Appendix

CRWC Study Requests

TABLE OF CONTENTS

CRWC Study Request #1. Water Quality Monitoring Study 2
CRWC Study Request #2. Model River Flows and Water Levels Upstream and Downstream from Fife Brook Dam and Integrate Project Modeling with Upstream and Downstream Project Operations 5
CRWC Study Request #3. Instream Flow Habitat Assessment Downstream of Fife Brook Dam 8
CRWC Study Request #4. Entrainment of Riverine Fish from the Deerfield River Into the Bear Swamp Pump Storage Facility and Fife Brook Dam 11
CRWC Study Request #5. Aquatic Mesohabitat Assessment and Mapping 15
CRWC Study Request #6. Fish Assemblage Assessment 17
CRWC Study Request #7. Abundance of naturally reproduced trout and distribution of spawning areas in the Deerfield River below Fife Brook Dam. 21
CRWC Study Request #8. Impacts of Water Level Fluctuations on Riparian and Aquatic Vegetation Including Invasive Species and their Associated Habitats in the Fife Brook Impoundment and 17-Mile Reach Downstream of Fife Brook Dam 24
CRWC Study Request #9. Baseline Study of Terrestrial Wildlife and Botanical Resources 28
CRWC Study Request #10. Baseline Mussel Survey 31
CRWC Study Request #11. Controlled-flow Recreation Study 33
CRWC Study Request #12. Recreation Site Inventory, Use, and Needs Assessment 36
CRWC Study Request #13. Economic Analysis of Project Operations and Recreation 41

CRWC Study Request #1. Water Quality Monitoring Study
Goals and Objectives
Determine the current water quality of the Deerfield River within the area affected by Project operations. The results of the study should provide information sufficient for stakeholders to understand water quality conditions at the project. The study plan should be developed in consultation with the U.S. Fish and Wildlife Service (FWS), the Massachusetts Department of Environmental Protection (MassDEP), and stakeholder groups.
The specific objectives of this study are as follows:
• Characterize water quality upstream of the Project to the highest pool elevation of Fife Brook impoundment and downstream to the boundary of the highest pool elevation behind Deerfield No. 4 station.
• Evaluate the potential effects of project operation on water quality parameters such as temperature and dissolved oxygen in conjunction with various other water uses.
• Collect dissolved oxygen (DO) and temperature data during the spring through fall period and under various hydropower operating conditions at the Bear Swamp Project.
Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in protecting the water quality of the river water to maintain its status as a Class B cold water resource, as designated by Massachusetts Department of Environmental Protection, 314 CMR 4.06(5). Class B rivers are assigned the designated uses of habitat for fish, other aquatic life and wildlife, and for primary and secondary contact recreation, 314 CMR 4.05(3)(b). Class B waters must also have consistently good aesthetic value and meet minimum criteria for numerous water quality indicators to achieve compliance with the standards set forth in the regulations. The anti-degradation provisions of 314 CMR 4.04 require protection of all existing and designated uses of water bodies, and maintenance of the level of water quality needed to protect those uses. The Massachusetts Surface Water Quality Standards (314 CMR 4.02) defines cold water fisheries as waters in which the mean of the maximum daily temperature over a seven day period generally does not exceed 68° Fahrenheit (20° Celsius) and, when other ecological factors are favorable (such as habitat), are capable of supporting a year-round population of cold water stenothermal aquatic life such as trout (salmonidae). Waters with a cold water designation have a 6.0 mg/l dissolved oxygen standard. The information resulting from this study will help ensure that the operation of these projects does not degrade water quality in the Fife Brook impoundment and reaches downstream.
Existing Information and Need for Additional Information
The PAD provides a summary of existing water quality data. While a number of monitoring efforts have taken place and include sample sites within the project boundary, none of those studies were designed to comprehensively investigate whether all relevant project areas currently meet Class B standards. The Massachusetts DEP’s Deerfield River watershed assessment monitoring occurred in 2000 and only had three sampling events just downstream of Fife Brook Dam. An earlier effort in 1995/1996 produced 9 sampling events collected from two sampling locations. A volunteer monitoring program by the Deerfield River Watershed Association produced two sampling events in 2001/2002. Toxicity testing results taken for the Monroe Wastewater Treatment Facility in 1999/2001 did not include dissolved oxygen. Frost and Easte (1977) provide a historic comparison of water temperature and dissolved oxygen readings measured just before and just after the Bear Swamp facility was installed. River fluctuation happened in a weekly pattern that does not exist now, and minimum flow requirements have been increased since the 1970’s.
No directed, site-specific surveys have been conducted to determine whether waters within the Project area meet State standards. This information gap needs to be filled so that resource agencies can evaluate properly the potential impact of project operations on water quality.
Nexus to Project Operations and Effects
The Fife Brook Dam is located 4.2 miles downstream from Deerfield Station No. 5. It creates an impoundment of unknown length and depth where there would naturally be a free-flowing river. The dam operates in a run-of-release system, in response to regulated, peaking inflows from the immediately upstream Deerfield No. 5 station, which is owned and operated by TransCanada Hydro Northeast Inc. Allowable headpond fluctuations to use the Fife Brook impoundment as the lower reservoir for Bear Swamp pumped storage are up to 40 feet, with proposals to continue as such. The below-project flow requirement is equal to 125 cfs. It is unknown whether the impoundment exhibits stratification. Water quality can be affected by the operating regime of a hydropower project. Past studies have shown dissolved oxygen saturation as high as 99%.
CRWC requests that the applicant conduct a water quality survey upstream of the Project to the highest pool elevation of the Fife Brook impoundment and downstream along the Deerfield River to the boundary of the highest pool elevation behind Deerfield No. 4 station in order to determine whether state water quality standards are being met under all currently-licensed operating conditions (i.e., during periods of generation and non-generation). Results of the survey would be used, in conjunction with other studies requested, to determine an appropriate below-Project flow prescription and to recommend an appropriate water level management protocol for controlling impoundment fluctuations.
Proposed Methodology
Water temperature and DO measurements (concentration and percent saturation) should be collected from a minimum of six locations: 1) at the highest pool elevation of Fife Brook impoundment, 2) at a deep location within the Fife Brook impoundment, 3) on the Deerfield River just downstream of Fife Brook dam, 4) in the Zoar area of the Deerfield River upstream of the confluence with the Cold River, 5) the Deerfield River approximately 1-2 miles downstream of the confluence with the Chickley River (near the USGS Charlemont gage would be a site to consider), and 6) just upstream of the boundary of the highest pool elevation behind Deerfield No. 4 station and one halfway between the last two. In order to ensure that data are collected during a time of important biological thresholds and anticipated “worst case” conditions for dissolved oxygen (low flow, high temperature, antecedent of any significant rainfall event), we recommend deploying continuous data loggers at all locations, with biweekly vertical profiles taken at the deep impoundment location from April 1 through November 15. Loggers should be placed in a consistent manner at all sites. Biweekly pH and specific conductance readings should be taken at all locations. Results should include date, time of sampling, sunrise time, GPS location, pumping/generation status at Bear Swamp and Fife Brook, and precipitation data should be provided with the data.

