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Fish Futures on a Broken River

Posted by on 04 Nov 2017 | Tagged as: 5-year FERC licensing process, American shad, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, Daily Hampshire Gazette, Dr. Boyd Kynard, Endangere Species Act, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, fish passage, Holyoke Fish Lift, National Marine Fisheries Service, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, PSP Investments, Rock Dam Pool, Rutland Herald, shad, Shortnose Stout, shortnose sturgeon, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont, Vermont Digger

Copyright © 2017 by Karl Meyer, All RIGHTS RESERVED

FISH FUTURES ON A BROKEN RIVER

(NOTE: the following appeared in The Rutland Herald, wwww.rutlandherald.com, and on the pages of Vermont Digger, www.vtdigger.org in October)

It’s been decades since migratory fish on New England’s Great River got a break–bleak since deregulation came to federally-licensed electricity plants on the Connecticut beginning in 1998.

Deregulation turned a regional market into a venture capital free-for-all, opening the door to speculators and foreign interests controlling public resources. In less than 20 years the Vernon hydro station changed hands three times. The Vermont Yankee nuclear plant next door is currently courting a third owner. Downstream the Northfield Mountain Pumped Storage Station and Turners Falls hydro complex flipped four times between investors. Further south, the Holyoke hydro station sold only once in 2002.

None of this proved healthy for an ecosystem.

The post-deregulation decade saw a steep slide in American shad passing Holyoke Dam. After two decades of averages well above 300,000 fish, yearly numbers plunged to near half that—a far cry from the 720,000 passed in 1992. Things were even more desperate at Turners Falls Dam. There, impacted by the massive water appetite and violent, peaking flows sent downstream by the Northfield Mountain Pumped Storage Station, passage dropped below 1% some years. For a decade, just 3 or 4 migrating shad in 100 were tallied emerging alive upstream. Today’s numbers languish near 1980s levels.

The federal license signed by Holyoke Gas & Electric in 2002 required they complete lift improvements at Holyoke by 2008 to pass endangered shortnose sturgeon upriver. Sturgeon were literally unable to spawn–blocked at that dam from reaching their only documented natural spawning site, a fail-safe refuge known as the Rock Dam Pool at Turners Falls. Year-in, year-out, that mandate went unenforced. It was finally met last year.

(Note: below, the flow-starved CT in Turners Falls looking downstream toward Rock Dam.CLICK, THEN CLICK AGAIN TO ENLARGE)

In 2004 federal fish biologist Dr. Boyd Kynard handed results of 15 years of Connecticut River shortnose sturgeon research to the National Marine Fisheries Service. He and colleagues had documented that that Rock Dam spawning site for the only federally-endangered migratory fish on the river was being decimated by industrial practices. Yearly gatherings failed for the few dozen spawning-ready sturgeon surviving upstream of Holyoke—as they attempted to continue a tenuous 200 million year-old genetic line. But NMFS didn’t come to their aid; no watchdog intervened.

Ultimately, decades of research by Kynard and company was compiled into Life History and Behaviour of Connecticut River Shortnose and other Sturgeons, published by the World Sturgeon Conservation Society. After experts at the Europe-based WSCS published the book in early 2012, the US Geological Service (where Kynard retired as a federal fish scientist) began making belated objections, halting all publication for a time. Their objections caused a de facto embargo of its sale in the U.S through that spring.

USGS cited editorial and style concerns in “recalling” three chapters on sturgeon biology and spawning—including the data and text showing industrial flows caused spawning failure at Turners Falls. Nearly a dozen state, federal, and university contributors to the book cried foul, citing censorship and the public’s right to government information. In June, concurrent with press inquiries and a letter from Congressman John Olver questioning the withholding of public science, USGS suddenly withdrew all its objections—days before an article highlighting the issues appeared in The Daily Hampshire Gazette. Federal agencies now had the facts. Yet despite the Endangered Species Act, none took action.

In spring of 2014 a popular beer, Shortnose Stout, debuted in the region. Its label displayed Kynard’s website and highlighted spawning conditions at Turners Falls. The Connecticut River Watershed Council soon stepped up to collect donated profits from its sale, yet those sturgeon were left hanging once more. Today conditions at Rock Dam remain as ruinous as when the first 2004 findings were released.

In 2015 the controversial chapters from Kynard’s book got entered into the public record in the current Federal Energy Regulatory Commission’s relicensing process for Northfield Mountain and Turners Falls. With that science on the record, things changed at federal proceedings. Sturgeon spawning became a key factor in flow discussions for future FERC licenses there mandating river conditions. This June, new restoration targets to meet failed 50 year-old federal Anadramous Fish Conservation Act requirements were released by the US Fish & Wildlife Service. With passage failed for half a century at Turners Falls, new shad targets mandate 397,000 fish passing annually. New owner, Canada Public Pension Investments, will be on the hook to build lifts and safeguard sturgeon spawning.

