Turners Falls power canal, Uncategorized, Waterkeeper Alliance

THIS GREAT AND BROKEN RIVER VII

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 7, Part 2, REIMAGINING A RIVER: Not Nearly Hydro Power; Not Renewable Energy, Northfield Mountain’s Transition from Nuclear-fueled Net-loss Energy to Natural and Fracked Gas Net-loss Energy.

Author’s Notes: It is impossible to write at this time without mentioning the obvious. The country is in a moral crisis right now and it is time to stand up for the rights of Black people, and for the survival–and revival, of our democracy. This is a precious opportunity, one that we squander at our peril.

In the river-keeping world, there is also an opportunity for change that must be grasped now. The relicensing of MA CT River hydro and pumped storage projects is quietly moving toward its end game. A new model for protecting the ecosystem for coming generations is imperative. These licenses will govern conditions on the mainstem river for decades to come, and there is not a credible organization on the ground here that’s up to the task. The link below was forwarded to me. This is what’s called for. It will take hard work, money, and organizing. I hope there are those out there ready to contribute for the love of New England’s Great River.

https://waterkeeper.org/news/waterkeeper-alliance-to-appear-in-the-visionaries-series-on-pbs/


9-6-2010: Northfield Mountain Pumped Storage Station under EPA Sanction for violations of the Clean Water Act forced to dredge the hundreds of tons of muck they dumped into the River over a 3 month span.Photo-Copyright-©-2020-by-Karl-Meyer All Rights Reserved. (Click X3 to enlarge, use back arrows to return to text)

The Connecticut River has been running in reverse in northern Massachusetts for nearly half a century now. Daily at Northfield—125 miles from Long Island Sound, New England’s Great River is strangled away from its ancient gravitational course and literally forced to run counter to its nature. It’s not some bizarre phenomena related to distant tides, nor even some twisted water park trick. It’s caused by the lethal, ecosystem choking mechanisms of the Northfield Mountain Pumped Storage Station.

That river suction and reversal is the by-product of a massive, net-energy-loss, power re-generation scheme begun in the early 1970s. Originally running on the profligate excesses of nuclear power, today NMPS plugs in daily to suck giant streams of climate heating, natural-gas- produced megawatts from a bloated New England power grid. By yanking the river backward, Northfield’s huge energy and water appetite results in damage across parts of three states. Just a fraction of its ecosystem impacts have ever been fully measured and understood.

Since 1972 there’s been just seven months out of one year where those impacts were silenced. Beginning in May of 2010–and for the first time in the decade after Massachusetts implemented electricity deregulation, American shad passage at the Turners Falls Dam showed dramatically, exponentially, renewed signs of life. The big mystery was: why?

EPA-ordered Dredge Spoil Dump Site Mountain on Rt. 63 site after NMPS choked on its own silt and shut down for 7 months. Today that scar is covered by a friendly looking solar array. Photo Copyright © 2020 by Karl Meyer (Click x3 to enlarge, back arrows to return)

By June of that spring, with the abrupt silencing of grim river conditions created by Northfield’s massive sucking and surging, 5 miles upstream of Turners Falls Dam, the rising shad passage results could not be ignored. Fish passage in the river and up through the power canal past that dam was already known to be sorely impacted by the annual deluge-and-dearth flows that Northfield visited on the Connecticut. Without its suck and surge, ecosystem conditions changed immediately. Shad passage at Turners Falls soared to more than 500% above the average for the prior decade. And, no surprise, the New England power grid worked just fine without the daily addition of Northfield’s costly peak inputs.

The Northfield Mountain Pumped Storage Project was designed as a net-power-loss, buy-low/sell-high, money-making cousin to the now-closed Vermont Yankee nuclear plant. It was built to profit by piggy-backing on VY’s nightly over-bloat of cheap, excess megawatts. With VY as its engine, Northfield started massively twisting the Connecticut into a broken, reversing knot in northern Massachusetts, 125 miles from the sea.

When it came on-line in 1972, NMPS corralled for its use a full 20 miles of river—slowed and stilled behind the Turners Falls Dam all the way into southern Vermont and New Hampshire at Vernon Dam. Since that time it’s been yanking the Connecticut’s currents into reverse and sideways daily, ultimately sucking them a mile uphill into their 4 billion gallon reservoir via net-loss grid megawatts. But with Vermont Yankee closed in 2014, Northfield is today juicing an ecosystem by gorging on climate changing, natural gas produced megawatts–which is what now powers half of all New England’s energy consumption. And, ironically, the bulk of traditional hydropower consumed in this six-state region is actually produced hundreds of miles away in Canada.

