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FERC sanctions crippling flows for federally-endangered Connecticut River shortnose sturgeon

Posted by on 01 Mar 2016 | Tagged as: 5-year FERC licensing process, endangerd shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, Fish and Aquatics Study Team, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, NOAA, US Fish & Wildlife Service

The following Stakeholder Comments concerning proposed study flows that will wipe out this season’s spawning for federally-endangered Connecticut River shortnose sturgeon at their only documented natural spawning site in the river system were submitted to FERC Secretary Cheryl on Friday, February 26, 2016. They include comments submitted on Wednesday, February 24, 2016 to FERC staff, federal and state fisheries agents responsible for endangered species protection, and FirstLight–who proposed to include the crippling 1500 cfs(cubic feet per second) flows in FERC-ordered Study 3.3.19.

On Thursday, February 24, 2016, Vince E. Yearik, FERC Director of the Division of Hydropower directed FirstLight’s James Donohue that the ruinous 1500 cfs flows will be allowed at the Connecticut River shortnose sturgeon’s only documented natural spawning site in the spring of 2016.

My Stakeholder Comment letter, on the FERC official record for P-2485 and P-1889, is directly below.

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 February 26, 2016

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

RE: P-1889 and P-2485

Dear Secretary Bose,

The comments below respecting federally-endangered Connecticut River shortnose sturgeon and Study 3.3.19 were delivered via email to GDF-Suez FirstLight�s James Donohue, FERC staff including Brandon Cherry, and Caleb Slater(MA), Julie Crocker(NOAA), and John Warner(USFWS) on 2/24/2016.

Thank you,
Karl Meyer

Dear Chris et al,
I commented to you and in the FERC record on your RSP for Study 3.3.19, the Ultrasound Study in P-2485 and P-1889, to repel fish from Cabot Tailrace. Since I was somehow left off the email list in the �call for comments� that went out on 2/11/2016, I will take the opportunity to comment at this time.
In your newly-revised RSP you failed to reply to this comment of mine in particular:

�The final week should be at a minimum of 2,500 CFS�which, as FL has indicated in their response to a new Stakeholder Study suggested at the Rock Dam for shortnose sturgeon spawning: 2,500 CFS is the absolute minimum, uninterrupted flow necessary through the Bypass from April 25 � May 22, in order to not interfere with the spawning of a federally endangered species at Rock Dam. In their response, FL cited �Kynard� et al. Minimum flows to keep SNS embryos and eggs motile, watered, and viable are required there throughout the month of June.�

FirstLight has now indicated it intends to use test flows including 1500 cfs in its Ultrasound Study. This is unacceptable, as data shows this will harm a federally endangered species, the Connecticut River shortnose sturgeon. FirstLight has cited Kynard, Kieffer et al; Life History and Behaviour of the Connecticut River shortnose and other sturgeons, in their official FERC comments. Both FERC and the agencies are in possession of the scientific study data contained therein. An examination of Chapter 3 and the �Effects of hydroelectric operations on spawning� makes it quite clear that 2500 cfs is the minimum continuous flow needed to allow females to sustain a presence at the site and complete successful spawning. Flows go below that level�and 1500 cfs is far below that required threshold, will cause sturgeon spawning to fail.

A continuous flow of 2500 cfs is the only protective flow that should be allowed in the Ultrasound Study�it is also necessary throughout the month of June to protect the Early Life Stages of shortnose sturgeon. Please make the required modifications, as I�m certain the agencies and FERC will not give you license to run afoul of the federal Endangered Species Act, as well as similar state statutes.
A review of the FERC record, as well as your proposed Revisions for 3.3.19 are included below. Thanks.
Best,
Karl Meyer,
Fish and Aquatics Study Team

In 2015, FERC agreed with FirstLight and rejected requested snorkeling studies to determine the fish assemblage in the By Pass Reach out of an abundance of caution for impacts they might have on federally-endangered shortnose sturgeon whose only documented natural spawning site is the Rock Dam Pool in that reach.
Though the record clearly misstates that that snorkeling survey request was for the By Pass Reach downstream of Turners Falls Dam�written as �downstream of Cabot Station�, the protected status and determination to �do no harm� was quite clear in FERC�s reply. Excerpts from FERC Staff directly below.
From 01/22/2015, FERC Study Modifications Determination Letter

Study 3.3.11 – Fish Assemblage Assessment
�Requested Study Modifications

The U.S. Fish and Wildlife Service (Interior) proposes modifying the study to require FirstLight to conduct snorkeling surveys in the reach downstream of Cabot Station, in order to avoid all effects on shortnose sturgeon during the spawning season. The Nature Conservancy and Karl Meyer support Interior�s proposed study modification.

