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DON’T SHORT-SELL NEW ENGLAND’S GREAT RIVER

Posted by on 17 Mar 2017 | Tagged as: Alex Haro, American Whitewater, Andrew Fisk, Bob Nasdor, Caleb Slater, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River Watershed Council, CRWC, Dr. Boyd Kynard, ecosystem, Endangered Species Act, ESA, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FERC, FERC licensing process, FirstLight, Holyoke Gas & Electric, John Warner, MA Division of Fish and Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain Pumped Storage Station, PSP Investments, public trust, Relicensing, Sean McDermott, Society of Environmental Journalists, The Nature Conservancy, Turners Falls, Turners Falls dam, US Fish & Wildlife Service, US Geological Survey

(Note: the following piece appeared in The Recorder, www.recorder.com, on March 11, 2017 under the heading: “Who will protect Connecticut River?”)

DON’T SHORT-SELL NEW ENGLAND’S GREAT RIVER

Copyright © 2017 by Karl Meyer

Canadian investors are looking to purchase the Connecticut River for a few decades, cheap and quick. Canada’s Public Sector Pension Investment Board bought up the Northfield Mountain Pumped Storage Station and Turners Falls hydro complex last year as part of PSP Investments. Their New England power play comes in the middle of the 5-year relicensing process for both facilities. That Federal Energy Regulatory Commission process will decide future conditions impacting this four-state ecosystem for decades.

The long-failed Cabot Station Fish Ladder on the Connecticut and competing flows flushing down the Turners Falls Power Canal’s Emergency Spillway. (Note:CLICK, THEN CLICK AGAIN TO ENLARGE.)

Thus, PSP may soon hold sway over what’s long been the most desolate 10-mile stretch of the entire Connecticut. It includes 2.1 miles of riverbed sitting empty for months at a time below Turners Falls Dam. It also includes the reach where, nearly 20 years back, federal fisheries expert Dr. Boyd Kynard found his boat being yanked backward—the Connecticut pulled into reverse by the suction of the Northfield Mountain Pumped Storage Station while he was drifting for bass a mile downstream near the French King Bridge. Looked at fully, it encompasses the entire reach where a 50 year federal migratory fisheries restoration program has long foundered.

On March 7th, after four years of meetings, thousands of pages of reports–and with volumes of study information incomplete and disputed, owners of these FirstLight-branded facilities are hoping select interests agree to take licensing talks underground. They’ll be fishing for backroom deals at a Boston area hotel well before this process has had a full public vetting. FL wants to take this little party private, fast. They’re asking invitees to agree to an embargo on public information about settlement talks, positions and decisions.

The key phrase in their invitation reads: “Because this meeting is intended to initiate confidential settlement discussions, it will not be open to the press or general public.” That’s FirstLight’s Director of Massachusetts Hydro Gus Bakas. His selected invitees include the National Oceanographic and Atmospheric Administration(Sean McDermott), US Fish & Wildlife Service(John Warner), US Geological Survey(Alex Haro), MA Fish & Wildlife(Caleb Slater), towns including Erving, Gill, Northfield, Montague, the Franklin Regional Council of Governments, The Nature Conservancy(Katie Kennedy), the Connecticut River Watershed Council(Andrew Fisk), and American Whitewater(Bob Nasdor).

That FirstLight stipulation is part of the quick-bait to get stakeholders thinking the time is right to cut deals. Sign-up, shut up; then we’ll talk. Cash out with what you can get for your agency, town, non-profit; or your fun-time rafting interests. Promises from this venture capitalist firm–in what’s become an ownership merry-go-round for these facilities, will surely all come true.

Ironically, many of these invitees descend directly from those who failed to step in and step up for the decimated river here decades back. They’re agencies and so-called watchdogs who failed to enforce laws and conditions negotiated when they were signatories to settlement talks for NMPS and Turners Falls nearly 40 years back–and for the 1999 FERC license negotiated for Holyoke Dam as well. At that site, Holyoke Gas & Electric just finally completed required improvements for endangered shortnose sturgeon last spring. Their license had mandated they be completed in 2008. Eight years, nine–no suits, no injunctions; no action.

Maybe that’s because the Watershed Council’s board chair works for HG & E, or because a significant number of board members are retirees from the region’s legacy power companies. Or, might it be because CRWC receives grant monies from National Marine Fisheries, US Fish & Wildlife, and MA Division of Fisheries, that these agencies were never taken to court for the withering spawning conditions and crippling flows experienced by federal trust American shad and federally endangered sturgeon in the reaches from Turners Falls to Northfield?

So who can our river look to for environmental protections under the National Environmental Policy Act, the Fish and Wildlife Coordination Act, the Endangered Species Act, and the Clean Water Act in the future?

Fourteen months remain in this relicensing. Key reports won’t be available until April, while other critical study information won’t be out until July. Some studies may need repeating. The best future for New England’s River will not be well served by quick-and-dirty agreements made in the shadows. Remember, Dear Stakeholders, it’s your names that will be forever associated with the conditions on a future Connecticut River—the river your grandchildren will be relying on. This is no time to sell the Connecticut short. What’s your price for a river’s soul?

Karl Meyer of Greenfield is on the Fish and Aquatics Study Team in the FERC relicensing for the Northfield Mountain and Turners Falls hydro facilities. He is a member of the Society of Environmental Journalists.

(Note: Bob Nasdor is former director of the Massachusetts Commission on Open Government.)

END

River Science Dead Ends….Again

Posted by on 11 Feb 2014 | Tagged as: American shad, Connecticut River, Federal Energy Regulatory Commission, FirstLight, New Hampshire, Northfield Mountain, power canal studies, shad, Turners Falls dam, Turners Falls power canal, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, US Geological Survey's Conte Fish Lab, Vermont

Copyright © 2014, by Karl Meyer 

                          River Science Dead Ends…Again

Since 1980 it’s been clear the Turners Falls power canal is a dead end for the Connecticut River’s American shad migration.  Thirteen years of federal fish research in that watery rabbit hole only serves to reinforce the point.    

