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THE CONNECTICUT RIVER SHORTNOSE STURGEON: A PLANNED EXTINCTION?

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

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

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

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

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

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

New Stakeholder Comments filed with FERC re: Northfield Mountain

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

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

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA  01301

 

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, N.E.

Washington, DC  20426

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

Dear Secretary Bose,

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

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

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

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

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

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

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

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

 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

                                                End of Formal Comments

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

Sincerely,

Karl Meyer, M.S.

The curious nucelar history of Northfield Mountain Pumped Storage Station

Posted by on 08 May 2014 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, ecosystem, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, Haddam nuclear plant, Millstone 1, Montague Nuclear Station, Northfield Mountain, Northfield Mountain Pumped Storage Station, right-to-know, shad, shad larvae, US Fish & Wildlife Service, USFWS, Vermont Yankee, Yankee Atomic

Copyright © 2014, by Karl Meyer

The curious nuclear history of Northfield Mountain’s pumped storage plant

(The following piece first appeared on April 30, 2014 in The Recorder in Greenfield, MA, under: Follow the power currents; How the pumping station once fit)

GDF-Suez FirstLight has applied for a new 30-year license from the Federal Energy Regulatory Commission for its Northfield Mountain Pumped Storage plant on the Connecticut.  In this 5-year relicensing process US Fish & Wildlife Service has requested a study to protect a public resource: they want to know the mortality impacts NMPS has on eggs and larvae of migratory American shad.  But FirstLight wants FERC to substitute data from a 22 year-old Northfield study–their counsel has argued that eggs and larvae aren’t technically migratory, and thus have no right to protection at NMPS. 

Pumped storage is a most inefficient form of generating “hydro” electricity, and NMPS is not what it once was.  When proposed, Northfield was to be a nuclear-charged plant designed to gulp-up massive amounts of the Connecticut River, pushing it uphill to a reservoir carved into a mountain.  This would be done purchasing cheap, otherwise-wasted, night-generated nuclear energy from a fleet of soon-to-be-built local plants–which don’t switch off at night.

Once the net-loss task of pushing water uphill was accomplished via nuclear megawatts and reversing turbines, they’d send that water charging downhill to generate large pulses of energy during peak-use times.  Profits would come from reselling that energy back into the electric grid when demand and prices were highest, with consumers picking up the tab. 

But a river system also bore the hidden costs of NMPS and now USFWS wants to know what they are. FirstLight today doesn’t dispute NMPS kills all adult and juvenile shad drawn into its plant.  But that’s just one species.  FERC itself is mandated to protect federal trust fish, and the public is entitled to information on NMPS’s impacts.  Researchers report it sometimes draws so much river water that boats 5 miles downstream are pulled backward.    

Because of the limits of physics NMPS can only operate for 6 – 8 hours.  Then, water-depleted and power-less—it must again purchase new outside electricity to pump water uphill.  It was new technology when NMPS was proposed–technically “hydro” electricity, but not in the way people commonly understood it. 

During mid-1960s Federal Power Commission hearings, questions arose about the proposed NMPS plant’s impacts on the ecosystem.  One option, never implemented, was that it would cease operating during migration season to avoid slicing up the public’s fish in accordance with goals of the federal Anadromous Fish Conservation Act of 1965.

Back then just one local nuclear plant was operating, Yankee Atomic, 20 miles away in Rowe, MA.  But big, local, nuclear build-out plans were in the offing—the lion’s share of which would come to be owned by Northeast Utilities.  Fifteen miles upstream Vermont Yankee was under construction.  It opened in 1972 in lock-step with the completion of Northfield.  As VY and NMPS began tandem, nuclear-powered operation, plans were already underway for NU to build two reactors at a new Montague Nuclear Station, five miles from Northfield.

By fall of 1973 a 500 foot tower loomed over the Montague Plains, testing humidity, temperature, and prevailing winds in preparation for construction.  That tower was toppled in an act of civil disobedience by Sam Lovejoy the following February, helping bolster opposition to the plants.  But NU rebuilt the tower and collected the mandated data by 1975.  By then however, the playing field was changing.

