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My FERC finding…

Posted by on 21 Jan 2020 | Tagged as: "environmental" species act?, Amherst Bulletin, Connecticut River, Connecticut River ecosystem, Federal Energy Regulatory Commission, FERC Chairman Neil Chatterjee, FERC Commissioner Bernard McNamee, FERC Commissioner Richard Glick, FERC Secretary Kimberly D. Bose, The Recorder, Vermont Digger, VT Digger, vtdigger.org

Photo credit: USGS Conte Lab

Copyright © 2019 by Karl Meyer. All Rights Reserved.

My FERC finding…

On August 11, 2019 I sent FERC Secretary Kimberly D. Bose a request for a rehearing of FERC’s allowance of several transfers of licenses for the Northfield Mountain and Turners Falls Projects. My evidence-based objections were based on the federal Endangered Species Act, specifically under the takings and interference prohibitions in that 1973 law.

Exactly two months ago, on November 21, 2019, FERC made its finding: ORDER REJECTING REQUEST FOR REHEARING. I will note here that I have not updated my blog notes as promised just prior to that time. My sole excuse, which may sound flimsy, is simply this: that finding, issued among a rote list of perhaps 20 others simply noted by project and number, came at a regular meeting of the Federal Energy Regulatory Commission in Washington DC.

I watched the FERC meeting, live, and found the proceedings wholly absurd, insular, insulting to the idea of democracy and fact-based decision-making in a time when planetary systems are failing and a climate emergency is breathing down the neck of this and all future generations.

Perhaps it is no surprise that FERC Chair Neil Chatterjee is a former aide to Mitch McConnell. The Chair seems to run the agency like a kid given the keys to the candy store. Though my decision and a score of others were not mentioned in any specific way, Mr. Chatterjee gleefully boasted of FERC’s sanctioning of two massive LNG EXPORT facilities in Texas. This at a time when–out of the other side of its mouth FERC is bragging that it is a big proponent of energy STORAGE. This is climate denial incarnate.

In my particular case, my request was rejected on technical grounds: “Under Rule 713(c)(2) of the Commission’s Rules of Practice and Procedure, a request for rehearing must include a separate section entitled “Statement of Issues” listing each issue presented to the Commission in a separately enumerated paragraph.20 Any issue not so listed will be deemed waived.21 Mr. Meyer’s rehearing request does not include a “Statement of Issues” and is, therefore, rejected.”

FERC also dismissed my submission of further evidence corroborating ongoing impacts on a federally endangered species—again, not on fact-based findings, but on grounds that my furthering evidence, discovered later, had not been included in my first objections. Apparently, FERC does not allow the interference of witness-based evidence as they hone the narrow logic of their un-vetted decrees. In my case though, it seems my submission presented substantial enough arguments that they at least spent several pages in lame rebuttal after noting that my further submissions were inadmissible:

“In addition, the facts identified by Mr. Meyer in support of his arguments were not raised in his comments in the transfer proceedings, but rather provided after issuance of the Turners Falls and Northfield Transfer Orders. We have previously rejected parties’ attempts to submit new facts and allegations at the rehearing stage because doing so “presents a moving target and frustrates needed finality.”22 Therefore, we also reject Mr. Meyer’s request for rehearing for improperly seeking to enlarge the scope of this proceeding, which is inappropriate at the rehearing stage.”

As far as my finding of these proceedings to be objectionable to the very idea of democracy—and to justice for future generations concerning climate, I must note that FERC Commissioner Bernard McNamee actually referred specifically to the “‘ENVIRONMENTAL’ Species Act” during the proceeding. I wasn’t aware of this new act—but it was actually scrolled, verbatim, across the text feed–on-screen. This is your federal agency, safeguarding and enforcing the laws that will protect future generations. Embarrassed??

One long-standing note on the current make-up of FERC, of the usual 5 commissioners, there are currently only three as of late last year. And, even at this dog-and-pony celebration of burning up yet more ecosystems and draining planetary veins, Commissioner Richard Glick did speak out and decry FERC’s long-standing dereliction of duty in not including the evaluation of climate impacts and green house gas GHG emissions in their greedy corporate math in sanctioning massive new energy projects. At least from a lip-service angle, young people seem to have an ally in Glick.

