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

Re: Connecticut River Watershed Council comments on Updated Study Reports
for Projects 1892, 1855, and 1904 as filed with FERC 9-14-15

The Connecticut River Watershed Council (CRWC) is a nonprofit membership organization that has an interest in protecting environmental values that directly and indirectly support the state, regional, and local economies and quality of life throughout the four state watershed.
The interests and goals represented by CRWC include improving water quality; enhancing habitat for fish and other aquatic biota; protecting threatened and endangered species; protecting wetlands; preserving undeveloped shore lands; enhancing public recreation and promoting recreational safety. CRWC works to protect aesthetic values; protect archeological, cultural, and historical resources; foster sustainable economic development, and environmentally responsible energy production.

CRWC has some general concerns that go to the relicensing process. It may seem a small thing, but for the average river user who should be engaged in the use of their river, the titles published on the public project web site are confusing at best. Your average river user would never know when trying to access any of the individual studies that a report entitled “Updated Study Report Volume III – Containing Sub Volumes III.A – III.B” contains reports for studies 13 and 27 when searching the web site. Please add study descriptive information to the titles of the published documents.

CRWC finds that commenting on 33 studies with a tight deadline when virtually none of the studies is complete and even those purported to be complete wait for information from other studies to make them useful and informative, is a less than productive and certainly not a satisfying experience. FERC should adjust the process or the timeline for taking and completing steps so that information gathered from the fieldwork is not seeping out over extended periods.

CRWC is concerned that we do not even know the closing date for when TC must submit complete studies to FERC. We do not know whether to be concerned or not about the length of time available to make our final comments on those studies. We request that FERC consult with the stakeholders to determine a legitimate amount of time between final reports submitted on March 1 and the presumed date of FERC acceptance of the final reports since that is an undetermined period based on the schedule as of now.

In the notes from the October 1 and 2 USR meetings there is no mention of a request made by CRWC of TC that when an individual study relies on information and/or conclusions in other studies that all of the data and field observations from those other studies be presented in the topical study relying on that information. As an example, Study 3 relies on Studies 1, 2, 4, and 5. It should not be necessary for someone reviewing Study 3 to have all four studies open and be cross-referencing between them. If a study relies on data from another study, the topical study should present that data in total in the topical study.

CRWC Study Comments

Study 1 – Historical Riverbank Position and Erosion Study
We know that TC has gather historic riverbank position collection of historic information but we have yet to see any presentation of the gathered information. CRWC cannot verify or deny the initial analysis offered in the report based on what the report presented. Not only does CRWC requests that we have adequate time to review what TC submits but also so do landowners throughout the affected reach of the river, Vernon to Woodsville.

Study 2 – Riverbank Transect Study
The report does not present any of the cross sections results. The three examples offered in detail do not create enough information to assess causes or status of shoreland erosion. The report says three sites of the 21 selected sites show signs of accelerating erosion. The report is silent on the remaining sites with more information to be forthcoming. CRWC requests that FERC allow adequate time for analysis between final reports March 1 and the presumed date of FERC acceptance of the final reports since that is a floating date (TBD) on the schedule right now.
CRWC requests that the study clarify the reasons for differentials in cfs flow values that would trigger additional non-spring runoff high flow event surveys at each of the three hydroelectric dams. The current updated study report states that 35,000 cfs at the Wilder project, 44,000 cfs at the Bellows Falls project, and 49,000 cfs at the Vernon project would trigger additional high flow event surveys (non-spring runoff), but the study fails to provide rational for that differential in flow values.

Study 3 – Riverbank Erosion Study
This like many of the other studies relies on data generated in Study 4 and Study 5 so this study is incomplete. CRWC requests that all data presented in the final report be in a format that the average landowner without sophisticated computer skills or software programs can access and understands what the report presents in order to ascertain the veracity of any conclusions offered in the report. CRWC requests that FERC allow adequate time for analysis between final reports March 1 and the presumed date of FERC acceptance of the final reports since that is a floating date on the schedule right now.

CRWC request that the final report address land uses and the state of the riparian buffer as one of the factors that affects erosion. The draft report does not address that consideration but should.

CRWC requests that the final report address the effects of motorboat wake action have on the shore and wake action’s role in erosion forces acting on the shore.

Study 4 – Hydraulic Modeling Study
CRWC requests that FERC allow adequate time for analysis between final reports March 1 and the presumed date of FERC acceptance of the final reports since that is a floating date on the ILP schedule right now.
CRWC is aware of at least one alternative hydraulic model under development. There is nothing in the report and there was no discussion at the October USR meetings whether or not TC will review, evaluate, or consult with other models before issuing a final hydraulic model report. CRWC requests that CRWC, TC, and other interested stakeholders have access to the other model for evaluation before TC issues the final report.

CRWC requests the study report include characterization of the processes of erosion occurring within the project-affected area. This issue is within the objectives of the study; though it is not touched upon in the study progress, remaining activities, or study results to date, indicating the study ultimately may not address this aspect.