Environmental questions were raised about the effects of Montague Nuclear Station’s drawing huge amounts of river water and dumping heated effluent back into the Connecticut on the federally-endangered Connecticut River shortnose sturgeon.  Questions also arose about the cumulative effects of entraining various life stages of American shad into the intake systems of two Montague plants and NMPS. 

Meanwhile, NU moved ahead on planned nuclear plants for the heavily-populated I-95 Providence-/New Haven corridor–some 100 and 125 miles distant from Northfield.  Four got built, but just two operate today. Their Haddam nuclear plant on our river was shut permanently in 1996 for safety and equipment failures.  So too in 1998 was Millstone Unit I in Waterford, CT.  In 1999 NU to accepted the largest nuclear fine to that time–$10 million for operational failures at those plants. 

Opposition, environmental impacts, soaring costs, and a partial meltdown at Three Mile Island saw NU abandon Montague Station in 1980.  Thus the Connecticut River basin doesn’t today host a forth, de-facto, nuclear waste dump.  Rowe’s Yankee Atomic closed in 1992—it’s now repository to hundreds of tons of spent nuclear fuel.  Vermont Yankee will close in December.  Entergy Nuclear has yet to fully endow their mandated decommissioning fund. 

Local nuclear power to push a river up Northfield Mountain is today nearly nonexistent.  The net-loss “hydro” generating process now taking place there essentially derives from a non-renewable, climate-warming mix of oil, coal and natural gas, plus some nuclear and even pulses of conventional hydropower purchased from as far away as Quebec. Beyond the yet-to-be-examined costs to the public’s ecosystem and fish, consumers are paying dearly for Northfield’s twice-sold electricity.  A fair relicensing process requires robust public information on the lethal aspects of Northfield’s operations.  FERC will decide the issue by early May.

Greenfield writer and journalist Karl Meyer has contributed written and oral testimony in the FERC relicensing process for the Northfield Mountain and Turners Falls power stations.

New Stakeholder Comments filed with FERC

Posted by on 31 Mar 2014 | Tagged as: American shad, Connecticut River ecosystem, EPA, Federal Energy Regulatory Commission, FirstLight, Northfield Mountain, US Fish & Wildlife Service, USFWS

The following Public Stakeholder Comments were filed today with the Federal Energy Regulatory Commission and Dispute Resolution Proceedings concerning Relicensing Studies to be conducted at the Northfield Mountain Pumped Storage Station.

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA  01301                                                                        March 31, 2014

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, N.E.

Washington, DC  20426

Stakeholder Comments for: FERC Project No. 2485-063, the Northfield Mountain Pumped Storage Project; and FERC Project No. 1889-081, the Turners Falls Hydroelectric Project.

 RE: US. Fish and Wildlife Service’s Notice of Study Dispute, filed March 13, 2014; and FirstLight’s response filed March 28, 2014, as Information Relevant to the US Fish & Wildlife Service Notice of Study Dispute.

Dear Secretary Bose,

Please consider the following comments concerning the necessity of robust study information being required of the license applicant in order for the US Fish and Wildlife Service and stakeholders to be fairly represented in this process.  The requested full Study on impingement and entrainment and data arising from examination of Northfield Mountain Pumped Storage Station’s operational effects on all life stages of American shad is new information that will also assist FERC in fully considering public resources and the public’s interest in a balanced and functioning Connecticut River ecosystem.

On March 13, 2014, the U.S. Fish and Wildlife Service (USFWS) filed a Notice of Study Dispute with the Federal Energy Regulatory Commission (Commission) stating that the Study Plan Determination issued by Commission staff would not elicit adequate information specific to “the effects of Northfield Mountain Pumped Storage Project (NMPS) on certain migratory fish species.”  FirstLight argued that information from a 1992 entrainment study would be sufficient to stand-in for current relicensing information.