Plugged-in to run via four giant, reversible turbines, the Federal Power Commission in 1972 sanctioned NMPS to operate as a net-loss emergency back-up and peak demand regeneration appliance. It would do so by consuming 25% percent—or at times over 30% more, electricity than it would ever later re-feed into the power grid as peak-priced megawatts. After Northfield’s dumping in of its 6 hours of peak-priced, net-loss energy, it would then be completely dead-in-the-water and have to begin its daily cycle of gobbling up virgin grid juice to suction the river uphill again. Consumers would pay for Northfield’s privileged permission.

Upon start-up NMPS’s daily net-loss operations became the most disruptive and efficient fish killing machine in a four-state ecosystem. Northfield kills virtually everything it sucks into its turbines for hours at a time, drawing in at up to 15,000 cubic feet per second everything from tiny fish eggs to full-size American eels. That deadly draw is known as entrainment, with the result being all fish disappearing through its pumping turbines termed “functionally extirpated.” The daily carnage continues down to this day.


7-20-2010: Clouds of Silt Plume around a nearly-invisible French King Rock in the Connecticut River from FirstLight’s illegal silt dumping. Photo Copyright © 2020 by Karl Meyer (Click x3 to enlarge)

A 2016 FirstLight consultant’s study estimated NMPS’s operations resulted in the loss of just 2,200 juvenile American shad. Yet study results released in 2018 by the US Fish & Wildlife Service and MA Fisheries & Wildlife estimated the carnage from a year of Northfield’s operations was massively higher. Their study estimated a single year loss of 1,029,865 juvenile shad. And that’s for just one of four migratory fish species subject to its suction annually—the others are American eel, blueback herring and sea lamprey. Consider then, that there are another 20 resident fish species sharing that same Northfield reach of the Connecticut, plus recent findings that federally endangered shortnose sturgeon may also be present. The more NMPS runs, the more life it kills.

As far as Northfield’s massive energy consumption impact goes, here are a few recent statistics: In 2018 FirstLight reported to the Federal Energy Regulatory Commission that NMPS consumed 1.205 billion Gross Kilowatt Hours pumping the river backward and uphill to its reservoir. After doing so, it later reproducing just 907 million GKH of peak-priced power. In the following year, 2019, NMPS consumed 1.114 billion GKHs, while only actually regenerating just 828 million GKHs to send back through the wires.

The tritium-leaking Vermont Yankee Nuclear Station closed in 2014, putting an end to its 42 year run of heating up the Connecticut River—but leaving in its wake a deadly thousand-year legacy of high-level radioactive waste. Since that time NMPS’s net-loss megawatts have transitioned from running on nuclear to being the ugly by-product of sucking in the climate-changing megawatts from a New England grid largely run via natural gas. Natural and fracked-gas today supply nearly half of all New England’s electric power. And Massachusetts, living far beyond its means, is the grid’s biggest customer.

The bloated power grid all that juice is relayed over is today run, supported and marketed by the likes of the Federal Energy Regulatory Commission, ISO-New England, Nepool, and a host of private corporate interests. The public is essentially shut out of both ISO-New England and Nepool decision making, as is the media. That is living proof of the failure of energy deregulation here. We’re failing our kids.

In that vein, there is another way to examine the absurdity of NMPS’s benefits vs. ecosystem impacts. FirstLight’s Northfield Mountain Pumped Storage Station’s annual net-loss-energy consumption largely erases the output of traditional, locally-produced Connecticut River hydropower from FirstLight’s own Turners Falls power canal and Cabot Station just downriver.
FirstLight’s 2018 actual hydropower operations 5 miles downstream at their power canal and Cabot Station reported generating 316 million Gross Kilowatt Hours of electricity. In 2019 FirstLight again reported on those hydro operations, which totaled 357 million GKHs. There was a 398 million GKH deficit produced by Northfield pumping the river uphill in 2018—used to later regenerate second-hand juice. That deficit erased nearly all 316 million GKH of the hydropower FirstLight produced downstream. In 2019, Northfield’s deficit of 286 million GKHs whittled the contribution of all Turners Falls hydro operations down to just 71 million GKH of the 357 it produced. The river and consumers pay dearly.

FERC, today, is comprised of just four commissioners, three of them Trump appointees who consistently vote to sanction big, climate-heating GHG extraction and export schemes for giant corporations. The lone Democrat, Phil Glick, is the sole voice calling on the Commission to consider climate impacts. Piggy-backing net-loss, river-killing power on top of imported, climate-destroying GHG generation is a grim business. FERC and ISO-New England have fashioned a huge, consumptive system where the public never has to give a thought to its unseen, climate-killing energy sources. Their scheme has blithely conditioned the public to always having at its fingertips a seemingly-limitless energy supply—deceptively cheap, always on hand, and available at a moment’s notice. By design here’s no thought process involved; no downside visible. That, in itself, is a crime against future generations.

