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The Connecticut River still “America’s best landscaped sewer” in Massachusetts

Posted by on 12 Oct 2021 | Tagged as: America's best landscaped sewer, Connecticut River, Connecticut River clean up, Connecticut River ecosystem, Connecticut River Refuge, Connecticut River Watershed Council, Conte National Fish & Wildlife Refuge, Death-Sewer, Delaware LLC, Federal Energy Regulatory Commission, FirstLight, FirstLight Power, ISO-NEW ENGLAND, MA Department of Energy and Environmental Affairs, net-loss power, Northfield Mountain, Northfield Mountain Pumped Storage Station, PSP Investments, source to sea, Turners Falls, US Fish & Wildlife Service, USFWS

The Connecticut River still “America’s best landscaped sewer” in Massachusetts Copyright © 2021 by Karl Meyer

Citizens standing against relicensing the river-killing Northfield Mountain Pumped Storage Station in Massachusetts on October 9, 2021. Photo Copyright © 2021 by Karl Meyer

Something is deeply wrong on the Connecticut River in Massachusetts. That something is secrecy, obfuscation, and public agencies pointedly ignoring the forest for the trees. For 49 years the Northfield Mountain Pumped Storage Station has been the number # 1 ecosystem disruptor and fish predator in the 4-state river system comprising today’s S.O. Conte Connecticut River US Fish and Wildlife Refuge.

So grim is this machine’s daily impact that it literally obliterates 100s of millions of fish and aquatic animals annually–consuming the river’s aquatic life via giant turbines that actually pull the river backward for miles and flush all that river life uphill into Northfield’s 4 billion gallon Death-Sewer each day. It’s an energy-squandering electricity resale scheme that is today netting Canadian venture capital firm PSP Investment wads of tax-sheltered cash via limited liability registration in the State of Delaware.

Thus, despite what’s been grandly touted in massive yearly hype for EXACTLY 25 INDIVIDUAL SATURDAYS since 1996, proclaiming a “cleaned-up river”–the Connecticut remains the grim, stilled, reversed and deadly, daily flush-sink it has been in Massachusetts for ALL of the NEARLY 18,000 DAYS of it’s operation since 1972.

Photo Copyright © 2021 by Karl Meyer

The grand irony of this massive ecosystem crime is that MA Department of Energy and Environmental Affairs and Holyoke-based ISO-New England whole-heartedly support the continued use of this FirstLight-branded, net-power loss, ecosystem killer in a Federal Energy Regulatory Commission relicensing scheme that will last for decades. Meanwhile the Bay State has been home to the Connecticut River Watershed Council since 1952–as well as its quarter century of cleanup hype, while the US Fish & Wildlife’s Northeast Regional Headquarters (just 25 miles from Northfield in Hadley), has done nothing to shut the giant sucking mouth of Northfield Mountain’s death trap across their River’s quarter century as a US FISH & Wildlife Refuge

So in case you were wondering why these out-standing people are situated above the deadened Connecticut River and look content and happy to be doing something about it–these are the folks making a stand for a living ecosystem for the generations to follow. They are the people who never swallowed the Kool-Aid.

Turners Falls Stand-out Returns Against River Extinction

Posted by on 08 Oct 2021 | Tagged as: Connecticut River, Federal Energy Regulatory Commission, FirstLight, FirstLight Power, fish kill, MA Division of Fish and Wildlife, Massachusetts DEP, National Marine Fisheries Service, NMFS, Northfield Mountain Pumped Storage Station, P-2485, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turners Falls, US Fish & Wildlife Service, USFWS

Turners Falls Stand-out Against River Extinction, Saturday, Oct.9, 11- noon Copyright © 2021 by Karl Meyer

Photo Copyright © 2021 by Karl Meyer

As secret relicensing talks between Canadian-owned, Delaware-registered FirstLight and federal and state environmental agencies are taking place, citizens are again returning to the Turners Falls Bridge above the Connecticut to demand an end to the ecosystem slaughter occurring daily at the Northfield Mountain Pumped Storage Project.
Photo Copyright © 2021 by Karl Meyer

On September 18 over 50 people took to the bridge demanding a halt to the annual FirstLight slaughter of 100s of millions of fish and aquatic animals.
Photo Copyright © 2021 by Karl Meyer

CONNECTICUT RIVER BLOG: DISMAL SPAWNING SEASON ON THIS UNPROTECTED RIVER IN MASSACHUSETTS

Posted by on 05 Jul 2021 | Tagged as: blueback herring, Connecticut River Atlantic Salmon Commission, Connecticut River Conservancy, Connecticut River migratory fisheries restoration, CRASC, Federal Conte Anadromous Fish Research Center, FirstLight Power, John McPhee, Landmark Supreme Court Decision 1872, National Marine Fisheries Service, NMFS, Rock Dam, shortnose sturgeon, The Dead Reach, Turners Falls power canal, Uncategorized, US Geological Survey's Conte Fish Lab, USFWS, Vermont

Connecticut River Blog: dismal spawning season on this unprotected river in Massachusetts Copyright © 2021 by Karl Meyer

*American shad run lowest since 2010
* 2021 shortnose sturgeon passage will likely be the worst at Holyoke in the half decade since it’s lifts were modified to restore the population and allow spawning in critical upstream nursery habitat.

The spillway fish lift and attraction water at Holyoke Dam, June 2, 2021. Photo Copyright © 2021 by Karl Meyer

The migratory fish run on the Connecticut River is done for the season. No one should be celebrating. At Holyoke Dam fish passage was the lowest it’s been in over a decade, with just 238,000 American shad counted passing that site. Seesawing spring flows that at first saw little April rain to fill river channels then quickly ramped up as May was ushered, creating big attraction flow for shad seeking upstream access via the Holyoke lifts.

But for 10 days, beginning April 30th, no lifts ran at Holyoke. HG&E won’t run lifts with flows above 40,000 cubic feet per second, so those shad had to hold there in the currents of a quickly cooling-down river for over a week. Then, as the flows ebbed to lift-able levels they were again left stranded and burning energy for extra days—as turbidity protocols from the National Marine Fisheries Service (NMFS) won’t allow awaiting fish runs to be helped upstream because they might miss tallying a single endangered shortnose sturgeon in the murky waters. Does this make sense–even for the sturgeon, or any of this ecosystem’s migrants?

In a time of climate heating chaos, this will only happen more often. Here’s a quick sketch of that migration dead-stop from USFWS Project Leader Ken Sprankle, who works to get regular fish passage updates out to the public: “Sierra at HFL(Holyoke Fish Lift) reported operations since the 4/30 closure did not resume until 5/10, with last weekend through 5/10 impacted by very turbid conditions that did not allow lift operations (sturgeon management factor).”

The parched riverbed in front of Holyoke Dam on June 2, 2021. The usual spring peak for shad runs occurs in late May. For 10 days in early May no lifts operated… Photo Copyright © 2021 by Karl Meyer

At first this might seem understandable—this abundance of caution while holding up thousands of other fish, except that the NMFS is doing literally NOTHING to protect and document shortnose sturgeon spawning success upstream at their critical Rock Dam site, and at a default industrial spawning site below Cabot Station’s ramping outflows. The whole purpose of fish lifts is to come into compliance with the Holyoke Company v. Lyman, landmark 1872 US Supreme Court decision, guaranteeing safe upstream and downstream passage at all dams.

So why hold up ANY fish—including shortnose sturgeon, in merely turbid early season conditions, when the purpose is to make sure all migrants can access upstream spawning habitat? To me, it’s disingenuous to implement a policy that seems more about data collection and missing a sturgeon or three—delaying and holding back runs of SNS and all other fish, when you are not doing a thing to ensure that those few endangered sturgeon have habitat and flow to successfully spawn. Are there any priorities that really put fish and protection first here?

As was noted at a June 24th meeting of the Connecticut River Atlantic Salmon Commission, US Geological Survey sturgeon biologist Micah Kieffer did virtually no work at the Rock Dam, the only documented natural spawning site for shortnose sturgeon in this river system that he helped confirm while working for decades with Dr. Boyd Kynard. Not a single bit of investigation or a gill or egg nets set to see about spawning success—just 250 yards from the Conte Lab where Kieffer works. It appears looking after sturgeon is important everywhere BUT the place where they need protection in order to successfully reproduce.

Micah Kieffer spent a good chunk of this season looking for ghost shortnose sturgeon and chasing fish stories far upstream from their critical habitat all the way to Bellows Falls–which proved as fruitful as finding the Loch Ness Monster. Last year, the emphasis was again chasing ghosting fish upriver that were never found. It has now been three seasons since I begged and badgered Micah to take a receiver down to Rock Dam, just a literal stone’s throw away from Conte Lab. After he took me up on that single visit he ultimately ended up documenting 48 SNS present at their ancient site–the largest spawning aggregation ever recorded there across decades of investigation. The fish were there several more days–that is until Canada-owned FirstLight Power cut off the flows—interfering with the spawning of a US federally endangered species.

De-watered critical sturgeon spawning and nursery habitat at Rock Dam, May 16, 2021. Photo Copyright © 2021 by Karl Meyer

There were likely no suitable conditions allowing SNS spawning and rearing at their Rock Dam nursery again this year. I documented that in my photos of their sheltering cobbles baking in the sizzling June sun. So, so much for anyone protecting endangered fish or habitat. When there is no watchdog, there is no enforcement.