Comments on Requested Study Modifications

To avoid all effects on shortnose sturgeon during the April-June period in the reach downstream of Cabot Station, FirstLight states that it will rely on sampling from the project impoundment, sampling of the reach downstream of Cabot Station during other times of the year (after June 30), and existing data from a 2009 electrofishing survey of the area downstream of Cabot Station.

Discussion and Staff Recommendation

The goal of this study is to provide general information on fish species that are present in the impoundment and in the river downstream of the dam and Cabot Station. Based on the description in the modified study plan, FirstLight�s proposed method will provide information on species occurrence, species distribution, relative abundance, and habitat associations that will adequately describe the existing fish community. Because FirstLight�s proposed methods would achieve the goals of the study while avoiding effects on spawning sturgeon, we conclude that snorkeling is not necessary and the study plan filed with the ISR should be approved without modification.�

And�FirstLight�s current revised flow plan for 3.3.19:

�This study would establish a high frequency sound (ultrasound) array across the entire Cabot Station tailrace and determine the effect of the ensonified field on upstream migrating shad moving by Cabot Station. Bypass reach test flows during the study will include flows of 1,500 cfs, 2,500 cfs and 4,400 cfs. These flows will be released depending on river flow conditions. When possible, flows will alternate with the array on for one day then off for one day at 1,500 cfs, followed by one day on and one day off at 2,500 cfs, then one day on and one day off at 4,400 cfs. This sequence will be repeated throughout the study depending on river flow. The field study will include two components: a) DIDSON count of shad entering the Cabot fish ladder and b) detection of telemetered adult shad to determine their movements after they encounter the sound field.�

CASHING IN ON A CASH COW

Posted by on 15 Jan 2016 | Tagged as: American shad, climate change, Connecticut River, Connecticut River shortnose sturgeon, Daily Hampshire Gazette, endangerd shortnose sturgeon, Endangered Species Act, Energy Capital Partners, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, fossil plant, GDF-Suez FirstLight, ISO, ISO New England, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, NMFS, NOAA, non-renewable, Northfield Mountain, Northfield Mountain Pumped Storage Station, Rock Dam, shortnose sturgeon, The Greenfield Recorder, The Pioneer, The Recorder, Turners Falls dam, Uncategorized, US Fish & Wildlife Service, USFWS, Vermont

The following piece appeared in the Daily Hampshire Gazette(www.gazettenet.com) and the Recorder(www.recorder.com) in the first week of January 2016.

CASHING IN ON A CASH COW

Copyright © 2015 by Karl Meyer

Ever dreamed of owning your own bank? I got a deal for you! Northfield Mountain Pumped Storage Project is for sale again, along with the Turners Falls canal and dam—and a string of little assets down in Connecticut. But Northfield’s the cash cow. Fourth time in a decade they’re unloading this golden calf–always at a tidy chunk of change. A quickie corporate win-win! It’s really like an A.T.M., run at the expense of the Connecticut River ecosystem.

Place works like a giant toilet–suck huge amounts of the river backward and uphill, then flush it all back and—viola, money spews out the other end. Could be ours! They’re holding bidder tours as we speak. I just need a few partners with ready credit. We go in on short-money and cash-in on the no-brainer electricity “spot market” for a few years. Then, with inflated power-price futures in play, we offload this puppy for a final cash-out of 30%–maybe 50%!

Here’s how it goes down. With the cheerleading of Northfield’s not-so-silent partner, ISO New England–the “independent” system operator (created by the Federal Energy Regulatory Commission), we simply slow dance this darlin’ past the banks, the FTC and FERC. Then, in 2016, its sweet business-as-usual—maybe with new shirts for employees.

Trust me, this works every time. Everyone walks away with full pockets—without the public knowing what hit them. Northfield got wholesaled in 2006 by Northeast Generations Services(formerly WMECO—formerly of Northeast Utilities, now Eversource—you follow?) They grabbed a quick $1.34 billion for the package, slipping it to a trio of Jersey venture capitalists, Energy Capital Partners. ECP renamed their little project FirstLight Energy. Those smartest-guys-in-the-room hung-in and grabbed Northfield’s peaking spot-market profits for two years, before off-loading it for a nifty $1.89 billion in that crazy year, 2008.