In its current, over-bloated, over-subscribed power configuration, the New England power grid could run just fine without the daily depredations of NMPS’s peak use. Solar proliferation has recently resulted in the addition of 3400 megawatts of locally-produced renewable energy, nearly tripling the imported, 1100 MW of brief, peak, second-hand output from NMPS. Particularly in spring–when energy use is lowest and fish are migrating, spawning and a river is regenerating its life, Northfield’s deadly use should be limited to emergency output only. The carnage needs to stop.


9-3-2010: The Mountain of NMPS Dredged Sludge Growing along Rt. 63 after EPA’s Clean Water Act sanctions. Photo Copyright © 2020 by Karl Meyer (Click X3 to enlarge, back arrow to return)

Ironically, while Northfield Mountain was being proposed and ultimately built, a new coalition of anglers and environmentalists over on the Hudson River fought off plans for a similar pumped storage station proposed by energy giant Consolidated Edison in the late 1960s. That very public and consolidated action by citizens saved both the Hudson River and the top of scenic Storm King Mountain from becoming cogs in a killer machine like the one here. The on-the-ground result was ultimately an organization now known as Hudson Riverkeeper. Sadly, a similar battle wasn’t waged here to save the Connecticut. The top of Northfield Mountain was blasted to oblivion to create a 4 billion gallon reservoir and two massive, mile-long water shafts were sunk through rock to begin sucking up a river.

That failure to thwart Western Mass Electric/Northeast Utilities’ pumped storage scheme occurred even though the Connecticut River Watershed Council would be 20 years old in 1972 when NMPS finally plugged itself in. However, since that battle for the Hudson, the Hudson Riverkeeper and WaterKeeper alliances have blossomed into key organizations in ecosystem protection, proliferating and thriving via a very public investigation, enforcement and litigation model. They are upfront and vocal about consistently taking offending corporations to task and prosecuting them.

The only solace in the River’s history here in Northern Massachusetts is that the public got wise to the environment–and to the unending downsides of nuclear waste and building fleets of reactors and river diversions. In the early 1970s Northeast Utilities proposed another two nuclear plants, twins, both to be built on the Montague Plains. Their hot wastewater would be flushed into the nearby Connecticut River. They never got built.

On February 22, 1974, Sam Lovejoy of Montague Massachusetts set about loosening the bolts and toppling a Northeast Utilities weather testing tower, installed there to monitor winds to inform the planning layout for nuclear emergency evacuations—just in case there might be a little meltdown at the twin nuke site. That act of courage and civil disobedience, undertaken with deliberation and with an understanding of its potential civil consequences, bolstered a gathering opposition to the project. It ultimately helped galvanize a growing opposition to dozens of proposed reactors across the country.

It was a combination of that direct public opposition, Lovejoy’s protest and the subsequent discovery of larval shortnose sturgeon by research biologists Mike Dadswell and B.D.Taubert that ended what would today be yet another sprawling nuclear waste dump sitting above the Connecticut River. Again, a strong leadership role was not played by the Watershed Council. What ultimately made the difference was concise action, public engagement, and legal action in the courts. This was a victory for those who take full responsibility for the public turf they lay claim to.

The Connecticut River Watershed Council just recently became the Connecticut River Conservancy, but it still remains an organization laying claim to protecting the mainstem Connecticut across four states while not employing a single staff lawyer. Nor has it adopted a mission mandate to enforce and prosecute–continuing the model of a CRWC legacy dating back to 1952. The Connecticut River has long deserved better.

Honoring Peskeomscut

Posted by on 18 May 2020 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Deerfield River, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power, fish passage, Holyoke Dam, Narragansett, Nipmuck, Norwottuck, Peskeomscut, Pocumtuck, Relicensing, Riverside, sea lamprey, shad, The Dead Reach, Turners Falls dam, Turners Falls Massacre, Uncategorized

THIS GREAT AND BROKEN RIVER IV

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 4: Honoring Peskeomscut


Peskeomscut, Island?
Photo Copyright © 2020 by Karl Meyer(Click X 3 to enlarge; back arrow to return to text)

At a glance, this could be a photo of a quiet pond in New England. It is not. This is the mid-May, midstream view of an island in the Connecticut River, just 250 yards below the Turners Falls Dam in Massachusetts. With a quick look you might be wondering: where’s the river—and, what island?? This is a chasm and landscape robbed of its water, life and dignity. On any mid-spring day for ages past, thousands of American shad would’ve been pulsing through the rolling froth on both sides of what is a now-erased and bereft island. Today, shad here are not even offered a decent puddle to flop in.