One big reveal at the June CRASC Technical Committee meeting was much-touted news that shortnose sturgeon eggs were recovered below Holyoke Dam. Here’s that event, put down in USFWS’s Fish Passage Report from Ken Sprankle on June 30th: “Some important fisheries news was shared at the CRASC Tech when CTDEEP confirmed they had sampled Shortnose Sturgeon eggs in habitat immediately downstream of the Holyoke Dam. Eighty eggs were collected in a sampling bout using egg mats with genetic confirmation, the first documentation of spawning outside of the Rock Dam and Cabot Station shoal, Turners Falls.” But this was really nothing new. Some minor spawning activity has long been known to occur below that industrial site where sturgeon were blocked from accessing their upstream habitat for well over a century.

Chapter 2 in Life History and Behavior of Connecticut River Shortnose and Other Sturgeons, 2012, published by the World Sturgeon Conservation Society (a chapter authored by B. Kynard, M. Kieffer, B.E. Kynard, M. Burlingame, and P. Vinogradov) states that spawning activity has been documented, understood and accepted since the late 1990’s in the area below Holyoke Dam. This is the place where sturgeon had forever been trapped in a spawning cull de sac—more or less since the first dam there was completed in 1849. So, though it is some new data, it does nothing to protect the SNS’s critical upstream spawning site–or the broken river ecosystem at Turners Falls and well beyond.

More CRASC hubbub was created when it was noted that professional divers looking for yellow lamp mussels stumbled on several dozen young-of-the-year shortnose sturgeon and took videos of them at a major in-river construction site in Springfield. Ironic that those divers were not sturgeon researchers… The big excitement was the cute video of baby fish. But it seems the ‘discovery’ was more a celebration of a random technological happenstance than progress in safeguarding this season’s sturgeon spawning run and success.

Anglers in a motorized raft in fragile Rock Dam habitat May 25, 2021 Photo Copyright © 2021 by Karl Meyer

Here’s just one other twisted shortnose sturgeon kicker: those motivated, early-spring spawning-run shortnose sturgeon that get rejected at Holyoke’s lifts in that April-to-late May spawning window because of high flow or the dreaded “turbidity”, are denied a season’s spawning opportunity at their critical upstream Rock Dam site. But this July a new circumstance has been implemented that could help deny more up-running SNS a shot at successful spawning NEXT year!

For Connecticut River shortnose sturgeon there’s actually a bigger, seasonal early-SUMMER migration peak. It’s an upstream push for shortnose sturgeon attempting to find their way past Holyoke Dam. It occurs at the beginning of July and peaks soon thereafter. This is thought to be a “staging” migration for spawning-age fish–for sturgeon moving upriver to prepare to spawn the following year.

However, this year HG&E decided that maintenance on the fish lifts was overdue, and the federal agencies gave the okay for Holyoke Gas & Electric to shut down its lifts beginning July 1st–keeping them off-line for up to three months. Most sturgeon get lifted at Holyoke in July. Delaying those lift closures by just two weeks could have allowed a significant chunk of that critical SNS run to pass upstream. So much for ESA protections…

The average upstream count at Holyoke these last 5 years has been 58 shortnose sturgeon lifted. This year’s count stands at a paltry 11 fish. Thus, it’s pretty much guaranteed it will be a dismal year for passage upstream to critical habitats—Holyoke Company v. Lyman and all those endangered fish be damned!

There was one … tiny ray of hope noted at the June CRASC meeting. After two years of my reporting and intervening on behalf of the buckling banks, sink holes and grim discharge from the failing Connecticut River banks at Rock Dam, Ken Sprankle has been the sole fisheries person to take note. He actually proposed action. The Connecticut River Conservancy, with their water lab, refused to do testing there, and there was no action whatsoever from the Connecticut River Streambank Erosion Committee. On a river with a watchdog pressure would have been applied to force the National Marine Fisheries or MA DEP to take action on the failing riverbanks—which are the responsibility of FirstLight. Or, more to the point, a watchdog could have gone straight after the corporation. But no one to stepped up in that role. Because there is no watchdog here.

Rock Dam raft runners on May 29, 2019.

However, the USFWS’s Ken Spankle did get a study proposal put together that could potentially document the common-sense linkage of those crumbling banks to the Turners Falls power canal–just 150 feet away, as possible culprit and source of the bank failures and habitat pollution. Isn’t this ultimately a potential TF canal failure—the DIVERTED Connecticut River trying to return to its own riverbed less than 200 feet distant? This–on a protected river, would seem a slam dunk to document during a critical time when a new license for decades to come is in the offing. I raised these issues again in questions to the CRASC in their on-line meeting.

Rafters invade fragile Rawson Island at the Rock Dam site to lug their boat upstream for another tilt at Rock Dam’s tiny rapid, May 29, 2019.

Ken Sprankle needs just $131,000 to get the study done–at a time when a $100-million-plus foreign corporation is seeking to run our river here for decades. But he’s found he can’t find the money amongst and between all these federal and state agencies that would enable it to go forward.

You’d think all of CRASC member agencies would be falling all over themselves to chip in and get this critical information—especially since it was their forebears who ruined an easily restorable fish passage prospect at Turners Falls Dam in the mid-1970s. They did this by turning their backs on constructing a simple fish ladder there. That ruined prospects for a true Connecticut River migratory fisheries restoration for hundreds of thousands of American shad and blueback herring to VT, NH, and northern MA each spring for a full half century.

BTW, in the name of further explanation of the above: the predecessor and immediate precursor of CRASC, is the fed/state fisheries cooperative that—in 1969, turned what should have been an CT River fisheries restoration project into a 43 year odyssey that put the river’s long extinct salmon strain (since 1809) at the top of Connecticut River species restoration pyramid, stumbling right past the needs of American shad and blueback herring. These same two federal agencies and four states signed off on the wretched, river-emptied, three-ladder fish passage based on salmon at this Dead Reach in Turners Falls. That has left this river system broken from mile 122 all the way upstream into southern Vermont and New Hampshire.

Their decision at Turner Falls for fish passage essentially killed a true river restoration when that ladder system was completed in 1980. VT, NH and northern MA never saw a fraction of their promised runs of American shad and herring. CRASC’s current chairperson, Andy Fisk of the Connecticut River Conservancy recently described shad as “lazy” in an interview with the Springfield Republican. I think those shad–as well as John McPhee, would agree American shad deserve a better spokesperson.

Failing Connecticut River banks at Rock Dam, June 15, 2021. Photo Copyright © 2021 by Karl Meyer

I do credit Ken Sprankle, who is extremely busy, for making that pitch and getting a study plan put together. This is a Massachusetts problem—home of the broken Connecticut River, and all those present here should find it shameful. The study would take two seasons. But time is tight for it to have any merit in terms of licensing, and this is a river bureaucracy bathed in INACTION.

In a time when the Dead Reach of the Connecticut has been left half-dead and de-watered at the fragile and failing Rock Dam reach for over half a century, you might think the first priority there would be protection and letting this critical patient have a chance to finally begin to heal. Thus it seems rather ironic and no less a bit dangerous that the Connecticut River Conservancy, Appalachian Mountain Club, American Whitewater and other groups will be doing a big PR push in mid-July to bring more joyriding traffic through the fragile Rock Dam site–which has any number of legitimate critical preservation needs and designations.

A campsite and someone living on the south end of Rawson Island opposite the Rock Dam pool on July 4, 2021. Does this critical habitat merit protection, or merely a flood of new visitors… Photo Copyright © 2020 by Karl Meyer

What seems sure to absolutely create more damage and dishonor at this place are crowds jamming downstream to run the single tiny Rock Dam rapid. Many of us have witnessed the ugly traffic jams and trash sites on the Deerfield River. What will happen when crowds descend on this critical area? Does CRC have a plan to protect this habitat? Will they pay for police and search and rescue operations? Will the AMC? Or does the Town of Montague get stuck with the problem and the bill in this tiny backwater so critical to a restored ecosystem?

Perhaps the full CRASC will have something to say about this at their upcoming meeting? Oh but Andy Fisk of CRC is the CRASC’s chair, so perhaps it’s just fine. I’m sure there’s a plan. Be careful what you wish for! What I’m not certain of is whether the folks living in the little “Patch” section of Turners will be thanking CRC. Certainly the sturgeon won’t…

Connecticut River: not clean; not healthy–it’s this river refuge’s hall of shame in MA

Posted by on 17 Jun 2021 | Tagged as: Andrew Fisk, climate change, climate-heating, Connecticut River, Connecticut River Conservancy, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, CRC, Dead Reach, Delaware LLC, Dr. Boyd Kynard, ecosystem, ESA, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC, FERC license, FirstLight Power, fish passage, ISO, ISO-NEW ENGLAND, LLC, Micah Kieffer, National Marine Fisheries Service, NMFS, Northfield Mountain Pumped Storage Project, Public Sector Pension Investments, pumped storage, Rock Dam, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, Turners Falls dam, Turners Falls power canal, Uncategorized, USFWS, Vermont, water lab

Copyright © 2021 by Karl Meyer


June 15, 2021, the baking, dewatered Rock Dam cobbles at the shortnose sturgeon nursery, where early life stage sturgeon should find watery shelter. This is DEAD, critical habitat. Photo Copyright © 2021 by Karl Meyer

For a fourth season beyond the date (4/30/2018)Canada’s Public Sector Pension Investments FERC (Federal Energy Regulatory Commission) license expired to operate their FirstLight Power, river-ravaging Northfield Mountain Pumped Storage project and river-starving Turners Falls/Cabot Station power canal diversions out of the main stem river, conditions for fish and a living river ecosystem have again proven grimly dismal. Conditions last weekend in the 20 mile reach backed up for NMPS’s river-gorging behind TF dam got so ugly there was not even water to launch a boat just a half mile above the dam at the state boat launch. See Ch. 22 link below.

https://www.wwlp.com/news/local-news/franklin-county/low-water-levels-for-parts-of-connecticut-river-in-franklin-county/

Without a watchdog and a lawyer with an injunction at the ready, that’s just what you come to expect here. Insanity is witnessing the same lack of enforcement and leadership languishing, year-in, year-out, and expecting different results.