As with the Impeachment Hearings–beginning this very day, facts and witness evidence seem to have little in common with FERC proceedings and their own version of “just” findings. This is not an agency of the people…

NOTE: directly below is a piece that appeared in The Recorder, Vermont Digger, the Amherst Bulletin, and elsewhere in recent weeks.

Copyright © 2019 by Karl Meyer

The Grinching of the Great River

Each Winter Solstice a few friends and I gather on a quiet bridge to offer a toast honoring New England’s Great River. Lingering above its cold December waters, we send along hopes for the River’s coming year.

As central artery to a 4-state ecosystem and the Conte National Fish and Wildlife Refuge, the Connecticut needs all the help it can get. Just upstream are the grimmest 10 miles of habitat in its entire 410-mile run. Worst are the suctioning turbines of FirstLight’s Northfield Mountain Pumped Storage Project, eviscerating millions of migratory and resident fish year round. Nearer-by are the starkly-dewatered 2-1/2 miles of riverbed dubbed the “By Pass Reach”—ground zero as the sole documented natural spawning site for federally-endangered shortnose sturgeon.

Rinse, kill; repeat has been the daily routine at Northfield since 1972. Formerly running off Vermont Yankee’s excess nuclear electricity, it now operates via massive amounts of imported electricity–basically functioning like a nightmare giant electric toilet. Sucking the river up to its 4 billion gallon reservoir-tank for hours at rates of up to 15,000 cubic feet per second, it kills all life vacuumed up in its vortex. Later, at peak times and peak prices, operators flush that dead water back through turbines, producing a few hours of expensive second-hand juice.

To picture one second of 15,000 cfs suction imagine a 3-story mansion with 7 bedrooms and 8 full bathrooms—filled to the rafters with aquatic life. Now watch it wrenched backward and sucked to oblivion: all fish, eggs, animals and insects destroyed by reversing blades on a twice-through Northfield sleigh ride. Now picture 60 grim implosions each minute, 600 every 10 minutes–3,600 mansions obliterated every hour for hours on end.

A FL consultant’s 2016 study estimated NMPS’s operations resulted in the loss of just 2,200 juvenile American shad. Yet results from a study released in 2018 by the US Fish & Wildlife Service and MA Fisheries & Wildlife estimated that carnage from those same operations actually resulted in the loss of 1,029,865 juvenile shad. Other imperiled migrants include American eel, sea lamprey and blueback herring. Largely unstudied are lethal impacts on 2 dozen resident species. The more it runs, the more it kills.

NMPS has never produced a single watt of its own power. Nor will owners–after bragging to be able to power a million homes for 7 hours, point out they must actually consume the megawatts of some 1.25 – 1.33 million homes in order to do so. It’s a net-loss system, an electric toilet filled by chewing through the core of the S. O. Conte National Fish and Wildlife Refuge.

FirstLight now wants to run NMPS even more—attempting to rebrand its second-hand electric output as clean, renewable energy. And the Federal Energy Regulatory Commission and ISO-New England are doing their best to keep FL’s unholy new vision afloat. It marries ecosystem-destruction with renewable ocean-energy in a corporate-shareholder package to service unprecedented, climate-warming, construction booms in metro Boston, Providence, Worcester and elsewhere. Massachusetts, host to this plant–and as the largest energy-consuming state in New England, ought to be ashamed and brought to task for the climate- and ecosystem-futures of its children.

In the 1980s a grim proposal arose to employ NMPS to suck up more of the river and pipe it to Quabbin Reservoir for use as reserve metro-Boston water. But citizens, states and towns rebelled under leadership from the likes of the late-Terry Blunt of the Connecticut River Watershed Council and Hadley’s Alexandra Dawson of the Conservation Law Foundation. The result was the 1984 MA Interbasin Transfer Act, forbidding the out-of-basin export of river resources until all conservation efforts are first exhausted. Such leadership is sorely missed today.

On December 20, 2018 FirstLight’s Canadian parent-owners quietly spirited their assets out of New England–re-registering them as separate, limited liability corporate tax shelters in Delaware. It was slick timing. Federal fish negotiators were to undergo a government shutdown the next day. Meanwhile FL remained in the middle of a bid to keep operating their US facilities for decades here under new FERC licensing.

Stakeholders didn’t learn of their move until January 8, 2019. Nearly all cried foul to FERC.