A Federal Energy Regulatory Commission inquiry of US Geological Survey Conte Fish Lab researchers in Turners Falls, MA, found that it takes a radio-tagged American shad an average of eight days to swim the 2-1/2 miles from the end of the Turners Falls power canal to an area near the dam.  A person can stroll those same 2-1/2 miles along the Canal Side Rail Trail to the dam (basically the entire TF power canal) in less than 45 minutes.  So, what’s dragging these fish down?

Things are becoming clearer as information dribbles out from Conte Lab’s endless fish passage studies in the Turners Falls power canal via the FERC hydro-relicensing process on the Connecticut River.  What’s obvious is how little we know about conditions encountered by the thousands of migrating shad forced into the private canal.  Nor do we have any definitive science describing what happens to tens of thousands of shad that choose their ancient migratory route directly up the Connecticut to Turners Falls Dam.  These are fish seeking passage toward Gill, Millers Falls, and Northfield, MA; Brattleboro and Bellows Falls, VT; and Chesterfield and Walpole, NH.  That dam holds back migration-sustaining flow to feed FirstLight’s deregulated pumped-storage hydro plant inside Northfield Mountain.   

The first thing noticed from a FERC memo dated January 27, 2014, is that the 2008 – 2012 studies from the USGS fish lab are being provided “with the caveat that they contain preliminary data that is subject to revision and that the reports have not been subject to independent peer review.”  In short, this un-vetted research does not meet some basic scientific benchmarks for making long range decisions on river regulation.  And, while conducted by federal researchers, some of it is over a half decade old, while all of it’s been subsidized with power company funds.

Today just one-fish-in-ten passes upstream through that canal to the river beyond TF dam–no better than averages tallied there in the mid-1980s.  So why has hydro-company FirstLight had access to this study information over these years while the public has gone wanting?   And when do study findings from 2008, 2009 or 2010 get finalized—when do they get published and made available for peer review?  Is this public-science, or private consulting?  How much weight can FERC accord them?

Here are further tidbits from a January 30, 2014 memo released by FERC.  They’re from a follow-up phone call between FERC’s Ken Hogan and Conte Lab’s Dr. Ted Castro-Santos, a principal investigator in the Turners Falls canal studies.  “Specifically, Mr. Hogan sought information from Dr. Castro-Santos on the duration of the upstream migration of adult shad within the Turners Falls power canal.”  Though there isn’t an exact transcription for the public record, we do have this telling quote: “Dr. Castro-Santos stated that duration of the radio-tagged shad migration within the power canal from Cabot Station to the vicinity of the Gatehouse, is a median of 8-days.”

Examined carefully, the language of Dr. Castro-Santos’s reply is specifically—vague.  What it reveals is that most tagged spawning-run shad take over a week to swim less than 30 city blocks.  Some take much longer.  But on average that’s a full four days to swim the mile from The Farren Care Center to 18th Street, and another four days to fin the last 18 blocks to 1st Street–the “vicinity” of the dam.  Castro-Santos specifically describes fish as reaching “the vicinity of the Gatehouse.”   “Vicinity” in this instance, is exculpatory language.  It means shad experience further delay here, with some not proceeding upstream past TF dam.  It describes another fatal choke point in the power canal configuration–underscoring failed engineering, fish passage, and science. 

Curiously, Dr. Castro-Santos has noted at fisheries meetings that a small segment of the shad population that does manage to thread the canal maze and emerge above Turners Falls Dam to continue upstream arrives at the base of Vermont’s Vernon Dam just 1-1/2 to 2 days later.  That’s a 20 mile swim in 36-48 hours.  After 14 years of study and 34 years of excruciatingly poor fish passage through that canal towards the 50 miles of empty Connecticut River spawning habitat upstream, the only explanation for shad taking 8 days to arrive at the “vicinity” of the dam through a 2-1/2 mile-long canal is this: it’s a failure. 

 What’s dragged these fish down?—clearly an alien migration route, unasked questions and poor public science.  But electricity demand eases in spring; and FERC is asking good questions now.  Federal statutes require working fish passage and river flows that facilitate the time-sensitive spawning and migration requirements of the public’s fish.  Those requirements have clearly not been met at Turners Falls these last 34 years.  FERC releases its Study Plan Determination for new science required for hydro-relicensing on February 17th.

Note: new book on restoring East Coast migratory fish runs: Running Silver: Restoring Atlantic Rivers and Their Great Fish Migrations, by John Waldman, published by Lyons Press.  A good read, with fine, thought-provoking writing—and plenty to chew on about the Connecticut River including takes on the Turners Falls power canal migration route, river rats, and researchers.  www.LyonsPress.com

 

Comments sent to FERC Re: Northfield/TF Canal Relicensing

Posted by on 15 Jul 2013 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, New Hampshire, Rock Dam, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, US Geological Survey's Conte Fish Lab, Vermont, Vernon Dam Fishway

The following are my formal Stakeholder Comments submitted on July 15, 2013, to the Federal Energy Regulatory Commission concerning GDF-Suez FirstLight’s Updated Proposed Study Plan for gaining relicensing for the Northfield Mountain and Turners Falls/Cabot Power Canal projects.  Please excuse wide line-spacing due to document format.

                                                                                                          

July 14, 2013

 

Karl Meyer, M.S., Environmental Science
Greenfield, MA  01301

 

 

 

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
88 First Street, N.E.
Washington, DC  20426

 

Stakeholder Comments, RE: FirstLight Hydro Generating Company’s Updated Proposed Study Plan (PSP) for Northfield Mountain Pumped Storage Project, FERC Project No. 2485-063; and Turners Falls Hydroelectric Project, FERC Project No. 1889-081

 

Dear Secretary Bose,

 

 

Please consider the following comments, changes and proposed improvements to FirstLight Hydro Generating Company’s Updated Proposed Study Plan (PSP) in order to achieve the best measurable outcomes for the public’s interest in a balanced and functioning Connecticut River ecosystem as you consider new operating licenses for hydropower generation at these two projects.