Migration season spill to the actual riverbed amounts to little more than a pan of dishwater–for fish seeking an upstream route to Vermont and New Hampshire. Photo Copyright © 2021 by Karl Meyer

The most interesting statements on the situation did not come from any of the agencies or the ngo laying claim to safeguarding this massively abused reach, but from PSP’s FirstLight Power–now re-registered out of the Bay State as a Delaware llc. Here, in their press statement they actually felt quite comfortable pointing to ISO-New England in Holyoke–the “electric grid operator,” as the responsible party for choking the life out of the Connecticut in Franklin County–right in the midst of key spring spawning when development of early life stages are critical to restoring beleaguered runs of migratory fish. READ FL statement BELOW:

“Over the weekend water levels in the area of Barton Cove were exceptionally shallow due to several overlapping conditions affecting water levels in the Turners Falls Impoundment.These factors included dispatch of our facility by the electric grid operator at the same time we were spilling water over the Turners Falls dam to meet federally required flows to support fish passage. These conditions are all within the approved and licensed operation of the facilities, however, coupled with lower than usual flows in the river, the water levels dropped to an unusually low level in this instance.”

ISO-New England and PSP/FirstLight are like corporate kissing cousins–in a grim Bermuda Triangle where the river disappears. That triangle goes from Northfield/Turners Falls through Holyoke, thence down to Delaware for tax-dollar cleaning; and then way back north to Canada for profit-taking. OOOPPS, I guess that makes it a Bermuda RECTANGLE!

Anyway, hard to reconcile those grim, pillaging river conditions with any massive requirement for huge amounts of power… It was simply a gorgeous June weekend–no giant peak power use or anything in the way of summer heatwave stuff going on. Could it be that our ecosystem was being massively thrown under the bus purely for profit taking? Or, was ISO-NE exporting our river–ravaged for its megawatts, far outside our region? Did the Connecticut get pillaged for use in the New York power grid? It’s just a scam, wrapped in a riddle, with no media scrutiny permitted.

Here, though, I must extend a prize for BS to FirstLight’s PR people who blame, in part, the fact that they “were spilling water over the Turners Falls dam to meet federally required flows to support fish passage.” Their sole and absurdly “required” offering of spill into the riverbed for migrating fish is 400 cubic feet per second in fish passage season. That’s the equivalent of a dishpan’s worth of water, when a swimming pool’s worth is the minimum required to restore a living ecosystem below the Turners Falls dam. These communications people are high paid, and they are so good when you have an uninformed public.

MEANWHILE, I visited that DEAD REACH below TF Dam on Monday. The Rock Dam, the only documented natural spawning site of the only federally-endangered migratory fish on the Connecticut in Massachusetts. For endangered shortnose sturgeon in Franklin County, just yards away from the Conte Fish Lab, and just across the river from the home of the Connecticut River Conservancy, it was just another de-watered, failing riverbanks day. Baking cobbles, blood-orange sludge drooling down failing banks and entering the Connecticut as slurry. Months back Andy Fisk of CRC–with its own in-house water lab, definitively told the media he would not sample that grim soup. I guess if you sample and find a problem, people would expect action.


June 15, 2021: here are the blood-orange, buckling Connecticut River banks sloughing directly into the Rock Dam pool. Photo Copyright © 2021 by Karl Meyer


The sludge outlet into Rock Dam. The sturgeon bakery-beach cobbles are in the background, right–that little tongue of dead water is the CT River’s “flow”. Photo Copyright © 2021 by Karl Meyer

The Rock Dam pool, as some of this river’s most critically endangered habitat, was exhaustively investigated by Conte Lab’s Dr. Boyd Kynard and his assistant Micah Kieffer, for 17 straight seasons. Yet today, in the midst of critical relicensing times, Conte Lab does not even set out a basic water-level data loggers–which would at the very least, offer annual data during the critical spawning months of April through June on flows, depth and temperature. That would at least tell you on what particular date and time. and at what water temperature the dam and headgate operators upstream inside FirstLight’s Northfield Mountain shut off the spigot at Turners Falls dam, sending their grim pumped storage surges sideways into their canal and screwing another sturgeon spawning season at this ancient nursery site for endangered fish trying to hold their place in the ecosystem.

I personally paid for and installed a data logger at Rock Dam a half decade back–though I could not have got it done without the quiet and prodigious help and expertise of a leading sturgeon biologist and investigator. The results were incontrovertible and damning. They got forwarded to the National Marine Fisheries Service, the lead agency on sturgeon protection, and USFWS. No action was ever taken.

I also intervened with FERC vs. FirstLight for dewatering Rock Dam three spawning seasons back–citing violation of the ESA in the face of the KNOWN presence of spawning sturgeon there. My argument, which did result in a FERC hearing in Washington DC, was made on the basis that FirstLight violated their license requirement to coordinate operations of their Northfield and TF facilities, which also includes adherence to the tenets of “takings” under the Endangered Species Act. FERC tossed out the my arguments on inscrutable grounds, but I at least stood up.

If I had a federal lab this season–or for ten seasons past, I would have protected that shortnose nursery just 300 yards away and right under my nose at my federal lab. That’s “Science for a Changing World.” And if I had a water testing lab at my facility, the first thing I would have done is take that water sample–just to be sure. This year, or last year–because that’s what real river protection means.

Clean water;healthy habitats in Franklin County Massachusetts? I think not. Massachusetts is where the Connecticut River ecosystem dies; and the profits fly out of the region. Special thanks to PSP Investments, your neighbor since 2016, and ISO-New England, your bulk power corporate facilitator.

OHHHHH, OOOOHHH! And please don’t forget, every time Len Greene from FirstLight, or Alicia Barton leaves you walking away from some press release somehow thinking that Northfield Mountain is producing ‘clean’, ‘carbon free’ energy?–do note that Northfield is a huge energy CONSUMER that has never produced a single watt of virgin power. In reality it is running off the massive slugs of carbon gorging/planet warming natural gas that today powers the ISO-New England Power grid. In recent days, without any heat wave in sight, their energy “mix” that is massively pulled on for NMPS’s river killing has exceeded 60% natural gas at times. There is everything deadly, and little benign, about what Northfield has done to the Connecticut these last 49 years–or what it will do in the future.

Finally, the thing to note and remember about the Connecticut River across all these decades:

WHERE THERE IS NO WATCHDOG, THERE IS NO ENFORCEMENT.

There is no watchdog protecting this river.

CONNECTICUT RIVER: maybe not left for DEAD after all

Posted by on 04 May 2021 | Tagged as: American shad, Anadromous Fish Conservation Act, Andrew Fisk, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River Watershed Council, Conte National Fish & Wildlife Refuge, CRC, Daniel McKiernan: Director MA Division of Marine Fisheries, Delaware LLC, Eversource, Federal Energy Regulatory Commission, federal trust fish, FERC, FirstLight, Julie Crocker, Kathleen Theoharides, MA Division of Fish and Wildlife, Martin Suuberg, Martin Suuberg: Commissioner MA Department of Environmental Protection, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Ron Amidon: Commissioner MA Dept. of Fish and Game, Source to Sea Cleanup, State of Delaware, The Greenfield Recorder, Traprock Center for Peace and Justice, US Fish & Wildlife Service, USFWS, Wendi Weber

CONNECTICUT RIVER: maybe not left for DEAD after all

Following the Great Earth Week Walk for River Survival to the Northfield Mountain Pumped Storage Project on April 24th, it’s been inspiring to see people publicly raising their voices to pull the grim, daily carnage of that power-hungry machine out from the shadows. One of particular insight was written by Susan Olmsted and appeared in The Recorder on April 30:
https://www.recorder.com/my-turn-olmsted-NorthfieldHydroStation-40211638 . Later, Ms. Olmsted relayed those same points into the public record of Federal Energy Regulatory Commission’s relicensing comments for the Northfield docket: FERC P-2485. Those are the routes to raising the public profile of our endlessly crippled River—its fate all but buried under confidentiality agreements and generations of inaction by the responsible agencies and so-called protectors. They all continue to lay low in a process that will decide our river’s ultimate viability for decades.


At the NMPS Intake. Photo Copyright © 2021 by James Smethurst

I again must thank the Traprock Center for Peace and Justice and Anna Gyorgy for organizing the event. Having written about this broken river for decades, and now having served on the Fish and Aquatics Study Team in this endless FERC process since 2012, it was an honor to speak up for the river with a caring and determined crowd in attendance. As I’ve noted to several people, last October I witnessed MA Energy Secretary Kathleen Theoharides and Watershed Council/Conservancy Director Andy Fisk launch a PR canoe tour for elected officials–directly upstream of the killer suction pipes of Northfield. In grim, self-serving fashion neither stepped up to the TV cameras or spoke with attendant reporters to proclaim, “This thing is our river’s greatest killer, it should be closed; this company, FirstLight, wholly re-registered these holdings out of state into Delaware as tax shelters two years back—they have no business here.” Shame on them both.