The USFWS’s information request was made to fulfill responsibilities in determining the impact of NMPS pumping operations on American shad mortality, from eggs and early-life stages, to juvenile and adult fish.  USFWS noted that a “failure to provide this information will compromise the Commission’s ability to establish license conditions and the Service’s ability to set mandatory conditions under Section 18 of the Federal Power Act (FPA).”

The USFWS further stated:

“A new study of NMPS is needed because operations have changed since the last study was conducted and FirstLight is considering additional changes to project operation that could increase the potential for entrainment at NMPS. With anticipated improvements to fish passage facilities as part of the relicensing process for the Turners Falls Project, those numbers could increase into the hundreds of thousands.”

Under Goals and Objectives USFWS stated: “The goal of the Service’s original study request (Appendix A) was to determine the impact of NMPS pumping cycle on entrainment of American shad (including early life stages.)”

Pursuant to a March 26, 2014 teleconference between USFWS, FirstLight, and Commission staff, FirstLight formally responded on March 28, 2014, by supplying a portion of six years of seasonal pumping information from NMPS.  FirstLight submitted it as being representative of an overall decrease in plant pumping operations since the original 1992 mortality/entrainment study.  FirstLight supplied monthly and daily pumping data for the bracketed years of 1991 – 1993; and then again for 2011 – 2013.  In its filing FirstLight stated that, aside from the 1992 study-year data included, the other five years “were arbitrarily selected.”

A preponderance of accepted data shows NMPS operations impacting reaches of river at least as far downstream as Holyoke Dam, 36 miles distant, as well as throughout the Turners Falls Impoundment nearly to Vernon Dam, 20 miles upstream. In the months of June and July NMPS’s unrestricted pumping output of up to 15,000 CFS actually outstrips the Connecticut’s natural flow volume. Studies confirm that entrainment of eggs, juveniles, and adult fish have significant impacts on ensuing year-class strength.  They can impact whole-river populations.

Given this understanding, the “arbitrary” pumping years FirstLight has submitted to support limiting the scope of this study appear selective, rather than “arbitrary.” They coincide exactly with the all-time peak years of fish migration on the Connecticut during the early 1990s, and again, with the only shallow bit of improvement for shad migrating into the Turners Falls Impoundment since deregulation in 2000–the years 2011, 2012, and 2013, leading directly into a relicensing application. It should be noted that “arbitrary” is not synonymous with “random.”  Random is an accepted scientific parameter.

It is noteworthy that FirstLight selected as its first grouping the years 1991 – 1993 for pumping information.  Those years selected can be characterized as skewed, rather than arbitrary or random, in that two of them represent the highest years of fish passage ever recorded (1991, 1992) through Turner Falls Gatehouse.  These were record years along the entire river. However, the slight fall-off starting in 1993, began the first extended period where shad returns along the Connecticut River began a steady downward spiral.

The other data set FirstLight offers as “arbitrary” are from the years 2011 – 2013.  What is interesting about this “arbitrary” FirstLight data is that it excludes the entire decade–beginning in 2000, when NMPS began operating as a deregulated entity. Then, as today, NMPS could draw, and release—unrestricted, up to 15,000 CFS into the TF Pool, according to market prices and demand.  What is powerfully obvious about the years not included in their study data is that 2000 – 2009 represent the worst decade of fish passage at Turners Falls Gatehouse ever, with passage counts dropping to 1% or less some years. Some might describe this as cherry picking data.  They arbitrarily picked the only two minor peaks of any note across a very dismal quarter-century of poor upstream shad recruitment.

Good science requires, at minimum, randomly selected figures when data samples are too large. That is not the case here.  We are only considering 25 years of data, and only three months from each year.  A complete data set should be provided—especially when it is small, as in the present case.  Given such a brief span of time, and considering that a FERC license may be in place for 30 or 40 years—data from years 1991 to 2013 should be presented to better understand entrainment, mortality and recruitment of all life stages.