Glancing quickly, you might not have made note of an island. But a closer look reveals a small, tree festooned bump in the center-right background. That site was identified by FirstLight Power as PesKeomscut Island in their initial 2012 application for a new federal hydro license to operate Turners Fall Dam—which is just out of view to the right of this photo. Unfortunately, Turners Falls Dam has been the place where New England’s Great River has died for well over two centuries now.

As far as any real river here?—there’s a just-visible bridge in the upper right, beneath which the mouth of the Fall River is adding a little flow and a tiny bit of froth to the barely-running current in the background. What should be the strong, rolling pulse of the spring Connecticut here should to be pushing downstream from left to right across the entire foreground of this photo. Instead, there’s just a stilled pond. And, yes, that island has been virtually erased. To be an island, you must have water.

On this May 14, 2020, FirstLight has subtracted that main ingredient. At mid-afternoon the Connecticut has been turned off in its own 200 million year-old chasm, robbed of all but a riverlet of dribbling flow. They do that most months out of the year. This spring day all but a tiny percentage of its life-giving current is diverted into FL’s adjacent power canal. The Connecticut is broken here at a place once called Peskeomscut–broken since the first dam stretched across this ancient chasm from Turners Falls to Gill in 1798. That began the 2-1/2 mile reach just downstream that robbed the river of life and flow. It gave rise to a landlocked “island” without a watery moat.

Further out and to the left in the photo, two more humans engage in a leisurely stroll over exposed sand—mid-river at mid-spring, padding over a dry shoal that should be teeming with river life at this season. But not here; not in northern Massachusetts. The place is a desert.

Instead of a life-giving, roaring spring cataract–encircling an inaccessible island, just a salutary wash of water is spilling from the dam above. Peskeomscut Island has been reduced to an abandoned, rocky spit in a parching, emptied chasm.

Looking closely, lower left of center you can make out an angler at the quiet, current-less shore. He might as well be on a pond—migrating American shad won’t find an upstream current deep or strong enough to follow their ancient migratory path toward the lost waterfalls here this day. While downstream, Holyoke Dam had reported 10,000 shad passing there through May 8, Turners Falls Dam had a whopping 38 passing here…

Peskeomscut is an approximate spelling of an Algonquian term used to denote the place where an ancient waterfall, cataract and island anchored the landscape. That place, which teemed with life throughout its annual seasonal cycles back into the mists of time, is today robbed of its soul–deprived of dignity. What, in 2020, should be a restored, thriving, May Connecticut River–full of shad, herring, lamprey eels and frothing currents, is today a drying, emptied bed. Its “island” is simply a rocky spit, easily accessible across the barren, bedrock ledge.


Midstream Peskeomscut 1-1-2018 (Click X 3 to enlarge)
Photo Copyright © 2020 by Karl Meyer

There is more than a little irony to this site being referenced today in Massachusetts as Turners Falls or the Great Falls. Any visitor here would more than likely find this curving, ancient chasm hollowed out at nearly any month of the year. There rarely are falls to see here. This is a broken place, a starved place. There is something raw and enduring about the injuries perpetrated here year in and year out. The once abundant life of this place is merely an afterthought here, if considered at all.

From Turners Falls Dam downstream to just above the river’s confluence with the Deerfield River, these 2-1/2 miles of the Connecticut are best described as its “Dead Reach.” There is no river in this stretch, just a parching/choking series of on-off flows that alternately starve and inundate what was once a life-filled artery.

In the spring of 2020, this should not be. It should all be the past history of the Great River. The current 52 year-old Federal Energy Regulatory Commission license to operate Turners Falls Dam expired in 2018. But FERC has allowed repeated extensions of that license, in a so-called “5-year” relicensing process that began in 2012. This stilted, corporate-skewed federal process has seen virtually no forward movement for over a year–and will soon be celebrating its 8th birthday. That stale status quo seems to suit FERC and FirstLight–as well as their shareholders, quite nicely. It’s just another abuse in the ongoing nightmare for the central artery of Western New England’s largest ecosystem.

On May 19, 2004, I witnessed a reconciliation ceremony at a park in Montague adjacent to the Connecticut, just above Turners Falls Dam. Local officials, citizens, and representatives from several of the region’s Native American tribes were present. All were there to honor, and attempt to heal the lingering injuries and moldering legacy of a grim injustice committed here in the pre-dawn dark on the morning of May 19, 1676.