In August a fisherman near Vernon landed an endangered shortnose sturgeon–a fish thought not to exist above Turners Falls. He took a photo and released the fish, sending the picture to officials who confirmed it; then forwarded it to the National Marine Fisheries Service. There is reason to believe that landing may not be an isolated occurrence. NMFS is taking the confirmed capture seriously. Is a remnant shortnose population clinging to life in Vermont and New Hampshire waters? Did someone release them there? Either way, federal law requires owners at Vernon Dam, VT Yankee and Northfield Mountain to protect the migratory fish of the United States as a public trust. After decades of speculation, it’s high time our fish had their day.

NOTE: author Karl Meyer was the idea-creator and author of the beer brand Shortnose Stout. He neither requested or received any compensation or recognition for his work, which was solely aimed at getting important information to the public.

ONE WILDLY ILL-ADVISED RIDE

Posted by on 31 Jul 2016 | Tagged as: AMC, American Whitewater, Appalachian Mountain Club, Connecticut River Atlantic Salmon Commission, Connecticut River migratory fisheries restoration, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, CRWC, Dead Reach, Dr. Boyd Kynard, EOEEA, Executive Office of Energy and Environmental Affairs, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, Fish and Aquatics Study Team, GDF-Suez FirstLight, Jack Buckley, John Bullard, MA Division of Fish and Wildlife, NMFS, NOAA, Regional Director of the National Marine Fisheries Service, Secretary Matthew Beaton, Society of Environmental Journalists, University of Massachusetts, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, Wendi Weber

The following piece appeared in The Recorder, www.recorder.com on July 30, 2016, under the heading, “Rafting over prime sturgeon habitat unwise; State officials need to be smarter.”

Copyright © 2016 by Karl Meyer

ONE WILDLY ILL-ADVISED RIDE

A photo from May 25, 2016 posted on American Whitewater’s website shows Massachusetts’ Secretary of the Executive Office of Energy and Environmental Affairs Matthew Beaton and his staff lumbering across a small run of Connecticut River whitewater on a large raft. The short rapid they just surfed over is at a place called Rock Dam. It drops directly into a small, crescent-shaped pool–the sole natural spawning and nursery site for the federally-endangered Connecticut River shortnose sturgeon.

That Turners Falls site is the last place you’d want to see the Commonwealth’s highest environmental official rafting in May. Rock Dam is critical habitat for survival of the river’s most endangered migratory fish. There’s no other place like it in the ecosystem. It’s also where the state-endangered yellow lamp mussel was last recorded in this reach. Ecological protection is key to preserving the natural heritage there for future generations.

Why Secretary Beaton was at Rock Dam on the heels of the state’s failure to protect endangered timber rattlesnakes in their remaining habitat is a puzzlement. That site is literally where the Connecticut has long been left for dead. Each spring it is alternately starved and inundated—making spawning and survival of young for shortnose sturgeon nearly impossible. Rapid pumped storage hydro fluctuations also help make successful upstream passage for wild American shad, sea lamprey, and blueback herring a 1-in-10 proposition above Turners Falls.

The EOEEA was joyriding on “test” flows returned there specifically for environmental protection. They were meant to allow wild fish to reenter critical habitats where they might successfully gather; then spawn—in a natural pool that would subsequently nurture developing young in critical weeks lasting through mid-June. Those flows were delineated by John Bullard, Regional Director of the National Marine Fisheries Service, to not drop below minimum thresholds that would drive spawning sturgeon out. NMFS mandated the higher limits through June 3rd to ensure sturgeon had sufficient time there. That meant healing water for the most impoverished 2.7 miles of habitat on the entire 410 mile Connecticut.

The shortnose is a dinosaur-age fish—a yard-long creature with a shark-like tail and toughened leathery “scutes” instead of spindly scales. It’s the second species listed under the Massachusetts Endangered Species Act, and the most exhaustively studied endangered migratory fish in the river. It has long had a federal recovery plan, one now including the boatload of science documenting building blocks necessary for its survival. None call for boaters bashing over them during spawning gatherings, or beaching in shallows where developing embryos shelter. If this iconic fish is ever to begin the road back from the brink of extinction, mandated protections and uninterrupted flows are critical at Rock Dam.

Dr. Boyd Kynard, formerly of the US Fish & Wildlife Service, the USGS Conte Lab and UMass, led the 17 years of studies that documented Rock Dam as the species’ sole natural spawning site in the ecosystem. He recently stated, “As to protection of the pre-spawning, spawning, and rearing area at Rock Dam, exclusion dates for boating should be the same as the dates for water flow, 15 March to 15 June.”

A “watered” Rock Dam had long-offered sturgeons a wide choice of depths and flow levels they could selectively adjust, and readjust to, when natural surface flow or river temperatures fluctuated beyond optimal conditions for spawning. And that cobble and sand pool was ideal for dispersing tiny eggs and young. Only when flow is present does Rock Dam regain its function as an ancient species shelter, protecting early life stages in currents circulating through cobbled shoals.