Study 5 – Operations Modeling Study
Since study 4 links to Study 5, one affecting the other as well as several other studies, CRWC requests that CRWC, TC, and other interested stakeholders have access to and a discussion about any other model before TC issues the final report.

CRWC requests that TC fashion produce a model run for true run of river operations. The interim report says that the model can run flow levels different from the five selected years upon which the model is based and run of river flow should be tested to see if it will enhance environmental protections for the river ecosystem and overall reduce erosion.

Study 6 – Water Quality Study
Prior to TC publishing the study, CRWC would request that the study show a correlation of WQ data with TC operations data. We especially would like to see the generation levels charted over the WQ monitoring period.

Study 7 – Aquatic Habitat Mapping Study
CRWC has no comments because we will not be able to assess project impacts until TC completes and publishes Studies 4 and 5 and TC incorporates that information into Study 7.

Study 8 – Channel Morphology and Benthic Habitat Study
CRWC has no comments at this time as we are waiting for relevant studies 1, 2, and 3, 4, and 5 that are not complete. Waiting to present the analysis as part of the Draft License Application is not timely and CRWC requests that FERC allow adequate time for analysis between final reports March 1 and the presumed date of FERC acceptance of the final reports since that is a floating date on the schedule right now.

Study 9 – Instream Flow Study
Since assessing project operation impact on the HSCs is dependent on results of the Operations Modeling Study 5, CRWC does not have comments at this time. CRWC requests that FERC allow adequate time for analysis between final reports expected March 1 and the presumed date of FERC acceptance of the final reports since that is a floating date on the schedule right now in order to complete a time series analysis of various project flow scenarios for each reach including a true run of river flow.

Study 10 – Fish Assemblage Study
CRWC found none of the fish recorded as present during sampling as usual and await the final study with the following comments.
CRWC requests that the study report alter the data represented in table 10-2. The table should include zeros where no fish were identified within a particular reach rather than leaving that field blank. This change would make it abundantly clear whether that the surveyors the reach and no individuals of a particular species were identified, or if the reach was not surveyed for that species, the data did not pass QA/QC standards, etc.

CRWC requests that the study report provide clarity regarding an additional species included in table 10-2. The table includes total catch data for both chain pickerel and northern pike, but also includes total catch data for a third species labeled Esox, which is the genus encompassing the aforementioned species. The report should provide rational as to why a separate third species labeled Esox was not included in the chain pickerel or northern pike total catch counts.

CRWC requests that the study report provide clarity regarding an additional species included in table 10-2. The table includes total catch data for several species encompassed by the genus Lepomis (bluegill) but also includes total catch data for a third species labeled Lepomis. The report should provide an explanation as to why this third species was not included in the total catch data for one of the species encompassing this genus.

Study 11 – American Eel Survey
CRWC requests as we have previously that the study sites for eel expand to include the first impassable barriers up tributaries. Eel congregate at the base of those barriers and it would not be a major effort to do sampling at those few sites. The fact that only two American Eels were captured means that the sampling missed eels and this preliminary report understates their presence in the watershed.

CRWC requests that the study report specify the types of bait used in the eel traps that yielded such low catch productivity.

Study 12 – Tessellated Darter Survey
CRWC awaits the final report.

Study 13 – Tributary and Backwater Fish Access and Habitats Study
The narrative section of the summary of this report for water quality parameters sampled as part of the study should describe the effects of the conditions found whether the WQS have numerical values or not. Readers should not need to flip from values found in this study and the charts related to the fish assemblage study and then to the narrative standards in the VT and NH Water Quality Standards.

TC conducted Study 13 from the period between late July and mid-November 2014. CRWC knows that this is the dry time and for measuring access to a tributary or backwater area starting at the main river that time period makes sense.
However, the study was to look at fish habitat as well as access so CRWC requests TC continue the survey work to look at the effects of water level fluctuations in the setbacks especially along the shoreline.

In the spring, these areas have lots of structure from fallen trees and emerging aquatic plants, depending on the drawdown level the areas have what seems like the proper water depth for fish to spawn, no current to speak of and therefore all of these areas are prime spawning areas for all of the sunfish family and perch. We continue to hear from active fishers that in the early spring the water draw down is affecting fish habitat, especially through desiccation of redds and stranding egg masses on limbs and plants where eggs deposited during high water levels end up high, dry, and dead.

CRWC requests that TC extend the habitat portion of this study to do more fieldwork early next spring (2016) in order to quantify what is persistent antidotal information of dewatered nests and eggs. Depending on the findings, project operations may affect available fish habitat and it would be necessary to look at alternative operating conditions to mitigate the effects.

The fisheries agencies have stated their concern that using a standard of .5 feet depth greater than 25% of the time is not appropriate to select access issues further. CRWC shares their concern that 25% is too high and requests that any location where water depths were

Study 14 – Resident Fish Spawning in Impoundments Study
CRWC is anxious to see the analysis of the WSE information in conjunction with the operations and flow data relative to dewatering nest and egg masses and the possibility that TC could modify future operations to prevent the dewatering of egg masses in setback shore areas.