 

 

Comments refer to Updated PSP #s: 2.2.1; 2.3.1; 3.2.2; 3.3.1; 3.3.2; 3.3.3; 3.3.5; 3.3.6; 3.3.7; 3.3.8; and 3.3.19.

 

Comments:

 

 

2.2.1 & 2.3.1: Proposed Changes to Project Operation

 

FL Updated Proposed Study Plan, Numbers 2.2.1 and 2.3.1: Operator is considering additional generation by adding volume, flow and velocity in, 1(p.2-15): the Turners Falls Power Canal at either Station #1 or Cabot Station, or operating Cabot Station at full capacity; and, 2(p-2-35): at the Northfield Mountain Project.  Hydraulic capacity increase at TF/Cabot sites, and at Northfield Mountain would be near 2,000 CFS respectively.

 

Any back-dated decisions in adding generation at these two licensed sites may impact the effectiveness and criteria of studies that will be implemented in the interim, and may prove confounding to the two-year study regimen.  Both would certainly impact downstream habitats and flows.  What criteria is FirstLight looking at when deciding on new generation requests—and when will they reveal their choices?

 

3.2.2: Hydraulic Study of the Turners Falls Impoundment, Bypass Reach, (“power canal”—now omitted by FL) and below Cabot Station

 

 

Note: Hydraulic study of the TF Power Canal is a key need if this is again to be considered an upstream route for migratory American shad.  After 14 years of continuous study and project improvements near the head of the Turners Falls Canal, Gate House fish passage numbers are no more improved–nor consistent, compared to numbers of fish passing Holyoke Fish Lift, than they were a quarter century ago: Holyoke Lift versus the actual percent that were able to pass up through the TF Power Canal and through the Gatehouse: (Figures from the Connecticut River Atlantic Salmon Commission Tech. Committee Meeting, Secretary’s Report: 6/18/2013)

 

Gatehouse passage success: 1989: 2.7%; 1990:7.8%; 1991:10.5%; 1992: 8.3%; 1993:3.0%

 

Gatehouse passage success: 2009: 2.4%; 2010:10.0%; 2011:6.9%; 2012:5.4%; 2013: 9.2%.

 

 

 

(p. 3-50) “FERC has requested that FirstLight develop an unsteady state HEC-RAS model in the Turners Falls Impoundment, bypass reach, power canal, and below Cabot Station to the upper limit of the Holyoke Impoundment.”

 

 

FirstLight states that a hydraulic study of the TF power canal is unnecessary, as surface (WSEL) elevations fluctuate very little.  “Given the power canal’s limited WSEL fluctuations, FirstLight does not believe a hydraulic model of the power canal is warranted.”

 

 

FERC is correct.  A full hydraulics study of the TF Canal is needed.  It is necessary as baseline information if migratory fish continue to be diverted into the power canal.  It will also be critical information if generating capacity in the TF Canal and upstream at the Northfield Project is increased by 2,000 cfs, respectively(2.2.1 & 2.3.1).  This would certainly impact hydraulics at the head gates and downstream in the power canal.

 

There are 14 head gates at the TF Gatehouse flushing directly into the TF Power Canal.  Surface level elevations have very little to say about actual flow hydraulics at this site.  Those head gate openings and the fluctuating head-levels from the TF Impoundment behind the dam create a region of extreme turbulence in the canal running some 500 feet downstream from Gatehouse.  This is one of the bottlenecks in the power canal route that has not been overcome after 43 years of study and structural changes in this upstream route.

 

 

When the agencies and the public were taken on FERC site visits, only one group in three was given a tour of this side of the TF Gatehouse.  At that time, only 4 head gates were open.  The canal appeared a relatively calm place.  When all head gates are open—as the Northfield Project and Cabot are run in peaking modes, or the TF Canal is run at baseload capacity through the day, this region is a boiling-roll of water.  Surface speeds reach nearly 10 mph (as monitored by cyclists on the canal path).  We need to know how this affects velocity and turbulence throughout the water column

 

 

Given recent fish passage increases at Holyoke Dam, it is feasible that building a facility to lift migratory fish out of the CT River and into the TF Canal below Cabot Station could divert as many as 100,000 fish into the canal over a period of a few days.  Recent work by USGS Conte Anadromous Fish Research Center showed American shad spending an average of 25 days in the power canal.  Researchers did not investigate whether this was a signature of fish mortality, spawning, or milling. Nor has the TF canal ever been investigated as spawning habitat—which would have been logical, given those lengths of stopover.  American shad notably do not do well with stress.  Piling up the population in a power canal will likely result in major migratory delays and increased mortality—which needs a full investigation if this path remains an option.

 

This should be a two-year effort, to control for differences in flow years, fish tagging and handling, and to assure that full acoustic coverage is gained through proper array deployment.

 

American shad have not been able to negotiate this region of high turbulence since this canal route was chosen for them in 1980.  At Holyoke, as well as at Vernon Dam, fish follow attraction water that leads them directly upstream to the dams.  Rates of passage at both are within the acceptable range of 40-60% that the agencies have set as targets.  When the Connecticut River above Cabot Station—aka, the Bypass Reach, was allowed to be de-watered in deference to this power canal route, shad and herring were expected to locate and negotiate a series ladders, turns, turbines, and turbulence at a half dozen canal sites in order to reach upriver spawning areas.  It’s a migratory knot; created by humans.

 

The Connecticut River migratory fisheries restoration effort risks repeating four new decades of failure if it again ignores logic.  The TF Power Canal is in need of a full hydraulic study.

 

Hydraulic modeling must be done here in order to avoid another migratory fisheries restoration disaster at Turners Falls.  Northern Massachusetts, Vermont and New Hampshire have yet to see their guaranteed shares of the targeted shad and herring runs, nor has the program achieved anything near its stated goals:  “The intent of this program is to provide the public with high quality sport fishing opportunities in a highly urbanized area as well as to provide for the long term needs of the population for food,” as stated in the New England Cooperative Fisheries Statement of Intent in 1967.