Watershed Council/CRC Director Andy Fisk, in vest, Chairs the Connecticut River Atlantic Salmon Commission 12/10/2018

BTW, we spoke at some depth on the Walk about the NU/Eversource building-of, and current massive connections to NMPS–and also the long-standing financial and Source to Sea greenwashing links between the Watershed Council/Conservancy and Eversource? Well, here’s a little late-breaking Eversource monopoly news: https://www.eenews.net/stories/1063731537

Personally, I would feel I’d failed our Great River, this ecosystem and coming generations had I never stood in front of this killer to bear witness to the truth. NMPS is a killer, and no configuration that leaves its grim sucking mouth open for ANY part of the year will retrieve it from being the most lethal machine ever deployed on the Connecticut. After so many years I am grateful that I had that opportunity–to stand up with other people and keep faith with our river–and link with those who will depend on its living waters in the future.


Revival Walk Crowd April 24, 2021 Photo Copyright © 2021 by David Keith

I don’t think a single person in attendance that day believes the snake-oil logic for continuing NMPS: that wasting massive amounts of energy to actually pull a river backward for miles–sucking 100s of millions of fish to their deaths as it wrenches its deadened water up a mountain, will ever be any kind energy “clean” or “green” solution on a heating-up planet whose ecosystems are unraveling. FirstLight’s will merely continue the laying-waste to our long-crippled river. It has nourished life here for millennia; they want to trade that in for their few hours of peak-priced energy.


MA Secretary of Energy & Environmental Affairs Kathleen Theoharides talks to the media–just yards away from Northfield’s deadly intake on a fluff PR tour on the river, October 2020. Photo Copyright © 2021 by Karl Meyer

It’s important to remember that this machine’s emplacement ran counter to one of the most significant landmark environmental decisions ever from the US Supreme Court, centered right here on the Connecticut River in 1872. In Holyoke Company v. Lyman the Court decided private operators of dams and facilities on the Connecticut—and thence, for all rivers, must provide safe upstream and downstream passage for migratory fish. Nearly 150 years later, this machine continues crushing millions of migratory fish—among them federal trust American shad, blueback herring and American eels. That killing occurs for eggs, larvae, juveniles and adult fish across the many months of their full migratory life cycles.

With the presence of a real watchdog, NMPS’s illegal presence never would have arisen here. There were decades to have sued for its shutdown. Today, neither its operation–nor FirstLight’s thin mitigation proposal to put up a partial, temporary net across its mouth annually that might spare some adult shad and eels from its suction just two months out of their killing year, even remotely passes the smell test for legal operation in a US Fish & Wildlife Refuge.

Raising public voices and flushing the buried dealings in this race-to-the-bottom FERC relicensing process is now the key to having some real impact in saving the Connecticut.

This Great River still feeds bodies and souls. It’s been struggling for well over half a century without an entity taking on the necessary mandate to “enforce” and take on the employ of a day-to-day legal team worthy of facing down predator corporations. This is an ecosystem destined to failure if citizens stay on the sidelines. But people are getting it; and standing up. Maybe this critical life-line of a river can be revived for the coming half century, to again nourish those of the future.

WORTH NOTING: Massachusetts and federal agency officials responsible for securing a living Connecticut River for your great, great, grand kids–upstream and down, through to Vermont and New Hampshire:

Kathleen Theoharides: Sec. of MA Energy & Environmental Affairs
Martin Suuberg: Commissioner MA Department of Environmental Protection
Ron Amidon: Commissioner MA Dept. of Fish & Game
Daniel McKiernan: Director MA Division of Marine Fisheries
Wendi Weber: Director Region 5, U.S. Fish & Wildlife Service
Julie Crocker: Branch Chief, Endangered Fish Recovery unit, NOAA, Gloucester MA (endangered CT River shortnose sturgeon habitat)

ENDGAME LOOMS FOR NEW ENGLAND’S GREAT RIVER

Posted by on 10 Sep 2020 | Tagged as: American shad, Anadromous Fish Conservation Act, Atlantic salmon, blueback herring, climate-destroying, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, endangerd shortnose sturgeon, Endangered Species Act, ESA, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power Resources, Fish and Aquatics Study Team, GHG, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, pumped storage, right-to-know, Rock Dam, shad, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Revelator, The Society of Environmental Journalists, Turners Falls, Turners Falls dam, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, USFWS, Vermont

Endgame Looms for England’s Great River Copyright © 2020 by Karl Meyer


The impoverished Connecticut River looking downstream to Turners Falls Dam. The run stops here. Photo Copyright © 2020 by Karl Meyer All Rights Reserved. (CLICK x 3 to enlarge)

NOTE: The following piece first appeared as an Op-Ed in The Revelator, an initiative of the Center for Biological Diversity on August 26, 2020. www.therevelator.org

FURTHER NOTE: * On September 1, 2020, after this piece first appeared, FirstLight petitioned FERC for an open-ended date to extend the filing of their Final License Applications citing a need for new test data to respond to the USF&WS. If FERC agrees, that would add another 4 months and possibly another full year, to this endless process–without any long-awaited relief for a flow starved Connecticut River. It’s time for FERC to wrap this up.

After a half-century of failures, the recovery of the Connecticut River ecosystem hangs in the balance. Will authorities finally act to save it?

Rivers should not die in the dark.

On Aug. 31 FirstLight Power Resources is expected to file its final license applications with the Federal Energy Regulatory Commission to continue operating three hydro facilities profiting off massive water diversions from the Connecticut River in Massachusetts. The conditions written into FERC licenses can last up to 50 years.

These applications signal the beginning of the final chapter in determining the future of the four-state river at the heart of the Silvio O. Conte National Fish and Wildlife Refuge, founded to protect a 7.2-million-acre watershed. Their rendering will decide the future of migratory fish, river flows and a host of embattled ecosystem conditions on New England’s longest river, some running counter to laws in place since 1872.

When decisions affecting a river for decades are being made, the public has a right to know of the stakes, the players and the key decision makers. In this case the public knows little of issues potentially affecting 2.4 million people in a sprawling watershed.

One of the failed fish ladders sending all spring migrants into the Turners Falls power canal maize. Across 45 years just 5 shad in 100 have succeeded in passing the Turners Falls Dam–leaving 50 miles of spawning habitat in 3 states largely empty. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife have been at the table in this FERC license-determining process since 2012. But three years back, all parties signed nondisclosure agreements with FirstLight — ostensibly to facilitate settlement discussions on flows, habitat, dismal fish passage and endless mortality cycles at these Massachusetts hydro sites. Those NDAs have kept these issues largely out of the media, even as initial settlement talks broke off a year and a half ago.

*Since 2012 I’ve been a FERC-recognized intervener in the relicensing process. I chose not to sign the company’s confidentiality agreement in order to preserve the right to address and highlight the critical, long-term decisions being made about the Connecticut River in a process that remains largely out of public view.

FirstLight is part of the giant Canadian investment outfit PSP Investments, which arrived in Massachusetts four years back to buy up these facilities from GDF Suez. In 2018 it quickly reregistered the facilities as limited liability tax shelters in Delaware. Regardless of their state of incorporation, the licenses they now vie for will each be subject to current federal and state environmental laws, under terms mandated by the fish agencies and FERC.

Entranceway to the “Great Falls Discovery Center” where, most days out of the year, there are literally no great falls running here at all… The sprawling rocky riverbed is an emptied bowl. Photo Copyright © 2020 by Karl Meyer.

Of more than 500 U.S. refuges, Conte is one of just three with “fish” in its name. Today hopes for the long-term protections of its fish and the river comprising its central artery rest heavily in the hands of the U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife. They have “conditioning authority” in these relicensings — mandates to protect the life in this river system. FERC, the ultimate relicensing umpire here, is also mandated to ensure compliance with environmental laws. For the fish agencies this is their one chance to redeem some far-reaching mistakes made by their predecessors.

Forty-five years ago these agencies — operating on limited information and pursuing dreams of reprising a salmon not seen on this river since 1809 — signed agreements with different owners of these facilities. That hobbled, for generations, a four-state migratory fisheries restoration for American shad and river herring and a recovery for federally endangered shortnose sturgeon. They sanctioned the daily use of the massive river-reversing pumped storage facility still chewing through generations of migratory and resident fish today. Concurrently they left two miles of the river emptied downstream, its flow diverted into a turbine-lined power canal that all migrants must negotiate in order to access the next 50 miles of open spawning habitat. Just 5 shad in 100 have ever succeeded. Perhaps worse, the river’s only documented natural spawning habitat for the endangered shortnose sturgeon was left without life-sustaining flow.

A Tale of Two Salmon, a River Without Fish

The last wild salmon run on the Connecticut River was recorded in 1809.

Science later revealed the salmons’ end was likely a combination of warming temperatures following the unusually cold period known as the Little Ice Age coupled with modern dam building.

For 165 years there were no salmon. Then, in 1974, a single fish arrived at Holyoke Dam. Far from being a native of the Connecticut River, this was a new hybrid — a returning fish produced at one of several federal hatcheries completed five years prior. This salmon’s genes, like the genes of all the fish that would return in subsequent years, were cobbled together using salmon from several still-surviving runs in northern New England.