In the current 5-year Federal Energy Regulatory Commission relicensing process that will govern hydro operations and ecological conditions here for decades, the Connecticut River Watershed Council and Appalachian Mountain Club are jointly advocating new access points into this delicate habitat for whitewater interests. Both have sat at FERC hearings where Rock Dam has been delineated as critical habitat. In joint AMC-CRWC testimony to FERC they’ve argued their interests in increased flows stem from aquatic habitat concerns, as well as recreation desires. Yet it was AMC that posted dates of those ecological study flows to their website, urging whitewater enthusiasts to exploit them: “Fish Study to Provide Paddling Opportunities: May – June 2016”

Secretary Beaton needs better advice.

Several expert appointees represent the Commonwealth on the Connecticut River Atlantic Salmon Commission. Jack Buckley, Director of MA Fisheries and Wildlife studied Connecticut River shortnose sturgeon at UMass. Mr. Buckley’s Anadromous Fish Project Leader Caleb Slater is also well versed on critical Rock Dam habitat. And the US Fish & Wildlife’s Region 5 Director Wendi Weber also sits at that CRASC table. Dr. Weber studied shortnose sturgeon in Georgia’s rivers. Ultimately, turning a failing Connecticut River migratory fisheries restoration in Massachusetts into a success story will require government leaders embracing solid government science.

Karl Meyer is on the Fish and Aquatics Study Team for FERC hydro-relicensing studies of the Turners Falls and Northfield Mountain Pumped Storage projects. He is a member of the Society of Environmental Journalists.

Shad anglers help ground-truth test flow impacts at Turners Falls

Posted by on 13 May 2015 | Tagged as: American shad, Connecticut River, Conte, endangerd shortnose sturgeon, Endangered Species Act, ESA, Federal Conte Anadromous Fish Research Center, federally-endangered shortnose sturgeon, Holyoke Fish Lift, Northfield Mountain, Rock Dam, Rock Dam Pool, shad, shad fishing, Turners Falls dam, Turners Falls power canal, US Geological Survey's Conte Fish Lab

P1000360 - CopyP1000358 - Copy
The above photos were taken at the Rock Dam Pool today, May 13, 2015. Many shad could be seen with the naked eye fidgeting and milling through the pool. Two anglers were enjoying plucking a few out of the drink. (CLICK ON PHOTO FOR LARGER IMAGE)

Shad anglers help ground-truth test flow impacts at Turners Falls

Federally mandated test flow releases from Turners Falls Dam continued today, with flows reduced to 2,500 CFS (cubic feet per second). That drop, from 4,400 CFS the day prior, produced some interesting results for shad anglers fishing the 2-1/2 mile long Dead Reach below the dam.

At 12:20 p.m. I stopped by the Connecticut River’s Rock Dam Pool, off G Street and “Migratory” Way in Turners, basically just a few hundred yards upstream of the Conte Fish Lab. Curiously, with the tamped-down flows, the Rock Dam Pool was a-bustle with milling shad—perhaps defaulted to this site when flow got cut at the dam. What’s clear is that 2,500 CFS is not a flow level that moves migratory fish upstream in the river through this site toward the TF Dam. When I spoke to three anglers at the base of the dam just 20 minutes later, they said the shad had run out with the decreasing flow.

The river levels today at the Rock Dam though, would at least likely have sustained the presence of the annual spawning gathering of federally endangered shortnose sturgeon in the Rock Dam Pool. They were many levels above the mid-summer conditions created by dam operations at this site on May 3, 2015, which basically scuttled a year’s reproduction there. But hey, who’s enforcing the Endangered Species Act these days??

I did meet a young angler at the Rock Dam who was having a blast pulling in shad. He will graduate Westfield State this coming weekend, and noted that his dad—President Elect for the American Fisheries Society, works in fisheries for the US Fish and Wildlife Service in Hadley.
He’d been tossing in shad darts at the Rock Dam Pool for maybe an hour, and had landed and released 7 shad. Big ones, he noted. I explained a bit about the test flows, and we both stood for a bit marveling at the pods of shad turning quick laps around the pool—ten, then a run of a few, then a line of several more—all darting into shadows beneath the high, mid-spring sun.

Hopefully, he’ll carry news to his dad that these fish are here because there’s flow being released to the river. A well-kept secret in these parts is that USGS Conte Lab fisheries biologists who like to get in a little fishing on lunch break always make their way down to the Rock Dam Pool when there’s flow in the Connecticut—cause that’s where the fish want to be.
You won’t find them flicking darts into the power canal just out their front gate.

When I debriefed a trio of 20-somethings fishing below Turners Falls Dam just 20 minutes later, they reported the fishing had turned to dust once the flows were tamped down to 2,500 CFS. One of the guys said that yesterday—Tuesday, all he had to do was just cast and reel in. “I probably caught a hundred.” OK, that’s fish talk, but I’ve seen these guys before. They are shad people. When I told them the Rock Dam was rocking, one said to the woman angler with them, “Wanna go down there?” “Hell yeah!” was the response.

