November 14, 2014

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

Re: Northfield Mountain Pumped Storage Project No. 2485-063
Turners Falls Project No. 1889-081
Comments on the Initial Study Report dated September 15, 2014
Comments on the 2014 Initial Study Meeting Summary dated October 15, 2014

Dear Secretary Bose,

The Connecticut River Watershed Council, Inc. (CRWC) is a nonprofit citizen group established in 1952 to advocate for the protection, restoration, and sustainable use of the Connecticut River and its four-state watershed. We have been participating in the relicensing of the five hydropower facilities on the Connecticut River since the beginning of the process in late 2012. Below are our comments on the September 14, 2014 Initial Study Report (ISR) and October 15, 2014 Initial Study Meeting (ISM) Summary submitted by First Light.
3.1.1 2013 Full River Reconnaissance Study

CRWC is a member of the Connecticut River Streambank Erosion Committee (CRSEC). We were involved in drafting the letter commenting on study 3.1.1 submitted by CRSEC. We include the letter as CRWC Attachment 1 in order to endorse the comments and include them as part of our own.
In addition to the CRSEC comments, we would like to make the following comments.
Categorical data error.
The Full River Reconnaissance (FRR) is described in the Revised Study Plan, the Quality Assurance Project Plan, and in the Initial Study Report as a “reconnaissance level survey,” not a quantitative study. It is not quantitatively correct to simply treat categorical data as if it were numeric data (directly measured) to calculate the extent within the study area (or percent of total) of the various riverbank characteristics and erosion classifications. One may sum the segment lengths for each category in the study area, but that is not the same as the sum of each characteristic or classification, since the categories do not require a characteristic or classification to be solely present in the entire segment. The data presented in Table 6.1 of the FRR represents the proportion of riverbank classified in the categories, not the proportion of the riverbank exhibiting the various riverbank characteristics and erosion classifications. The FRR analysis frequently treats these data about categories in Table 6.1 as if they were referring directly to characteristics and classifications. This error is most prominent in the report’s assertion that the 84.8% of riverbank in the category of None/little reported in the 2013 FRR represents an increase of 1.5% in riverbank stability and corresponding decrease in eroding banks from the 83.3% of riverbank categorized as None/little in the 2008 FRR (p. ii, v, 6-13, and 6-25). The difference between these studies is the difference in the category None/little, not the difference in length of eroding banks. The conclusion of a 1.5% increase in riverbank stability is not valid based on these data.
Riverbank lengths differ.
Despite being a reconnaissance level survey and not quantitative, the FRR on page 6-25 states, “From 2008 to 2013, the extent of riverbank experiencing None/Little erosion increased from 83.3% to 84.8% (205,153 to 211,158 feet), representing a 1.5% increase in stable length over this 5 year period.” We would like to stress that the lengths given are very much quantitative. They also represent the lengths of all the segments that were classified as “little/none”extent of erosion. One could definitely not conclude that there is any change in the amount of erosion, since extent of erosion is assessed over segments that are not delineated on erosion features. Moreover, the extent of erosion is not the same as the stage of erosion, as implied when the FRR says there is a 1.5% increase in stable length. This statement is meaningless.
The 2008 FRR showed on page 2 of the Executive Summary that the total length of banks including islands is 246,282 ft. We took the GIS data provided to us from the 2013 FRR and found the total length of banks including islands is now 248,958 ft, a 1% difference. This alone shows you how different years measure things differently, despite having the same team do the work. Likewise, the 2007 Field report titled, “Fluvial Geomorphology Study of the Turners Falls Pool on the Connecticut River between Turners Falls MA and Vernon VT” describes on page 28 that two mapping efforts in 1990 provided an opportunity to determine how differences in mapping methods alter the results. Field 2007 also noted “A significant amount of the apparent changes between map years may merely be an artifice of differences in mapping techniques, personnel, and season of mapping.”
CRWC request: In addition to comments and requests in the CRSEC letter, we request that First Light revise the FRR to remove the instances where categorical data are incorrectly analyzed. These statistical errors lead to false or misleading conclusions and assessments. Any estimates of length of riverbank (or percent of total) exhibiting riverbank characteristics and erosion classifications derived from the categorical data must also include confidence intervals or error bars.
3.1.2 Northfield Mountain/Turners Falls Operations Impact on Sediment Transport