With that, GDF-Suez, third owner in four years, swept in–the world’s largest private energy corporation, based in France. They’ve been gobbling up contracts to run water systems across the US under the name Suez United Water. But GDF-Suez recently did a clever name-change to Engie, keeping the public totally confused. They got game! The true costs of these premium-priced plant sales get buried in the list of acronyms on electric bills. It’s like owning a 25-mile stretch the Connecticut River to dip into for cash any time you please.

This is a turn-key operation–with us, the new guys, pushing the buttons. The joke is that the public thinks Northfield is a hydropower operation, while this baby has never produced a single watt of its own energy. It’s imported!–huge swatches of bulk electricity now run-in from outside the region to suck a mountain’s worth of flow from the Connecticut up to a reservoir. Then, dump it out on the power lines when prices peak. It’s hugely inefficient, now largely carbon-based—and massively damaging to the river. But amazingly profitable!

That’s where we come in. Sure it was built as a sister to the region’s nukes to gobble up their monstrous stream of unused electricity–because nukes can’t shut down their feverish output at night. That’s how you get to put in a giant straw and suck the Connecticut uphill at a rate of 15,000 cubic feet per second–more than enough to pull the river backward for a mile downstream under low flow conditions. But who’s watching? When the region’s last nuke shut down, nobody said ‘boo!’ with Northfield going fossil. What climate change?

And when it became clear years back that Northfield operations were imperiling spawning success for the federally-endangered shortnose sturgeon at the Rock Dam in Turners Falls–their singular natural spawning site going back into pre-history, again, nobody came forward. Not the US Fish & Wildlife Service, the National Marine Fisheries Service or the MA Division of Fish & Wildlife—or any river protection group. No bureaucrats, no suits–nobody. At Turners Falls—instead of 70% of migratory fish heading upstream toward Vermont and New Hampshire, they squeeze out 4%. We have it made!

Still skeptical? ISO and FERC are addicted to Northfield—even though its power-flush characteristics might come into play maybe a handful of times a year, if at all. For this they let owners cash in on the river whenever y they want. In 2012, the owners of this “asset” collection of 1500 megawatts(of which over 1100 MW derived from Northfield alone) told investors a full 40% of their profits were realized from “Capacity Fees.” What that means is you get paid for holding back the Connecticut! They’re not required to use it at all if they don’t want to—just flush when prices are high. Paid for being you! Of course another 50% of profit comes from generating, though the public doesn’t know it only operates a few hours a day when prices are highest.

Here’s the kicker: in 2014, after a cry-wolf energy deficit winter that never materialized, FERC–with ISO as cheerleader, sanctioned the doubling of those “capacity fees”. Plants are now collecting 2X the amount they were two years back, for having the potential to dump some power on the lines—not for actually generating. Paid for being you! With 1100 potential megawatts at Northfield, how quick can you say “windfall at the public’s expense?” Lastly, Northfield petitioned FERC the last two winters to increase its reservoir storage by a full 25%, with ISO their biggest cheerleader. FERC agreed, twice. Double-dip with a cherry, anyone?

This thing’s a cinch! Even with all the nukes shut—when this should have been moth-balled to emergency use as more climate-warming, spent nuclear junk, it soldiers on as a virtual river monopoly with the blessings of FERC and ISO. Trust me, no one goes to court. Ecosystem damage, costs to the public? Fuggetaboutit!

Got credit? Give a call!

From the Rutland Herald: Where our fish are trapped

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


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

Dear Vermont and New Hampshire:

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

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

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

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

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

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

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

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

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

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

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

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

With apologies,
Karl Meyer, Greenfield, MA

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

Greening Greenfield’s “Green Hero” for September

Posted by on 11 Sep 2015 | Tagged as: 5-year FERC licensing process, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FERC licensing process, Fish passage results, Greenfield Recorder, Greening Greenfield, Holyoke Fish Lift, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Project, Rock Dam, shortnose sturgeon, teachers, The Recorder, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS

Greening Greenfield’s “Green Hero” for September

I’ve had the honor of being selected as Greening Greenfield’s “Green Hero” for September, 2015. The award was announced in the pages of The Recorder on September 9th; the text from that piece is attached below.

Thanks to all the people of Greening Greenfield for extending me that recognition—as well as focusing on the importance of the critical artery in Western New England’s ecosystem, the Connecticut River. Greening Greenfield has been hard at work locally on issues of climate and sustainability for over a decade. Their efforts reach into all aspects of local energy, economy, and quality of life issues. They’ve made great strides in steering Greenfield toward an environmental future that will nourish coming generations. www.greeninggreenfield.org .