Lastly, I drove Greenfield High Girl’s Softball down to South Hadley later in the afternoon. It’s only a mile or so hike down to South Hadley Falls Dam from there. I took the stroll. There were maybe two dozen anglers strung out along the edge of Slim Shad Point at around 4:30 p.m., but things looked fairly quiet. I didn’t have much time, but I did a little de-briefing to two hefty Latino guys I’ve seen fishing from the Veterans Memorial Bridge before. “Shad are done!” one said of the days fishing. “There’s no water.”

Interesting, since its possible this could be equated to the cut-off of nearly 4,000 CFS up at TF Dam earlier. It’s known to take 6 – 8 hours for the impacts of flow manipulations at Northfield Mountain and Turners Falls Dam to be experienced 36 miles downstream at Holyoke. Thus, these guys may have been experiencing the impacts of test flows, which temporarily quieted the upstream run of fish. Be interesting to try and tease out the correlations. Test flows at Turners will bump up again to 6,300 CFS this Saturday through Monday.

The Greenfield Varsity Girls won at South Hadley.

As of Tuesday, Holyoke had lifted 181,000 shad.

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

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

 

Unconscionable: The Fate of the “Canal Nine”

Posted by on 09 Sep 2013 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Conte, Dead Reach, Federal Energy Regulatory Commission, federal trust fish, FERC license, FirstLight, GDF-Suez FirstLight, shad, Turners Falls power canal, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey's Conte Fish Lab

Note: the following piece appeared this August in Connecticut River Valley publications including: Vermont Digger, www.vtdigger.org; the Daily Hampshire Gazette, www.gazettenet.com, The Montague Reporter and The Shelburne Falls Independent, and at The Recorder www.recorder.com, (edited version).

THE FATE OF THE CANAL NINE

Copyright © 2013, by Karl Meyer     All Rights Reserved

Forty-three years after being chosen as the upstream route for migratory fish, the Turners Falls power canal remains the black hole of fisheries restoration on the Connecticut.  In current filings the US Fish & Wildlife Service is requesting telemetry coverage across the mid-Turners Falls canal to puzzle out the unexplained fate of thousands of fish.  Trout Unlimited wants balloon-tagged shad and more monitors bracketing its powerhouse to study turbine kills and migratory delay.  The Federal Energy Regulatory Commission wants a hydraulics study of that canal, where all migrants must bypass two turbine stations, then negotiate blistering turbulence just to have a shot at spawning in Vermont and New Hampshire.  On August 14, 2013, canal/dam owners GDF-Suez FirsLight rejected those studies as unnecessary in legal filings for a new 30 – 50 year federal operating license.

While every fish attempting to spawn upstream of Turners Falls dam must enter the canal, scores of questions about their fate there remain unanswered.  Basic questions like, do shad spawn in the canal, have never been studied–even though shad spend an average of 25 days there and just one-fish-in-ten that enters emerges beyond the canal.  US Geological Survey Conte Fish Lab researchers have been paid by Northeast Utilities and FirstLight for studies to improve the fish exit from the canal for the past 15 years.  Yet forty-three years after this system was put in place, it’s still one-fish-in-ten.  And canal spawning, germane to the ecosystem restoration puzzle, has never been studied.

Even more basic to success is this: if only one fish in ten makes it through—what’s the fate of the other “canal-nine”?  But you don’t pose that question if you want to keep being paid to study the public’s fish in the company’s private canal.  You study little sections of the canal–fiddle around near the company’s preferred exits and entrances—make big claims for tiny, discreet successes.  A mountain of data is collected, yet never finalized, published; nor peer reviewed.  After 15 years of study and reengineering, it’s still one-fish-in-ten.  Other agency experts wink in this shared belief: most fish entering that canal don’t survive.  Sliced-up in downstream turbines, they flush directly into the river.

“Unconscionable” is the term Dr. Boyd Kynard uses for plans afoot to move hundreds of thousands of shad into that canal via a new lift (as opposed to tens of thousands today.)   He’s an award-winning fish passage expert who logged over 25 years as a federal fish scientist– helping found the Conte Fish Lab while with the US F&WS.  Kynard believes the ineffective ladder system in place there for decades may have actually saved hundreds of thousands of fish from death in Cabot Station turbines, “The Cabot ladder is so bad most fish never reach the canal where most will exit downstream through deadly station turbines.”

Kynard, a fish behavior specialist who studied shad passage and turbine mortality at Holyoke Dam through the 1980s, believes a new lift below Cabot Station could prove the ecosystem’s next 50-year disaster.  He witnessed massive fish kills in Holyoke’s canals in the early 1980s when, starting in 1976, a new lift passed hundreds of thousands of fish upstream to spawn for the first time in 120 years.  It was hugely successful, but no one foresaw what would happen when adults headed back to sea.  While part of the migrants rode over the dam during high flows, others reencountered the dam-and-canal-system.  Tens of thousands got sucked into turbines at Hadley Falls Station or died in the canal–unable to return safely to the river. A stench of rotting fish hung over that city while dump truck after dump truck hauled tens of thousands of dead shad from the canal to the landfill.  (That condition was eventually remediated when dam owners installed a louver system in the canal to divert down-running shad into a pipe and back to the river, thus bypassing all turbines.)