As a member of CRSEC, CRWC was involved in drafting the letter commenting on study 3.1.2 submitted by CRSEC. We include the letter as CRWC Attachment 2 in order to endorse the comments and include them as part of our own.
3.2.1 Water Quality Monitoring Study
CRWC expressed concern in our July 28, 2014 comment letter and again verbally at the ISR meeting held on September 30, 2014 about the varying depths and distance from the banks to which the temperature loggers will be placed upstream of the Turners Falls Dam, within the bypass reach, and downstream of the Deerfield River confluence. We continue to be concerned that the depths may be representative of different conditions.
To summarize, according to the revised Study 3.2.1:
• Data loggers in the Turners Falls impoundment “will be deployed in a representative location at a minimum of 4 ft from the surface, but not deeper than 25% depth. To confirm representativeness, periodic measurements of surface, logger depth and near bottom will occur.”
• Loggers in the bypass reach, power canal, and below Cabot Station “will be placed in a representative location in mid-channel or thalweg at mid-depth, or just off the bottom depending on site-specific characteristics. Installation locations will be selected that are low risk for vandalism and will be as unobtrusive as possible to minimize conflicts with recreational use of the river. Areas of low water velocities (~< 1 fps) and significant turbulence will be avoided to the extent possible (MADEP, 2007). All loggers will be encased in perforated pipe, and attached to an immovable object or anchor using polypropylene rope or cable (MADEP, 2009).”

• The loggers between Cabot Station and the Holyoke Dam will “be encased in perforated protective housing, and secured off the bottom of the river with rocks or concrete blocks. The logger assembly will be tethered to an immovable object on shore with polypropylene rope or cable.”
CRWC request: FirstLight should either modify the study plan to make all loggers consistently placed, or propose one location in each of the three study segments that to have duplicate loggers to demonstrate the varying logger locations lead to insignificantly different results.

3.3.7 Fish Entrainment and Turbine Passage Mortality
The ISR for study 3.3.7 indicates Task 1 is mostly complete. The August 14, 2013 Revised Study Plan (RSP) stated that in Task 1, FirstLight “will develop a summary of the life history traits and habitat requirements of key resident species as they relate to these factors affecting entrainment at the Northfield Mountain Project and Turners Falls Project from standard literature sources.”
The key resident species nor any of their traits or requirements were provided in the ISR. However, despite FirstLight’s objection to presenting results before a final report, Section 1.2 of the ISR, under Task 1, says,
“Preliminary results indicate that most of the common resident fish are unlikely to be in the area of the intakes due to their habitat preferences, and therefore, unlikely to be entrained or impinged. Two species, walleye and fallfish, prefer habitat that is found in front of the Northfield Mountain Project intake/tailrace and may be more susceptible to entrainment or impingement depending on length. Most of the common resident fish are likely to sustain their populations even if individuals of the population are entrained because with the exception of largemouth bass, white suckers, walleye, white perch, and fallfish can double their numbers every 1.4 to 4.4 years (species summaries accessed at www.fishbase.org, 2012) and are not isolated populations due to the presence of upstream and downstream fish passage facilities.”
Stakeholders are not able to evaluate such a statement when additional data are not provided. Stakeholders have to wait until March 2016 for this final report to be submitted. An ISR and/or the USR next year is an appropriate time to discuss species and methods so that stakeholders can get a sense of how the study is progressing.

3.3.9 Two-dimensional Modeling of the Northfield Mountain Pumped Storage Project Intake/Tailrace Channel and Connecticut River Upstream and Downstream of the Intake/Tailrace.

