US Fish & Wildlife Service

Archived Posts from this Category

Bald eagles; canal shad and anglers up-close; fishy fishway windows

Posted by on 23 May 2015 | Tagged as: American shad, bald eagle, canal shad, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte, CRASC, Dead Reach, Federal Conte Anadromous Fish Research Center, federally-endangered shortnose sturgeon, fishway windows, National Marine Fisheries Service, New Hampshire, NMFS, Northfield Mountain Pumped Storage Station, power canal studies, Rock Dam, Rock Dam Pool, shad, shad fishing, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont

May 23, 2015. Turners Falls, MA. The test flows at Turners Falls Dam are now tamped down to 2,500 cubic feet per second. Thus anglers had given up fishing the riverbed below the dam yesterday(Friday) morning. However, the head gates beside the dam were open, releasing water at a good clip to course down the Turners Falls Power Canal. With little flow moving fish upstream in the actual river, it is commonly accepted knowledge that this forces fish to default to where they will find stronger upstream current to attract them. In this case that means a place 2-1/2 miles back downstream in the Dead Reach–the terminus of the canal at Cabot Station, where the power company dumps the river back into… the river. Thus, the canal becomes the impoverished, default habitat for migratory fish, attracted via privately- controlled flows that can be manipulated by dam operators. Thus, on Friday, just down from those head gates was the place where a few anglers gathered to fish the canal–just down the paved path to the low bridge behind the Great Falls Discovery Center.
P1000416
These gents were fishing shad that are part of the US Fish & Wildlife Service and the Connecticut River Atlantic Salmon Commission’s 1967 fisheries restoration mandate to move migratory fish upstream into New Hampshire and Vermont–to create a source of “seafood” for the public. These American shad, in Latin Alosa sapidissima–or “most delicious herring” were going to be eaten.
P1000417
With the main attraction flow coming from the downstream end of the power canal, it was primarily company flow through that conduit that was affecting upstream fish movements. Friday morning that flow was facilitating good numbers of fish in the viewing windows at Turners Falls Dam. The public’s fish and river should never be left in the private control of a corporation. That situation has resulted in the Black Hole of fish passage all these decades: the fish never reach Vermont and New Hampshire, and no one knows their fate after all upstream migrants are forced to enter the Turners Falls Power Canal.
A mile and a half downstream, there were two other potential anglers–perched in a cottonwood above the partially-flowing Connecticut’s riverbed. At just 2,500 cfs, they may have been licking their lips over fish that were confused or slowed and turning back in the river due to the withering upstream current. Slowed or stalled fish make for good eagle forage.
P1000425
Another half mile on down the river fishermen at The Rock Dam Pool were also happy to try and take advantage of a slowed or confused migration at this ancient site. Looking down from the rock ledge at the head of the pool, shad could be seen streaming through the water just 10 feet out. They moved by in tens and fives and dozens, but there was no way to discover whether they were milling through the edges of that frothy pool and simply returning to be seen again in an endless circling, or whether they were trying to shoot through one of the upstream notches in flows that were diminished by reductions at the dam.P1000433P1000432
Lastly, on “Migratory” Way, just down the canal past the USGS Conte Anadromous Fish Research Center, a crew of Conte fisheries people were inside FirstLight’s gates at the Cabot Hydro Station on the canal. USGS and the power company owners of the canal have been very close friends for decades now. Lab staff have worked for years on endless canal studies subsidized by Northeast Utilities, then NGS, and–of late, GDF-Suez FirstLight. Funny, though USGS holds the only National Marine Fisheries Service permit to study federally endangered shortnose sturgeon right here on the Connecticut, no study or tagging of sturgeon was done at all this year at their only documented natural spawning site–the Rock Dam Pool, just yards away from Conte Lab. And this, in a critical year of FEDERAL RE-LICENSING STUDIES.
P1000442
The folks in this picture are likely doing studies on migrating American eels. Power companies tend not to mind this type of work–as eels are difficult to study, they don’t spawn in the Connecticut River and thus are not an angler concern, and putting in “eelways”–which are wonderfully inexpensive, is a dirt cheap way to look “environmental” in the marketplace. Just as USGS Conte staff did endless canal studies with corporate study cash for decades on the TF Canal, they may be embarking on yet another cozy partnership, where years of data collection can be corporately subsidized, while true flows and fish passage upstream in the broken Connecticut River ecosystem through the Dead Reach here–and north past the Northfield Mountain Pumped Storage Station, gets ignored.
P1000438
The Turners Falls Power Canal’s emergency spillway chute and a portion of its failed fishway are pictured here, with a bit of Cabot Power Station in the background.

On Monday the Holyoke Fishway passed 21,198 shad; the Turners Falls season total as of 5/17 was just 22,499 shad

Posted by on 21 May 2015 | Tagged as: American shad, FirstLight, Holyoke Fish Lift, New Hampshire, sea lamprey, TransCanad, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, Vermont

May 21, 2015: The Holyoke Fishway lifted 7,360 American shad on Tuesday and 21,198 shad Monday according to today’s update fro the Connecticut River Coordinator’s office. Fish passage reports from FirstLight’s Turners Falls fishways are always days behind–due to having no real-time fish counters there reporting. Howsoever, as of their last report from Sunday, May 17th, the season’s total number of shad passing upstream there toward VT and NH spawning grounds was 22,499. That’s a decent DAY’S count at the Holyoke Fish Lift.

Holyoke has also passed 10,849 sea lamprey this season, while 794 have been reported at Turners Falls. This morning test flows from the Turners Falls Dam had been reduced to 2,500 cfs. At 7:30 am head gate flows into the Turners Falls Power Canal were generally quiet as well, with a nearly mirror-like surface and shuffle-along flow visible 100 feet downstream. At 3:30 pm, head gate flows were perhaps a tad more vigorous, but so mild that there we no bubble in the current whatsoever 60 feet from the gates. With more timely fish passage reports it might be possible to tease out how some of these settings are impacting upstream fish passage success.
P1000385
The photo above is of an American shad in the bubble-filled window of the Vernon Fishway on Sunday, May 17th. TransCanada has yet to submit fish passage reports to the USFWS website this season.

Spawning shortnose sturgeon denied flow at Rock Dam Pool

Posted by on 08 May 2015 | Tagged as: 5-year FERC licensing process, American shad, Atlantic salmon, blueback herring, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Endangered Species Act, ESA, Extinction, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, Rock Dam, Rutland Herald, shortnose sturgeon, The Greenfield Recorder, University of Massachusetts, US Fish & Wildlife Service, Vermont Digger

PRockDamPoolDewatered (2)
(to view lager image, click on photo).