The study plan must include a section on quality assurance and quality control.
If river flow and temperature conditions are representative of an “average” or “low” water year, then one year of data collection should be sufficient to perform the study. If conditions are not representative (i.e., a “wet” or cool year) then a second year of data collection may be necessary.
Level of Effort and Cost
CRWC estimates that the cost of conducting this study from May 1 through November 1 will be $30,000-50,000.
In the PAD, the applicant proposes to assess the effects of the Fife Brook Development and Bear Swamp Pump Storage Development operations on water quality by monitoring water temperature, dissolved oxygen, percent saturation, pH and specific conductance at locations within approximately 7.5 miles downstream of Fife Brook. We believe the effects of this Project extend to the Deerfield No. 4 station, some 17 miles downstream of Fife Brook.

CRWC Study Request #2. Model River Flows and Water Levels Upstream and Downstream from Fife Brook Dam and Integrate Project Modeling with Upstream and Downstream Project Operations
Develop a river flow and operations model designed to evaluate the hydrologic changes to the Deerfield River caused by the physical presence and operation of the Fife Brook and Bear Swamp Pumped Storage (BSPS) developments, and the interrelationships between the operation of Fife Brook/BSPS and the Deerfield River Project (FERC No. 2323) facilities upstream and downstream. The flow study should assess the following topics:
1. Conduct quantitative hydrologic modeling of the hydrologic influences and interactions that exist between the water surface elevations of the Fife Brook impoundment (lower reservoir) and discharges from the Fife Brook and BSPS generating facilities and the upstream and downstream hydroelectric facilities. Data inputs to and outputs from the model(s) should include:
a) discharges into the Fife Brook impoundment from the Deerfield River Project’s Deerfield No. 5 development;
b) withdrawals from the Fife Brook impoundment by BSPS;
c) discharges to the Fife Brook impoundment by BSPS;
d) existing and potential discharges from the Fife Brook development (generation, recreational releases, and spill flows);
e) existing and potential water level fluctuation restrictions (maximum and minimum pond levels) of the Fife Brook impoundment and flows downstream of Fife Brook dam; and
f) existing and potential required minimum flows and/or other operation requirements at each of the upstream projects.
2. Document how the existing outflow characteristics from the Deerfield No. 5 facility affect the operation of the Bear Swamp Project, including downstream flow releases and Fife Brook impoundment levels.
3. Document how the existing Fife Brook and Bear Swamp operations affect the Deerfield River from Fife Brook dam downstream to the upstream extent of the Deerfield River Project’s Deerfield No. 4 impoundment.
4. Assess how recreational use of the Deerfield River (paddling, floating, angling) is impacted by flows under a range of conditions.
Goals and Objectives
Determine the extent of alteration of river hydrology caused by operation of the project and the interactions between upstream project operations, Bear Swamp Project operations, and downstream operations at Deerfield No. 4. The models will provide necessary information on what changes can be made to flow releases and/or water levels restrictions at the Fife Brook and BSPS developments, and how those changes affect downstream resources.
As other specific operational modifications at the Fife Brook and/or BSPS developments are identified based on results of other requested studies, these desired conditions will need to be input into the models to assess how each potential change at one development affects the operations of the other development and the implications of those changes on other resources and/or the ability to achieve desired operational changes at each development.
Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in balancing the protection of water quality, aquatic habitat, natural flows, and recreational use of the river with the use of the river for power generation.
Existing Information and Need for Additional Information
Available information in the PAD does not indicate how project operations have altered downstream hydrology, which may affect riverine fish, macroinvertebrates, rare, threatened, and endangered species, aquatic plants and other biota and natural processes in the Deerfield River from below the Fife Brook Dam downstream to the Deerfield No. 4 facility.
In the PAD, BSPC indicates that Fife Brook operates in a run-of-release mode, reacting to and passing inflows from TransCanada’s upstream hydropower facilities and that Bear Swamp operations have no effect on Deerfield River flows upstream and downstream of the BSPS and Fife Brook developments. No information on the frequency, timing or duration of reservoir fluctuations is provided, nor is the extent of upstream backwatering during pumping and generating. Likewise, the PAD contains no data on the extent of water surface elevation fluctuations downstream of Fife Brook Station. Figure 4.4-2 indicates that outflow peaks from Fife Brook may be lower than inflow peaks from TransCanada, but only two months from a single year of data are shown. Figure 4.4-3 from the PAD re-enforces this observation, showing inflow and outflow at Fife Brook (for two years only), however the scale of this figure makes it hard to see much detail.
Article 401 in the 1997 Order Amending Bear Swamp’s Project License requires a minimum flow of 125 cfs as measured below the dam for the protection and enhancement of fishery resources in the Deerfield River. Article 404 requires whitewater boating releases from Fife Brook of 700 cfs for 3 continuous hours on 50 weekend days and 56 weekdays between April 1 and October 31. After complaints about minimum flows, a gage was installed below Fife Brook but that gage was ruined in Tropical Storm Irene. Anglers complain that releases strand anglers on one side of the river. BSPC states that it increases flows and holds them for 15 minutes for safety, yet no supporting data are provided to validate this statement.
Operations, water surface elevation and flow information is needed to better understand the impact of operations on recreational uses of the river and whether or not modifications can be made to improve river habitat and river uses. The PAD provides no information regarding how project operations affect fisheries resources or recreational use. The requested hydraulic and operations models will allow for testing different scenarios that will aid in understanding if, and to what extent, the Bear Swamp Project has the ability to re-regulate to benefit fish and wildlife resources within the project-affected area.
Nexus to Project Operations and Effects
The Bear Swamp Project is currently operated with a continuous minimum flow of 125 cfs. The project operates as a daily peaking project, often with large, rapid, daily flow fluctuations between the minimum and project capacity (1,400 cfs). In addition, the Fife Brook Dam headpond (also known as the lower reservoir) elevation fluctuates 40 feet (830 feet msl to 870 feet msl) as does the upper reservoir of the Bear Swamp Pumped Storage (BSPS) development (from 1,600 feet msl down to 1,550 feet msl). These changes affect fish, wildlife and their habitats within the project-affected reach. Project operations and potential changes to operations to mitigate impacts are influenced by inflows and operations of upstream peaking projects and the Bear Swamp Project operations. Results of river flow and project operations analyses will be used to develop flow-related license requirements and/or other mitigation measures (e.g. angler safety).
Proposed Methodology