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

Please ADD to Existing Information: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu.  Chapter 3-Migrations, Effect of River Regulation documents over a decade of highly relevant studies.

 

 

FirstLight’s Water Level Recorders (River Stage)”The Water Level Recorders deployed by FL in 2010 that supplied “limited data” from the By Pass Reach and below Station 1 should be removed from “existing information” status.  WSEL monitoring in this reach needs to be redone.  Several more monitors at key sites are needed to protect resident and migratory fish, as well as the federally-endangered shortnose sturgeon, which gathers for pre-spawning in the pool immediately below the Rock Dam, and–when flows allow, chooses to spawn there.

 

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.” (Refer to chapters 1 & 3, Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

 

Need for Additional Information (3-53):  Where, exactly, did FL locate WSEL monitors in the By Pass Reach?  How do they intend to guard against “vandalism” ruining further data collections?

 

Add to information list for specific information on this reach: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society, publications, ISBN: 978-3-8448-2801-6.

 

Additional WSEL monitors needed. In order to protect pre-spawning and spawning of shortnose sturgeon in this reach of river additional WSEL monitors should also be placed at: 1. In the pool immediately below Rock Dam, 2. on the west side of the river, in the main stem channel, upstream of Rawson Island which is adjacent to, and just west of the Rock Dam.  That Rock Dam ledge continues through the island and reemerges as part of the thalweg near the river’s west bank.

 

3.3.1 Conduct Instream Flow Habitat Assessments in the Bypass Reach and below Cabot Station 

 

If migratory fish are again to be diverted into the TF Power Canal via a new lift in the river near Cabot outflows (proposed), special consideration needs to be made when considering siting the lift facility.

 

Federally-endangered shortnose sturgeon will likely enter the lift, and there exists the risk of putting them into the power canal where there is potential for turbine mortality.

 

Migratory delay: another reason for special care in considering diversion is migratory delay for American shad and blueback herring at this site.  If a lift gets built at Cabot, there will be a need for full-time monitoring personnel in order not to risk sending SNS into the canal.  Just as at Holyoke, with Atlantic salmon monitoring, the lift would then have to shut down—sometimes for weeks at a time, due to turbidity and the risk of NOT identifying a migrant salmon(or in this case, a federally endangered SNS).  This type of migratory delay would not likely be acceptable to the agencies, or FL (see FL’s added text about “without delay” under 3.3.19 : “Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding Cabot Station Tailrace.”

 

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

The IFIM Study needs to be conducted with increased WSEL monitors given FL’s stated intent to potentially increase generation and flow at the Northfield Project, Station 1, and Cabot Station.

 

Several more monitors at key sites are needed to protect resident and migratory fish, as well as the federally-endangered shortnose sturgeon, which gathers for pre-spawning in the pool immediately below the Rock Dam, and–when flows allow, chooses to spawn there.

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.” (Refer to chapters 1 & 3, Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

 

Need for Additional Information (3-53):  Where, exactly, did FL locate WSEL monitors in the By Pass Reach?  How do they intend to guard against “vandalism” ruining further data collections?

 

Information list for specific information on this reach, ADD: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society, publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

Additional WSEL monitors needed to capture fuller By Pass flows profile. In order to protect pre-spawning and spawning of shortnose sturgeon in this reach of river additional WSEL monitors should also be placed at: 1. In the pool immediately below Rock Dam, 2. on the west side of the river, in the main stem channel, upstream of Rawson Island which is adjacent to, and just west of the Rock Dam.  That Rock Dam ledge continues through the island and reemerges as part of the thalweg near the river’s west bank.

 

Table 3.3.1-1: Target Species and Life Stages Proposed for the IFIM Study Reaches.

 

Under Reach 1 & 2: blueback herring: add “spawning”—as New England Cooperative Fisheries Research Studies document BBH spawning in this reach, at the mouth of the Fall River.

 

 

Under Reach 1 & 2: shortnose sturgeon: add “pre-spawning.”

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.”

 

 

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

 

Study Goals and Objectives (18 CFR § 5.11(d)(1))

 

“The goal of this study is to identify the effects of the Turners Falls and Northfield Mountain Projects on adult shad migration. The study objectives are to:”

 

 

Add: “Determine route selection, behavior and migratory delays of upstream migrating American shad through the entire Turners Falls Power Canal.”

 

Add to “Describe the effectiveness of the gatehouse entrances;” …

 

 

ADD IN: “and describe the behavior of migratory American in the Turners Falls Power Canal within 500 feet of the gatehouse entrances.”

 

ADD IN: “Evaluate attraction for shad reaching the dam spillway under a range of spill conditions.” 

Note:  Since a lift is being considered at this site, evaluating spillway attraction is most important.

 

 

 “Evaluate attraction, entrance efficiency and internal efficiency of the spillway ladder for shad reaching the dam spillway, under a range of spill conditions;”  see immediately below.

 

Footnote 35 “This may be achieved with existing information; FirstLight is awaiting data from the USGS Conte Laboratory.”

 

 

NOTE: USGS has done 6 years (2008 – present) of study and data collection at Spillway and Gate House.  All of it remains “preliminary”—hence never finalized, or peer-reviewed.  Only “finalized” study data and findings should be included in FERC study plan design, and made available to all stakeholders for review.  All studies are partially FirstLight funded.

 

The Need for Additional Information

 

Under  Task 1: “Review existing information:”

Only finalized USGS study information should be considered.

Task 2: Develop Study Design:

As per FERC request, a radio and PIT tag study of the entire Turners Falls Power Canal should be included in this study.

 

 

Task 3: Evaluation of Route Selection and Delay

 

             Under: Radio Telemetry Tracking: Add in:

 

“Tagged fish will be tracked throughout the Turners Falls Power Canal during bothupstream and downstream migration with fixed antennae and mobile tracking; usingPIT tags in addition to radio telemetry tags.”