NOTE: the photo above documents conditions found at the Rock Dam Pool on the Connecticut River on May 3, 2015. Seventeen years of published studies conducted by federal and University of Massachusetts fisheries researchers at the adjacent Conte Anadromous Fish Research Center show that these river conditions cause spawning failure for federally-endangered Connecticut River shortnose sturgeon at the Rock Dam Pool, their only documented natural spawning site. The May 3rd river conditions found at Rock Dam mimicked mid-summer flows on the Connecticut–conditions that research shows drives spawning-ready females from the site, and de-waters the cobble-strewn pool where eggs and embryos attach and develop. April 25 to May 22 is the documented spawning window for the shortnose sturgeon on the Connecticut. It is a crime to kill, injure or interfere with endangered Connecticut River shortnose sturgeon under federal and state law. The Federal Energy Regulatory Commission, the National Marine Fisheries Service, the US Fish & Wildlife Service, and the MA Division of Fisheries & Wildlife are responsible for the protection of the Connecticut River’s only federally-endangered fish under the Endangered Species Act(ESA). GDF-Suez FirstLight controls river flows to this site via spill gate operations at the Turners Falls Dam, just upstream.

A RIVER PRESERVED IN PLASTIC Copyright © 2015 by Karl Meyer

(The following essay–with minor variation in each, appeared recently in The Recorder, The Rutland Herald, and at Vtdigger.org)

A lifeless, three-foot long Connecticut River shortnose sturgeon sits on display at the Great Falls Discovery Center in Turners Falls, MA. The shortnose has been this river’s only federally-endangered fish since 1967. That plastic sturgeon has sat amidst other replica fish for a dozen years now—a plastic American shad, a blueback herring, a trophy-size Atlantic salmon. They’re framed beneath a slightly-ruffled acrylic surface representing the Connecticut River at this flagship site of the Silvio Conte National Fish & Wildlife Refuge.

That display is the basic message offered to visitors here: ‘This is a river with congenial flows supporting populations of shad and herring, big native salmon, and federally-protected sturgeon.’

Nothing could be further from the truth.

Few upstream migrants reach Vermont and New Hampshire today. That’s part of the legacy of failure of federal and state fish agencies and watchdog groups claiming to safeguard an ecosystem and its native migratory fish. That legacy will remain intact until they confront ongoing conditions in Massachusetts that have been crippling the river here for decades.

That Discovery Center depiction falls apart if visitors simply walk outside onto the deck of the Turners Falls Bridge, adjacent to Turners Falls Dam. There, often for months on end, what they’ll see is the hollowed-out heart of New England’s Great River–a waterless chasm, or one teased by just a trickle from the power company’s dam. Conversely, when rain or snow send more river downstream than can be profitably sent through FirstLight’s power canal or stored upstream for their Northfield Mountain Pumped Storage Station, those spill gates open wide–producing violent, see-sawing flows few fish can fight or follow.

Meanwhile a 200 million year-old evolutionary gem, the Connecticut River shortnose sturgeon, remains all but abandoned just downstream–teetering on the verge of extinction for decades. Likewise, American shad can’t move upstream in the river here at all. They’re forced into that turbine-lined power canal where less than 1-in-10 will emerge alive beyond the dam. And those blueback herring–protected on paper as a “federal trust” species, have not been counted here in almost a decade. Just 20 years back they passed by the thousands.

That plastic salmon, showcased for decades as the darling of this river’s fisheries restoration, has been extinct here since 1809. It should not be presented as a living native fish. In science, extinct isn’t subject to interpretation.

That trophy-sized model derives from a massive hybrid hatchery program created by cross-breeding salmon imported from Canadian and northern New England rivers. For 43 years federal and state fish farms produced the millions of tiny fry dumped into the river each spring. Those fish factories repeatedly proved vectors for the potential spread of disease throughout the river system. Though those tiny fish proved great for public relations, no spawning population of engineered salmon ever took hold.

Hybrid salmon became the red herring that masked the massively broken ecosystem that exists on an eight-mile stretch of New England’s Great River from the Northfield Mountain Pumped Storage Station to the tailrace of the Turners Falls Power Canal. Those salmon were the stand-ins for agencies including the National Marine Fisheries Service, the USFWS, and MA Division of Fish & Wildlife that had failed to protect living migratory species here–and an ecosystem suffocating right in their backyard.

The plight of the only state- and federally endangered fish here represents the ultimate failure of responsibilities. Dr. Boyd Kynard spent decades studying the shortnose and documented it’s only natural spawning site–the Rock Dam Pool, less than two miles downstream of Turners Falls Dam. Dam operations there were annually creating conditions that crippled spawning success for the remaining 300 sturgeon still able to reach their ancient rendezvous site.

Kynard’s federal- and state-funded findings were given to fish agencies a decade back. Each bore legal responsibility for that sturgeon. Yet no agency or non-profit stepped-in to monitor and enforce Endangered Species Act protections. None intervened to halt the trickle-and-torrent flows preventing reproduction. That step alone would’ve put living waters back into the river here–aiding the shad and herring attempting to reach Vermont and New Hampshire. Likewise in 2012, when Kynard published a book on the shortnose–documenting its life history and the river conditions necessary for its recovery, again, no one went to court to protect this public legacy.

Had agencies and watchdog groups taken responsibility years back for protecting spawning sturgeon at that Rock Dam Pool below FirstLight’s dam, native migratory fish and the river ecosystem would be in a far better place today. Instead, that work was left to become part of the current studies in the Federal Energy Regulatory Commission’s 5-year relicensing process for the Turners Falls and Northfield hydro sites, where I’m on the Fisheries and Aquatic Studies Team.

Sturgeon spawning is not monitored today. It’s unconscionable to have waited for a 40 year relicensing process to come around before broaching concerns for an endangered fish and broken ecosystem. Hopefully it won’t prove the difference between a living river, and one merely depicted in a museum model.

Greenfield, MA journalist Karl Meyer is participating in the Federal Energy Regulatory Commission’s relicensing process for the Northfield Mountain and Turners Falls hydro sites.

New Comments to FERC, RE: Turners Falls Fisheries Studies

Posted by on 08 Apr 2015 | Tagged as: 5-year FERC licensing process, American shad, Cabot Station, Connecticut River, Connecticut River shortnose sturgeon, Conte, Dr. Castro-Santos, Dr. Haro, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, MA Division of Fish and Wildlife, Mr. Colton Bridges, New Hampshire, Northfield Mountain Pumped Storage Project, Revised Study Plan, Secretary Kimberly Bose, shad, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont

NOTE: the following comments were submitted to Federal Energy Regulatory Commission Secretary Kimberly Bose respecting FirstLight’s withdrawal from its stated position of using video-monitoring equipment at the Turners Falls Dam’s Spillway Ladder to compile study data and information on aggregations of migrating American shad.

This is information that has been the fisheries restoration’s Black Hole these last forty years. It can only be gathered at this site. However, with the withdrawal of these tools, fisheries agencies and the public will be relying on just a few hundred radio-tagged and tracked fish as substitutes for on-site, real time monitoring of aggregations of what are understood to be perhaps hundreds of thousands of migratory shad. (Comments to FERC were slightly abbreviated due space limits in E-filing.)