Significantly, as history, in 2010, FirstLight entrained its own turbines at NMPS plant while attempting to clear silt from its upper reservoir. NMPS operations came to an abrupt halt; the US EPA sanctioned them for “polluting the navigable waters of the United States,” and no pumping occurred at NMPS from May 1st, until November.

Fish passage at TF Gatehouse in 2010 saw a 400-500% increase over averages for the previous decade that year NMPS remained inoperable.  However significant that increase was, it merely represented a return to disappointing fish passage and recruitment levels regularly reached there in the 1980s.  The following year, Holyoke Dam saw a 30% increase in fish passage, yet no corresponding increase in shad passage was tallied at TF Gatehouse in 2011. 

However Gatehouse fish passage did continue–across the “arbitrary” 3-year data set FirstLight submitted for 2011 – 2013, to show a level of fish passage comparable to the returns achieved in the mid-1980s.  By not including pumping files from 2000 – 2009, FirstLight offers just three years of data during which improved fish passage numbers could be shown—but only if passage and recruitment targets are scaled back to the disappointing results of the 1980s.

As “arbitrary” as those selected years of data may be, they only give a snapshot of three “good” years of fish movements and recruitment above Gatehouse toward Northfield and VT/NH habitats. Certainly it’s possible that pumping operations get skewed over some years for various reasons.  But three years of data–just prior to a relicensing bid, is no substitute for the full set of pumping files.  Pumping data beginning from the year of deregulation—2000, to the present, will shed light on the impacts of pumping on entrainment and recruitment across the time frame necessary to help make decisions on issuing a decades-long license.

Ample decision-making studies and data—beyond just the most recent years FirstLight wants to supply, is what are called for in this instance.  The remaining pumping data, monthly, daily, along with standard deviations for the years 2000 – 2009, should be supplied in order to protect public resources.

Stakeholders should have an understanding of the plant’s potential pumping impacts and a fuller knowledge of the spectrum of its operating regimes since becoming a deregulated entity across three different owners—as there is no guarantee of single, long-term ownership over the term of license.

It is also critical to note that an overall “decrease” in pumping across selective years is just a single factor and may not be as significant to various life-stages of fish survival as the actual days, dates, and times when pumping and entrainment is occurring.  This is why the full USFWS entrainment study and a full report of pumping operations are necessary.  This is information that is sorely lacking.

Under Existing Information the USFWS states: “In its original study request, the Service noted that, while a number of studies had been conducted over the years, only one study attempted to quantify the number of shad entrained at NMPS.”

USFWS further stated that information from a single study conducted in 1992 would be insufficient for determining new protective licensing requirements: “The ichthyoplankton sampling requested by the Service would follow the methodology used in the 1992 study.”  USFWS further argues: “Existing information is not sufficient to use in the relicensing proceedings because operations have changed since the last study was conducted and FirstLight is considering additional changes to project operation as part of relicensing and that could increase the potential for entrainment at NMPS.”

Nexus to project operation and Effects: “Both the previous licensee (Northeast Utilities Service Company) and FirstLight assume that all fish entrained are lost to the Connecticut River system (i.e., 100% mortality). Without quantification of entrainment of all life stages of American shad, it is not possible to determine what the overall impact of that entrainment is on the shad population. This information relates both directly and indirectly to the Service’s statutory responsibilities under Section 18 of the FPA;”

Cost: The US Fish and Wildlife Service notes that a suitable entrainment study that includes early life stages can be conducted at NMPS for well under $50,000.  This is a modest expense to attain critical information that is not available elsewhere.  Not gathering such information would amount to a failure of due diligence in the current relicensing.  A single, 22 year old study is inadequate science on which to base conditions for a license that could impact the Connecticut River ecosystem until 2048—at which time the last data collected will be 60 years old.

I urge you to require the full study of NMPS entrainment on all life stages American shad. The information gathered will enrich and inform decision-making gathered from related shad studies occurring under relicensing, including 3.3.2; 3.3.3; 3.3.6; and 3.3.7. Further, please require that the full spectrum of May, June, and July, pumping files for the years 1991 – present, be released as information critical to making decisions on NMPS’s long-term impact on the entire Connecticut River ecosystem.