CRWC proposes that the study methodology be similar to that used in studies 3.2.2 and 3.8.1 in the Turners Falls and Northfield Mountain relicensing effort currently underway on the Connecticut River in Massachusetts. Both of those studies were approved, with modifications, by the Commission in its September 13, 2013 Study Plan Determination letter; therefore, the methodology is consistent with accepted practice.

The purpose of the hydraulic model is to determine, for a given flow, the corresponding water surface elevation at a given location within the river, as well as water depth and mean channel velocity. The one-dimensional HEC-RAS can be run in both a steady state mode and an unsteady state mode.
River level loggers will need to be placed within the study area (from the upstream extent of the lower reservoir downstream to the head of the Deerfield No. 4 headpond). Past project operations (at a sub-hourly time step) for 2005 through 2014 should be used in the model. Past project operational data should also be provided and summarized to stakeholders as part of a report. Any proposed modifications to facility operations should be identified and modeled.
The simulation model (HEC-ResSim) will be used to evaluate the impacts of current and potential alternative modes of operation in the project area on the timing and magnitude of river flows. Output from the model will be used in other studies to evaluate the impact of current and potential alternative modes of operation on water surface elevations and aquatic habitat.
Level of Effort and Cost

Level of effort and cost of model development are expected to be moderate but to be valuable in developing license conditions. The model(s) will need to be run under various scenarios throughout the relicensing process to assess the implications of any changes to the operations. Therefore, ongoing consultation and re-running of the model(s) are likely to be needed throughout the relicensing process. The modeling exercise will also require coordination and cooperation between BSPC and the upstream licensee to assure that the model inputs and outputs can be accurately related.
FirstLight has said that their study 3.2.2 will cost $100,000-120,000 and study 3.8.1 will cost $100,000-125,000. Because the Deerfield River is smaller than the Connecticut River, flows coming from upstream are more straightforward, and Fife Brook does not have a canal system, we would expect the costs for this study to be significantly lower than the studies at Turners Falls and Northfield Mountain. The U.S. Fish and Wildlife Service (USFWS) estimates that the requested study would cost $150,000 to $200,000.
The applicant has proposed no studies to address this resource concern. The water quantity and operations study that BSPC proposes will only characterize flow fluctuation, attenuation and travel time patterns in the 7.5 mile long reach downstream of Fife Brook Station under existing operations. It would not provide the ability to model different operational scenarios.

CRWC Study Request #3. Instream Flow Habitat Assessment Downstream of Fife Brook Dam
Conduct an instream flow habitat study to assess the impacts of the range of the proposed project discharges on the wetted area and optimal habitat for key species. The study should include non-steady flow approaches to assess effects of within-day flow fluctuations due to peaking power operations on target fish species and benthic invertebrate communities. Target fish species potentially include brook trout, brown trout, rainbow trout, longnose sucker, fallfish, and white sucker.
Goals and Objectives

The goal of this study is to determine an appropriate flow regime that will protect and enhance the aquatic resources from the Fife Brook Station tailrace downstream to upper end of the Deerfield River Project’s Deerfield No. 4 impoundment. Specifically, the objective of the study is to conduct an instream flow habitat assessment of the impacts of a range of flows on the wetted area and optimal habitat for key species, including the impacts of hydropeaking flow fluctuations on the quantity and location of suitable habitat.

The study should include non-steady flow approaches to assess effects of within-day flow fluctuations due to peaking power operations on target fish species and benthic invertebrate communities. Target species potentially include brook trout, brown trout, rainbow trout, longnose sucker, fallfish, white sucker and benthic macroinvertebrates including mussels.

Relevant Resource Management Goals

Not applicable. Requester is not an agency or Indian tribe.