This past June 30 marked a different milestone on the river. It ended the first season in 46 years when not a single hatchery-derived Atlantic salmon returned past Massachusetts’ Holyoke Dam.

That unnatural history event passed with little fanfare. Its silent-spring absence marked the end of a half-century-old program that consumed hundreds of millions of dollars and ate up far too much room in a badly broken ecosystem. The U.S. Fish and Wildlife Service abandoned its hatchery program at the end of the 2012 migration season, but across its 43 years — which saw the annual release of millions of fry and smolts to tributaries in Connecticut, Massachusetts, Vermont and New Hampshire — so few adults returned that no one was ever allowed to catch one.

This second salmon ending highlights the fish agencies’ last shot at returning ancient ocean connections to the river’s still-viable, age-old runs of American shad, blueback herring and federally endangered shortnose sturgeon in three states.

All these species have been guaranteed safe passage on U.S. rivers, going back to the landmark Supreme Court decision in Holyoke Company v. Lyman in 1872. That finding centered on the dam in Holyoke, Massachusetts and held that private dam owners operating on U.S. rivers must provide for the free movement, upstream and down, of migratory fish past their facilities.

Looking west across the CT to the Holyoke Dam fish lift complex. Since 1955 it is one of the East Coast’s few fish passage successes. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Its implementation on New England’s river is now 148 years overdue.

A River Run in Reverse

What’s ultimately at issue here is flow.

Having taken a back seat for generations, wild runs of shad, herring and sturgeon remain in desperate need of passage and consistent, exponentially increased river flow in FirstLight’s hydro-complex dominated reach. It’s literally the weight of water that matters most to FirstLight. It’s money in the bank. And where flow diversion is concerned, it’s been pretty much a free ride for companies here for the past 50 years.

The 20 miles of river backed up into Vermont and New Hampshire behind Turners Falls Dam are massively suctioned for hours at up to 15,000 cubic feet per second to fill the 4-billion-gallon reservoir above the Northfield Mountain Pumped Storage Station.

Northfield’s suction is so violent it literally reverses the Connecticut’s current for up to a mile downstream at times, erasing the essence of a living river system. The station kills everything it sucks in, from tiny fish eggs to full-size eels. In pumping mode it suctions the equivalent of 3,600 seven-bedroom mansions, each filled with the aquatic life of a river, vaporized every hour, for hours on end. Agency studies on America shad show tens of millions of eggs and larvae extinguished at Northfield annually, plus the deaths of over 2 million juvenile shad sucked in on migrations back to the sea. Five migrant species are subjected to Northfield. In all 24 species live here, most unstudied.

Warning floats on the CT at the entranceway to Northfield Mountain Pumped Storage Station’s massive subsurface suctioning site. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Northfield’s operations are nothing like classic hydro, operating to produce virgin electricity via a dam in or adjacent to a river. It’s actually an electric appliance, built to take advantage of excess, unused megawatts produced nightly at the nearby Vermont Yankee nuclear station. Northfield burns electricity to pump water from the river a mile uphill to into its reservoir tank, which was created by blasting off the top of a mountain. The company’s original owners would buy up Vermont Yankee’s cheap electricity to power its giant, reversible turbines. Later, during peak energy times, that now-lifeless river water would get sent back through the turbines to generate hours-long pulses of energy at peak market prices.

It’s a buy-low, sell-high operation, still running at the expense of a river system six years after Vermont Yankee shut down.

Idle bulldozers sit in the emptied bed of the giant NMPS reservoir on June 27, 2010–the year they broke their giant appliance by fouling the pumps with muck and silt. Sanctioned by the EPA for a cover-up and massively dumping the muck from their mile-long intake tunnel directly into the river, Northfield didn’t operate for over half a year. Photo Copyright © 2020 by Karl Meyer. All Rights Reserved. (Click x3 to enlarge.)

Northfield is a net-loss energy machine — a giant underground appliance consuming massive amounts of grid electricity, half of it now generated by the climate-scorching natural gas that dominates New England’s power grid today. The station consumes 25% to 33% more juice than the secondhand megawatts it sends back by dumping deadened river water back through its turbines. It and a smaller pumped storage station in Connecticut are responsible for gobbling up 1.4% percent of the region’s energy in order to reproduce the few hours of secondhand juice they regenerate. According to grid operator ISO-New England, they are the only facilities whose operations flush out as negative input in the regional power mix.

Northfield has never generated a single watt of its own electricity. And though it may be fine as blunt instrument for use during the occasional power grid slump or rare emergency blackout, its endless, river-crippling, pump-and-purge cycle of regenerated megawatts is unnecessary for the daily operation of the New England grid. While its owners brag of being able to power a million homes for a few hours, they never mention having already burned through the energy of 1.25 million homes to do so. After its daily flush, Northfield is virtually dead in the water and must begin pulling from the grid and sucking life from the river all over.

Past mistakes not only allowed for this massive upstream disruption, they sanctioned diversion of nearly all flow, as well as all migrating fish, into a downstream power canal that on average just 5% of shad have ever successfully negotiated. That left another two miles of New England’s river dysfunctional, with the company providing just a dribble flow of 400 cubic feet per second in the riverbed in spring, when fish are moving upriver. That riverbed remains emptied of all flow more than half the other days of the year.

The most critical time for sustaining flows and the river’s migrants is April through June, when New England’s energy consumption is at its low annual ebb. But federal and state studies and in-river findings show that spring flows will need to be increased by a factor of 20, supplying 8,000 cfs rather than the current brook-like drizzle of 400 cfs. That’s what it will take to guide shad and blueback herring upstream in the river past Turners Falls Dam. That will also provide this river’s only endangered migrant the consistent flows required to successfully allow the shortnose sturgeon to spawn and ensure its larvae can develop in the cobbles at an ancient river pool in that impoverished reach.

Flow starved Connecticut River at the Rock Dam–critical shortnose sturgeon spawning and rearing site, May 13, 2018. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Back in 1967, when four New England states and these agencies signed the “Statement of Intent for the Cooperative Fishery Restoration Program for the Connecticut River Basin,” they projected some 38,000 salmon would return annually to this four-state ecosystem. For salmon, a pinnacle of sorts was reached in 1981, when 592 were tallied passing Holyoke. But for a hybrid fish whose wild prototype disappeared 160 years prior, it was downhill from there. Most years fewer than 100 salmon returned to the river.

That 1967 agreement also set annual run targets of one million American shad heading upstream, with 850,000 shad passing Turners Falls and 750,000 entering Vermont and New Hampshire habitats above Vernon Dam. The highest shad return saw 720,000 passing Holyoke in 1992. Sadly, they’ve never made it much farther.

The Run Stops in Massachusetts.

Just 36 miles upstream of Holyoke, all semblance of a successful restoration ends when the annual shad run reaches Turners Falls Dam. Of the 537,000 shad that passed Holyoke in 2017, just 48,000 — a mere 9% — squeezed back into the river beyond Turners Falls.

Vernon Dam between Vernon VT and Hinsdale NH, March 2020. Photo Copyright © 2020 by Karl Meyer

The annual inversion at the next upstream dam in Vermont illustrates the perils on this broken river. In 2017 29,000 or 59% of the shad that survived the miseries of Turners Falls were subsequently counted passing Vernon Dam, 20 miles upriver. That inverted interstate ratio has been the case since 1975, with few shad managing to break out beyond the brutal ecosystem conditions in Massachusetts.

Why the Restoration Failed

The current restoration, congressionally authorized in 1967 and still operating today under the moniker of the Connecticut River Atlantic Salmon Commission, made their biggest blunder in 1975 when they signed off on new license requirements for upstream fish passage. They ultimately chose a design based on hydro project fish ladders on Washington State’s giant Columbia River, known for huge Pacific salmon runs. What got built was a three-ladder fish passage that forced all migrants out of their ancient river highway and into the byzantine maze of the company’s power canal, while leaving two miles of riverbed all but emptied of flow.

Scaled down and put in place at Turners Falls, it worked fine for the program’s few successfully returning hybrid salmon but failed immediately for 95% of the hundreds of thousands of migrating shad. No big run has ever passed that site, leaving three states without their promised bounties. Vermont and New Hampshire remain this river’s shad deserts today.

The Prescription

It’s now 2020. At this late date, corporate re-registrations can’t hide what’s legally required and a half-century overdue on New England’s river. The last opportunity to undo those festering mistakes for the Connecticut now rest in the hands of the National Marine Fisheries Service, U.S. Fish and Wildlife Service and Massachusetts Division of Fish and Wildlife. They are the people’s gatekeepers, mandated to guard the public trust — agencies with the authority to change to the generations-old crippling conditions here in Massachusetts.

Across 45 years of tracking fish runs passing upstream at successive dams on the Connecticut, shad counts have averaged 315,369 at Holyoke, 17,579 at Turners Falls, and just 9,299 at the Vernon Dam in Vermont. But recently long-term federal and state studies on passage and juvenile survival for American shad have led to new minimum benchmarks for fish passage at each dam to ensure the long-term survival of the river’s runs.

Using those findings, the Atlantic States Marine Fisheries Commission, National Marine Fisheries Service, U.S. Fish and Wildlife Service and the four states have formally adopted new Connecticut River fish passage goals. They include annual minimums of 687,000 shad passing Holyoke, 297,000 passing Turners Falls, and 227,000 at Vernon Dam annually. Those federal and state targets are now part of the public record in the current FERC relicensings. Their implementation would also ensure the endangered shortnose sturgeon gets the flows needed to begin its recovery here.