Huge concerns included the loss of access to information used for valuations and information assuring FirstLight can and will be held accountable to supply the construction and funds necessary to meet US and state environmental laws–including the Anadromous Fish Conservation Act, the Endangered Species Act and the Clean Water Act under new licensing.

One year later at the Solstice New England’s Great River remains without courageous leadership and in desperate need of a new NGO–one with a fiery legal department.

Karl Meyer’s “River Report” is broadcast regularly on WHMP. He’s been on the Fish and Aquatics Study Team in the “5-year” FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2013. Meyer is a member of the Society of Environmental Journalists. He lives in Greenfield.

CAN NEW ENGLAND’S GREAT RIVER SURVIVE MORE DECADES OF PUMPED STORAGE GENERATION?

Posted by on 12 Mar 2017 | Tagged as: 5-year FERC licensing process, American shad, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Dr. Boyd Kynard, ecosystem, endangerd shortnose sturgeon, EPA, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC licensing process, FirstLight, Montague Reporter, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, shad, shortnose sturgeon, Society of Environmental Journalists, Turners Falls, Turners Falls dam, Vermont Digger, vtdigger.org, WBUR

NOTE: The following piece first appeared on the website of vtdigger.org in late February. It also appeared in print in the Montague Reporter, montaguereporter.org in early March.

Copyright © 2017 by Karl Meyer

Can New England’s Great River survive more decades of pumped storage generation? Long-term FERC licensing could lock out new river-sparing energy storage choices.

Dr. Boyd Kynard, retired federal expert on the Connecticut River’s migratory fish and endangered shortnose sturgeon, tells a story about bass fishing in Massachusetts around 1990. He was drifting near the French King Bridge, a mile downstream of the Northfield Mountain Pumped Storage Station’s subsurface tunnels when he glanced up and realized his boat had switched directions. It was being pulled upstream, “And at a pretty good clip.” Turbines at that Northfield MA plant had sucked New England’s river into reverse for at least a mile. This was nothing new, save that in this instance there was a daytime witness.

October 2, 2010, EPA ordered dredging at the site of Northfield Mountain Pumped Storage Station’s underground suction tunnels on the Connecticut.(CLICK TO ENLARGE, THEN CLICK AGAIN.)

In December a radio feature from Boson’s WBUR entitled “New England’s Largest Battery is Hidden Inside a Mass. Mountain” was rebroadcast widely in the Northeast. Referencing Ben Franklin, James Bond, even the Bat Cave, it painted a rosy future for the 1200 quick-start megawatts stored in a reservoir at the Northfield Mountain Pumped Storage Station. Roaring turbines were noted as company spokespeople staked claim to the plant’s “green” future as they bid to lock-in a new 50 year Federal Energy Regulatory Commission license. The occasional ring of an old phone connected directly to ISO New England–the grid’s “independent system operator,” was described as “the sound of money.”

Altogether missing in that story was NMPS’s violent mining of the Connecticut River. That ecosystem artery was never identified as the sole water source enabling it to regenerate electricity. Prior to Northfield construction the Connecticut had forever run seaward from the Canadian border to the tidal zone near today’s Hartford, CT. But 12,000 years of New England natural history changed in 1972, on the day NMPS came on line.

On January 22, 1974, two years after it began operation using overproduced nuclear megawatts then available on the grid at night to fill a 5 billion gallon reservoir, the Federal Power Commission (today’s FERC) notified Western Massachusetts Electric Company it required their “earliest response” on Northfield’s impacts for a Draft Environmental Impact Statement: “Since the Northfield Mountain Project became operational, which of the conditions described have been observed to produce reverse flows?” WMECO’s lawyers belatedly replied on October 16, 1974, they didn’t have the information. Questions about environmental impacts and reversing rivers went unanswered.

In 1967 a federal Connecticut River migratory fisheries program to restore American shad to historic upstream reaches in Vermont and New Hampshire got underway. That same year the embattled Connecticut River shortnose sturgeon was listed under the Endangered Species Act. Exactly fifty years later recovery goals for hundreds of thousands of spawning shad and thousands of shortnose sturgeon remain utterly unfulfilled. Spawning habitat access for both are impacted by Northfield’s suck and surge flows, which also create daily bank-eroding 4-foot “tides” along this reach, sometimes reaching to 10 feet.