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.

Cc: John Nagle, U.S. Environmental Protection Agency

USFWS Designee: Dispute Resolution Panel

DUE DILIGENCE: looking beneath the surface

Posted by on 27 Dec 2013 | Tagged as: American shad, Bellows Falls, Connecticut River, Connecticut River ecosystem, Daily Hampshire Gazette, ecosystem, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC license, FirstLight, hydraulic study, shad, The Greenfield Recorder, Turners Falls power canal, USFWS

Copyright © 2013, by Karl Meyer

NOTE: the following piece appeared recently in Daily Hampshire Gazette, www.gazettenet.com; The Recorder, www.recorder.com; the Montague Reporter, and the Shelburne Falls and West County Independent.

                    DUE DILIGENCE: looking beneath the surface

New England’s Great River is at a critical juncture in the closing days of 2013.  An ecosystem door was slammed shut at Turners Falls 215 years ago when private investors built a dam across the river.  After 1798, migrating fish no longer reached northern Massachusetts, Vermont or New Hampshire.  In a landmark 1872 decision the US Supreme Court reopened the door to an ecosystem restoration via “Holyoke Company vs. Lyman.”  It upheld a Massachusetts law requiring dam owners to provide fish passage as part of the public interest of stakeholders upstream and down. Yet today there’s still no working fish passage at Turners Falls. 

As a stakeholder wishing to see the Connecticut River’s fisheries restoration succeed after decades of failure, I’m participating in the current 5-year Federal Energy Regulatory Commission’s hydro relicensing process.  It will determine conditions in the river for the next 30-40 years.  If you go to www.northfieldrelicensing.com and click on “2013 Documents,” you’ll find FERC’s “Study Plan Determination Letter” dated 9/13/2013.  It’s a 74-page catalogue of studies FERC has determined necessary to protect the public interests as they move to issue new long-range hydro licenses on the river in 2018.  Curiously, if you open that letter and scroll to the last word on the last page (74) you’ll find “Karl Meyer,” listed as “Recommending Entity” for Study 4.2.3, “Hydraulic Study of the Turners Falls Power Canal.”

I was surprised to find my name there, given that each of the 18 studies above it lists Firstlight, owners of the Turners Falls Power Canal, as Recommending Entity.  But this was no accident on FERC’s part.  They’d originally included the canal study as part of Study 3.2.2 in their preliminary judgments on the science needed to define the impacts of FirstLight’s hydro operations on river environments.  I’d agreed with them.  But FirstLight, in all subsequent filings, seemed determined to exclude it.  They simply excised “power canal” from 3.2.2: “Hydraulic Study of Turners Falls Impoundment, Bypassed Reach, power canal and the Connecticut River below Cabot Station.”  Their main argument was that the water surface level in the canal remains relatively stable through the year.  But given that what happens below the surface is what’s critical to the needs of migrating fish, I argued a canal study was a critical consideration. 

Two generations back a chance to restore fish runs beyond Turners Falls was squandered when the US Fish & Wildlife Service and four state fisheries agencies agreed to steer migratory fish into the chaos of the privately-owned Turners Falls power canal.  A singular New England opportunity to recoup and expand the river’s biodiversity was lost.  Just as in 1980, at best one-fish-in-ten emerges alive upstream there today.  Some years it’s 1-in-100.  That mistake stemmed from a failed quest to create a hatchery-strain of extinct Atlantic salmon here.  As a result, due diligence wasn’t applied to the needs of growing populations of herring, shad and sea lamprey, who would now have to survive a trip through an industrial canal on their spawning runs.  It also scuttled the only natural spawning grounds of the endangered Connecticut River shortnose sturgeon. 

Merriam-Webster defines due diligence as “the care that a reasonable person exercises to avoid harm to other persons or their property.”  Today, after 14 years of power company-subsidized canal studies that remain unpublished, we know scant little about conditions fish encounter throughout that canal.  Save for a few dozen yards at its entrances and exits, two full miles of watery terra incognita lay in between.  That missing knowledge comprises this ecosystem’s black hole. 