It’s time to return flow to the Connecticut River below Turners Falls. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The time has come for facilities operating and profiting off the life of New England’s river to come into compliance with the laws of the land, including the Supreme Court’s 1872 finding in Holyoke Company v. Lyman, the Anadromous Fish Conservation Act of 1965, the Endangered Species Act of 1973 and a host of others. For the fisheries agencies charged with protecting a river’s bounty, standing up for their implementation is the sole prescription for success in a four-state restoration undertaken when back Lyndon Johnson was president.

By law, by right and by the public trust, the Connecticut River’s time has come.

Karl Meyer has been a member of the Fish & Aquatics Studies Team and an intervener in the Federal Energy Regulatory Commission relicensing process for three Massachusetts facilities on the Connecticut River since 2012. He lives in Greenfield, Massachusetts. Meyer is a member of The Society of Environmental Journalists.

* * FINAL NOTE from the author: if all this history is new and troubling to you it must be considered that: this is the only river in the Northeast with several federal designations that has remained the only major waterway without an independent and effective watchdog–one with a full legal team on staff, and a mandate to investigate, enforce, and go to court. The generations-long mistakes and brutal conditions that have existed here would’ve long ago been challenged in court had there been an effective organization protecting the integrity of this river system. If the Connecticut River is to have a future as a living ecosystem, a new model will have to come into being.

REIMAGINING A RIVER: The Year without Northfield Mountain

Posted by on 01 Jun 2020 | Tagged as: American shad, Clean Water Act, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River Coordinator, Connecticut River pollution, Connecticut River Watershed Council, CRASC, Daily Hampshire Gazette, EPA, Federal Energy Regulatory Commission, FirstLight, fish passage, Gary Sanderson, Greenfield, hatchery, Holyoke Dam, ISO New England, Larry Parnass, MA Division of Fish and Wildlife, migratory fish, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, Old Saybrook CT, pumped storage, Riverkeeper, salmon, salmon hatchery, The Daily Hampshire Gazette, The Greenfield Recorder, The Recorder, Turners Falls dam, Turners Falls power canal, US Environmental Protection Agency, USFWS

THIS GREAT AND BROKEN RIVER VII

Copyright © 2020 by Karl Meyer. ALL RIGHTS RESERVED.

Issue # 7, Part 1, REIMAGINING A RIVER: The Year without Northfield Mountain


Sunderland Bridge over the Connecticut. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

AUTHOR’S NOTE: I have found it difficult to write these past days. I am heartsick for my country. Are we to be a fair, generous and courageous people, or just a collection of frightened, soulless bystanders? What world do we want our children to grow up into? I have not been without a few tears at times over the past week. But, I know that good work and living rivers benefit all; they do not hate, judge, murder, or discriminate. So, noting that all of us have some heart-work to do, I continue here, with this also…

On May 1, 2010, I began a 5-day cycling trip from Greenfield MA, downstream to Long Island Sound and back again along the Connecticut River. I set out by bike to highlight and blog about the massively wasteful and misplaced emphasis on the forever-failed, hatchery-produced, 40 year-old salmon program for the river. Meanwhile, across the preceding decade, the formerly growing and robust American shad runs had concurrently experienced precipitous declines in fish passage returns at Holyoke Dam. More importantly, the shad run was literally flirting with extinguishment upstream of the Turners Falls Dam.


Miserable shad tally board at TF Fishway, 2007. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

The plunge at Turners Falls had taken hold pretty much simultaneously with the implementation of newly-legislated electricity deregulation in Massachusetts. It gave owners of the Northfield Mountain Pumped Storage Station a license to unleash new, lucrative and disruptive flow regimes in the river—just 5 miles upstream of Turners Falls Dam. Ironically, that same May Day when I left for the mouth of the river, was the day that Northfield Mountain was scheduled to shut down to begin mucking out the decade’s worth of silt and muck they’d inhaled up into their 4-billion gallon mountaintop reservoir.


Cyclist’s Shad Dinner, Saybrook CT. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

Unbeknownst to me–and to NMPS management, once they shut down and started draining their reservoir that net energy loss contraption would not suction the river again for over half a year. They broke their regenerating plant; their muck half-filling the mile-long tunnels connecting it to the river. FirstLight then tried to hide their plight and the evidence as they turned around and massively polluted the river for months. That came to an abrupt halt when the EPA(remember them?) issued a “Cease and Desist” order against them extensive violations of the Clean Water Act.

But, a great upshot benefit soon came into focus: with the river not suctioned and ramping up-and-down at Northfield, successful fish passage at Turners Falls Dam jumped back to well over 400% over 2009 totals–leaping to 16,422 shad passing in 2010(though likely significantly more, since FirstLight’s fish counting software was curiously ‘inoperable’ on 17 different days that spring), while just 3,813 shad squeezed past Turners Falls in 2009. Overall, that 2010 rise peaked at over 500% above that decade’s previous passage averages there. I returned to Greenfield on May 5, 2010, and learned of NMPS’s disastrous de-watering that same afternoon. It was of great interest, but its significance wouldn’t be understood for weeks until the unusual and increasing shad tallies passing Turners began coming in.

Just 3 years earlier, after spending over half a decade working at the Northfield Mountain Recreation Center (where I’d even for a time been secretary for the Safety Committee up inside the pumped storage power plant), I quit. The dismal shad runs, just downstream, were chewing on my soul.


Lynde Pt. Light at the River’s Mouth, Old Saybrook CT. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

By that May of 2010, I’d been doing part-time work for the Connecticut River Watershed Council for a few years. I immediately informed the Council of Northfield’s predicament when I got back. Sadly, I then had to watch their back-seat, kid-gloves handling of an opportunity to prosecute and hold the power company responsible for massive pollution. They stayed quietly in the background, letting the Massachusetts DEP and MA Div. of Fish & Wildlife take charge of holding FirstLight’s feet to the fire. It was a massive opportunity to begin taking on the gross daily river depredations of Northfield Mountain, but it was mostly just squandered here in Massachusetts.

The Commonwealth and MA Fish & Wildlife did little, though some effort by MA DEP and Natural Heritage ultimately bargained for a study of erosion effects on endangered dragonflies as some sort of restitution. I later felt compelled to quit the Watershed Council, which I did five months later. They weren’t players, likely because their board was full of former power company managers and folks still working as consultants, who might see some power company contract work in the future. It was just wrong that–as one of the oldest river organizations on the East Coast, they didn’t have a single lawyer on staff, nor have a mission that mandated enforcement. This was no Riverkeeper.

It wasn’t really until early that June that I began to realize the full ramifications of Northfield’s shutdown. Fish passage numbers just began creeping higher and higher at Turners Falls. I attended a June 22nd meeting of the Connecticut River Atlantic Salmon Commission (CRASC)—the Congressionally-authorized fed/state fisheries organization charged with managing and protecting migratory fish on the Connecticut. I asked the agency reps if they’d noticed the numbers and whether they’d been doing any studies on the relationship between the big shad passage at Turners and the turbine disaster upstream at Northfield. “We haven’t looked at it,” said a relatively new USFWS Connecticut River Coordinator Ken Sprankle.


Jilted American shad flashes CRASC attendees at the TF Power Canal. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

Even then, I was as yet unaware that NMPS was STILL not operating. But I got a curious look from FirstLight’s Bob Stira, also in attendance, when I posed that question. That look–and the immediate notice of the shutdown of Northfield Mountain’s reservoir trails that same afternoon, is what soon sent me on a recon trip with a camera up to that reservoir. I started crunching numbers and writing. On a Sunday morning one week later I found an unposted back woods trail up to the reservoir, and there was the whole story.

Days earlier, I’d independently handed over some initial fish passage numbers and gave a few pointed quotes in an email to Gary Sanderson, sports and outdoors editor at The Recorder. Gary enthusiastically included them in his column along with his own comments. The following week, after FirstLight’s sudden and inexplicable closure of trails leading to the reservoir–plus immediately moving their riverboat tour boarding site from Northfield down to Barton Cove in Gill, I snuck up and took a photo of that emptied reservoir with two fat earth movers sitting silent in the silt-filled bed.


Emptied Northfield Mountain Reservoir. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

Their riverboat got moved downriver to hide from the public the chocolate colored river that Northfield’s dumping was creating at intake tunnels next to the Riverview dock site. The silt cloud reached all the way down to the French King Bridge.


Muck-plagued Connecticut River beneath the French King Bridge. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

In late June, Daily Hampshire Gazette Editor Larry Parnass ran my rather telling Northfield Reservoir photo above my expository OpEd bringing to light the disaster there–and the surprise fish passage bonanza occurring at Turners Falls Dam. It wasn’t until the first week of August that the EPA finally stepped in to order FirstLight to cease and desist. They’d been dumping the equivalent of 40-50 dump truck loads of reservoir muck directly into the Connecticut for over 90 straight days. That EPA order would keep Northfield shutdown well into November.

Despite Northfield’s claims of the usefullness of its daily input, and the touted critical emergency readiness of their net-energy loss machine to the grid, no one in New England went without electricity in the long months their river-strangling contraption was lifeless. The only mourners during its 7 month coma appeared to be two climate-change cheerleaders: ISO-New England and the Federal Energy Regulatory Commission. Yet even during a long hot summer–one in which Vermont Yankee shut down for a week to refuel, everyone had essential power. The public didn’t miss Northfield, the shad run blossomed, and a river came back to life.