But whereas Holyoke’s lift allowed shad to first spawn upstream in the river before encountering turbines, at Turners two hundred thousand fish could find themselves in a turbine-filled canal before ever getting a chance to spawn in Vermont, New Hampshire or northern Massachusetts.  And this canal’s Frances-type turbines are far more deadly than Holyoke’s.  Stressed, those newly-lifted shad can encounter two discreet turbine sites before meeting the massive canal turbulence near the dam.

This ecosystem can’t absorb another 40-year failure in the Turners Falls canal.  The USFWS, TU, and the Connecticut River Watershed Council are backing a study–adopted from Kynard’s Holyoke work, which would use low-frequency sound to deflect shad from entering the canal.  If deployed correctly it could send migrating fish straight upriver to a lift at the dam, like the one that’s succeeded at Holyoke for decades.  It’s a simple, inexpensive study–one FirstLight is already seeking to limit to a single year, or exclude altogether.  But it’s FERC who’ll decide by September 13th.  And they have a mandate to protect the public’s fish.

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.

March 1st Deadline: Comments to FERC on Northfield/Turners Falls Hydro Relicensing

Posted by on 25 Feb 2013 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Conte, endangerd shortnose sturgeon, EPA, ESA, federal trust fish, federally-endangered shortnose sturgeon, FirstLight, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, NOAA, Northfield Mountain Pumped Storage Reservoir, Rock Dam, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab

Last Call to send comments and study recommendations to the Federal Energy Regulatory Commission to guide the Connecticut River conditions mandated in the 2018 relicensing of the Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project.  The licenses will the river ecosystem for decades to come.

To file any comments on the relicensing of the Northfield Mountain Pumped Storage Project and the Turners Falls Hydroelectric Project you will need to register at: www.ferc.gov/docs-filing/efiling.asp

You must include the following project numbers for Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project respectively, with any comments: P-2485-063, and P-1889-081.

All comments are due before MARCH 1, 2013.  Be sure to include your full mailing address, phone number, and email address in your comments. (I’ve attached my comments, which are now registered with FERC, below.)

Karl Meyer, M.S. Environmental Science

Greenfield, MA, 01301                                                             February 25, 2013

To: Federal Energy Regulatory Commission

RE: Comments on FERC Relicensing Projects: No. P- 2485-063 (Northfield Mountain Pumped Storage Project) and No. P-1889-081 (Turners Falls Hydroelectric Project)

Dear Commissioners,

Please carefully adhere to the standard FERC relicensing processes and deadlines as you relicense these two projects.  Holding public and agency site visits in early October 2012 may have been deemed convenient for circumventing winter weather that might have affected visits, however it placed invested parties in the difficult position of having to view and judge hydro operations and configurations at both facilities without the benefit of knowing what operational changes and information FirstLight Power Resources was including in its PAD.

Further, of the three FERC group tours at Northfield/Turners Falls, only one group, mine, was able to view the area of the By-Pass Reach and the Turners Falls Canal and head gates from the downstream side of the Turners Falls gate house.  This is a critical area to view, and the excuse being given was that there was construction happening on the Turners Falls Bridge.  However, unrestricted access to view these sites was available to any passing citizen just yards away via a bike and walking path, open to the public.  My group only received access because I made a direct request to FirstLight’s John Howard, who was my former boss.

The two other tour groups did not get to see the confused flows created by the 14 head gates at the upstream end of the Turners Falls Canal.  The canal has been a major disappointment as the upstream conduit for all migratory fish these last 34 years.  Those head gates are open at full bore during much of the upstream fish migration season; they should have been a key component of the tour.  Nor did interested parties get to view the exposed rock bed and de-pauperizing flow regimes created by flood gate manipulations at the Turners Falls Dam that renders the By-Pass Reach a non-river.  FERC should place particular emphasis on any studies that redirect upstream migrating fish away from the confused and failed conditions experienced in the Turners Falls Power Canal, and send them directly upstream to a lift at TF Dam.  That configuration has worked quite effectively at Holyoke Dam these last 58 years.

In late January 2013, GDF-Suez FirstLight Power Resource representatives noted at public hearings that it intends to apply to FERC with a Proposed Study Plan to begin its own investigations of flows in the reach below Turners Falls Dam this April 2013, rather than the 2014 and 2015 study seasons noted in the FERC Relicensing Process.  No study in this critical segment of river known as the By-pass Reach should be undertaken without a full vetting of the proposals.  This section of river is critical spawning habitat for the federally-endangered Connecticut River shortnose sturgeon, also listed as endangered under the Commonwealth of Massachusetts Natural Heritage and Endangered Species Act.  It is also the age-old upstream route for spawning federal-trust American shad and blueback herring.  It is noteworthy that in their expedited study application that FirstLight cites the area below Cabot Station as a key shortnose sturgeon spawning location, while the critical site for these fish—used for likely thousands of years, is the natural escarpment in the riverbed known as Rock Dam, a half mile upstream of Cabot Station.