Public Interest Consideration If Requester Is Not a Resource Agency

Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in protecting aquatic habitat in waters in the Commonwealth of Massachusetts, particularly in coldwater rivers and streams.
Existing Information

In the PAD, BSPC provides no information on the fish assemblage in the riverine reach downstream of Fife Brook Dam other than stating that the Massachusetts Division of Fisheries and Wildlife (MADFW) stocks adult brown and rainbow trout in the reach to support its management as a catch-and-release fishery. Limited information exists on the adequacy of the existing minimum flow regime to protect water quality and aquatic life. Further, the PAD contains no information regarding how project operations have altered downstream habitat quantity and quality important to fish, macroinvertebrates, aquatic plants and other biota and natural processes in the 17-mile-long stretch of the Deerfield River from below the Fife Brook Dam downstream to the impoundment of the Deerfield No. 4 development.

Surveys of macroinvertebrates in the Deerfield River below the Fife Brook dam (Cole 2007 and 2014) have shown a change in that community with distance downstream of the dam. Mayfly and stonefly taxa that were located in the lower sampled reaches were not present below the dam or approximately 2.5 miles below the dam.
Nexus to Project Operations and Effects

The Project is currently operated with a minimum flow release that was not based on biological criteria or field study. Further, the project generates power in a peaking mode, resulting in significant within-day flow fluctuations between the minimum and project capacity on an hourly or daily basis. Large and rapid changes in flow releases from hydropower dams are known to cause adverse effects on habitat and biota downstream of a project (Cushman 1985; Bain et al. 1988; Blinn et al. 1995; Freeman et al. 2001; Layzer et al. 1989). There are more than 17 miles of lotic habitat below the project’s discharge that are impacted by peaking operations at the Fife Brook Station. This section of the Deerfield River contains habitat that supports native riverine species. While the existing license does require a continuous flow of 125 cfs below the dam, this flow has yet to be shown to be sufficiently protective of the aquatic resources in this substantial reach of river, especially in the context of the magnitude, frequency, and duration of changes in habitat that likely occur between minimum and generation flows.

Results of the study will be used by agencies and stakeholders to determine an appropriate flow recommendation that will protect and/or enhance the aquatic resources below the Project.
Proposed Methodology

In-stream flow habitat assessments are commonly employed in developing plant operational regimes that will reduce impacts or enhance habitat conditions downstream of hydroelectric projects.

Given the length of the river reach (17 miles) impacted by project operations, we believe a study methodology that utilizes an IFIM approach is appropriate for this site. This same protocol currently is being used in the relicensing proceedings for the Connecticut River hydropower projects (FERC Nos. 1889, 1892, 1855 and 1904). The Commission’s Study Plan Determination letters to FirstLight and TransCanada dated February 21, 2014 accepted the proposed studies (FirstLight’s with modifications); therefore the methodology is consistent with accepted practice.

Habitat in the study area first must be mapped at a sufficient level of detail to spatially delineate different mesohabitat types for the purposes of transect selection. At a minimum, the study design should involve collecting wetted perimeter, depth, velocity, and substrate data along transects located in the reach of river below Fife Brook Station. The measurements should be taken over a range of test flows. This information then should be synthesized to quantify habitat suitability (using mutually agreed upon HSI curves) of each test flow for target species and life stages identified by the fisheries agencies. Habitat modeling using standard PHABSIM 1-dimensional modeling is acceptable for the river channel downstream from the Route 2 Bridge. The area from the Fife Brook Station discharge to the Rt. 2 Bridge should be modeled using 2-dimensional (2D) modeling to better characterize flows and velocities in this high quality area.

The types of data collected with this study should be sufficient to perform a dual-flow analysis and habitat time series or similar approaches that will permit assessment of how quantity, quality and location of habitat for target species changes over a range of flows between existing minimum flow and maximum project generation flows.
Level of Effort and Cost

Field work for instream flow studies can be relatively extensive but will depend on consultation with the applicant on study methodology and on-site decisions on locations for data collection and the number of collection locations. Post-fieldwork data analysis would be of moderate cost and effort. Based on cost estimates for similar studies (e.g., Turners Falls Project, FERC No. 1889), we anticipate that conducting the requested flow study would cost between $100,000 and $150,000.

The applicant has proposed no studies to address this resource concern. The aquatic habitat mapping that BSPC proposes will only characterize habitat in a portion of the project-affected reach. While habitat mapping is necessary, it alone will not allow for an evaluation of project operation impacts to the quantity, quality and location of suitable habitat for specific species of fish and aquatic invertebrates.

References

Bain, M.B., J.T. Finn and H.E. Booke. 1988. Streamflow regulation and fish community structure. Ecology 69(2): 382-392.

Blinn, W., J.P. Shannon, L.E. Stevens and J.P. Carder. 1995. Consequences of fluctuating discharge for lotic communities. Journal of the North American Benthological Society 14: 233-248.

Cole, M.B. 2007. Assessment of benthic macroinvertebrate communities in relation to regulated flows in the Deerfield River, Massachusetts. ABR, Inc. – Environmental Research & Services.

Cole, M.B. 2014. Deerfield River 2013 comprehensive ecological assessment. Cole Ecological, Inc.

Cushman, R.M. 1985. Review of ecological effects of rapidly varying flows downstream from hydroelectric facilities. North American Journal of Fisheries Management 5: 30-339.

Freeman, M.C., Z.H. Bowen, K.D. Bovee and E.R. Irwin. 2001. Flow and habitat effects on juvenile fish abundance in natural and altered flow regimes. Ecological Applications 11: 179-190.