SPRING: Private Profit; Public Loss

Posted by on 26 May 2020 | Tagged as: American shad, Connecticut River, Federal Energy Regulatory Commission, FERC, FirstLight, FirstLight Power, FISH CAM, fish passage, Holyoke Dam, Holyoke Fish Lift, Humor, ISO New England, migratory fish, Northfield Mountain, shad fishing, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Slim Shad Point, Turners Falls dam, Turners Falls power canal, USFWS

THIS GREAT AND BROKEN RIVER VI

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

SPRING: Private Profit; Public Loss

Despite the enormous and longstanding damages the Industrial Age visited upon the Connecticut River—the early clear-cutting of the north woods, the building of the main stem dams and canals, the profligate effluent pollution, the thermal heating from a pair of nuclear reactors, the eviscerating impacts of a massive, river-reversing pumped storage project, it somehow has survived into the 21st century with a relatively robust and still-restorable spring run of American shad in its lower reaches.


Fishing Slim Shad Pt. Holyoke Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge; back arrows to return)

The Connecticut is indeed rare in that respect—as well as for being host to the most successful fishway on the entire East Coast, with a lift first put in place at Holyoke Dam in 1955. That spurred a New England fisheries restoration effort begun here between federal and state fisheries agencies in 1967. It is why the Connecticut ultimately became the central artery of the 4-state Silvio O. Conte National Fish and Wildlife Refuge in 1997. But by that time the river’s migratory fisheries restoration had already stalled and foundered in Massachusetts just 36 miles upstream of Holyoke, at the foot of the Turners Falls power canal and dam.


Shad Angler Wading at Holyoke Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge; back arrows to return)

The complex of fish ladders and canal routes chosen and installed there in 1980 were largely weighted toward passage of a new, mass-produced hatchery-hybrid salmon strain. They proved an obvious and instant failure for the hundreds of thousands of shad returning to pass that place as soon as all the concrete dried. Vermont, New Hampshire, northern Massachusetts—never received their promised bounty.

And so it is to this day. The Connecticut, still massively overworked and under-protected, remains without any new bona fide restoration success for migrating shad in 3 out of 4 of the states over its 410 mile reach over the last 30 years. Where have the fish successfully passed? You need not go far to identify the break point. Smack in the heart of this spring’s migration peak here’s a quick look at the stats for fish passage success up through Memorial Day weekend. As of May 25, 2020, some 274,370 shad had been lifted past Holyoke Dam according to USFWS Connecticut River Project Leader Ken Sprankle.

And at Turners Falls? Well, the last report offered included a total of 735 shad passing as of May 17, 2020. They don’t report regularly from Turners Falls. If FirstLight had just installed a simple Fish Cam the public would have had something this year—while all their license-required recreational access has been shut down tight this spring, including fish viewing, camping, even hiking trails. But, just to compare: as of that same date, May 17, 2020, Holyoke had already reported passing 51,000 shad upstream. It only takes the 1-1/2 – 2 foot long, blue-green migrants just a day or so to start knocking on the door at Turners Falls. But as the failed restoration numbers have grimly shown for decades, the river’s great run dies in the alternately starved and ramped-up industrial flows set in motion by gatehouse and dam operators at Turners Falls and Northfield Mountain.

Listless Riverbed at Turners Falls, May 14, 2020
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED
. (Click X 3 to enlarge; back arrows to return)

It’s now three migration seasons past the April 30, 2018 expiration date of the current Federal Energy Regulatory Commission license for FirstLight’s Turners Falls Dam, yet no legally-mandated fish passage–upstream and down, has been constructed. Literally nothing has been done. While citizens in three states—including fifteen cities, towns and villages, are yet to see their rightful share of the river’s fish.

As always, FERC and ISO-New England (in Holyoke) have both made sure to requisition and have available a glut of power for the sprawling Northeast power grid here (at public expense, but without public input of course) It’s way more than enough to easily exceed the grip of a summer heat wave. Climate emergency be damned… It does means big corporate profits. Meanwhile, it’s mid-spring. Power use is at a low annual ebb. Yet New England’s Great River here in the United States is currently starved of both its fish and life-giving flows at Turners Falls–while Canada’s shareholder-owned FirstLight Power exports its profits out of the region.

A living river is a public right here. Whose pockets are being lined?

Issue # 3: The River Emptied at Spring

Posted by on 13 May 2020 | Tagged as: American shad, Bellows Falls VT, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC, FERC license, FirstLight, Greenfield Recorder, Holyoke Dam, Holyoke Fish Lift, migratory fish, Narragansett, Nipmuck, Northfield Mountain, Norwottuck, Pocumtuck, Rock Dam, Rock Dam Pool, shad, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turner Falls Massacre, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont, Walpole

THIS GREAT AND BROKEN RIVER III

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 3: The River Emptied at Spring

Dismal Mother’s Day flow at Turner’s Falls Dam and Fishway Copyright © 2020 by Karl Meyer (Click X 3 for closeup, click back arrow to return to text)

It was a grim Mother’s Day weekend for the Connecticut River in Massachusetts. The only current left in the riverbed below Turners Falls Dam amounted to little more than a thin, spreading soup winding a shallow path around successive ridges of drying ledge as it threaded together a downstream path along it’s ancient, impoverished bed. Anyone with a pair of rubber boots could’ve easily walked across the Connecticut just a few hundred feet below that dam without much risk of getting wet to the knees–smack in the middle of fish migration and spawning season in the heart of the Silvio O. Conte Connecticut River National Fish and Wildlife Refuge.

There’s something soulless in starving a river of its flow—particularly in the spring when the shadbush is in bloom, the columbine have sprouted, and the fish are in the river. This year, with the corona virus draining spirits and sapping energy during March and April, the presence of a living river in Western New England’s back yard was something to anticipate come May. The light returned, the trees were in flower, birds were making music, and energy use was in its usual seasonal retreat—demand being down ever since a warmer than normal winter.


Days Earlier Flow over Turners Falls Dam May 5, 2020 Copyright © 2020 by Karl Meyer (Click X 3, back arrow to return to text)

This should have been a promising early May on New England’s Great River. But no–not here in northern Massachusetts–not this Mother’s Day weekend. For migrating American shad seeking a route upstream here, the river was literally a road to nowhere. As of Monday, May 11th, though some 18,000 shad had passed upstream at the Holyoke Fishway, 36 river miles to the south, not a single shad had been tallied managing to pass beyond the grim maze of a power canal and several ladders to emerge above Turners Falls Dam. By Monday not a single migrant from the ocean had been tallied passing that dam–thus none were present moving upstream to open Vermont, New Hampshire and northern Massachusetts habitats. The public has no access to the fishway this year, and FirstLight has not provided a simple video feed for people to see their fish. At Turners Falls, the power company alone, is left to monitor itself and report on the public’s fish.


Shad Anglers below Holyoke Dam May 7, 2020 Copyright © 2020 by Karl Meyer

But, most grimly again this May, river conditions on Mother’s Day were altogether devastating for federally-endangered Connecticut River shortnose sturgeon attempting to spawn and nurture young in the currents at their ancient Rock Dam spawning pool–a mile and a half downstream of the dam. Vital river flows at a natural basalt, in-stream formation known as Rock Dam–which had been accommodating for spawning sturgeon just a week before, were shut down to the point where the cobble shoals that shelter eggs and developing young were now visible along a receded shoreline.

Hopeful shad anglers from the adjacent USGS Conte Lab and nearby US Fish & Wildlife Service in Sunderland were present to witness the impacts. This year’s potential progeny–at the sturgeon’s only documented natural spawning site in the ecosystem, were once more left to desiccate–starved of life-giving, oxygenating water as the sun warmed the prematurely exposed, rocky shallows. Though not fishing on this Mother’s Day morning, one of the leaders of the local Nolumbeka Project stopped to inquired of me if the sturgeon had been able to successfully spawn this year. I had to tell him no.

For the second year running FirstLight Power had squeezed the bascule gates closed at Turners Fall Dam, leaving just a curtain of a few hundred cubic feet per second (cfs) of flow entering the starved riverbed below Turners Falls Dam. The Federal Energy Regulatory license for FL’s Turners Falls and Northfield Mountain operations expired two years back on April 30, 2018. . Conditions in a new license would have hopefully increased that dribbling flow at the dam by a factor of 20. Grimly, the starving of this Great River is occurring at the exact site where women, children and elders of the Nipmuck, Pocumtuck, Norwottuck and Narragensett People were set upon and slaughtered in their pre-dawn sleep in the Turners Falls Massacre on May 19, 1676.

But FERC stepped in on FirstLight’s behalf, and has now offered two years of license extensions to this Canadian-owned, Delaware-registered company, allowing these grim impacts to continue. In doing so it has now green-lighted these conditions for three consecutive spawning seasons–allowing crippling industrial practices put in place 52 years back to choke the life out of four-state migratory fish runs, and crushing the spawning prospects for those sturgeon–literally the Connecticut’s only federally endangered migratory fish species. This, in an ecosystem that should have had connected and sustaining flows and fish passage upstream to Bellows Falls VT and Walpole NH long ago.