Three transects vs. four
FirstLight explained that it did not add a fourth transect as required in the September 13, 2013 Study Plan Determination 1 because the intake structure extends out under water to be close to Transect 1 shown in Figure 3.3.9-2 of the RSP. It is not clear to us how the stakeholders will understand velocity conditions experienced by fish in the large area that is typically underwater between transect 1 and the end of the wetted area at the eastern end of the tailrace.
Vector Maps
The ISM Summary leaves out a detail on page A-8. I asked if the consultant could make vector maps with vector arrows in the study reach of the Connecticut River (5km upstream and downstream of the Northfield Mountain tailrace). FirstLight’s consultants said it wouldn’t be 3D, but they could provide arrows showing which way the river was flowing at various flows and turbine production runs. I said that would be very helpful, and there was wide agreement in the room from stakeholders that these kinds of maps would be useful. The ISM Summary merely says, “Gary explained that only two-dimensional modeling was being done for the Northfield Mountain intake and Impoundment discharge area.” This indicates no commitment to make the vector maps.
It is very important that we see arrows for the direction of the Connecticut River in the vicinity of the Northfield Mountain tailrace. That was one of the main purposes of CRWC’s study request in the first place. It is important to understand river flows under pumping and generating conditions from a fisheries, erosion, as well as a recreation standpoint, from our perspective.
In the past, FERC has indicated an interest in the subject of flow reversals stemming from the operation of Northfield Mountain. Exhibit W to the 1972 Application for Relicensing for the Turners Falls Project submitted by Western Massachusetts Electric Company (WMECO) discussed flow reversals on pages 19 and 20, and Figure 5 to Exhibit W shows flow velocities in the vicinity of the Northfield Mountain tailrace under a river flow of 5,000 cfs and a pumping condition of 12,000 cfs. However, the analysis mainly considered Northfield pumping situations, not generation. A letter from the Federal Power Commission to WMECO dated January 22, 1974 requested more information on flow reversals. A response from WMECO to the Federal Power Commission dated March 12, 1974 indicated that WMECO was planning to conduct a study that summer to answer the questions in the January 22, 1974. WMECO indicated it would submit the study when complete. CRWC could not find any entries in the FERC e-library regarding the submittal of this study. Moreover, the weekday and weekend pattern of pumping and generation described in the 1972 Exhibit W is no longer applicable.
CRWC request: In the August 14, 2014 RSP, it states that the final report will contain, “Vector maps showing the magnitude and direction of water velocities.” The final report for study 3.3.9 should specifically have vector maps showing the entire study stretch (5 km above and below the Northfield Mountain tailrace) of the Connecticut River under various river flow and pumping and generating conditions.

3.3.12 Control Gate Discharge Events
CRWC reviewed the report provided in the ISR as well as the updated tables presented as Attachment F in the ISR Meeting Summary.
It is useful to see the flows in Tables 4-1b and 4-2 and how often these occur during emergency and non-emergency events. What would be most useful to CRWC is to know from fisheries agencies what flows are of a concern, and then have a table showing all the data for those flows. For example, Table 4-2 presents periods when more than four spill gates were open. But are flows of interest experienced when there are 1-4 gates open, and if so, how often? Knowing the reason for each non-emergency spill gate release could also help stakeholders understand which releases could reasonably be delayed or modified to minimize impacts on shortnose sturgeon in the future.
Tabular information about flows at the sluice gate and reason for opening (trash or otherwise) would be helpful.
As for the question about whether or not field studies are necessary, CRWC recommends FirstLight provide all data needed for discussion, then schedule a meeting or conference call of stakeholders to discuss this matter in more detail.
3.6.1 Recreation Use/User Survey
As noted during the ISR meeting, the user contact surveys did not implement FERC-required changes until August of 2014. This missed a large part of the peak summer season, and most or all of the winter ski season. CRWC continues to be concerned about this omission, despite FirstLight assuring us that it will have no effect on study results.
The residential abutter survey was mailed out on July 30, 2014, rather than in the spring as stated in the RSP. After CRWC received some communications from abutters that they either did not receive the letter or were given only a few days to fill out the form, CRWC requested a copy of the cover letter to the survey. The letter and survey were apparently sent by certified mail, meaning recipients needed to go to the post office to pick it up. The letter requested a response by August 11 2014, less than two weeks after the letter was sent out. Given August being a vacation month, and the added detail of needing to pick up the certified letter, it is likely that abutters did only have a few days to return the form.
The final report for this study should show a diagram of where the pressure tube traffic counters were placed at each site. During a visit to the Poplar Street parking area in August 2014, I noticed that the pressure tube counter was located in a section of the parking lot that most people would never drive over; it was located very close to the river and the vast majority of parking would take place farther away from the river. If the pressure counter was never moved all season, it will need to be re-done in 2015.
CRWC recommendations: User contact surveys should be re-done from January to August 2015 with the full set of FERC-required questions. The pressure tube counter should be re-done at the Poplar Street launch in 2015.