 

“Additional tagged individuals may need to be released farther upstream (Turners Falls power canal, * (ADD IN: “top of Cabot Station Ladder,”) upstream of Turners Falls Dam), to ensure that enough tagged individuals encounter project dams on both upstream and downstream migrations, that these individuals are exposed to a sufficient range of turbine and operational conditions to test for project effects, and to provide adequate samples sizes in order to address the objectives.”

 

Under: Video Monitoring

 

 

Video monitoring at the Spillway Ladder is insufficient.

 

Note: Video monitoring is insufficient in determining the number of fish attracted to the spillway.  It will only register fish that can FIND the Spillway Ladder Entrance.  This in confounded by a range of competing flows, water levels present in the By Pass, and spill from the dam.  A full range of telemetry tracking needs to be employed at the TF Spillway—not simply at the Spillway Ladder and SL Entrance.

 

Task 4: Evaluation of Mortality

 

Note: Preliminary USGS TF Canal studies have suggested uninvestigated data indicating mortality within the Turner Falls Power Canal.  Mortality tagged fish and data should be collected throughout the entire TF Power Canal, to correct for overall mortality.

 

 

The number of fish suggested to be fitted with mortality tags is insufficient in all these studies, and should be increased by a factor of two.

 

Table 3.3.2-1: Proposed locations and types of monitoring and telemetry equipment proposed for the upstream and downstream passage of adult shad study.

 

 

ADD in: (to identify migration routes and delays):

 

After “Cabot Ladder”, add new location: Eleventh Street Canal Bridge: PIT Tag Reader

 

Before “Rawson Island”, add new location: TF Power Canal, 400 feet downstream of Gate House.  PIT Tag Reader and Lotek SRX.

 

 

Also before “Rawson Island”, add new location: “Rock Dam Pool, immediately downstream of Rock Dam.”  Lotek SRX.

 

 

After “Turners Falls Spillway Ladder,” add: Turners Falls Spillway, Montague Dam.  Lotek SRX;  followed by a new location, add in: Turners Falls Spillway, Gill Dam.  Lotek SRX.

 

QUESTION: What is the exact location considered for “Below Turners Falls Dam” ?

 

 

3.3.3 Evaluate Downstream Passage of Juvenile American Shad

 

Task 3: Turbine Survival

 

Evaluations should be done for all turbines, with all turbines operating, at both Cabot and Station 1, to capture the broadest range of conditions at these sites.

 

 

3.3.5  Evaluate Downstream Passage of American Eel

 

Level of Effort and Cost (18 CFR § 5.11(d)(6))

 

Study ticket price is too expensive.

 

 

“The estimated cost for this study is approximately between $350,000 and $450,000.”

 

Note: Costs of this American Eel Study are prohibitive, particularly since there is no benchmark data on the ecosystem importance of eels above Mile 122, TF Dam.

 

This rivals the costs of all studies supported to assess migration and mortality of American shad, a restoration target species to Vermont and New Hampshire for 46 years.

 

 

 A significant proportion of that money could best be used to increase the scope of study: 3.3.2, and 3.3.7: Evaluate Upstream and Downstream Passage of Adult American Shad; and 3.3.7 Fish Entrainment and Turbine Passage Mortality Study.  These could then include a full study of the Turners Falls Power Canal–and increasing the number of mortality-tagged fish.

 

Cost effectively, a literature survey, and results from Holyoke Dam studies and Cabot data collection should suffice to gauge survival of American eel at Turners Falls/Cabot/Northfield.  A portion of the funding could be used to construct an eel-way at TF Dam—a relatively inexpensive structure.

 

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

 

 

Under: Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

Information as American spawning and spawning habitat is missing for the pool where shortnose sturgeon spawn, the Rock Dam Pool, immediately downstream of that notched ledge in the river.

 

Task 2: Examination of Known Spawning Areas Downstream of Turners Falls Dam

 

Note: The Turners Falls Power Canal needs to be investigated as a spawning location for American shad.  USGS studies have registered migratory shad remaining in the TF Canal for and average of 25 days.  Adult shad, which do not feed during spawning migration, must complete their salt-to-river-to salt spawning runs within 44 days in order to survive.  A critical need is to know whether these fish are spawning in the TF Power Canal, milling in the canal, or whether they have expired.

 

3.3.7 Fish Entrainment and Turbine Passage Mortality Study

 

Increase the number of mortality-tagged fish; run tests for all turbines at Station 1 and Cabot, with all turbines operating.

 

3.3.8 Computational Fluid Dynamics Modeling in the Vicinity of the Fishway Entrances and Powerhouse Forebays

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

 

Note: Three-dimensional CFD Modeling needs to extend 500 feet downstream of the Gate House in the Turner Falls Power Canal to capture the influence of the 14 head gates at the dam on migratory fish behavior and delay.

 

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

 

 

General Description of Proposed Study

 

FirstLight’s added language: “This study will be conducted in 2015 pending the results of Study No 3.3.1 and Study No. 3.3.2, which include analysis of historic fish passage data.”

 

Note: This study should be conducted for two seasons, the same time span accorded to American eel. 

 

Historic fish passage data likely has only minimal importance, as early spring freshet flows over the TF Spillway generally out-compete Cabot Station flows and send fish treading water at the base of TF dam—often for weeks.  Those freshet flows at the dam typically overwhelm any flow from the Spillway Ladder, and the shad essentially run down their engines treading water until the freshet subsides.  At that point, flows over the Spillway are allowed to be cut to 400 cfs, which sends the shad downstream to fight their way into the spill of the canal system. For this reason, historic data has limited value as the quantified presence of shad at the base of TF Dam is missing, and data on the effectiveness of Spillway attraction flow does not exist.

 

Resource Management Goals of Agencies/Tribes with Jurisdiction over Resource (18 CFR § 5.11(d)(2)) 

 

“• American shad must be able to locate and enter the passage facility with little effort and without stress.”

 

“• Where appropriate, improve upstream fish passage effectiveness through operational or structural modifications at impediments to migration.”