Karl Meyer, MS
Greenfield, MA 01301 April 8, 2015

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

Re: P-1889; P-2485

Dear Secretary Bose:

Please accept the following comments in the matter of the hydro-power licensing studies for P-1889, the Turners Falls Project; and P-2485, the Northfield Mountain Pumped Storage Project. These comments focus on changes FirstLight made to the Revised Study Plan. I first aired my objections to these RSP changes at a meeting on March 24, 2015–as a member of the Fisheries and Aquatics Study Team. They highlight a lack of Existing Information and a Need for Additional Information that FirstLight’s RSP revisions will not satisfy.

FirstLight has summarily excised all video monitoring in the vicinity of the Spillway Fishway at the base of Turners Falls Dam—a technique they’d agreed was needed in the initial RSP.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Existing Information and Need for Additional Information

Passage through the Turners Falls complex:

Study Goals and Objectives: (18CFR; 5.11(d)(1)

“Evaluate attraction, entrance efficiency and internal efficiency of the Spillway Ladder for shad reaching the dam spillway, under a range of conditions.”

FirstLight stated the following in their initial RSP response: (bolded italics below, mine

“Video monitoring will be used for specific study areas such as the Spillway Fishway. Use of video monitoring of the Spillway fishway will provide data on fishway efficiency; shad attempting to pass would be monitored versus only those shad that have been tagged.”

Task 2: Study Design and Methods:

FirstLight then wholly eliminated that key video information gathering technique that would help inform these studies with aggregate numbers of shad reaching the Spillway Entrance, versus only those few tagged fish approaching and passing the Spillway entrance.

From FirstLight’s March 14, 2015 RSP changes distributed to the Fisheries and Aquatics Study Team:

“The study will monitor shad migration within the study area using a combination of active and passive radio techniques and video surveillance.”

This needed information gathering was eliminated by FirstLight despite their description in the initial RSP that this was a proven and inexpensive technology:

“FirstLight proposes to conduct video monitoring using the Delta System commercial series of underwater video camera and lighting manufactured by Ocean Systems Inc. This system was recommended by A. Haro (Conte Lab) and has proven effective at other facilities. Video data will be recorded on a dedicated video recorder (DVR).”

“Video monitoring of the Spillway would add a modest cost to this study.”

As to why gathering information about aggregations of American shad at the Spillway adjacent to Turners Falls Dam is needed at this time–that need was stated in FirstLight’s initial RSP response as well:

“In general, the numbers of tagged fish passing through the Spillway Fishway were too low for vigorous evaluation (Haro and Castro-Santos 2005).”

Information about aggregations of migratory fish moving upstream to the base of Turners Falls Dam and the Spillway has been paltry to nonexistent these last 40 years. In the last 15 years, Dr. Haro and Dr. Castro-Santos of the USGS Conte Lab have focused nearly all their work in FirstLight’s power canal, while the Connecticut River passage route for these federal trust fish has been almost wholly ignored.

As to the huge gap in the information for American shad aggregations at this site, I herein cite expert testimony delivered before Commission members four decades back:

On August 21, 1975, in hearings before the United States Federal Power Commission in Boston, Mr. Colton Bridges, Deputy Director of the Massachusetts Division of Fisheries and Wildlife delivered the following expert testimony on the need for Spillway Fish Passage at the Turners Falls Dam:

To Mr. Bridges: Question: “Would either the Cabot power house fishway or the gatehouse fishway be effective in passing those early arriving shad?”

Answer from Mr. Bridges: “No, because with spill conditions at Turner Falls the major source of attraction water will be coming down river from the Turners Falls Dam and emanating from Cabot Station. Consequently, the conditions that existed at Holyoke with spillway flows limiting fishlift efficiency will prevail at Turners Falls Dam with only a Cabot Station fish passage facility in operation.”

Question: “What, in your opinion, would be the effect of the construction of the proposed fish passage facilities at Turners Falls Dam without the inclusion of the spillway fishway?”

Answer from Mr. Bridges: “Without a spillway fish passage facility, fish approaching Turners Falls during periods of spill will be attracted to the base of the dam and those isolated pools located immediately below it, and be subject to the same conditions that exist below Holyoke without the spillway fish collecting facility, i.e., migration delay and mortality due to lack of flow, increased water temperatures, and decreasing oxygen content.”

Given that, as of this date, FERC is refusing to allow the USFWS any in-situ access for snorkeling to get a general assessment of fish using this passage route to Turners Falls Dam during migration season–and that FERC is further disallowing any seining for fish or shad eggs in this reach due to concerns for endangered shortnose sturgeon, this is the only key place where any new information about Spillway aggregations of shad can be gained. This was stated as a result of FERC internal policy, though NMFS indicated a willingness to consult—and NMFS is the ultimate key-holder in decisions concerning Connecticut River shortnose sturgeon.

Hence, denying the gathering of this needed information at the Spillway effectively limits the public’s understanding of what is happening at this site. Though overall successful fish passage through the Spillway Ladder has proven ineffective these past 30 years, it should not limit the Entranceway as the key place to collect long-absent information on aggregating shad.

These are the early arriving fish that have long been known to be the key migrants–most likely to move upstream to Northern Massachusetts, Vermont and New Hampshire spawning sites on the Connecticut. As of this date, 40 years after Deputy Director Colton Bridges testimony, those fish are still not making it past Turners Falls Dam, and we don’t have the information about their numbers and when, where, and in what flow conditions they gather at the Spillway site.

For these reasons I respectfully request that Spillway video monitoring be returned to the Revised Study Plan for this season–to gather the data that cannot be gained simply by monitoring a few hundred radio-tagged fish.

Thank you.

Sincerely,
Karl Meyer, MS, Member, Fisheries and Aquatics Study Team for P-1889; P-2485

A look inside the FERC licensing process

Posted by on 06 Jan 2015 | Tagged as: 5-year FERC licensing process, Drew Huthchison, Federal Energy Regulatory Commission, FERC, FERC license, FERC licensing process, fracked gas licensing, GDF-Suez FirstLight, ISO New England, Kinder Morgan, Kinder Morgan pipeline, Mt. Tom Coal Plant, National Marine Fisheries Service, NOAA, Northfield Mountain Pumped Storage Project, shad, shad larvae, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont Yankee, Yankee Rowe Nuclear Plant

In mid-December I was interviewed on Greenfield Community Television’s Local Bias feature by Mark Wisniewski, former Greenfield City Council President. In a wide-ranging talk we discussed my experiences with the ongoing Federal Energy Regulatory Commission licensing process as both a journalist and stakeholder in the hydro projects at Northfield Mountain and the Turners Falls Power Canal on the Connecticut River. The FERC licensing process is a cumbersome and lengthy ordeal–transpiring over a 5- year swatch of time.

Anyone interested in–or involved as a citizen in, the deluge of FERC projects currently affecting our region, might gain some insight by tuning in: from fracked-gas pipelines, to hydro, nuclear, climate and ecosystem impacts.