Pictured in a less glowing light, NMPS is a 45 year-old dinosaur–a formerly nuclear-powered, net-loss energy transfer machine hacked out of the bowels of a mountain. With the region’s nukes now shuttered, it runs daily on imported electricity and has never produced a watt of virgin power. Today it’s a quick-start, high-profit operation relying on boatloads of fossil-fueled megawatts purchased in bulk on the wholesale market. Suctioning the river uphill, it later releases those waters down through its turbines in dense pulses—pumping out 25 percent less juice than the virgin power it consumes.

NMPS is not renewable energy, nor anything resembling the public’s idea of hydropower. It reproduces just a fraction of New England’s power at peak times, and peak prices, but can only generate for eight hours maximum. After that it is literally dead, its reserves spent. The Canadian-owned plant must then start consuming juice by reversing its turbines anew, yanking the river backward, sideways, and a mile uphill for hours into its reservoir.

That pumping occurs nightly at rates of up to 15,000 cubic feet per second. Picture 15,000 milk crates filled with a living river–every second for hours at a time. For more than two-thirds of the year the Connecticut’s “natural routed flow”—the water moving into and through this reach, is less than 15,000 cfs. Thus this plant is consuming more water than is entering the river. That’s how to turn an ecosystem on its head. The result is the evisceration of all manner of aquatic life, juiced twice through those turbines—tens of thousands of resident and migrating fish, millions of developing eggs, and their young. There’s nothing more violent you can do to a river.

Now the Canada Public Pension Investment Fund—latest in the decade’s revolving door of four different venture-capital owners of the FirstLight Power Resources-branded plant, is angling to lock those ecosystem assaults in place for another half century through the Federal Energy Regulatory Commission’s 5-year hydro relicensing process.

In its planning stages one model would’ve required Northfield to shut down during fish migration season due to impacts. That didn’t happen. Still, a chance experiment in 2010 gave a belated glimpse of those potential benefits. For half a year, from mid-spring through a hot summer into early November, NMPS sat broken, sanctioned and off-line. But seven miles downstream the migrating shad normally impacted by its violent suck-and-flush flows made great and unexpected gains in tandem with that spring break. Having languished for decades, the federal program to move American shad upstream into Vermont and New Hampshire saw a stunning boost at Turners Falls Dam. Shad passage jumped over 700 percent above the previous ten year average–16,440 shad swam past the dam in 2010, compared to the 2,260 annually over the previous ten years. Though meager, it was by far the best result since MA energy deregulation came to the NMPS reach of river in 1999.

The 5 billion gallon Northfield Mountain Pumped Storage Reservoir, as it sat emptied and idle from May 1st through early November 2010.
(CLICK TO ENLARGE, THEN CLICK AGAIN.)

On that May 1, 2010, NMPS had choked on the tons of silt and eroded riverbanks it constantly sucks into its reservoir. In attempting to clear that mucked-in lake a mile of mud-slumped tunnels resulted. Desperate, they began dumping it directly into the Connecticut at a rate equaling 30-40 dump truck loads a day. FirstLight’s sludge turned a mile of river brown for weeks. A contractor died when a suction hose broke loose.

One of thousands of dump truck loads of sludge the EPA ordered FirstLight to dredge back out of the Connecticut River. (CLICK TO ENLARGE, THEN CLICK AGAIN.)

Severe thunderstorms on May 27, 2010 resulted in tens of thousands of western New England power outages, many lasting for days. Yet as a back-up energy plant, Northfield’s sole output that week was more of the 45,000 cubic square yards of muck they’d eventually dump directly into the river. They succeeded for over 90 days, until they got caught. On August 10, 2010, the EPA issued a cease-and-desist order citing FirstLight for “polluting the navigable waters of the United States” under the Clean Water Act.

Major dredging operations continued for months at Northfield where FirstLight had dumped their sludge in the Connecticut for 90 straight days.(CLICK TO ENLARGE, THEN CLICK AGAIN.)

Throughout NMPS’s half-year off-line–and record-breaking summer heat in the Northeast, the purportedly ever-hungry, ever-fragile grid ISO New England claims makes Northfield’s dense, quick-start functions so indispensible, never faltered or failed—not even when the nearby( now closed) Vermont Yankee nuclear plant went down in June to refuel.