Layzer, J.B., T.J. Nehus, W. Pennington, J.A. Gore and J.M. Nestler. 1989. Seasonal variation in the composition of the drift below a peaking hydroelectric project. Regulated Rivers: Research & Management 3: 29-34.
CRWC Study Request #4. Entrainment of Riverine Fish from the Deerfield River Into the Bear Swamp Pump Storage Facility and Fife Brook Dam
Goals and Objectives

The goal of the study is to determine the impact of the Bear Swamp Pump Storage (BSPS) facility during pumping and generation cycles and estimate the impact of the Fife Brook dam on entrainment of riverine fish, including early life stages.

The objective of the study is to quantify the number of riverine fishes entrained at the BSPS station intake on an annual basis in order to evaluate potential impacts to fish populations in the lower reservoir (Fife Brook impoundment) and Deerfield River Project’s Deerfield No. 5 bypass reach. This will be accomplished through netting using various gear types to quantify and identify species of different life stages. A desktop analysis of entrainment at Fife Brook dam is being requested in this study.
Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in protecting fish populations in the Deerfield River and its tributaries.
Existing Information and Need for Additional Information

Limited project specific information exists regarding entrainment of fish and aquatic organisms at the BSPS facility. Under Article 44 of the Bear Swamp Project license, fisheries surveys were undertaken in the Fife Brook impoundment (lower reservoir) and the BSPS upper reservoir: two years of pre-operational surveys were conducted (1972 to 1973), one survey during a transitional year (1974), and two years of post-operational surveys (1975 to 1976). Those surveys collected fish in the newly created upper reservoir, indicating that fish were being entrained at the BSPS intake (Frost and Easte 1977). No further studies have been undertaken in the ensuing years.

BSPC evaluated the potential impact of increasing the hydraulic capacities of the two pump-turbines in 2008 as part of an amendment of license proceeding. In a March 8, 2008 letter responding to comments from Trout Unlimited on the proposed upgrade, BSPC stated that once the turbine upgrades are completed, the intake velocities at the BSPS trashracks will increase from 6.68 foot per second (fps) to 7.54 fps in pumping mode and from 7.79 fps to 8.88 fps in generation mode (13 percent and 14 percent increases, respectively). However, in a supplementary filing to its amendment application that included an analysis of the potential risk of entrainment due to the proposed upgrade, the increase in intake velocity was calculated as being from 1.8 fps to 2.3 fps under high tailwater and from 2.5 fps to 2.8 fps under low tailwater. CRWC assumes that those velocities represent the incremental increase (i.e., in excess of the 7.79/8.88 fps) as a result of the upgrade.

Table E-2 of the July 3, 2008 supplementary filing identified 11 species of fish as occurring in the bypass of the Deerfield River Project’s Deerfield No. 5 development (and therefore, conceivably present in the lower reservoir). Of those 11 species, BSPC only selected adult brown and rainbow trout to analyze for risk of entrainment (by comparing target species’ burst swim speeds to the calculated intake velocities). As these two species have the highest sustained and burst swim speeds of any fish within the vicinity of the project, they are least likely to be at risk of entrainment. Their analysis of adult salmonids only leaves a large data gap with respect to understanding the relative risk of entrainment for other species and/or life stages. In addition, Table E-2 omitted the documented presence of longnose sucker in both the lower and upper reservoirs. As a state species of special concern, it should have been evaluated. Clearly, the fact that it was caught in the upper reservoir documents that it is at risk of entrainment.

The 2008 entrainment evaluation is insufficient in the context of the current relicense proceeding. Because the 2008 entrainment evaluation was a desktop exercise, no empirical data exist on the timing, magnitude and duration of entrainment of riverine fishes in the BSPS area. Riverine species occurrence and susceptibility relative to space and time exposure windows to BSPS pumping are undocumented. This lack of information leaves questions unanswered on the types and extent of impacts to these populations that may be linked to the near daily cycling of river water up and down through the BSPS operations system. Therefore, it is necessary to obtain baseline data on project operation impacts for species potentially impacted by BSPS. An additional study request seeks to obtain an up-to-date, accurate documentation of fish species within the project-affected area.

At Fife Brook Dam, the intake is equipped with trashracks consisting of 0.5-inch-wide bars having 3.0-inch clear spacing. The powerhouse houses a single Francis-type turbine and generator unit with an installed capacity of 10 MW. The PAD on page 5-47 states that there are no upstream or downstream passage facilities at the Bear Swamp Project. The impact of the operation of Fife Brook on resident fish populations with no passage facilities should be determined.

Nexus to Project Operations and Effects

The BSPS consists of an intake located along the banks of the Deerfield River (which acts as the lower reservoir), a powerhouse, a pressure shaft, and a 118-acre upper reservoir. The powerhouse contains two reversible Francis-type pump turbines that have a total nameplate capacity of 600 MW. The BSPS pumps at a maximum hydraulic capacity of 4,520 cfs and generates at a capacity of 5,430 cfs. The intake to the lower reservoir is covered with trashracks that have 6-inch-clear spacing. An upgrade to the turbine units was approved in 2008 but has not been implemented yet.

BSPS operates as a peaking facility, typically pumping at night when power prices are low and generating during peak power periods during the day. The upper reservoir is allowed to fluctuate 50 feet (from elevation 1,600 feet mean sea level [msl] down to elevation 1,550 feet msl). However, the lowermost 5.5 feet of storage are held for emergency/reserve conditions, resulting in a usable storage capacity of 4,900 acre-feet. Within a 24-hour period, the facility will generate at full discharge off of the usable storage for 5.9 hours, and then pump for 7 hours to refill the upper reservoir.

The intake velocity at the BSPS lower reservoir trashracks has been calculated to be 6.68 fps in pumping mode and would increase to 7.54 fps once the approved upgrade has been completed. What remains unclear is what lower reservoir elevation these velocities are based on (i.e., if they are for “full pool” then the velocities could be higher when the lower reservoir is at minimum pool). Regardless, velocities ranging from nearly 7 fps (currently) to possibly over 8 fps (post-upgrade) exceed the swimming ability of many riverine species, particularly early life stages that may be moving past the intake.