Local Bias airs beginning Wednesday, at 5:30 pm, and repeats on Thursday and Saturday nights at 9 pm throughout the month of January 2015.

Local Bias is produced and directed by Drew Hutchison.

Try the link below,.. or go to look up GCTV, Local Bias to connect to a copy of the show.

http://gctv.org/videos/local-bias-karl-meyer-121514

New CT River Stakeholder Comments Submitted to FERC

Posted by on 14 Nov 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, FERC, FirstLight, GDF-Suez FirstLight, National Marine Fisheries Service, NMFS, Northfield Mountain Pumped Storage Station, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following Stakeholder Comments/Requests on FERC Projects P-1889 and P-2485, Turners Falls Hydro and Northfield Mountain Pumped Storage were submitted on November 13, 2014 to the Secretary of the Federal Energy Regulatory Commission.

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

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

ILP COMMENTS–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 in order to continue plant operations beyond 2018. An Initial Study Report Meeting Summary has been filed by GDF-Suez FirstLight. Please accept these comments on the ISR and my proposals for modifications and new study requirements in the FERC ILP for these projects.

3.3.11 Fish Assemblage Assessment:

Further information/study needed:

FirstLight has declined to undertake any study in the By Pass Reach of the Connecticut River due to stated concerns of interference with spawning and development of embryos of federally endangered shortnose sturgeon in this area. Information from the 2009 EPA study is insufficient to quantify presence and abundance of resident and migratory fish in this reach during critical migration and spawning periods—April through June. That investigation used only 3 sites in the By Pass Reach and was not undertaken to illuminate key species requirements in the current ILP for this critical reach.

NMFS notes that FirstLight has failed to consult with stakeholders on SNS issues here. I am in agreement with USFWS that a dedicated snorkeling, SCUBA, or hookah diving assessment of this critical reach of the four-state CT River be conducted in the riverbed between the Turners Falls Dam and downstream of Cabot Station during the April-June migration and spawning window–and that it continue after FirstLight’s suggested June 30 beginning target date.

I personally snorkeled parts of this reach in May 2013 and found that identification of migrants and resident species was easily attained. An in-situ investigation of this river reach in order to assess species presence and relative abundance is necessary groundwork for making decisions that will impact the 45-year long fisheries restoration on the Connecticut.

Dr. Boyd Kynard, who FirstLight cites in their argument and who spent decades investigating shortnose sturgeon on this reach of the Connecticut told me (personal communication 11/12/2014) that this study method can be accomplished without impacting SNS from the pool below the Rock Dam upstream to the base of Turners Falls Dam.

3.3.12 Evaluate Frequency and Impact of Emergency Water Control Gate Discharge Events and Bypass Flume Events on Shortnose Sturgeon Spawning and Rearing Habitat in the Tailrace and Downstream from Cabot Station.

Further information/study needed: FirstLight has supplied a grid of information for emergency gate and by pass flume openings for the years 2005 – 2012, though 2010 is missing, and we have no information on gate openings and placement for 2011 and 2012 in some instances, other than that there were no instances when greater than 4 emergency flume gates were open.

This study information should be updated with full information for years 2011, 2012—as well as 2013 and 2014 gate opening numbers, placements and CFS information.

Study findings from Kynard and Keiffer, as well as the long-term study of SNS in this reach catalogued in Life History and Behaviour of Connecticut River Shortnose and Other Sturgeons, published by the World Sturgeon Society, 2012, specifically delineate emergency and canal flume gate spill as having a profound and deleterious impact on shortnose sturgeon spawning and early life stage development.

As was stated recently by sturgeon biologist Micah Kieffer at a fall 2014 meeting of the Connecticut River Atlantic Salmon Commission, “one instance” of ramped-up or ramped-down flow from TF dam or emergency spill gate and flume operation can abruptly terminate or abort spawning attempts at Rock Dam and below Cabot Station by federally-endangered SNS for the entire year. Operations of emergency and by pass flume gates on the TF canal also can have deadly parching or burying impacts SNS embryos.

FirstLight contends that its operations of Bypass flume gates above Cabot Station are aimed at either emergency load rejection at Cabot Station, or opened to flush debris. They also contend that it is rare to have more than one flume spill gate open, though most of the numbers belie this statement–and the number of days when 4 or more gates have been open during SNS spawning window is highly significant and impactful. Opening of 4 flume gates needlessly diverts flows approaching 4,000 CFS out of the Connecticut’s By Pass Reach at TF Dam, and sends it into the canal to be needlessly flushed back into the river in a configuration that impacts migratory species and imperils annual spawning attempts of the federally-endangered CT River shortnose sturgeon.

In May 2014, I personally witnessed 3 consecutive days when two or more spill gates were open at the TF canal bypass above Cabot—all at the same time of day: 12:25 pm. These openings occurred while both Station 1 and Cabot were generating, which would appear to indicate that the spill gates had been left in this position for hours, or perhaps days, as part of flow regulation in the canal–rather than emergency or debris clearing. I have sent this information to both FERC and the federal and state fisheries agencies.

It is clear to anyone who examines the TF power canal that it is mostly a lake-like, slow-water habitat, save for the thalweg. It is rare to see debris of any significant size floating in the canal. It gets culled off at the trash racks in front of the TF Gatehouse, or at racks on the canal that dog-leg off to Station 1, or it simply settles out in the lake section of the TF Canal.

The minor amount of small, floating debris that enters the fat part of the canal is culled off by the trash rack skirt above Cabot that steers it to the east side of the canal where a bascule gate can be operated to pass anything of significant size.

The continuous openings of two or more bypass gates, up to six and seven gates open on a “non-emergency” basis on the TF canal above Cabot Station during SNS spawning and early life stage periods threatens the recovery of the Connecticut River’s only federally endangered migratory species.

As I have witnessed, multiple gates open on the canal while both Station 1 and Cabot were in operation indicates that canal flow is at times being regulated at this site, rather than at the TF Gatehouse, where excess flow could be delivered to the river in the Bypass Reach, which would nourish, rather than destroy SNS chances for successful spawning at Rock Dam and below Cabot. During SNS spawning season, mid-April – June 30th, endangered species protections dictate that all flow, save for documented, specific emergency situations, by controlled at the Head Gates of the Turners Falls Dam.

Information for years 2013 and 2014 should further be included, and a Study and study season for 2015 should be implemented that documents both the reason and instances when emergency gates were open—and any flume gates above 1 that were open to vent flow from the canal to the ByPass.

I would also like to FERC to have FirstLight include information for 2010, as the May 4 time of 8-gate emergency spill operation occurred exactly at the time frame when Northfield Mountain had burped up a massive sediment spill into its intake, and was trying to flush that pollution downstream. It would be helpful to know the position of both the Bypass flume gates and the positions of TF Dam headgates and bascule and tainter gates at that juncture—as it most definitely impacted SNS present for spawning that year. This would again offer data on whether the TF canal flows were being regulated via emergency by pass flume operation.