A special thanks from me to Susan and Dorothy.

Text of The Recorder piece follows:

A Passion for the Connecticut River

The first thing you notice about Karl Meyer is that his eyes light up when he speaks about the Connecticut River and the fish that live in it. His commitment and enthusiasm shows through in his words and in every action he takes.

In the 1970s’, Karl was interested in the river for its scenic qualities. But in the 1980’s, he visited Holyoke fishway during May spawning season and observed some of the more than a million fish moving through lifts there. One year 720,000 American Shad and 500,000 blueback herring came through the river at Holyoke. That image never left him.

Since that time, Karl has concentrated on the needs of the fish in the river, with a particular concern for American shad and the shortnose sturgeon, an endangered species. Karl believes the Connecticut’s restoration concentrated on the wrong species. The U.S. Fish and Wildlife Service put a great deal of effort into stocking the river and building fish ladders for Atlantic salmon, a fish extinct here since 1809. That emphasis diverted attention from shortnose sturgeon, shad, and blueback herring, none of which benefit very much from those Turners Falls fish ladders which diverted all migrants into the Turners Falls power canal.

In 2015, 410,000 American shad passed through Holyoke, but because they are diverted out of the river and into the power canal only 60,000, fewer than 15%, made it past Turners Falls to reach open, upstream spawning grounds. This is clearly unsustainable. Today’s US Fish & Wildlife Service passage goal is 60% passing Turners Falls. Their original 1967 target was 75%.

With fewer fish making it to food-rich, open habitats, fewer newborn fish survive. There will be fewer fish for eagles, herons and osprey, and fewer for anglers and the public to consume. Eventually 15% of very little will result in the failure of the restoration to return vibrant shad runs to three target states.

Karl has a simple solution for this problem. Require life-giving flows in the river throughout spawning and migration season. When fish aren’t diverted into a turbine-lined power canal they’ll have a much greater possibility of making it to spawning grounds in MA, VT and NH. It’s a last chance for river restoration.

The other great danger to river health is the Northfield Mountain Pumping Station. It draws on the 20 miles of river backed up behind Turners Falls Dam, pumping it uphill to a 5 billion gallon reservoir. Northfield hugely impacts river flows and migration.

“An original design proposal had Northfield closing during migration and spawning season. Implementing that today would return more natural flows to the river. It would allow fish to migrate directly upriver in natural habitat, and let sturgeon gather and spawn successfully at their ancient Rock Dam spawning site,” stated Karl.

So how do we encourage this change? Easy. Right now the Northfield and Turners Falls/Cabot Station facilities are both up for 30-year relicensing with the Federal Energy Regulatory Commission (FERC). We can all comment on the relicensing of these plants at http://www.ferc.gov/docs-filing/ecomment.asp. The FERC project number for Northfield is P-2485; Cabot Station is P-1889. Advocating that our river run free during spawning and migration season could make a huge difference in improving the health of the Connecticut.

Karl would like to see local high schools adopt the National Marine Fisheries Service’s SCUTES Program and encourage monitoring of tagged, adult shortnose sturgeon at their ONLY documented natural spawning site, The Rock Dam in Turners Falls. By developing an awareness of the numbers and needs of these endangered fish, students will build a new relationship to this river. http://www.greateratlantic.fisheries.noaa.gov/prot_res/scutes/kits.html

For his tireless work to create a healthy Connecticut River and a vibrant fish population within it, Karl Meyer is our Green Hero for the month of September.

Sucking out the river’s life

Posted by on 11 Aug 2015 | Tagged as: 5-year FERC licensing process, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, EPA, Federal Energy Regulatory Commission, FERC, FERC license, GDF-Suez FirstLight, National Marine Fisheries Service, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, Relicensing, The Recorder, Turners Falls dam, Turners Falls power canal, US Environmental Protection Agency, US Fish & Wildlife Service

The following piece appeared in The Recorder in Greenfield, MA in the first week of August.

Sucking out the river’s life

Copyright © 2015 by Karl Meyer

Whether it’s Federal Energy Regulatory Commission licensing for a sprawling gas pipeline or a cluster of power projects on the Connecticut, the public isn’t getting the accountability and voice its entitled to. That hit me after contacting Tobey Stover from the US EPA’s Region 1 Offices about GDF-Suez FirstLight’s Northfield Mountain Pumped Storage Station. I called EPA because FirstLight had just given notice they were cancelling part of an ongoing sediment-testing program to gauge the impacts of their giant Northfield station on the Connecticut’s ecosystem.