In a letter from FERC to Mr. John Howard of FirstLight Power Resources dated March 12, 2010, the Commission noted that FirstLight had failed to comply with Article 34 of the license for the Turners Falls Project, releasing just 120 cubic feet per second to this segment of the river to protect shortnose sturgeon from the effects of low flows.  The minimum requirement is 125 CFS.

With respect to measured, in-depth, long-term investigations on flow and river regulation in this reach I would direct you to the 17 years of research done by Dr. Boyd Kynard and colleagues at the Conte Anadromous Fish Research Center adjacent to this river segment in Turners Falls, MA.  The work was largely conducted via the federal Conte Lab under the US Fish & Wildlife Service and later, under the US Geological Survey, when it took over responsibilities for Conte Lab after 1999.  These investigations were also supplemented by funds, research and personnel from the University of Massachusetts at Amherst.

This research is documented in: Life History and Behaviour of Connecticut River shortnose and other sturgeons, published in 2102 by the World Sturgeon Conservation Society and produced by Books on Demand, GmbH, Norderstedt, Germany: ISBN 978-3-8448-2801-6.  Copies can be obtained from the North American Sturgeon and Paddlefish Society:

www.nasps-sturgeon.org/#!publications  Chapter 3 concerns the long-term study of flows and river regulation on spawning success of the last 300, spawning-capable, federally endangered shortnose sturgeon in this river system—covering the period of 1993 – 2005.  This is critical, long-term research that includes seven years of findings from the time before Northfield Mountain Pumped Storage and Turners Falls Hydroelectric Project operated as a regulated utility, and the seven years when Northfield’s pumping was unconstrained by regulations and operated to profit from price spikes and drops in the energy spot market using the public’s river.  Deregulation was fully implemented here in 2000 or thereabouts.  All of these issues need careful consideration before sanctioning a rushed study plan in such a critical river reach.

When considering a new license for these facilities, careful consideration of the public’s interest should be made respecting the changes and power generation, flows, and operational practices from the commencement of the current licenses down to the present.  In 2012, Northfield Mountain Station added 40 megawatts of power to its generating facilities through retooling two of its turbines.  This increase nearly equals the total power generated at HG&E’s Holyoke Dam, the next downstream project licensed by FERC.  Two remaining turbines await power up-rates, which is a considerable addition to the generation at this plant, originally proposed and installed at 1,000 megawatts.  Currently, due to mid-license changes, it now produces 1,119 megawatts of power in an unregulated power market. noteworthy and important to be considered in weighing the public’s right to a living ecosystem, upstream fish passage, and protection of endangered species, is that Northfield Mountain’s original license was for a plant used to create “peaking power, and as a reserve unit.”  It can only produce 6-8 hours of stored power before it is spent and needs to purchase replacement power on the open market.  Its stated intention was to peak twice daily in high-demand winter and summer months, and once a day during shoulder months in spring and fall when energy demand is low.  Northfield now generates when demand is present, or—when energy prices will make the greatest profit for investors.  The river and the states have been impoverished by this profound change.

The building of Northfield was based on the availability of current and proposed power from collected regional nuclear sources (New England Power Pool) that included Maine Yankee (closed 1997); Yankee Rowe (closed 1992) Connecticut Yankee’s Haddam Neck (closed 1994), as well as two proposed nuclear plants at Montague, MA (never built.)  Vermont Yankee is currently the only “local” nuclear plant still operating, and its 40 year operating license expired March 21, 2012.  Its continued operation is contingent on findings in the courts.  It is currently operated at a loss by Entergy, and has a failing condenser system which could force its closure.  In short, Northfield is now operated well beyond the bounds of its originally stated purpose.  The public’s river is paying a high price for power, much of it now imported to pump river reserves uphill to Northfield’s reservoir from sources outside the region.  The ecological impacts to fish runs and the damaging flow regimes imperiling endangered species in the river are apparent.

As a facility with great ecological impacts that cannot produce any of its own power–one totally dependent on outside sources for power, one proposal for using this stored power source put before the Federal Power Commission in the 1960s was that Northfield not operate during the spring fish migration due to its impacts on the runs.  It is time to revisit the option of silencing the effects of Northfield Mountain so that towns and cities including Greenfield, Montague, Gill, Turners Falls, and Northfield, MA; and all the towns north to Vernon, Brattleboro and Bellows Falls, VT, and Hinsdale and Walpole, NH receive their share of the river’s ecological bounty.

Northfield does serve a function as an emergency “reserve unit” for ISO New England (Independent Systems Operator) during times of severe heat waves, or high winter demand, to deliver a high volume of power on short notice to accommodate spikes in the power grid.  Northfield could be taken off-line and kept in reserve to be operated by ISO New England solely for that purpose during the low-demand spring energy months when fish are migrating.  This would greatly benefit river ecology, species, and all upstream stakeholders.  New England’s power grid resources are currently rated at 15% above demand.  Removing the damaging effects of these operations on river ecology during critical months is a simple, equitable solution.