3.3.14 Aquatic Mapping of Turners Falls Impoundment:

Further information/study needed:

If migratory fish targeted for restoration in Northern Massachusetts and Vermont and New Hampshire are to continue to be diverted into the TF Power Canal, where few emerge upstream, then an addition to this study should be conducted: Aquatic Mapping of the Turners Falls Power Canal—as it is technically an extension of the Turners Falls Impoundment, and the public has a right to understand the habitat where their fish get privatized.

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

Further information/study needed:

The 2014 Canal Drawdown study was flawed as it occurred over the course of two days, due to an error in spill gate function. Since this is a study of live and dead fish and organisms, as well as the presence of dissolved oxygen, a two-day study time frame represents a flawed evaluation. A night of drying, predation, and fluctuating oxygen presence confounds the results of this work. FirstLight does an annual drawdown of the canal—has down so for decades, thus a mistake at the time of a critical habitat study should corrected by conducting a second year of study.

Further, since FERC has ordered that FL conduct a study of American shad spawning in the TF Canal, it is important to note another anomaly in their canal drawdown work. At five-year intervals the TF Canal receives a full canal muck-out during drawdown. The last one occurred in 2009. This would have been the fifth year—a time when the major muck-out would occur. It did not happen. What occurred was canal “light”, with a large snafu in the middle of the one day study, making it a two day effort. Whether FL agrees that this should have occurred in 2014 or not, a big-dig in the canal is needed regularly, as the sludge, silt and muck settles out and fills in the wide part of the basin.

This must be figured into the “impacts” of the drawdown, as it has profound implications for forcing migratory fish into this habitat, as well as the survival of resident fish and aquatics.

Please see attached photo of the canal muck-out that I took in 2009.

This is the habitat all upstream migrants are diverted into at Turner Falls

This is the habitat all upstream migrants are diverted into at Turner Falls

 

3.3.19 Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement of Migratory Fish to Turners Falls Dam by Avoiding Cabot Station Tailrace

Further information/study needed: the need for this 2016 study will be fully realized if planned studies of American shad movement and spawning in the canal confirm that these fish are experiencing significant migratory delay, and are being coralled into a migratory spawning trap by confused and insurmountable flows or pre-mature warming in artificial habitat that induces spawning in the canal—preventing fisheries restoration on the river in Northern Massachusetts, New Hampshire and Vermont.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Further information/study needed: I concur with FERC’s requirements of an intensive array of radio and telemetry receivers throughout the TF Power Canal to track migrating shad in the canal.

However, I request that FERC require FirstLight, in consultation with stakeholders, add an array temperature monitors calibrated to the radio and telemetry sites to understand whether canal delays for American shad–lingering for an average of 8 days in the TF Canal, are forcing these fish to spawn in this privatized, lake-like habitat because of warmed, shallow, and slow water conditions.

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

Further information/study needed:
I concur with FERC that a full spawning study of the Turners Falls Power Canal be conducted in 2015, undertaken in consultation with stakeholders. Temperature monitors should be deployed to assess impact on migratory delay and spawning on-set; and cumulative impacts of head gate and by pass use of spill gates should be factored into the study to determine the impact of silt deposits on spawning success.

3.3.9 Two-Dimensional Modeling of the Northfield Mountain Pumped Storage Project Intake/Tailrace Channel and Connecticut River Upstream and Downstream of the Intake/Tailrace

Further information/study needed: In the Initial Study Report Study Meeting Summary for stakeholder in October 2014, a request was made that FirstLight provide vector maps with arrows and indication of directional flow around the Intake and Tailrace Channel at the Northfield Mountain Pumped Storage Project. This is critical information for flow, erosion, and sediment displacement and needs inclusion.

This is information that has been missing on Northfield Mountain Pumped Storage Impacts since at least 1974. See attached at end of document.

Thank you for this opportunity to comment on these critical relicensing issues.

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

1974 attached file below.

 

The Hidden Costs of Northfield Mountain Pumped Storage

Posted by on 01 Sep 2014 | Tagged as: Connecticut River, Connecticut River ecosystem, ecosystem, Entrainment, Federal Energy Regulatory Commission, FirstLight, GDF-Suez FirstLight, Haddam nuclear plant, Ludington Pumped Storage Plant, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, resident river fish, US Fish & Wildlife Service, USFWS, Vermont Yankee, Yankee Atomic, Yankee Rowe Nuclear Plant

Copyright © 2014 by Karl Meyer

The hidden costs of Northfield Mountain Pumped Storage: after Vermont Yankee closes, FirstLight wants to ramp up pumping and profits

(a version of this piece first appeared in the Greenfield Recorder, August 23, 2014)

Vermont Yankee, the last of the region’s nuclear plants, will close in December. In response, GDF-Suez FirstLight’s Northfield Mountain Pumped Storage plant is looking to change its stripes. On June 27th it applied to the Federal Energy Regulatory Commission for a “temporary” license amendment to allow it broad new freedoms to consume unprecedented amounts of the Connecticut River from December 1, 2014 through March 31, 2015. That plan would add an additional 22 feet of pumping capacity to its 5-billion gallon reservoir, sucked directly from the river. More pumping is certain to create more riverbank erosion and draw more silt into that reservoir. It will also kill untold thousands of the public’s resident river fish.

The unprecedented request defies logic. Northfield was built specifically to use energy from local nuclear plants to push water up to its reservoir. In its request FirstLight also cited the closing of the 330 megawatt Salem Harbor coal plant as rationale for why it should be allowed to pump more, and grow larger. FirstLight Hydro Compliance Director John Howard stated, “The requested increase in operational flexibility is needed to provide ISO-New England with additional resources to deal with a potential shortage of energy in the Northeast this winter.” However Andrea Donlon of the Connecticut River Watershed Council found that ISO-New England, the grid’s Independent System Operator, had made no requests concerning Northfield, stating it expected to have adequate energy supply this winter.

FirstLight’s application failed to mention is that it is shutting down its own 135 megawatt Mt. Tom Coal Plant this October. Rather than the “peaking energy” and “emergency resource” plant it’s been since coming on-line in 1972, Northfield seems to be implying it will somehow serve as a replacement for those 24/7 “baseload” energy plants. The other logic-defying reality is that it would be consuming more baseload energy to create more brief pulses of high-priced energy to re-sell to us at “spot” market prices.

Northfield was fashioned during the nuclear build-out in the late 1960s to use the excess power generated at night from nuclear plants in Rowe, Vernon, VT and Haddam, CT to gulp giant slugs of the Connecticut up to its reservoir. When demand “peaked” during mornings or late afternoons it would release that stored nuclear energy—our river, back to its bed through massive turbines. It could produce some 1,000 megawatts in just minutes, great for short-term needs and emergencies. But it could only store enough water to produce 6-8 hours of electricity, total. Depleted, it then waited to re-start the process.