Entrainment of fish and aquatic organisms associated with water withdrawal and hydroelectric operations has been documented to result in injury or death of entrained organisms. The Massachusetts Division of Fisheries and Wildlife (MADFW) documented the presence of brown and brook trout, longnose and blacknose dace, and white suckers in the No. 5 bypass reach. Frost and Easte (1977) collected 11 species of fish from the lower reservoir, including the state species of special concern longnose sucker. Eight of those 11 species also were sampled from the upper reservoir.

Some of these fish likely spend the majority of time in the lower reservoir (e.g., bluegill, rock bass, pumpkinseed and yellow perch), whereas other species would be expected to move between the lotic environment of the reservoir and the lentic environment of the No. 5 bypass (e.g., white sucker, fallfish, smallmouth bass). Regardless, while inhabiting the lower reservoir, these fish may pass within the vicinity of the BSPS intakes and would be at risk of entrainment and thus exposed to passage though the project pumps and reservoir supply tubes. Regardless of whether fish survive the pumping process, they are lost to the Deerfield River system. Depending on the species, life stages, and numbers entrained, this loss could impact the ecosystem productivity of the stretch of the Deerfield River between the No. 5 dam and the Fife Brook dam and may hinder management and/or restoration goals for fishes.
Proposed Methodology

The Frost and Easte (1977) study used a combination of sampling methods (boat shocking, gill nets, and rotenone) to document fish assemblages in the upper and lower reservoirs. In order to quantify entrainment of various life stages, it is likely that a combination of methods would provide the most reliable results. As part of the relicensing of the Northfield Mountain Pump Storage Project (NMPS, FERC No. 2485) on the Connecticut River, FirstLight will use a combination of methodologies, including hydroacoustic monitoring, radiotelemetry, and ichthyoplankton netting to assess entrainment.

At BSPS, CRWC recommends ichthyoplankton netting either at the intake or off of the water conveyance system to quantify entrainment of early life stages (eggs and larva) and either sampling at the upper reservoir outlet or in the reservoir itself using boat shocking and gill or trap netting to collect older life stages (juveniles and adults). Sampling for planktonic fish larvae should capture early spring spawning species (white suckers) through later season centrarchid species (bass and sunfish). Plankton sampling should utilize a sampling design that adequately captures temporal and spatial changes in water pumping cycle.

At Fife Brook, a desktop analysis can take place after the fish assemblage study. First a qualitative assessment of entrainment and impingement can be done of the fish located in the Fife Brook impoundment for various size groups. Turbine mortality rates can be estimated based on literature values for studies of Francis-type turbines with characteristics similar to that located at Fife Brook.
Level of Effort and Cost

We know of no other tool that will provide for this type of assessment for all fish species and organisms that may pass through the project. Cost and effort are expected to be moderate to high. At NMPS, the ichthyoplankton sampling component of the entrainment analysis was estimated to cost $60,000 to $70,000. Based on this information, CRWC estimates it would cost the Applicant $75,000 to $100,000 to conduct the requested study.

The Applicant did not propose any studies to meet this need in the PAD.

BSPC has not proposed any studies to address this deficiency; therefore CRWC is submitting a request for a rigorous, empirical entrainment study.

References

Frost, J.N. and W.E. Easte. 1977. Bear Swamp Pumped Storage Hydroelectric Project Fishery Study, January 1972 – December 1976. New England Power Company and Massachusetts Division of Fisheries and Wildlife. 73 pp.
CRWC Study Request #5. Aquatic Mesohabitat Assessment and Mapping
Determine the effect of Project operations on aquatic habitat within the Deerfield River from the Fife Brook Dam to the upstream extent of the Deerfield Project #4 impoundment and in the Bear Swamp Pumped Storage Project’s (BSPS) upper and lower reservoirs.
Aquatic mesohabitat characterization and mapping will provide the information necessary to choose sample sites for the Fish Assemblage Study and will provide information to help define whether, or to what degree, Project operations are impacting aquatic resources. To our knowledge, no comparable aquatic habitat mapping has been conducted in the study area.
Study Area
The study area is divided into three distinct sections as follows:
• The Deerfield River from the Fife Brook Dam to the upstream extent of the Deerfield Project #4 impoundment
• The Bear Swamp Pumped Storage Project’s upper reservoir
• The Bear Swamp Pumped Storage Project’s lower reservoir
Goals and Objectives
The goal of this study request is to quantify the type and extent of aquatic mesohabitat available in the areas affected by the Bear Swamp Pumped Storage Project. The objective of the aquatic mesohabitat assessment is to gain a preliminary understanding of the aquatic mesohabitat resources in the three areas described above. To reach this objective, aquatic mesohabitat will be delineated and mapped in each of these areas. The assessment will provide data that will support and focus other relicensing activities needed to assess Project effects on riverine resources.
Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in protecting fish populations in the Deerfield River and its tributaries.
Existing Information and Need for Additional Information
To the CRWC’s knowledge, no comparable aquatic habitat mapping has been conducted in the study area.
The mesohabitat mapping and accompanying characterization of aquatic mesohabitat will provide essential information regarding the character and extent of aquatic habitat that may be affected by Project operation. The quantified spatial data generated by this survey will help to provide a framework for upcoming data collection efforts.
Nexus to Project Operations and Effects
Project operations have the potential to directly impact fish species life history requirements, biological interactions, and habitat quantity and quality. For example, headpond and tailwater water level fluctuations could dewater important spawning areas, thus limiting productivity of important game fish species by direct impacts to their spawning success or indirectly by limiting the spawning success of forage fish species. Accordingly, a thorough understanding of the current fish assemblage structure and associated metrics are needed in order to examine any potential Project-related impacts.
Proposed Methodology
Mesohabitat delineation will follow the method of Ball (1982); see also FirstLight (2012).