Study 15: Resident Fish Spawning in Riverine Sections
CRWC requests that the study report include potential explanations as to why the study design yielded no white sucker eggs. It is stated within the study report that a likely explanation for the lack of walleye eggs yielded by the study design was upstream tributary spawning, however no rational as to why there were no white sucker eggs observed is not provided within the report.

Study 16 – Sea Lamprey Spawning Study
CRWC awaits the final report. CRWC finds it interesting that the base of impassable barriers on tributaries were one of the sites where field workers went to look for Lamprey since CRWC is requesting that TC examine these same locations for American Eel and so far, TC refused that request.

Study 17 – Upstream Passage of Riverine Fish Species Assessment
Table 17-1 needs to be reconfigured because by giving just the sum of up minus down fish passage does not give an accurate picture of the total amount of fish movement in the ladders. CRWC requests that TC reconfigure the chart so that it shows a total up stream count and total downstream counts of fish. The chart could still show the net passage figures in the chart as it does now as a matter of interest.

Study 18: American Eel Upstream Passage Assessment
CRWC requests that the study include a description of the methodology for baited eel pots, specifically a list of different baits used within the eel pots and their locations prior to ceasing this method of eel trapping.

Study 19 – American Eel Downstream Passage Assessment
CRWC hopes that TC successfully secured the permissions necessary to bring the eels to the river, that the eels are completely disease free, and that they are still on schedule to complete this study this fall. We await the final report.

Study 20 – American Eel Downstream Migration Timing Assessment
CRWC hopes that TC successfully secured the permissions necessary to bring the eels to the river, that the eels are completely disease free, and that they are still on schedule to complete this study this fall. We await the final report.

Study 21 – American Shad Telemetry Study
We await the inclusion of the relevant data from Study 4 and the final report.

Study 22 – Downstream Migration of Juvenile American Shad – Vernon
CRWC awaits the final report.

Study 23 – Fish Impingement, Entrainment, and Survival Study
CRW awaits the inclusion of the data from Studies 10, 19, 20, 21, 22 and the final report.

Study 24: Dwarf Wedgemussel & Co-occurring Mussel Study
CRWC requests that the study report provide transparency regarding the rational for limiting the scope of the study to the Wilder and Bellows Falls project areas, not to include the Vernon project area within the assessment.
CRWC has recently, as a member of the Fifteen Mile Falls M&E Fund Advisory Committee been party to funding a DWM study on the upper Connecticut River beyond the project area. High water delayed the completion of the study so there is no formal report yet. An informal conversation about the study revealed that the selected transects for that study were not selected parallel but perpendicular to the flow. The field workers in that study found DWM. The original and revised study plan relied on parallel and quadrats study transects. If the current plan design does not give useful information then CRWC requests that TC extend this study through the spring of 2016 and that TC use perpendicular transects in some percentage of the transects selected.

Study 25 – Dragonfly and Damselfly Inventory and Assessment
CRWC awaits the inclusion of data from Studies 4 and 5 and the final report.

Study 26 – Cobblestone and Puritan Tiger Beetle Survey
CRWC awaits the inclusion of data from Studies 4, 5 and 9 and the final report.

Study 27 – Floodplain, Wetland, Riparian, and Littoral Habitats Study
CRWC awaits the inclusion of data from Study 9 and the final report.

Study 28 – Fowler’s Toad Survey
CRWC awaits the inclusion of data from Studies 4, 5 and 9 and the final report.

Study 29 – Northeastern Bulrush Survey
CRWC awaits the inclusion of data from Studies 4, 5 and 9 and the final report, although the inclusion of that data is unlikely to change the result that the survey work found no bulrush in likely habitat locations.

Study 30: Recreation Facility Inventory and Use & Needs Assessment
CRWC requests that the study report include a list of survey & interview questions used throughout the course of this study, as well as demographics data surrounding those who participated in written surveys and/or face-to-face interviews.
The study report states that most public boat launches were below capacity for the majority of the year. The intent of this comment is to request that poor facility maintenance or closure of facilities due to lack of maintenance, as well as severe overcrowding at the few well maintained facilities within the project affected area be taken into account before making this claim.

Study 31 – Whitewater Boating Flow Assessment – Bellows Falls and Sumner Falls
CRWC requests that TC present the survey tool used to determine the value of the experience at the different flow levels in the final report.

Study 32: Bellows Falls Aesthetic Flow Study
CRWC requests that the final study report include any available demographic data and residency status of those who participated in the interviews in this study report.

Study 33 – Cultural and Historic Resources Study
CRWC requests that TC make the reports presented to the state SHPO offices and FERC available on the secure relicensing site.

Thank you for the opportunity to comment on the studies. We will remain hopeful that FERC will respect our request for adequate time to review the final and completed studies.

For the Connecticut River Watershed Council

David Deen Upper Valley River Steward
Chris Yurek EcoAmeriCorps volunteer