In her book “Inventing Niagara” Ginger Strand described the inefficiencies and rationale behind selling pumped storage electricity to the public as a textbook case of corporate capitalism: buy low, sell high. Northfield has never been a renewable hydro source. It is inefficient and operates at a net-energy loss. While its impacts on the river ecosystem are profound, its brief, staggering pulses of violent, high-volume output are no more efficient than that of legacy electric producers, just more short-term profitable.

Northfield only makes sense while it operates as a designated nuclear adjunct, run on the excesses of the region’s short-lived and now-shuttered nuclear fleet. But now it wants to soldier on, utilizing imported power and climate-changing resources. Meanwhile the river pays an as-yet unstudied price–as the public is asked to accept yet more “peak” energy, repackaged and re-sold at “peak” prices culled from bidding boards on the “spot” market.

FirstLight’s FERC request sparked official replies from entities involved in the current 5-year relicensing of Northfield. The National Marine Fisheries Service’s William McDavitt noted to John Howard “the timing of this temporary amendment application is a bit unfortunate as the proposed change could bear some impact on proposed 3.1.2 Northfield Mountain/Turners Falls Operations Impact on Existing Erosion and Potential Bank Instability. Were the proposed changes to go into effect, it seems as though the duration that NMPS pumps or generates could be changed.”

MA Fish and Wildlife made no objections to the up-rate, but the Watershed Council noted that fish kills there–known as “entrainment”, are worrisome, “Currently the entrainment impact of the NMPS facility during the winter is not well understood, which the pending appeal by USFWS regarding the sufficiency of FirstLight’s proposed entrainment study well illustrates,” further noting, “So until such time as we have a much better understanding of the entrainment impacts of NMPS, it seems inappropriate to request additional pumping capacity.”

In 1995 the owners of the Ludington(MI) Pumped Storage Plant agreed to a $172 million dollar settlement for its killing of the public’s fish across the previous two decades. There, according to the Ludington Daily News, they at least had the benefit of a one-time study showing LPSP “in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.”

Since 1972 it’s been a free ride up at Northfield.

Karl Meyer is a member of the Society of Environmental Journalists.

Kynard,Part II: Fisheries restoration, or a new half-century of death in the TF Power Canal?

Posted by on 06 Aug 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River, Connecticut River ecosystem, Dead Reach, Dr. Boyd Kynard, ecosystem, Federal Energy Regulatory Commission, federal trust fish, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Station, shad, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont

Tune in to Local Bias on Greenfield Community Television, GCTV.org, for Part II of a wide ranging interview with fisheries biologist and US Fish & Wildlife Service Conte Anadromous Fish Research Center founder Dr. Boyd Kynard. He gives direct answers to questions about the fate of the millions of American shad that have been tricked out of the Connecticut River into the deadly and alien habitats of the private Turners Falls Power Canal for the last 35 years.

Dr. Boyd Kynard Part II; a Deadly Canal or a River Migration Solution?

http://mfi.re/watch/pdx5yqvqv7ygzdk/Local_Bias_147.mpg

The current Federal Energy Regulatory Commission Re-licensing process for FirstLight Power’s Turners Fall/Cabot Station and Northfield Mountain Pumped Storage Stations represents the last chance the Connecticut River gets to recover some of its biodiversity, fecundity and ecosystem functions for many decades to come. A second failure by the public agencies charged with protecting the public’s fisheries resources and endangered species will likely close off–forever, the last, best chance to restore New England’s Great River.

Will the federal and state agencies responsible for protecting and guiding the migratory fisheries restoration since 1967 (USFWS, National Marine Fisheries Service, VT, NH, and MA Division of Fish & Wildlife), again steer migratory fish headed upstream to northern MA, VT and NH spawning habitats into a private “roach motel” of deadly hydro blades and muck? Or, will they bring them directly upstream to a fish elevator at the Turners Falls and redeem decades of failure? Get the low-down, and hear about viable alternatives in this half-hour interview.

Tune in to Local Bias this Thursday, August 7 at 9 pm, or on Saturday, August 9th, at 9 pm. The shows repeat at those scheduled times the following week.

THE CONNECTICUT RIVER SHORTNOSE STURGEON: A PLANNED EXTINCTION?

Posted by on 08 Jul 2014 | Tagged as: Atlantic salmon, Connecticut River, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, ecosystem, Endangered Species Act, Extinction, federally-endangered shortnose sturgeon, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Turners Falls, US Fish & Wildlife Service, USFWS

Click on the link above for: Part one of Local Bias interview between Karl Meyer and Dr. Boyd Kynard, produced by Drew Hutchison of Greenfield Community Television.

Watch an interview with fisheries biologist Dr. Boyd Kynard who has made a career of researching migratory fish behavior and fish passage at dams in large rivers across four continents. Kynard is the long-standing research expert on the federally-endangered Connecticut River shortnose sturgeon.

For 45 years federal and state fisheries agencies plowed $100s-of-millions into a program targeting “restoration” of a strain of Connecticut River salmon extinct since 1809. Failing to understand the concept of extinction, that project failed.

For those same 45 years agencies including NOAA’s National Marine Fisheries Service, the US Fish & Wildlife Service, and Massachusetts and Connecticut fish and wildlife departments ignored, dismissed, and failed to provide the protections, outreach, and funding needed to rescue a native, four foot-long, living fossil: the federally-endangered Connecticut River shortnose sturgeon.

Listed among just 22 fish species in the original 1967 federal Endangered Species Act, these agencies–as well as regional non-profits, have failed to protect the 2-mile stretch of river decimated by industrial flows containing the only known natural spawning grounds of this pre- Dinosaur-Age fish: the pool below a natural rocky cleft in the river known as the Rock Dam, in Turners Falls, MA. Just 300 Connecticut River shortnose sturgeon can access the Rock Dam site today–where industrial flows cripple their spawning attempts, and endangered species protections are ignored.

New Stakeholder Comments filed with FERC re: Northfield Mountain

Posted by on 21 May 2014 | Tagged as: American shad, Bellows Falls, Connecticut River, Connecticut River ecosystem, ecosystem, Endangered Species Act, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, GDF-Suez FirstLight, Ludington Pumped Storage Plant, New Hampshire, Northfield Mountain Pumped Storage Station, shad larvae, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following Stakeholder Comments were filed today, 5/21/2014, with the Federal Energy Regulatory Commission respecting Connecticut River fish mortality investigations at Northfield Mountain Pumped Storage station (NMPS)

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA  01301

 

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, N.E.

Washington, DC  20426

Stakeholder Comments, RE: FERC P-2485-063, and P-2680-108: relevance of FirstLight Hydro Generating Company’s document submission issued by FERC as “Conference/Meeting Transcript issued in FERC P-2485-063, et al” on May 9, 2014 for Northfield Mountain Pumped Storage project (NMPS).  The inclusion of “Transcript of the April 17, 2014 FERC Scoping Meeting held in Pentwater, Michigan re Consumers Energy Company’s et al Ludington Pumped Storage Project under P-2680-108” offers an incomplete, unsubstantiated and confusing picture of its applicable connection to the relicensing of NMPS on the main stem of a four-state river system in Massachusetts.