The Project owner will conduct a field survey to identify the mesohabitat present in the study areas and to delineate the relative quantity and spatial distribution of each habitat type. Each mesohabitat type of interest will be assigned specific attributes to be used for field delineation. The exact classification criteria for each mesohabitat type will be developed in consultation with stakeholders, but will generally include:
Riffle: shallow, moderate velocity, turbulent, high gradient, moderate to large substrates (cobble/gravel)
Rapid: shallow, moderate to high velocity, turbulent, chutes and eddies present, high gradient, large substrates or bedrock
Run: moderately deep to deep, well defined non-turbulent laminar flow, low to moderate velocity, well defined thalweg, typically concave stream geometry, varying substrates, gentle slope
Glide: moderately shallow, well defined non-turbulent laminar flow, low velocity, well defined thalweg, typically flat stream geometry, typically finer substrates, transitional from pool
Pool: deep, low velocity, well defined hydraulic control at outlet
Backwater: varying depth, minimal or no velocity, long backwatered reaches
Delineation of Deerfield river reach should be conducted by boat or on foot, where too shallow, and will occur during a period of relatively low flow so that breaks in mesohabitat, substrate, object cover, and hydraulics, can be readily observed.
Habitat mapping below Fife Brook dam will require days to complete and flows during this period may vary due to operations of the Deerfield River Hydroelectric Project. To quantify the flow at which the mesohabitat mapping is conducted, records of discharge from Fife Brook dam will be used.
Aerial imagery should be uploaded to a laptop computer enabled with a Geographic Information System (GIS) to permit mesohabitat mapping directly in the field. The upstream and downstream boundary of each mesohabitat unit within the study area should be delineated and georeferenced.
Additional features relevant to differentiation of mesohabitats, such as biological and geomorphic, characteristics, should also be collected where appropriate including; readily observable aquatic fauna, predominate substrate types , relative embeddedness , wetted width, channel geometry, thalweg depth, and cover. The data should be recorded on data sheets, a dedicated field book, or via a laptop computer. Upon completion of the survey, all data will be rechecked for quality control and archived.
Level of Effort and Cost
This study will require sampling of the Project-affected areas of during the summer. CRWC estimates the study will cost in the vicinity of $30,000.

CRWC Study Request #6. Fish Assemblage Assessment
Goals and Objectives

The goal of this study request is to determine the assemblage of fish species present in the areas affected by the Bear Swamp Project, which potentially includes Species of Greatest Conservation Need (SGCN) and/or state listed species for Massachusetts.

Specific objectives include:

1) Describe fish assemblage structure, distribution and abundance within the project-affected area along spatial and temporal gradients.

2) Compare historical records of fish species occurrence in the project area to results of this study.

Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in protecting fish populations in the Deerfield River and its tributaries.
Existing Information and Need for Additional Information

Based on surveys conducted as part of the relicensing process for the Deerfield River Project, fish assemblages of the Deerfield No. 5 and No. 4 development reservoirs include rainbow trout (Oncorhynchus mykiss), smallmouth bass (Micropterus dolomieu), rock bass (Ambloplites rupestris), pumpkinseed (Lepomis gibbosus), white sucker (Catostomus commersonii), fallfish (Semotilus corporalis) and spottail shiner (Notropis hudsonius). MADFW surveys of the Deerfield No. 5 bypass reach collected brown trout (Salmo trutta), brook trout (Salvelinus fontinalis), longnose dace (Rhinichthys cataractae), blacknose dace (Rhinichthys atratulus), and white suckers. Both age 0+ and age 1+ trout were collected, which documents that natural reproduction is occurring in that reach. MADFW stocks adult brown and rainbow trout in the river reach downstream of Fife Brook dam, which is managed as a catch-and-release fishery.

The only site-specific information on the fish community within the project boundary provided in the PAD dates from the 1970s (Frost and Easte 1977). Those surveys, conducted by the previous Licensee (New England Power) and MADFW, collected white sucker, smallmouth bass, yellow perch (Perca flavescens), rock bass, golden shiner (Notemigonus crysoleucas), chain pickerel (Esox niger), pumpkinseed, bluegill (Lepomis macrochirus), and the state-listed longnose sucker (Catostomus catostomus) from the lower reservoir over a 3-year period (1974 to 1976).

Upon review of the Frost and Easte (1977) report, we note that BSPC failed to identify that the survey also encompassed the upper reservoir. Eight species of fish were collected from the upper reservoir, including white sucker, rock bass, pumpkinseed, golden shiner, fallfish, brown bullhead (Ameiurus nebulosus), yellow perch, and longnose sucker.

Nexus to Project Operations and Effects

Project operations have the potential to directly impact fish species life history requirements, biological interactions, and habitat quantity and quality. For example, headpond and tailwater water level fluctuations could dewater important spawning or rearing areas, or affect habitat availability, thus limiting productivity of fish species by direct impacts to their spawning or rearing success or indirectly by limiting the spawning or rearing success of forage fish species. Furthermore, SGCN have been documented in the project-affected area. Accordingly, a thorough understanding of the current fish assemblage structure and associated metrics is needed in order to examine any potential project-related impacts.

Proposed Methodology

An accepted and robust field sampling design (e.g., as described in Pollock et al. 2002 or MacKenzie et al. 2006) and accepted methods for collecting fish species likely to be present in the project-affected areas (Bonar et al. 2009) should be used to conduct field surveys. Fish sampling, measuring length and weight, and calculating associated metrics are commonly used methods to determine fish assemblages and assess fish populations (Bonar et al. 2009). Randomly sampling multiple habitat types using a multi-gear approach will be required to ensure that all fish species present are sampled. The spatial scope of the study is from the upstream extent of the Fife Brook impoundment (also called the lower reservoir) downstream to the head of the Deerfield River Project’s (FERC No. 2323) Deerfield No. 4 development, including the BSPS upper reservoir. Sampling should occur at each selected site across multiple seasons (spring, summer, and fall). Digital photographs should be taken to avoid misidentification of certain species such as Cyprinids.