Turners Falls Dam and Riverside Massacre Site
Photo Copyright © 2020 by Karl Meyer(Click X 3 to enlarge, back arrow to return to text)

Just across the river in the Riverside flats of Gill, 160 colonial troops swept down a hillside, firing muskets and stabbing bayonets into the tents of sleeping elders, women, and children of the Narragansett, Nipmuck and Pocumtuck and other peoples—encamped there in a hungry and desperate attempt to harvest fish and plant sustaining corn in their ongoing attempt to defend and keep the territories of their ancient homelands. For the colonists, it was a grim and successful slaughter of hundreds of defenseless Indians. For the indigenous tribes, though their surprise counter attack quickly sent the blood-bathed attackers into a chaotic, F-Troop rout, the loss of life ultimately proved a spirit and soul crushing disaster.

On this May 19th, 2020, much of the signaled healing and reconciliation of 16 years back seems to remain orphaned on the 344th anniversary of the Turners Falls Massacre. The wounds of that day are yet present. And, the later and ongoing theft of a river’s life-giving current–begun with that 1798 dam, still remains in place. The Connecticut here is–most days, an emptied and soulless place. It is long past time for the life and lives lost at Peskeomscut–and some of what is still missing as well, to see the beginning of a long overdue restoration. The river belongs to the people. Some of that healing must begin with water. Water is where life begins…

Connecticut River shortnose sturgeon: a spectacular failure to protect

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

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

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

“Dear Mr. Traester:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Enviro Show

The Shortnose Sturgeon are Coming to Spawn –in THIS?

Intervening for the Connecticut River Ecosystem

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

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

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


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


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

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

August 11, 2019

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

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

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

Dear Secretary Bose,

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you for your careful review of these matters.

Sincerely,
Karl Meyer

Connecticut River banks collapsing at critical shortnose sturgeon spawning ground

Posted by on 21 Oct 2019 | Tagged as: Uncategorized

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


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.

The Connecticut River banks above the Rock Dam pool–the only documented natural spawning site in the entire ecosystem for the federally endangered Connecticut River shortnose sturgeon, are collapsing and discharging polluting silt and what has been noted as a red, oxidizing leachate of manganese which is now entering the fragile habitat . Several sink holes, 4 and 5 feet deep have also begun showing up in the last three years atop the eroded trails leading to this ancient fishing area. They are inhabited by still-living, sunken hemlock trees. In other places, large trees are toppling.

These site are subject to the conditions in the current Federal Energy Regulatory Commission licenses P-1889, and P-2485, governing the operations of the Turners Falls Dam/Power Canal/Cabot Station, and the Northfield Mountain Pumped Storage Project. Both of these projects are currently the subject of FERC relicensing. They fall under the protections of the Clean Water Act and the Endangered Species Act.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.

NOTE: the Rock Dam pool and the pollution entry site are pictured in several photos. A tape measure draped across the red chair in these photos measures 5-feet across, for some perspective.

The apparent eroding water source for these collapsed banks is the outer curve of the ballooning Turners Falls power canal, just 200 feet away, at this site just few hundred yards north of the Silvio O. Conte Anadromous Fish Research Center. The last time the canal was fully mucked out and examined at this site was 2009. Note the photos from that year of heavy machinery in the canal.

Photo copyright © 2019, by Karl Meyer. All Rights Reserved.

The rate of collapse of these banks has increased dramatically this year, with two area gashes of 8 feet, and 25 feet across, falling away into a widening gully that feeds this silty pollution directly into the cobble, rubble, and sands that are the critical spawning and nursery habitat of the shortnose sturgeon, this river system’s only federally-endangered migratory fish. The maintenance of these banks has long been the responsibility of FirstLight Power, operators of the Turners Falls Dam, power canal, and of the violently disruptive peaking operations of the Northfield Mountain Pumped Storage Project, 9 miles upstream.

Photo copyright © 2019, by Karl Meyer. All Rights Reserved.

In the photo below are those same canal banks filled with thousands of cubic yards of muck, left un-shoveled and uninvestigated, where they bow out, adjacent to the collapsing banks above the Rock Dam site. It was taken during this year’s canal draw-down in the first week of October 2019. That muck, adjacent to those leaching/collapsing banks, was again not removed this year. That hasn’t occurred in a decade, since 2009.
Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.


Photo copyright © 2019, by Karl Meyer. All Rights Reserved.

Why no FISH?, STILL???

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

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

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

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

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

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

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

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

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

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