Northfield and Turners Falls have greatly profited by incremental power increases and operational changes over the past 34 years, while the public has watched flows, regulation, and conditions in the By-pass Reach wither to a brutal, feast-or-famine regime that denies spawning for endangered fish, and passage for upstream migrants.  This situation has effectively privatized the 2-1/2 miles of river, depriving my town, Greenfield, as well as Gill, of its share of fish and a river.  This de-pauperization has impacted all the towns upstream of Cabot Station and Turners Falls dam into central Vermont and New Hampshire.  None of these municipalities have received compensation, though in many states the loss and damage to these fish populations would be considered “take” under state statutes.  Damage in the By-Pass Reach to the Connecticut River’s last 300, spawning-capable Connecticut River shortnose sturgeon carries a significant federal fine, as well as possible imprisonment.

FirstLight’s new requests for more generation at both licensed sites should be rejected, and the damaging mid-license flow and power increases should be reversed in any new license.  Indeed, since there have now been no less than FIVE different owner/operators of this facility in the last 14 years, it would be prudent to grant only the shortest license possible in order to help track and minimize damage to the ecosystem due to operational/managerial changes, and protect the public’s interest in a living river.

Northfield’s impacts have never been fully measured with respect to flows in the By-pass Reach, but it is clear that fish passage is now at, or below, the paltry levels of the 1980s, and just a fraction of the 40 – 60% passage upstream long-targeted by the US Fish & Wildlife Service of fish that had been passed at the Holyoke Fish Lift.  Regulated, continuously monitored flows should be returned to the By-pass Reach at this time, and continuous monitoring should be included in any new licenses issued.  FirstLight has noted that in-stream data loggers for river levels and flow have been subject to vandalism.  Continuous camera monitoring of river levels and open and closed gate positions at the Turners Falls Dam would go a long way toward insuring compliance with any new license conditions.  This is an inexpensive solution that could easily include a back-up system.

With a federally endangered species present in the By-pass Reach, as well as federal-trust migrating American shad and blueback herring, FERC would do well to consider enforcing regulated flows in this stretch in accordance with law and statutes in the current license.  NOAA’s National Marine Fisheries Service has had the USGS Conte Lab findings from studies in the By-Pass reach by Kynard et al, in their possession since 2007.  This agency—as well as the MA Division of Fisheries and Wildlife, could intervene at any time.  These impacts are also affecting the success of the federal/state Connecticut River Migratory Fisheries Restoration, begun in 1967, which stipulates that all the states share equally in the bounty of migratory fish—as both a recreational and seafood resource.  In several studies by the Massachusetts Cooperative Fisheries Unit at UMass/Amherst from the 1980s it is noted that blueback herring, (Alosa aestivalis) were noted gathering at the base of Turners Falls Dam, and were also noted spawning in the mouth of the Fall River–just 300 feet downstream of the dam, by then Conte Lab Director Steve Rideout.

Further, in the late 1980s, in another mid-license power up-rate, up to 5,000 CFS was redirected out of the By-pass Reach and into the Turners Falls Power Canal for use by Cabot Station and a refurbished Unit # 1, some 1-1/2 miles upstream of Cabot.  This was undoubtedly another blow to the shortnose sturgeon attempting to spawn at their ancient grounds at the Rock Dam, though sturgeon spawning in the Connecticut here was not confirmed until 1993.

In the PAD, it is noted that FERC had not found any compliance issues during its inspections of these two projects.  However, as well as a failure to release minimum flows for sturgeon in 2009, I would direct you the US Environmental Protection Agency’s August 3, 2010 letter and Administrative Order Docket No. 10-016, sent to Mr. James Ginnetti, FirstLight Vice President, noting violations of the federal Clean Water Act.  FirstLight knowingly dumped up to 45,000 cubic square yards of silt into the Connecticut River below its fouled pumped storage plant in an attempt to clear its tunnels and intake.  This illegal enterprise was undertaken by FirstLight after failing to conduct silt removal in a manner consistent with the “due diligence” stated in its operating license.  This dumping took place throughout upstream fish migration season, May 1, 2010, or thereabouts, and continued until the EPA Cease and Desist Order of August 2010.  At that time, FERC then became involved in this egregious license violation, requesting a full report from Mr. John Howard, Plant Manager, in a FERC letter dated August 10, 2010.

In a subsequent fall meeting with agency and non-profit river interests, a FirstLight representative stated that they did not know how to remove silt from their upper reservoir, and that it had never been done successfully.  That admission came after 40 years of operating their plant.  Hence, the public, and FERC are being asked to grant a new license to operators who have not shown they can successfully maintain their facility without profoundly affecting a navigable four-state waterway and a migratory fish highway.  FirstLight has now asked for deadline relief, and is promising to have a study of siltation completed in 2014.  Perhaps all study decisions should be held in abeyance until that time, 2014—which would comply with FERC Licensing Guidelines.