 

 

“• Fish that have ascended the passage facility should be guided/routed to an appropriate area so that they can continue upstream migration, and avoid being swept back downstream below the obstruction.”

 

Note: This study should not be contingent on results of other studies, and should be conducted for two seasons. 

1.    Its effectiveness at another Connecticut River bottleneck has been tested.

 

2.    It addresses the need to avoid migratory delay and failure for two key species that have topped the CT River fisheries restoration since 1967: American shad and blueback herring.

 

3.    It keeps the fish migrating in the Connecticut River.

 

4.    If it proves effective, it would simplify fish passage mechanisms and cut by millions of dollars the cost required for passing TF Dam.  A single set of lifts at the dam would pass fish, as it has at Holyoke for decades.

 

5.    It would avoid the expense and pitfalls of requiring fish to negotiate two mechanisms at Cabot Station, another out of the canal, and a final grid through Gate House. 

 

6.    It presents the opportunity to avoid the stress required of migratory fish when they are driven into the TF Power Canal, then must find their way through turbulence and fight a path through several more untried, built mechanisms.

 

7.    USGS studies have found the average passage time through the TF Canal is 25 days; whereas transit times in the actual river—from Holyoke to TF Dam, or from TF Dam to Vernon Dam, are generally accomplished in a matter of 2 – 3 days.

 

8.    This would avoid the problem of shortnose sturgeon being picked up in a lift at Cabot Station, which would be a cause for further migratory delay as lifts would have to stop to retrieve fish—and also might have to be shut for days during times of high turbidity. 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3)) 

Information from Proposed Project Changes, Flow, Hydraulics, Habitat, and Telemetry studies: 2.2.1; 2.3.1; 3.2.2; 3.3.1; 3.3.2; should be used to inform the implementation of this study. 

 

FirstLight’s added-in text:

 

“however, simply repelling shad from the Cabot tailrace is not a satisfactory result, for this behavioral barrier to be successful the fish would also have to keep going upstream, without delay, as opposed to dropping down below Cabot.”

 

Note: this caveat does not present a satisfactory argument.  In order to be proven ineffective, delays caused by sonics repelling fish from the Cabot entrance would have to out-compete any delays American shad and blueback herring encounter by being drawn to the Spillway during spring freshet and not find a readable upstream flow or passage at the dam. To this must be added the delay and stress of having river attraction and Spillway flow cut to 400 cfs, thus sending them DOWNSTREAM to fight their way into the TF Power Canal. 

Question: Should FL be deciding what constitutes delay?  Shouldn’t American shad dropping back two miles downstream from the TF Spillway to Cabot Station be considered an “unsatisfactory result”? 

 

Methodology (18 CFR § 5.11(b)(1), (d)(5)-(6))

 

Note: Ensonification coverage may need to be deployed far enough out into the main stem so as to lead fish out to the thalweg/main flows on the west side of Rawson Island.  Simply steering fish out of the Cabot entrance, but then only allowing them the choice of the minimal flows coming down through Rock Dam at the time paltry 400 cfs release would likely keep the fish milling and confused below Station # 1. 

Study Schedule (18 CFR § 5.11(b)(2) and (c))

 

FirstLight’s Added text: “ 

“If performed, the study is anticipated to conclude by mid-July 2015.”

 

Note: This should not be a contingent study. 

                                                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.

The Last, BEST Hope for the CT River: GET INVOLVED!

Posted by on 06 Nov 2012 | Tagged as: Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, USFWS

The Federal Energy Regulatory Commission re-licensing process for GFD_Suez FirstLight Power’s Northfield Mountain and Turners Falls Power Canal Projects on the CT River officially began with FirstLight’s Notice of Intent to file for two new operating licenses to use our river to make electricity for the next four decades.  Over the next four months–until the end of February 2013, officials from the US Fish & Wildlife Service, National Marine Fisheries Service, and directors of fish & wildlife programs will be meeting to decide the critical studies needed to restore and safeguard the Connecticut River through the year 2058.

FirstLight is anxious to see that the main studies guiding the “restoration” of migratory fish is based on moving migratory fish upstream through their power canal, NOT upstream through the ACTUAL Connecticut River, sitting directly adjacent to their canal.  The Power Canal route has proven a disaster, patently deadly for any river restoration.  After 32 years, and study after study, “improvements” enable ONE fish in TEN, to emerge alive, upstream of the Turners Falls Power Canal passage.  It is a death sentence for any true restoration of the river.

To learn more, tune into a broadcast of Greenfield Community Television’s LOCAL BIAS, with host Drew Hutchinson.  In the program I attempt to explain how complexity is clouding the thinking and priorities of our wildlife officials, and h0w simply requiring the Connecticut River to be allowed to flow through its own bed at critical times is the key to having a working ecosystem for the next three generations to come.

Here’s how you can tune in:

Episode (# 127) will be cablecast Wednesday 5:30pm, and Thursday and Saturday 9pm starting November 7th for two weeks. It will also be available via video on demand at gctv.org sometime next week.

The Connecticut River for the next Half-Century: a federal hydro relicensing process already leaving the public behind.

Posted by on 24 Sep 2012 | Tagged as: Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Conte, CRASC, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey

Copyright © 2012 by Karl Meyer.  All rights reserved.

The Connecticut River for the next Half-Century: a federal hydro relicensing process already leaving the public behind.

The only public site visits scheduled in the Federal Energy Regulatory Commission (FERC) relicensing process for five giant hydro-power facilities and dams operating on the Connecticut River are taking place in less than two weeks.  In Massachusetts few members of the public appear to have been apprized of the opportunity to attend federally-mandated public site tours to GDF-Suez-FirstLight’s Northfield Mountain Pumped Storage Station and their Turners Falls Dam and Canal generating facilities.  A few news items appeared in the local media about the visits, published less than 48 hours before the deadline to sign up for tours.