Yet with just tidbits of canal study information leaking into the public sphere, there is evidence that canal conditions–and the weeks-long migratory delays fish experience there, are proving lethal.  “Shad are dying in droves in the canal and we don’t know why,” is how one federal Conte Lab researcher responded to a question about mortality in the canal they’ve repeatedly studied using FirstLight funds.  Since dead fish don’t head back to sea to return as repeat spawners, the canal impoverishes a full 172 miles of river ecosystem up to Bellows Falls, VT. 

Thus, I’m proud to have my name listed next to canal hydraulics study 4.2.3.  I believe it represents FERC’s effort to exercise due diligence in getting the information needed to make the best choices in these proceedings.  It certainly represents my own.  FERC’s Ken Hogan has stated that thorough studies and reliable data are what FERC is aiming for as they decide on conditions hydropower interests will have to adhere to as they operate on our river for generations to come.  Anything less would constitute a failure of their public mandate.

 FERC’s Public Comment Period on any of the 39 studies they may require for the relicensing of Turners Falls and Northfield Mountain projects ends December 31, 2013.  Go to www.ferc.gov , and “filing e-comments.”  P-1889 is the Project # required for Turners Falls dam and canal; P-2485 is for Northfield Mountain.

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

Double Standard on the Connecticut

Posted by on 09 Jul 2013 | Tagged as: American shad, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, ecosystem, EPA, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Reservoir, Riverkeeper, Rutland Herald, shortnose sturgeon, Times Argus, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following piece appeared in the Rutland Herald and the Barre-Montpelier Times-Argus during the first week of July.

Copyright © 2013, by Karl Meyer

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

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


                               A River Double Standard

On June 28, 2013, Federal Energy Regulatory Commission Director of Energy Projects Jeff C. Wright ruled against the US Fish & Wildlife Service as it sought two extra weeks to review hundreds of pages of just-released Proposed Study Plans for the relicensing of five Connecticut River hydro projects. “The request for a 15-day EOT to file comments on the licensee’s proposed study plans is denied.”  EOT is FERC-speak for “extension of time.”  Those studies will impact this four-state river for the next 20-40 years. Agencies joining that request included the National Marine Fisheries Service, MA Div. of Fish & Wildlife, The Connecticut River Watershed Council, The Nature Conservancy, Trout Unlimited, the Franklin Regional Council of Governments, NH Dept. of Environmental Service and The Vermont Agency of Natural Resources.

One big reason for that request was the difficulties in evaluating the impacts of FirstLight’s Northfield Mountain/Turners Falls hydro operations on the entire Connecticut River ecosystem.  Beginning last fall, FERC began deviating from its standardized relicensing model when it scheduled public site visits to FirstLight sites weeks before the company released a publicly-required 500-page Pre-Application Document describing its complex pumped storage operations and machinery.

This spring FERC also supported FirstLight’s expedited-request to conduct a series of complicated river flow studies this summer—an allowance falling well outside FERC’s strict licensing timelines.  In doing so they let the company schedule three days of river visits by fed/state agencies smack in the middle of their deadline to comment on FirstLight’s 434-page Updated Proposed Study Plan.  FirstLight released that document June 28th; comments to FERC are due July 15, 2013.  Even after nine meetings with the power company and FERC, many agency representatives continued to decry the lack of critical scientific detail provided in FirstLight documents.  Those were put together by its team of five consulting firms.  Ironically, those handpicked FirstLight firms will conduct the next two years of river studies—the ones meant to protect the river.  A fox and chicken coop analogy applies.

FERC is employing a legal double standard here on the Connecticut.  If you a public agency or citizen seeking protections for the ecosystem—well, even little rules are THE RULES.  At the same time it appears corporations can continuously and sometimes massively ignore federal license requirements with impunity.