 

Sincerely,

Karl Meyer

Greenfield, MA

THE RIVER FIX FOR FATAL ATTRACTION

Posted by on 12 Dec 2012 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, ecosystem, endangerd shortnose sturgeon, FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, salmon hatchery, shad, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey's Conte Fish Lab, USFWS

NOTE: The following piece, slightly edited, appeared earlier this month in Connecticut River Valley publications and outlets in CT, MA, and VT. The original version is below.

http://www.rutlandherald.com/article/20121206/OPINION04/712069975/1018/OPINION

http://www.recorder.com/home/3161519-95/falls-shad-fish-canal

Copyright © 2012, by Karl Meyer

The River Fix for Fatal Attraction

With a salmon hatchery program no longer clouding issues, the US Fish & Wildlife Service, National Marine Fisheries Service, and directors from MA, VT, NH and CT have a singular opportunity to redeem the Connecticut River restoration. They’re currently making choices for restoring migratory fish north to Bellows Falls, VT, begun under the 45 year-old New England Cooperative Fisheries Compact. The decisions stem from the 1965 Anadromous Fish Conservation Act. They’ll seal this ecosystem’s fate at four federally-licensed dams and the Northfield Mountain Pumped Storage Station until 2058.

US F&WS’s Region 5 Director Wendi Weber, John Warner, and Ken Sprankle will join National Marine Fisheries’ Daniel Morris, Julie Crocker, and MA Fish & Wildlife’s Caleb Slater in making the decisions—with input from state directors. Their 1967 mandate is restoration of shad and herring runs to offer the public “high quality sport fishing opportunities” and provide “for the long-term needs of the population for seafood.”

Sadly, in 1980 their predecessors abandoned two miles of the Connecticut to the power company operating at Turners Falls and Northfield Mountain. By allowing privatization of the river at mile 120, they killed chances of passage success for millions of American shad barred from spawning at Greenfield, Gill and Northfield, MA, right to the foot of Bellows Falls at Walpole, NH at mile 172. Unwittingly, they also continued the decimation of the ancient spawning grounds of the river’s last, 300, viable federally-endangered shortnose sturgeon.

Instead of mandating river flows and a direct route upstream to a lift at the dam, they acquiesced to diverting migrants into a power canal. That Rube Goldberg–a three-trick knot of currents and ladders, proved an utter failure to the hundreds of thousands of shad moving upstream annually through elevators at Holyoke Dam. There, via a lift built in 1955, 380,000 American shad streamed north in 1980. It’s the East Coast’s most successful fish passage; it by-passes the city’s canals.

Half or more of those shad swam upstream; but foundered in the treacherous Turners Falls complex. At the dam, just as today, some depleted their energies by treading water for weeks—washed back and forth by a power company’s deluge-and-trickle releases, finding no elevator or upstream entrance. Many eventually turned back, only to be tempted by spill from their power canal. Fish unlucky enough to ascend the ladder there found a desperate compromise. Over 90% wouldn’t exit alive. Just as today, alien habitat and extreme turbulence overwhelmed them. Only 1-in-100 emerged upstream. For the rest, a turnaround spelled almost certain death in turbines. Others lingered for weeks in an alien canal environment, until they expired. Just as today.

This year over 490,000 shad passed Holyoke. Half or more attempted to pass Turners Falls. Just 26,000, or 1-in-10, swam beyond the dam–a percentage consistently reached in the 1980s. This is described as “success” by US Geological Survey Conte Lab scientists, Dr. Alex Haro and Dr. Ted Castro-Santos, after fourteen seasons of canal study. In work garnering annual power company subsidies, they’ve attempted to model that canal is a viable migration path.

I interviewed Dr. Haro in 2007, subsequent to a 1999-2005 study finding shad passage at Turners Falls had plummeted to “one percent or less” directly on the heals of Massachusetts 1999 energy deregulation for the Northfield Mountain-Turners Falls’ complex. I asked why passage had failed there, “I wouldn’t call it failure,” Haro replied. Fish passage saw no significant rebound until 2010, when the effects of GDF-Suez’s Northfield Mountain plant were stopped cold for 6 months—sanctioned by the EPA for massive silt dumping. Likewise, Dr. Castro-Santos’s claims to passage of one-in-ten fish as progress seem deeply troubling when his findings, after 14 years, are just now revealing shad dying “in droves” in that canal, “We don’t know why.”

In 1865, James Hooper, aged 86, of Walpole, NH reported: (from The Historical Society of Cheshire County (NH) “The area just below Bellows Falls was a famous place for catching shad because they gathered there but did not go up over the falls. The fish were caught with scoop nets. One spring Hooper helped to haul out 1300 shad and 20 salmon with one pull of the net.”

Citizens upstream of the 1798 Turners Falls Dam need not accept the dead shad runs and severed ocean-ecosystem of the last 214 years at a dam operated to cull price-spikes from the electricity “spot market.” An 1872 US Supreme Court decision against owners of Holyoke Dam mandates passage of the public’s fish. Nor do citizens from Old Saybrook, CT to Bellows Falls have to accept endangered sturgeon, a lethal canal, and a dead river at mile 120. After 32 years of fatal attraction at Turners Falls, its time to stop steering fish into a canal death trap. Holyoke proves that’s possible.

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

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.