Thus, few members of the public registered in time to tour the complex of facilities GDF-Suez operates on a seven-mile long stretch of the Connecticut that profoundly hamper upstream migratory fish runs, and directly impact the annual spawning success of the federally endangered Shortnose sturgeon. The shortnose sturgeon’s Connecticut River spawning grounds are on a short stretch riverbed a mile below the Turners Falls Dam, adjacent to the US Geological Survey’s Silvio O. Conte Anadromous Fish Research Center.

The next chance for the public to visit and judge the impacts these facilities have on New England’s Great River may not come around again for two generations. These site visits are the critical beginnings to a six-year process that will dictate whether or not the Connecticut River is a restored and functioning ecosystem through at least the year 2058.  FERC licenses are issued to corporations for up to 40 years. The Connecticut belongs to the public, but licenses allow the leasing of a certain amount of flow to corporations to produce power, while dictating conditions that will protect the public’s interest in a restored and functioning ecosystem–including migratory and resident fish, and other riverine species and critical habitats.

Today, the Connecticut River ecosystem restoration fails profoundly at approximately river-mile 120, where most of the river’s flow and its upstream migratory fish have been shunted out of the riverbed and into the Turners Falls Power Canal.  Most migrants never emerge upstream of the punishing currents, upwellings, slicing turbines and silt-laden habitats found in the power canal.  The Connecticut River above the Northfield Mountain/Turners Falls hydro facilities has never been restored to anything resembling a functioning ecosystem.

In 1975 hearings before the Federal Power Commission (today’s FERC) that established the fish passage facilities that have failed for decades at Turners Falls, Colton Bridges, then Deputy Director of Massachusetts Fisheries and Wildlife, appeared as a member of the federal/state Connecticut River Fishery Program (established in 1967, and today known as the Connecticut River Atlantic Salmon Commission).  Bridges was asked, on the record, about the specific goals of the program:

“The program was designed to establish a run of a million American shad at the river’s mouth and extend their range to historic spawning and nursery grounds near Bellows Falls, Vermont.”

Thirty-seven years later, after Commissioners from four New England States and federally fisheries directors from what is today’s US Fish and Wildlife chose a complex series of Pacific salmon-based fish ladders and the Turners Falls Power Canal as the primary upstream route for migratory fish on the Connecticut, nothing resembling restored fish runs or an ocean-connected ecosystem exists above Turners Falls.

Simply put, those officials chose wrong—and the hangover has impacted this river for decades.

They get just one chance to do it right this time; for all of us.  But again, their silent stance seems to exclude bringing the public in on the process.  No messages or notices on state and federal public websites were posted about site tours and input.  Little or nothing on non-profit, river group sites, either. Once again it’s: “Don’t worry, we’ll take care of this.”  That’s a pretty dangerous position, considering the track record.  State and federal agencies have failed to demand operational changes that should have provided protection of federal-trust American shad, and federally endangered Shortnose sturgeon all these decades.  They have simply kept mum about their little mistake at Turners Falls back in 1975.  It has served no one well, save the power companies.

Dr. Boyd Kynard, an expert on migratory fish behavior and fish passage at large dams who helped established the federal Conte Fish Lab under the US Fish and Wildlife Service in 1990, led studies of the federally endangered Shortnose sturgeon in the Connecticut River at Turners Falls for 17 years.  It’s the fish fisheries officials don’t talk about in public.  Dr. Kynard spent over a decade compiling his work and that of nearly a dozen co-authoring scientists into a book entitled Life History and Behavior of Connecticut River Shortnose and Other Sturgeons, published by the World Sturgeon Conservation Society in Germany last February.  Intervention by the US Geological Survey delayed distribution of the book in the US for several months, and it continues to be difficult to purchase.

However, Dr. Kynard, with permission from the World Sturgeon Conservation Society, released a chapter of the book to me for citation while it was “in-press” back in August of 2011.  Since so few members of the public will get a chance to visit these sites, and since the book is currently only easily available through its chief author, Boyd Kynard, (contact Dr. Boyd Kynard at BK Riverfish, LLC, kynard@eco.umass.edu), I’m printing the abstract from the chapter on spawning and the effects of power company regulation of downstream flows at Turners Falls Dam.  The chapter’s science was done at the federal Conte Lab using funds from UMass, along with federal funding from US Fish & Wildlife Service and USGS.  Kynard’s co-author on this chapter is Micah Keiffer.  Note that the “Rock Dam” is not a conventional dam, but an ancient stone formation in the riverbed, creating a natural spawning pool that Shortnose sturgeon have used for centuries.

Abstract: “During 17 years, we studied the spring spawning migration and spawning of adult Shortnose Sturgeon Acipenser brevirostrum in the Connecticut River, Massachusetts.  Increasing day length (13.4−14.2 h), not increasing temperature (7.0–9.7°C) or river flow during 13 April–2 May likely triggered pre-and non-spawning adults to leave wintering areas and migrate.  Females initiated pre-spawning migration later than males, during lower flows and higher water temperatures, a strategy that conserved energy after wintering.  The pre-spawning migration failed one year (2002), an event probably related to reduced energetic resources of wintering fish caused by high temperatures and low flows during the previous summer foraging and wintering periods.  Pre-spawning adults homed each year to the same 1.4-kilometer-long spawning reach at Montague, Massachusetts, where river current likely determined where spawning occurred: either the Cabot Hydroelectric Station tailrace (area, 2.7 ha) or the Rock Dam, a natural mainstem fast run (area, 0.4 ha).  Spawning occurred when three spawning suitability windows were simultaneously open: (1) day length = 13.9−14.9 h (27 April–22 May), (2) mean daily water temperature = 6.5–15.9°C, and (3) mean daily river discharge = 121–901 m3s-1.  Annual spawning periods were short (3–17 d), which may be typical when only a few females are present.  Spawning periodicity was 1–5 years (mean 1.4 years) for males and 2−10 years (mean 4.5 years) for females.  Peaking operations at Cabot Station did not prevent females from spawning in the tailrace, but likely displaced and stranded early life stages.  During 14 years, spawning at Cabot Station succeeded 10 years and failed 4 years (28.6% failure); while spawning at Rock Dam succeeded 3 years and failed 11 years (78.6% failure).  Spawning failures at Rock Dam were due to river regulation.  Females spawned in a wide range of water velocities (0.2−1.3 m/s); however, the flow regimes created by river regulation and peaking operations exceeded even their broad adaptation for acceptable water velocities.”