Dear Secretary Bose,

Please consider the following comments respecting the relevance of FirstLight Hydro Generating Company’s recent document filing as it seeks a new license for the Northfield Mountain Pumped Storage station.  I testified as a Stakeholder in the NMPS Study Dispute Panel Technical Conference along with officials from the USFWS and Trout UnLimited on Tuesday, April 8, 2014.  The Dispute Panel was convened out of concerns that no study of the entrainment of eggs and larvae of migratory American shad was being required as part of a relicensing bid from GDF-Suez FirstLight Power for NMPS.  I find no clear context provided by FirstLight for the inclusion of a transcript for the April 17, 2014 FERC Scoping Meeting for the Ludington Pumped Storage Plant–a lakeside Michigan-based facility, as part of the NMPS relicensing proceedings. 

NMPS’s pumping/generating impacts are known to reach downstream to Holyoke Dam at river-mile 86 and affect spawning-run migratory fish that utilize Massachusetts, New Hampshire and Vermont habitats upstream to Bellows Falls Dam at river-mile 172.  It is critical to the relicensing of any pumped storage generation on this four-state river to have robust studies with measurable outcomes to protect the public’s interest in a balanced and functioning Connecticut River ecosystem. 

NMPS impacts migrating and spawning anadromous fish in a four-state ecosystem that has been the focus of a federal fisheries restoration program begun in 1967, “to provide the public with high quality sport fishing opportunities in a highly urbanized area, as well as provide for the long term needs of the population for seafood.”  NMPS, completed in 1972, has been shown to have direct impacts on migratory fish entrainment and fish passage from northern Massachusetts to central Vermont and New Hampshire.

The US Fish & Wildlife Service, National Marine Fisheries Service, and fisheries directors in MA, NH, VT, and CT are all charged with protecting these resources for the public.  Federal and state laws, licenses and statutes governing these mandated protections include the federal Clean Water Act, Endangered Species Act, and federal-trust fish protections beginning with the Anadromous Fish Conservation Act of 1965.  FERC authority also mandates licensee compliance and protections for the public’s fisheries resources and restoration projects.  FERC itself is mandated to comply with federal environmental law. 

The Ludington Pumped Storage Plant is a FERC licensed facility sited and operating within a single state on a lakeshore well over 100 miles from it closest bordering state—and situated with 118 miles of open water at its back.  Northfield Mountain Pumped Storage, situated adjacent to the Connecticut River, operates on the Navigable Waters of the United States in Massachusetts just 10 miles from where the Connecticut River passes out of Vermont and New Hampshire.  NMPS pumps and generates from a narrow ribbon of river that is less than 1,000 feet wide—during warm seasons can draws more water than the river’s natural output. 

In short, these are two very different animals, operating in very different habitats. 

However, there are similarities in the long-term environmental impacts of these far-flung pumped storage facilities.  They both kill large quantities of the public’s fish.  Unfortunately, those impacts were not cited or included in FirstLight’s submission to FERC in either Dispute Resolution Panel documents or its license application documents.  In 1995 the owners of the Ludinton Plant agreed to a $172 million dollar settlement for its killing o fish during the previous two decades.  The public there at least had the minor benefit of one-time study that showed LPSP “in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.” 

Unfortunately, to date, we have no such data from a study of NMPS, nor any compensation for the long-term damage to a public resource and a long-term fisheries restoration project.  In Michigan, a US-based entity was required to pay restitution and undertake remedial action.  Here at NMPS the plant operator is a transnational corporation, based outside the United States, that is “taking” an unknown quantity of a public resource without compensation or required analysis.  If a US Citizen were to do this they would be subject to legal action.  

 

Please see below: Ludington Daily News, August 13, 1987: “Federal agency rules on fish kill, Ludington hydro plant must comply within 60-90 days.” 

The Ludington plant had begun operations in 1973, and had been the subject of legal proceedings from that time forward.  The State of Michigan had filed a suit in Ingham County Circuit Court seeking more than $147 million in damages, and the National Wildlife Federation had won a federal court order that Consumers needed a pollution discharge permit for the plant. 

In summary here are several excerpts from that article defining the impacts at that time including references to a single study that found the plant killed millions of native fish in a single year, species that are today disappearing, or have essentially disappeared, in Lake Michigan waters: 

 “Environmentalists and state officials Wednesday hailed a federal ruling designed to end the fish kills at the Ludington Pumped Storage Facility operated by Consumers Power Co.”  (Co-owned with Detroit Edison Co.) 

“Finally, after 14 years of negotiations and litigation, and the destruction of millions of Lake Michigan sports fish, we’re going to see an end to this needless waste of an important resource,” said Thomas Washington, executive director of the Michigan United Conservation Clubs. 

“The MUCC, National Wildlife Federation and Department of Natural Resources have negotiated fruitlessly for years with Consumers Power to stop the fish kills.”

“The plant, in operation since 1973, pumps Lake Michigan water uphill into a reservoir, and generates electricity during times of high demand by letting it flow back to Lake Michigan through generators.  In the pumping process, it kills millions of fish.” 

“The MUCC said that a study commissioned by Consumers Power showed the plant, in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.” 

However, it took another eight years of environmental damage and drawn-out court proceedings before a settlement—totaling $172 million, was finally reached in 1995.  See: Ludington Daily News, March 7, 1995: “Local groups urged to begin working on projects for fish kill settlement plan.” 

“While 12 to 18 months more may pass before the settlement, valued at $172 million, becomes final state officials urged local groups not to wait to prepare proposals for enhancing local fishing.” 

“Many audience questions fielded by the five-person panel concerned the perception the settlement doesn’t do much for Ludington area fishing specifically—the fishing most affected by the fish kill at the plant.” 

It was only after 1995 that some of the large-scale impacts of Ludington Pumped Storage Plant began to be addressed.  Ultimately, a FERC-sanctioned 2-1/2 mile long (12,850 ft) barrier net was deployed across hundreds and hundreds of acres of riverbed and bank. 

Sadly, it seems that net did not mitigate or resolve the loss of local fisheries in the Ludington region.  Its deployment was either ineffective or far too late for a regionally- and culturally-important sustained harvest of local- sourced and eaten native yellow perch and lake trout.  Those perch have now essentially disappeared in the Ludington-Manistee region—which is noted in Stakeholder Testimony supplied for the Ludington Scoping Meeting on April 17, 2014 where Mr. Richard Underwood testified that past Michigan DNR creel surveys had found: “close to a quarter million perch” in Ludington habitats.  “In the last few years, four years, we have had a total of zero count of perch in Ludington, and that’s how it has affected.” 

The giant Ludington barrier net appears to be one key player in the puzzle of the missing perch. It appears to act as a fish trap.  According to Mr. Underwood that net, along with an artificial reef constructed nearby, attracts a giant collection of cormorants that feed on the fish trapped within the confines of the net, “There were so many birds on the reef and inside the barrier net you couldn’t count them.  I estimated there were 3,500.”  