NMPS’s main claim to its indispensability came 14 years ago during the 2003 August Blackout. Its quick start power was employed by ISO New England to smooth out Massachusetts’ reconnection to the New York sector of the Northeast’s mega-grid—which had failed due to a computer glitch in Ohio. That sprawling network would have been reenergized regardless, but Northfield’s dense energy provided a convenient assist and made ISO’s job easier. But are rare-hour emergencies enough to justify more decades of NMPS daily destructive use? In truth–what would amount to virtual energy storage monopoly, need not be locked-in, de facto, by FERC as this region’s energy future for decades to come. There are other options.

“Pumped hydro is the most cost-effective way to store electricity,” that story stated flatly. But in September of 2016 the MA Department of Energy Resources and the MA Clean Energy Center released a study: “Massachusetts Energy Storage Initiative: State of Charge.” It noted the Bay State lags behind in innovation and deployed energy storage, ranking 23rd nationally. However, comparing new storage technologies now available to the costs of pumped storage, it noted three that will all readily out-compete pumped storage costs by 2018: Lithium Ion, Flow Battery and Compressed Air Storage.

These local/regional storage solutions are already coming into use in New England. They create distributed generation and safer, more reliable micro-grids—less vulnerable to mass outages and mega-grid cyber attack and failure. They also create jobs. Certainly they are more attractive to consumers than sending local solar and wind across New England to recharge a river-crippling machine—and repurchase that juice later at inflated consumer prices.

That story mentioned Northfield’s 18,000 panel solar array–enough for a few hundred homes. But that tax-deductable FirstLight solar field actually covers the huge scar leftover from acres of EPA-mandated settling ponds—sludge pools required in 2010 when they had to dredge their mountain of muck back out of the river. Also not mentioned were handsome payments NMPS collects when it chooses not to generate any power. They accrue through a FERC mechanism known as “capacity fees.” If “spot market” prices aren’t sweet enough, FirstLight can simply sit their plant idle, collecting ratepayer cash just for their “capacity” to potentially generate. With NMPS as its chief hydro asset, former owner GDF-Suez once told investors 40% of its annual profits had been realized through capacity fees.

FirstLight’s EPA-ordered sludge settling pools and drying pile at the Rt. 63 site covered by a solar panel installation today. (CLICK TO ENLARGE, THEN CLICK AGAIN.)

Gus Bakas, FirstLight’s Massachusetts operations director, stated his goal for the 45 year-old plant is to someday see it running wholly on “green” power–solar and wind relayed to it from legions of regional rooftop panels and turbines. That would align with Massachusetts’ new “Energy Storage Initiative,” a 10-year effort purportedly aimed at saving ratepayers “hundreds of millions of dollars” while making the grid more reliable and reducing greenhouse gasses. But wind runs strongest at night and is not plentiful in western New England, while all solar is generated by day. With NMPS’s peak-demand profit model based on sucking up bulk power and the river at night, something seems missing from the equation. Unless there are now plans to again run the river backward by day, when migrating fish are most vulnerable to entrainment.

The Federal Energy Regulatory Commission is charged with supplying reliable electricity at fair costs to the public, while fostering competition and protecting against energy monopolies. All licensing decisions from FERC must also comply with federal law including conditions set under the National Environmental Policy Act, the Fish and Wildlife Coordination Act, the Endangered Species Act, and the Clean Water Act. The operation of NMPS continues to prove a stumbling block to the successful execution of these federal acts and policies.

In the near-term, for rare big-grid emergencies, a summer heat-wave or winter cold snap, NMPS remains a credible back-up tool. But Northfield otherwise continues today as an expensive, profoundly-damaging energy relay device whose net-loss operations chew apart a critical four-state artery daily. Given its violent year-round ecosystem impacts, its drag on federal trust and endangered species restoration programs–and the market’s current and emerging alternative energy storage solutions, FERC should not sanction NMPS long-term, as its dominant, de facto, New England energy storage monopoly.

End

Writer and journalist Karl Meyer lives in Greenfield, MA. He has been participating as a stakeholder and member of the Fish and Aquatics Study Team in the five-year FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2013. He is a member of the Society of Environmental Journalists.

Karl Meyer: Connecticut River power storage plant is an ecological, economic and energy disaster

http://www.wbur.org/bostonomix/2016/12/02/northfield-mountain-hydroelectric-station