EPA mandated that long-term testing after FirstLight massively violated the Clean Water Act by “polluting the navigable waters of the United States” in August 2010. To wit: they’d dumped the equivalent of 30 – 40 truckloads of sludge directly into the river at Northfield—each day for over 90 days straight, until getting caught. In the largest case of profligate dumping in decades, miles of river bathed in over 45,000 cubic square yards of sludge—smack in the middle of fish spawning time. Continuous testing was being required, in part, for inclusion in GDF-Suez FirstLight’s application for a new FERC license to continue sucking giant gulps of river to generate secondhand electricity.

Despite what many think, Northfield is not a hydropower plant. It’s a double-energy-loss, net-cash-gain contraption. It’s an energy transfer, storage and resale operation—offering twice-generated electricity back to the grid at peak-demand, peak market prices. Northfield was conceived as a giant, nuclear-powered pump. It technically qualifies on the books as a 1,200 megawatt unit —the output of TWO Vermont Yankees, but it supplies just a sliver of peak-priced electricity to our market while creating the most ecosystem havoc. This is a power-consuming operation, run on imported juice. On its own it can’t produce a single watt of electricity—nothing clean or renewable about it.

Northfield was built to profit from pumping the river backward via cheap, excess electricity produced at night at regional nuclear plants. With the nukes closed, it continues slicing through a river’s aquatic life on a diet of climate-warming fossil fuels. To do so it must purchases giant blocks of wholesale electricity so it can spend hours slurping endless gulps of river uphill through slicing turbines. When reversed those turbines spit our river back out as expensive, twice-produced juice. Sadly, Northfield can only offer 6 – 8 hours of peak-priced energy to the electricity “spot market”—because after that its 5 billion gallon reservoir is spent, rendering it unable to light your nite light. Then they start buying up “virgin” electricity to suck the river backward again.

If those daily pulses of destruction were silenced, an ecosystem would begin to heal. Though they fancy themselves as a key component of the grid, Northfield Mountain’s own sludge so-fouled its turbines in 2010 that it was instantly, unexpectedly, shut down for half a year. Yet nobody noticed, no one went without power—not even when Vermont Yankee went off-line to refuel. Instead of customers paying the high cost of a ruined river–sold back to them less than half-alive at peak prices, they received once-produced electricity without the collateral damage.

Mr. Stover at EPA was pleasant and helpful. He confirmed the world’s largest private energy purveyor would be let off their continuous-sampling-hook–because equipment they’d purchased had experienced repeated problems. They’d further petitioned EPA, whining about difficulties supplying electricity to their samplers. Hummn… GDF-Suez offered to instead use its own consulting firm to build a model of the plant’s operations, substituting simulations for real-time federal data. EPA was leaning toward accepting that too. Really?

It appears Northfield’s massive impacts are simply too violent to be directly calculated—perhaps too costly to allow to cripple an ecosystem? Why not order GDF-Suez to buy new equipment and start over? And isn’t it time EPA did their own study of the impacts of the massive sucking and juicing of all that aquatic life—fish, plants, insect larvae, twice through the turbines, for hours on end, at upwards of 15,000 cubic feet per second? Think 15,000 bowling balls a second, for hours—first up, then back through again.

Northfield creates such crushing impacts it shouldn’t have been built. Once Vermont Yankee closed, its damages should’ve been sidelined as well—used only as back-up to provide brief, dense pulses of juice during emergencies. Yet today it continues to operate, even during spring-summer fish migration season. Its voracious water appetite plays a key role in the failure of the half-century old, four-state Connecticut River migratory fisheries restoration program, Congressionally-authorized in 1967 under the US Fish & Wildlife and National Marine Fisheries.

This corporate “self-determination” is the grim legacy of the Bush-Cheney Administration’s secret energy policies. With huge gas, hydro, and pumped storage proposals on the docket, public accountability has gone AWOL. In the Holy Grail of “corporate citizenship” industry is now its own watchdog–“self-reporting” to agencies on the impacts of its own energy production and pollution. Both concepts belong in the Oxymoron Hall of Fame. Giant companies are running the table on climate, pollution, impacts and price–as our regulatory agencies fail to act on behalf of the public’s long-term interests.

Karl Meyer of Greenfield, MA is a member of the Society of Environmental Journalists. He is participating in the FERC hydro relicensing process for power plants on the Connecticut River.

The Great Eddy at Bellows Falls

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

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

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

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

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

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

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

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

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.
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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.
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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.
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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.
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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.
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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.
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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

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