Ironically too, in recent years, federal hatcheries in the Connecticut River basin have been producing lake trout to supplement the now-crippled and dwindling native population of lake trout on Lake Michigan. 

Another similarity in these two relicensing proceedings is that FERC’s Scoping Site Visits at both the NMPS plant and LPSP were scheduled either before the PAD had been given to Stakeholders, as it was NMPS, or—as noted in state fisheries testimony at Ludington, the Site Visits are not scheduled to take place until well after Study Requests and Stakeholder Comments are due. 

Both of these processes deprived the public and officials the ability to visit, witness, and develop an understanding of the complex impacts of these pumped storage plants before submitting testimony, comments, and informed study requests. 

Similarly, both plants have deployed barrier nets as a means of diminishing their fish kills and entrainment/mortality impacts.  And, at both sites the fishing is poor and with stocks deteriorating. 

The difference on the Connecticut River is that migratory fish here are forced to encounter two entrainment opportunities through FirstLight facilities.  The first occurs seven miles downstream, when they are deflected by attraction flows into the Turners Falls Power Canal, with Cabot Station turbines operating on the downstream end.   The small percentage of fish that manage to survive the 2-1/2-mile, 8-day (average) transit to the head of that canal—and the even smaller number that actually exit upstream(1-10%), then get the chance to be culled by NMPS turbines, just five miles further upstream.        

In its filing of the Ludington Scoping Meeting documents, GDF-Suez FirstLight seems to be suggesting some link between the large-scale wind power facilities built by LPSP owners Consumers and DTE, and a key, future role for renewables here in sucking the Connecticut River backward and pulling it uphill into the Northfield Mountain Pumped Storage reservoir. 

That connection is tenuous, at best.  Consumers and its partner DTE now own and operate a large-scale wind farm consisting of some 56 turbines.  Its deployment required the purchase or easement rights to 16,000 acres of Michigan property, most of it to trench-out underground power lines to reach back to their grid and pumped-storage plant.  Their large-scale wind operations are due to the presence of 118 miles of open Lake Michigan at their back, as well as a flat, open, prairie landscape to site giant turbines on. 

FirstLight seems to be implying that NMPS will be similarly employed at some future date—its ecosystem impacts ignored because of the huge amount of surplus, cheap, local, renewable energy available to pump a river uphill at night.  But solar doesn’t generate at night; and available local hydro here is modest and run-of-river—it would not constitute a “renewable” source to be tapped to pump water uphill.  And, wind power opportunities here are spotty, small scale, and generally available on isolated ridge tops. 

Clearly the Connecticut River Valley has none of the necessary features that might facilitate the large-scale wind renewables/pumped storage relationship found at LPSP.  Nor, has FirstLight proposed plans for any large-scale wind projects in the region.  No other entity has either.  Cape Wind, whose large scale deployment will be installed miles off the Atlantic shore, is not proposing a pumped storage plant be built above the Truro Cliffs in order for its renewable energy megawatts to be consumed.  Here, there just aren’t flatland mega-farm acres available, and only a few ridge tops here have proven suitable for siting isolated turbines.

GDF-Suez Manager John Howard stated at the Dispute Resolution Panel: “We can manage fluctuations in energy schedules with wind, solar, and imports from Canada and New York, primarily.  And then the ability to respond very quickly to energy and operating reserve needs of the power system, any time of the day or calendar year.”  He states that “We can manage…”  But there is nothing backing up the statement.  Nothing that proves there is a surplus amount of renewable energy reaching NMPS to state clearly that “We do manage…” or “We will be managing…”   The implication is that NMPS is a necessity here in order to implement renewable energy in the region.  Where is the science to back that up?  Solar is not around at night.  And the region is sub-marginal for large-scale wind, as well as lacking in opportunities for securing thousands of acres of right-of-way here. So, where is the implied connection between these two facilities—beyond fisheries destruction? 

Michigan, with its open face to the winds—which do blow at night, apparently ignores the to damage to its Great Lake ecosystem and fish, and tallies the wind-energy driving Lake Michigan waters and uphill to its pumped-storage plant as “renewable.”  We don’t have that wind here, and solar power generation is a whole different animal–not in any way the high-octane source needed to push a river uphill at NMPS.  FirstLight has built a 2 MW solar installation atop the 11 acres of land it was mandated to construct for silt-settling ponds by the EPA in 2010 after being sanctioned for massive infractions of the federal Clean Water Act by dumping up to 45,000 tons of pumped storage reservoir silt and sludge into the Connecticut River , the company has not included any information on how that solar facility connects to, and interacts with, and powers its pumped storage operations.  Unlike large-scale wind, solar does not deliver its energy at night–when NMPS asserts that it will do most of its pumping.

Pumped storage can only be deemed “renewable” energy in a generating environment where ecosystem impacts are not considered.  Pumped-storage itself was a net-loss bargain that was ill-considered even back when there was actually surplus nuclear available in the region.  Now this taking-of-a-river is mostly accomplished at NMPS by climate-warming, non-renewable fossil fuels.  This is a lose-lose situation for renewable energy use–and for an ecosystem. 

GDF-Suez FirstLight’s NMPS plant does feature “black-start” capabilities, and does offer FERC and ISO the ability to accomplish load-leveling at certain critical times.  However, these attributes must be balanced against long-standing federal and state efforts to complete a forty-seven year old migratory fisheries restoration on the Connecticut, and the public’s long-term need to have a sustainable Connecticut River ecosystem.  NMPS operations also need to adhere to federal and state environmental law.

In 1995, Consumers and DTE paid the public $172 million for their past fish kills of the previous decades.  Thus far, the public has not been compensated for the on-going taking of fish at NMPS on the Navigable Waters of the United States, nor have citizens in MA, VT, NH and CT been able to reap the benefits of anything near the stated goals of a four-state fisheries restoration program targeting recreation fishing and harvestable seafood. 

Studies with measurable results are required for a fair relicensing process.  Stated steps in the FERC relicensing process should be followed to allow the public a contextual look at the operations before the need to suggest studies or prepare testimony.  To facilitate a fair process, FERC should require context and full disclosure of all submitted documentation on the part of the applicant, as well as phone conference transcripts to allow an understanding of the ongoing dispute procedure. 

Placing a net in front of LPSP and NMPS has not stopped the fish kills at either plant.  A band-aid should not be applied to a gaping wound.  Complete and proper studies of all life stages of fish mortality are needed for NMPS relicensing.  Regulatory pumping and generating restrictions that protect the public resources of US citizens are overdue and necessary there.  The studies needed to accomplish this should take place before any new license allows this ongoing “take” to continue through 2048.     

                                                End of Formal Comments

Thank you for this opportunity to participate in improving license requirements and protecting the Connecticut River ecosystem for future generations.

Sincerely,

Karl Meyer, M.S.

« Previous PageNext Page »