The flows present in the river on Mother’s Day are flows that force endangered sturgeon to default downstream to attempt spawning in the pulsing industrial flows churning out of the Cabot Station powerhouse a half mile downstream. There, any spawned and developing young-of-the-year will have no defense against the scouring-out hydro surges pulsing canal water back into the riverbed below once fertilized young are dispersed in the flows to shelter in rocky shallows .

Those tamped-down Mother’s Day flows from the dam also create conditions that keep American shad in an endless Groundhog Day cycling at Rock Dam–circling and re-circling in the depleted currents at a pool where depths become too shallow to find a flow offering a negotiable upstream path. Anglers sometimes do quite well at this migratory cull-de-sac where agitated, circling shad snap at darts while wasting hours and energy in this suspended-migration.

But those same tamped down flows diverted at TF Dam also cause just-arriving American shad from Holyoke to be led directly to the false upstream currents exiting the power canal at Cabot Station. Sensing that upstream attraction flow, those unlucky fish get drawn into a ponderous and exhausting fish ladder there. There they are diverted entirely out of the riverbed and into a concrete chute where they must attempt to better an impossible series of steps, twists, and turns that will ultimately dump them into the alien and un-river-like environs of the Turners Falls power canal. Once they enter that industrial habitat, many end their upstream migrations altogether, spending weeks in the labyrinth of that walled corridor without finding a way out and upstream.

Grimly, this year was nearly a carbon copy of the brutal conditions visited below Turners Falls the week of Mother’s Day 2019. Last year at this time researchers tallied the largest-ever catch of spawning-run endangered sturgeon gathered at their Rock Dam nursery pool, corralling 48 fish in a morning survey of a biologist’s net. Days later, at the height of shortnose spawning season, FirstLight abruptly cut off life giving flows to the site. Those same banks and cobbles were exposed, and the spawning run sturgeon were sent packing—forced to abandon the site, with any embryos and young that might have proved viable left withering in the shallows.


FL’s Locked Entrance at Cabot Woods & Rock Dam mid-afternoon May 5, 2020 Copyright © 2020 by Karl Meyer

You might have expected more from FirstLight this year. This is a Canadian shareholder company seeking a new federal license to operate these facilities on the Connecticut River in Massachusetts after recently re-registering them in Delaware as tax shelters. But, now that FERC continues to allow them to profit off the grim and antiquated tenets of a license written under the Federal Power Commission 52 years ago, they seem in no particular hurry to become relicensed neighbors operating for profit on a four-state US river that is the centerpiece of a National Fish and Wildlife Refuge.

These ongoing grim flow regimes fly in the face of mandates long-ago included in the Endangered Species Act and the Anadramous Fish Conservation Act, here, in the most biologically important and critical habitat in the entire Connecticut River ecosystem. They also feel like a thumbing of the nose at Massachusetts taxpayers—as well as all the deserving citizens in the three states from Montague MA to Walpole NH, who also pay taxes and are certainly entitled to a living river. It is a form of public theft.

As the Connecticut River is left starved, its ancient fish runs foundering, there is no movement to bring to a close the Federal Energy Regulatory Commission’s “5-year” relicensing process—begun here in 2012 and lingering on, laughably unfinished. The power company continues to pocket profits, while the FERC is led by a stilted and hand-picked majority happy to feed the corporations what they want, to the benefit of foreign shareholders far from New England. Sadly, there is no state or federal environmental agency that appears willing to challenge this endless delay. And, as noted here before—this four-state river lacks a true NGO watchdog with a mission-mandate and staff lawyers protecting it. See The Greenfield Recorder: https://www.recorder.com/New-England-s-great-river-without-a-watchdog-33291778

FERC orders Canada’s FirstLight to investigate ITSELF on ESA impacts

Posted by on 27 Feb 2020 | Tagged as: Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, ESA, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, FERC Secretary Kimberly D. Bose, FirstLight, Kimberly D. Bose, MA Division of Fish and Wildlife, National Marine Fisheries Service, Rock Dam, Rock Dam Pool, Secretary Kimberly Bose, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS

Photo Copyright © 2020, by Karl Meyer.
NOTE: the above photo was taken on 2/25/20 at the Rock Dam pool in Turners Falls. This is the ONLY documented natural spawning site for the federally endangered shortnose sturgeon on the Connecticut River. NOTICE: the Connecticut River shortnose sturgeon is the ONLY federally-endangered migratory fish in the entire ecosystem. Shortnose sturgeon will be returning to the grim conditions in this ancient spawning pool in just 7 weeks.(Click, then click twice more to enlarge)

I sent the Federal Energy Regulatory Commission the following letter in October of 2019.

Karl Meyer, M.S. Environmental Science October 9, 2019
91 Smith Street
Greenfield, MA, 01301
karlmeyer1809@verizon.net

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

ILP COMMENTS re: Turners Falls Hydroelectric Project P- 1889, and Northfield Mountain Pumped Storage Project P-2485.

Dear Secretary Bose,

These comments are made with respect to immediate concerns respecting P-1889 and operations of the Turners Falls Dam and power canal impacting the riverbanks and the spawning habitat of the federally-endangered Connecticut River shortnose sturgeon at the Rock Dam, this species’ only documented natural spawning site in the Connecticut River ecosystem. I have been a participating Stakeholder in the FERC relicensing process for P-1889 and P-2485 since 2012. I serve on the Fish and Aquatics Studies Team for both these projects.

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

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

Of most import in the licensing and management of this critical habitat is the damaging, new eroded channel flowing around the Rock Dam site on river left that has grown from a trickle in the mostly rain-free months of this year’s late summer and early fall—until, by yesterday, October 8, 2019, it had grown to torrent of new water coursing through a new channel adjacent to those collapsing river banks. The corresponding connection to this dramatically increasing damage appears to stem from the increased flows currently being released from Turners Falls dam to facilitate the week-long dewatering of the Turners Falls canal, currently in progress. See attached photo of TF dam release on that day. This new channel presents an immediate threat, through deposition and erosion and pollution, to the spawning and early life stage development of shortnose sturgeon in the rock, sand, and cobble habitats at the Rock Dam pool, immediately downstream and adjacent.

Immediate action appears to be necessitated by these developments. This riverbank and traditional fishing access has been neglected and poorly maintained through the last decade. A cursory look would find neglected concrete pilings where steps were to be built, as well as literal sink holes in at least two sites in areas above these collapsed banks, where small hemlock trees are now sunk to the depth of 4 feet.

Please take action requiring immediate remedy to this situation, which appears to concern license and statute infractions that run afoul of the federal Endangered Species Act, the Clean Water Act, and Article 17 concerning erosion; Article 19, concerning construction and maintenance; Article 18 concerning fishing access; and Article 35 concerning State Historic Preservation under the current license for P-1889.

Thank you for your careful review of these matters; they are of immediate import.

Sincerely,
Karl Meyer

Cc:
Doug Bennett, FirstLight
Julie Crocker, NMFS/NOAA
Ken Spankle, USFWS
Melissa Grader, USFWS
Caleb Slater, MA Div. of Fish & Wildlife,
Rich Holschuh, Elnu-Abenaki”

Photo Copyright © 2020, by Karl Meyer.

Just one small section of FirstLight’s collapsing riverbank and the pollution that runs into the Rock Dam pool just 40 feet away. This is just 250 yards away from the USGS S.O. Conte Anadromous Fish Research Center. (NOTE: Click, then click x2 to enlarge)

NOTE: Over 4 months later the Federal Energy Regulatory Commission finally took the bold action to order Canadian-owned, Delaware-registered FirstLight to investigate and report on their own impacts on this critical endangered species habitat on the Connecticut River. THE ORDERS ARE BELOW:

FEDERAL ENERGY REGULATORY COMMISSION
Washington, D. C. 20426
OFFICE OF ENERGY PROJECTS
Project No. 1889-090 – Massachusetts
Turners Falls Hydroelectric Project
FirstLight Hydro Generating Company
VIA FERC Service
February 21, 2020

Mr. Donald E. Traester
Manager, Regulatory Compliance
FirstLight Power Services, LLC
99 Millers Falls Road
Northfield, MA 01360
Subject: Complaint – Erosion

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

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

2. The dates and timing of the Turners Falls power canal drawdown, why it was
performed during this time, whether it was typical of past drawdowns, and what
measures you took to protect downstream resources and the public.

3. Flow data for the entire period identified in item 2, including releases from the Turners Falls dam.

4. A comparison of the flow releases into the bypassed reach during this drawdown
to historical releases into the bypassed reach (e.g., for maintenance purposes,
naturally occurring high flows, etc.)

5. Any additional information you believe is pertinent to the allegations raised in the October 9, 2019 complaint.

20200221-3033 FERC PDF (Unofficial) 02/21/2020
Project No. 1889-090 – 2 –

The Commission strongly encourages electronic filing. Please file the requested
information using the Commission’s eFiling system at http://www.ferc.gov/docsfiling/efiling.asp. For assistance, please contact FERC Online Support at
FERCOnlineSupport@ferc.gov, (866) 208-3676 (toll free), or (202) 502-8659 (TTY). In
lieu of electronic filing, please send a paper copy to: Secretary, Federal Energy
Regulatory Commission, 888 First Street NE, Washington, D.C. 20426. The first page of any filing related to this letter should include docket number P-1889-090.
If you have any questions regarding this letter, please contact me at (202) 502-
6778 or Christopher.Chaney@ferc.gov.

Sincerely,
Christopher Chaney, P.E.
Engineering Resources Branch
Division of Hydropower Administration
and Compliance

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