3.6.2 Recreational Facilities Inventory and Assessment
This is a completed study. Though the RSP stated, “the bulk of this study was conducted in the summer of 2012,” that was not the case. With the exception of three sites, all sites were inventoried in the off-season by the same 2-person team during October 15-17, 2011, well before the relicensing studies had been drafted or approved. On October 16, 2011, 12 sites were inventoried. Given the length of daylight in the middle of October and drive time between sites ranging from the Vernon Dam to Unity Park in Turners Falls, it appears the team spent less than an hour at each site. One site was entirely left out, the fishway viewing area. The work done was incomplete and it was done when the surveyors would not have seen peak use.
Site 11: Boat Tour and Riverview Picnic Area. The condition of the bathrooms was not given. They were probably locked at the time of the survey.
Site 14: Cabot Camp Access Area. A building at the site is mentioned as being not open to the public. What is this building currently used for, and what was it used for in the past?
Site 15: Barton Cove Nature Area and Campground. The survey was done when the facility was closed. No information is filled in the field sheet for this site under “site facilities” – no mention of showers or the condition they were in, no mention of grills, picnic tables, or parking areas, or the condition of tem.
Site 16: Barton Cove Canoe and Kayak Rental Area. The survey was done when the facility was closed The section of the report with the field forms attaches the Barton Cove Campground and Canoe/Kayak Rental Rates for 2011. This form is 3 years out of date. The company no longer provides the $30 upriver shuttle, so it should not be assumed that this service is still in place. What other details are out of date?
There is no mention that this site is the take-out location for portage around the dam. Is there signage indicating this? Is there a phone number provided, a phone provided, or information about how to get portage transport at this site?
Site 17: (Barton Cove) State Boat Launch. No information is provided about the season that the dock is installed at the site. There is no information about the sign/kiosk at the site. The form for this site was filled out on October 16, 2011, well past peak use time. Even though the text in Section 5 states that there is a portable toilet that is seasonal, the form said that sanitation facilities were, “maybe portable – pulled already.” Predictably, there was no evidence of overcrowding, even though I have heard stories of vehicles being parked out on Route 2 and getting tickets. Barton Cove is used quite heavily for ice fishing in the winter. How do people get their fishing shacks out on the ice? Is the gate opened in the winter, or is the area accessed somewhere else?
Site 20, Gatehouse Fishway Viewing Area. “The condition of the public viewing facilities could not be rated since the inside of the facility was not open during the inventory site visits.” FirstLight could have given the keys to the surveyors, or the consultant could have paid a visit to this facility during the month it is open.
Site 23: Cabot Woods Fishing Access. The site description states, “The access road along the canal is open to the public and is used for sightseeing.” Note: this access road is used for fitness walking, dog walking, roller blading, bird watching, and bankside fishing in the canal. The field sheet indicates a flat gentle slope to the water. That may be true for the water in the canal, but not for the water in the bypass channel. The trails down to the water in the bypass channel are eroded and not maintained. The bypass channel is frequently used for informal swimming, something that would not have been determined during the October 17, 2011 site visit to fill out the form.
Site 24: Turners Falls Canoe Portage. This site assessment would be better broken into site 16 for the take-out and site 24, which is the Poplar Street boat launch. The Poplar Street boat launch is also used as a put-in for paddling between Turners Falls and the Sunderland Bridge, the only section of river with speed limits for motor boats and a ban on personal watercraft. The field sheet says it has 4 spaces, but it has more than 4. Because parking spaces are not marked, it appears the person completing the survey may have mis-interpreted the location and configuration of parking. The site condition sections says, “The portage trail at the put-in site is currently functional, but as there have been no improvements to the put-in, no condition assessment was made of this area.” This statement is astounding. Why would no condition assessment be made if there have been no improvements? This put-in is steep, eroded, and in poor condition. The field form indicates severe compaction, moderate erosion. There would also likely be no evidence of overcrowding when the survey was completed on October 17, 2011.
CRWC request: CRWC requests that closed more up to date information be collected during times of peak usage, that a survey be completed of the fishway viewing area, and that more thoughtful “assessment” of the sites take place.
3.7.3 Traditional Cultural Properties Study
CRWC hopes that FERC and FirstLight can broker a conversation with the tribes to allow for adequate consultation. The study due date can be extended beyond the first quarter of 2015 to accommodate consultation.
Lastly, we are aware that the Massachusetts Department of Fish and Game has submitted a study request for Habitat Assessment and Surveys for State-listed Mussels in the Connecticut River, and we are supportive of that request.
We appreciate the opportunity to provide comments on the ISR. We also look forward to receiving FERC’s process plan to keep track of the varying due dates and comment deadlines for FirstLight’s 38 studies.
Sincerely,
Andrea Donlon
River Steward

ATTACHMENTS

CRWC Attachment 1
CRSEC comment letter on Study 3.1.1
CRWC Attachment 2
CRSEC comment letter on Study 3.1.2