In FERC’s own words, the Commission “enforces the conditions of each license for the duration of its term, and conducts project safety and environmental inspections.”  Yet today Holyoke Gas & Electric is half a decade–and counting, in violation of its 2002 agreement to construct facilities to end the evisceration of federally endangered shortnose sturgeon and other “federal trust” fish migrating downstream at their Holyoke Dam facility.  So, why have a license at all? 

Upstream in 2010 GDF-Suez FirstLight dumped some of 45,000 cubic square yards of reservoir sludge directly into the Connecticut at Northfield Mountain over a 90-day period—the equivalent of 40 dump truck loads of muck per day, smack in the middle of fish migration season. Yet in current documents FERC states their inspections have never found FirstLight in violation of its license.

The US EPA found FirstLight in violation of the Clean Water Act in August of 2010 and ordered a massive clean-up, though the ecosystem damage was already done.  In an August 4, 2010 letter EPA sanctioned FirstLight for violating “FERC License No. 2485” and polluting the “navigable waters of the United States.”  A subsequent letter dated August 10, 2013 from FERC’s Biological Resources Branch Chief Steve Hocking to FirstLight Manager John Howard specifically referenced the EPA’s sanctions, directing him to “article 20 of your license.”  Yet there is virtually no FERC mention of that egregious violation in current relicensing documents.

That’s the standard that for-profit companies are held to here.  It rivals the Pirate Code.  Currently there is no watchdog entity on this river willing to go to the mat to protect the ecosystem.  If, like on the Hudson, there was an organization like Riverkeeper—which cites “enforcement” as one of its main responsibilities, these egregious injuries to the Connecticut would not likely stand.  Holyoke Gas & Electric would have been in court long ago for killing endangered sturgeon; and the full range of FirstLight’s lethal impacts on the Connecticut’s migratory fish when all are diverted into their turbine-filled power canal would’ve been fully investigated.  FERC’s inaction is a disgrace.

FERC Director Wright requested that questions regarding that EOT denial go to Ken Hogan at: 202-502-8434, or Kenneth.Hogan@ferc.gov. Ken has presided over the CT River relicensing hearings.  Also, you can find FirstLight’s 434-page “Updated Proposed Study Plan” at: www.northfieldrelicensing.com under Documents.  The public has until July 15, 2013 to send comments on that plan to FERC.  You do that at: www.ferc.gov/docs-filing/efiling.asp .  You must cite FirstLight’s project numbers, P-2485 and P-1889, and be sure to note that you are commenting on the “Updated Proposed Study Plan.”

Karl Meyer is a member of the Society of Environmental Journalists. He lives in Greenfield, MA. Read more at: www.karlmeyerwriting.com

The Connecticut River shortnose sturgeon

Posted by on 21 Apr 2013 | Tagged as: American shad, Atlantic salmon, blueback herring, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, shortnose sturgeon, US Fish & Wildlife Service, USFWS

 

Copyright © 2013, by Karl Meyer

The following piece appeared earlier this April in the Rutland Herald, Vtdigger.org, The Recorder, Daily Hampshire Gazette, Shelburne Falls Independent, and on other sites.

                       The Shortnose Sturgeon and Spring’s Teachable Moment 

There’s a watershed opportunity for teachers investigating migratory fish this spring.  It’s the final season classrooms will raise Atlantic salmon eggs from a massive federal hatchery program, dismantled after 46 years.  It’s a chance to teach kids that “extinct,” in evolutionary biology terms, means exactly that: gone, forever.  It’s a profoundly simple lesson, with ramifications that can be fully grasped in a week.  I’m hoping teachers will put a living dinosaur of a fish in that salmon’s place—one still here, though teetering on the edge of extinction these 46 years: the federally endangered Connecticut River shortnose sturgeon.  As teachable as T. Rex, this marvelously adapted, 3-4 foot fish has survived for 100 million years. 