* It should also be noted here that not a single representative from the National Marine Fisheries Service the agency federally mandated by Congress to protect the shortnose sturgeon, signed up to tour FirstLight’s power facilities.

 

A Failure to Protect

Posted by on 02 Aug 2012 | Tagged as: American shad, Bellows Falls Fishway, Connecticut River, Connecticut River ecosystem, Conservation Law Foundation, Conte, endangerd shortnose sturgeon, federally-endangered shortnose sturgeon, FERC license, FirstLight, National Marine Fisheries Service, NOAA, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey, US Geological Survey's Conte Fish Lab, USFWS

Copyright © 2012, by Karl Meyer      All Rights Reserved

The following essay appeared in July in the Vermont Digger (www.vtdigger.org); the Rutland Herald (www.rutlandherald.com), and other Valley venues.

A Failure to Protect

This Valley lost a lion of environmental defense when former Conservation Law Foundation Attorney and Antioch University Professor Alexandra Dawson of Hadley, MA died last December.  Quietly today, time grows desperately short for the ecosystem’s only federally-endangered migratory fish–the Connecticut River Shortnose sturgeon.  Alive since the dinosaurs, they arrived shortly after the glaciers left.  They are clinging to life by a thread–with perhaps 300 attempting to spawn annually in miserable conditions created in the 2-mile stretch of river below Turners Falls Dam.  NOAA’s National Marine Fisheries Service is responsible for protecting them; NMFS has known fully of those conditions since 2004.

FirstLight-GDF-Suez creates those conditions, right next to the US Fish & Wildlife’s Great Falls Discovery Center.  Yet the public is taught nothing of them.  Abandoned by federal agencies, the Shortnose is one industrial disaster or spill from extinction.  Your grandkids wouldn’t have been interested anyway…

But just in case, describe something that was a cross between a dinosaur, a catfish, and a shark.  At 3 – 4 feet long, Shortnose have bony plates instead of scales, with shark-like tails at one end, and suctioning, toothless mouths below cat-like feelers at the other.  They scarf down freshwater mussels whole; then grind them up in gizzards.  Shortnoses can live over 40 years: one alive today might’ve witnessed Richard Nixon signing the Endangered Species Act in 1973.  They had other priorities though, like survival.  But for how much longer?

Conditions most-imperiling the Shortnose are overwhelmingly the result of FirstLight-GDF-Suez’s floodgate manipulations and punishing water pulses sent to the riverbed and coursing down their two-mile long Turners Falls Power Canal via their dam, and operations at their giant 1,080 megawatt (now 1102 MW) Northfield Mountain Pumped Storage Station upstream.  Below the dam you won’t find anything like a river.  For a fish its manipulated chaos–a feast or famine flow regime run largely to maximize the day-trader profit margins of today’s deregulated energy spot-market.  And things may have just gotten worse.

FirstLight’s pumping and dam operations are the biggest disruptor to this ecosystem for a 7 mile stretch–affecting migratory fish restoration failures upstream to Bellows Falls, VT, and down to the Sound.  Instead of shad and other migrants moving up natural river habitat to the dam, they are funneled into a deathtrap: the turbine-riddled bottleneck of the Turners Falls Power Canal.  Barely one shad in ten emerges upstream alive–while crowded-in fish turning back out of that canal are diced-up in its blades.  US Conte Fish Lab researchers dubbed last year’s power canal shad passage a “success.”  FirstLight helped fund their study.  The dismal 16,000 shad they tallied mirrored “success” from 1987, a quarter century back.

And, if you are a spawning-age Shortnose wholly-dependent on spring riverbed flows resembling a natural system below that dam: you’re out of luck.  Annually, attempts at spawning fail in an ancient pool near Conte Lab.  Or, as conditions deteriorate, they default downstream to try spawning below the canal’s outflow.  Here again reproductive failure is common.  Dam-deflected surges deluge their gatherings; or flows get cut-off in minutes, causing mating-stage fish to abandon spawning.  Even when eggs get fertilized, embryos get silted-over or washed away by floodgate surges–or left to die on de-pauperized banks when flow is cut.  Most years no young are produced.  That’s extinction’s fast-track.

FirstLight’s Northfield Mountain offers tours of its 2 megawatt solar installation, but none to its reservoir and pumped-storage plant where, during fish migration in 2010, they dumped 45,000 cubic square yards of sludge directly in the river over 92 days.  This winter they quietly added 22 megawatts to those giant turbines: more than half all the power generated by HG&E’s Holyoke Dam.  This occurred despite their failure last July to have an EPA-mandated plan in place to prevent “polluting the navigable waters of the United States” with a mountain of pumped-storage silt.  Where are the public Federal Energy Regulatory Commission hearings on this license change?  Where is the Environmental Impact Assessment for endangered Shortnose sturgeon?

Northfield, dependent on nuclear power to pump its water, opened in 1970.  Its legally-stated purpose was as a “reserve” power source—to operate a few hours mornings and afternoons during peak energy use.  It can generate just 8-1/2 hours; then its reserve is depleted. Originally it was proposed they’d shut during fish migration.  Today, wildly outside its stated intent, those giant pumps are switched on like a coin-op laundry–day, night, with turnaround intervals of as little as 15 minutes.

Time is running out for the Shortnose; corporate fines for harming one start at $200,000. Our region’s electric capacity now exceeds 15% of demand.  Except for emergency power grid situations, why is this plant allowed to cripple an ecosystem?  Alexandra Dawson would surely cheer if her old Conservation Law colleagues sued National Marine Fisheries Service: for failure to protect a New England biological gem.

Environmental journalist Karl Meyer writes about the Connecticut River from Greenfield, MA and holds an MS in Environmental Science from Antioch University.