On April 20, 1967, two federal agencies and four states signed the Cooperative Fisheries Restoration Compact for the Connecticut River.  It specifically targeted American shad and blueback herring, plus salmon–extinct here since Darwin’s birth in 1809. Within two years its emphasis had overwhelmingly veered to conjuring up a new salmon.  Still, with a little help shad and herring populations blossomed.  Combined runs reached 1,000,000 fish in the 1980s; then dropped precipitously.  Bluebacks are now rare as hen’s teeth. 

By 1975, what was then the Federal Power Commission had heard testimony that Long Island Sound had warmed to a point that might prevent cold-water salmon from entering rivers in its basin.  The climate had changed.  Still, in 1980 MA and US Fish and Wildlife Service officials insisted a series of salmon ladders be built, leading all migrants into a power canal at Turners Falls.  It failed instantly; yet skewed logic continued.  In 1983 Congress renamed the restoration The Connecticut River Atlantic Salmon Commission.  It continues today. 

Those extinct salmon had only visited here–the southern tip of their range, for a few centuries.  Importing eggs from Canada and Maine, the program proved futile, costing millions annually.  It left the real problem for native shad, herring and endangered sturgeon—a broken Connecticut River, quietly untended.  Those species had returned here for thousands of years.  Bony-plated sturgeon had been vacuuming-up freshwater mussels eons before the present valley took shape. 

On March 11, 1967, the shortnose was listed as “endangered” in the original Endangered Species Preservation Act.  No one knew how they’d survived, or how many remained.  Shortnose were sometimes landed downstream of the 1849 Holyoke Dam; and a few were recorded upstream below Turners Falls.  By 1980, researchers discovered embryos and larvae upstream–proof shortnose spawned somewhere below Turners Falls.

Beginning in 1990, Dr. Boyd Kynard and colleagues began 17 years of continuous federal and state-funded sturgeon research.  Kynard ultimately uncovered the structure of the population, its migratory patterns, and ancient spawning grounds.  A key finding established that all shortnose head upstream to an ancient spawning pool between Greenfield and Turners Falls known as Rock Dam.  Less than 2,000 survive today.  They exist in two groups of a single genetic population, separated over 150 years ago by the raising of Holyoke Dam—which luckily had left some adults upstream with access to spawning.  Fish trapped downstream were out of luck.  

Today, the bulk of the population lives in the river below Holyoke Dam.  Known as “reproductive nulls,” some 1,500 sturgeon linger in a forced limbo created by agencies charged with protecting them.  If one manages to slip into Holyoke Gas & Electric’s fish lift for a spawning ride upstream, it is trapped and pointedly dropped downstream—per orders of the National Marine Fisheries Service and the MA Natural Heritage and Endangered Species Program.  Surviving for 40 years or more, adults will repeatedly attempt to pass the dam until, genetically unfulfilled, they expire.

NMFS, MA NHESP and USFWS claim this protects sturgeon from being sliced up in HG&E’s turbines, if they return downstream after spawning.  All the while HG&E is 5 years in violation of license agreements mandating construction of safe downstream fish passage.  The Federal Energy Regulatory Commission has done nothing to enforce environmental statutes that were key to Holyoke receiving a new hydro license in 1999.

Today, some 300 sturgeon cling to life upstream of Holyoke.  An unknown number are adults.  Some attempt to spawn near Rock Dam each spring (females spawn once every 5 yrs).   According to Kynard et al, success is far from guaranteed.  Unregulated flows emanating from FirstLight’s Northfield Mountain and Turners Falls dam and canal imperil that endangered process.  Annually, spawning fails 79% of the time at Rock Dam; and 29% of the time at a default site just downstream.  Fertilized embryos are also killed when waffling flows flush them out, or leave them parching on river banks.  Many years, no young are produced.

Laws ignored; habitats decimated, river groups mum: it’s a blueprint for extinction.  Yet, amazingly, our dinosaurs persist. It’s this spring’s teachable moment.  Anyone up to a challenge? 

Karl Meyer’s Wild Animals of North America won a 2008 Teachers Choice Award for Children’s Books.  He lives in 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.

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

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

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

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

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

Here’s how you can tune in:

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

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.

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