BSPC should ensure that at least one of the selected gear types is effective at collecting longnose sucker.

This will be a one-year study, provided river discharge conditions fall within the 25th to 75th percentile for weekly averages.

Specific Methodology

The study should employ a stratified-random sampling design. The study area should be divided into strata based on mesohabitat type. Each mesohabitat type will be further stratified into two broad microhabitat types. Proposed sampling methods include daytime boat/barge electrofishing, nighttime boat electrofishing, gill nets, seine nets, and minnow traps. Sampling should be performed during in the spring, summer and fall.

The stratified random sampling design will randomly assign sampling stations within particular mesohabitat types in proportion to their linear habitat distance. Multiple methods of fish capture should be used in each stratum, and both near-shore (shallow) and mid-channel (deep) habitats will be sampled to evaluate the potential differential effect of hydropeaking on the fish species and life stages that utilize these two habitat types (Bain 1985). Selected locations within each station should be sampled either by day and nighttime boat/barge electrofishing (shoreline and littoral habitat), gill nets (deeper, benthic areas), seine net (wadeable shoreline and littoral habitat), minnow traps, and eel pots. The exact number of sampling locations will be dependent on the weighted stratification of the study area by mesohabitat and sampling within each station will be further stratified by depth and proximity to shore.

In addition to biological data, supporting data also should be collected for each sample site including: location (GPS), sampling gear type, sampling effort, mesohabitat type, average depth, average velocity, river flow, water temperature, turbidity, predominant substrate, time of day, day of year, presence of cover, and proportion of vegetation cover.

Catch per unit effort (CPUE) and standard errors should be calculated for each species, station, and sampling technique. Data will also be separated into groups by size and a CPUE per size group will be calculated. Values of CPUE for each segment and gear type should be calculated as the sum of catch from all samples within a station divided by the sum effort expended within that station. The Shannon-Weiner index of diversity, which is a function of species richness and evenness, should also be calculated.
A final study report should include tabular data summarizing length, weight, and size class of fish captured, a map of the study area to depict the location of sample stations, and overall results including occurrence, distribution and relative abundance. Comparisons should be made with historical records. Results should be described in relation to other studies. Raw data should be provided to stakeholders in digital format upon request.

This study design is similar to the one detailed in Study 3.3.11 of FirstLight Power Resources Revised Study Plan for the relicensing of its Turners Falls Project (FERC No. 1889), which was approved by the Commission (with modifications) in its Study Plan Determination letter dated February 21, 2014; therefore, the methodology is consistent with accepted practice.

Level of Effort and Cost

The level of effort for this study would be moderate to high as seasonal sampling with several types of gear would be required. CRWC estimates the cost of this study to be $50,000 to $75,000, based on the estimated cost to conduct a similar study at the Turners Falls Project (FERC No. 1889).

BSPC has identified a fisheries survey as a potential study, but has not committed to undertaking such a study. Likewise, the objective of that study would focus only on select locations within the lower reservoir and the 7.5 mile reach downstream of Fife Brook Dam within the project boundary. The level of specificity, limited geographical scope, and lack of firm commitment to conduct the study leads CRWC to believe that it would not achieve the objectives identified herein. The study proposed will adequately address the objectives by documenting fish species occurrence, distribution and abundance within the project area along spatial and temporal gradients.

References

Bain, M.B. 1985. Fish community structure in rivers with natural and modified daily flow regimes. Ph.D. Dissertation. University of Massachusetts, Amherst, Massachusetts.

Bonar, S.A., Hubert, W.A., and D.W. Willis, editors. 2009. Standard methods for sampling North American freshwater fishes. American Fisheries Society, August 2009.

Frost, J.N. and W.E. Easte. 1977. Bear Swamp Pumped Storage Hydroelectric Project Fishery Study, January 1972 through December 1976. Final report to New England Power Co. 70 pp.

MacKenzie, D.I., J.D. Nichols, J.A. Royle, K.H. Pollock, L.L. Bailey and J.E. Hines 2006. Occupancy estimation and modeling: inferring patterns and dynamics of species occurrence. Elsevier: San Diego, California.

Massachusetts Division of Fisheries and Wildlife. 2006. Commonwealth of Massachusetts Comprehensive Wildlife Conservation Strategy. Westborough, MA. Available online: http://www.mass.gov/eea/agencies/dfg/dfw/wildlife-habitat-conservation/state-wildlife-conservation-strategy.html

Pollock, K.H., J.D. Nichols, T.R. Simons, G.L. Farnsworth, L.L. Bailey and J.R. Sauer. 2002. Large scale wildlife monitoring studies: statistical methods for design and analysis. Environmetrics 13: 105-119.
CRWC Study Request #7. Abundance of naturally reproduced trout and distribution of spawning areas in the Deerfield River below Fife Brook Dam.
Goals and Objectives

• Characterize the population of naturally spawning trout in the Deerfield River below the Fife Brook dam.
• Estimate the abundance of naturally produced trout in the project-affected area.
• Conduct spawning ground surveys to produce a map of spawning areas, characterize the habitat, and determine the distribution of spawning relative to river flows.

Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in protecting fish populations in the Deerfield River and its tributaries.

Existing Information and Need for Additional Information

The original fisheries studies of the Bear Swamp Project (MADFW, 1977) estimated that between 10% and 16% of the trout harvested in the Project area were naturally produced (wild). It was estimated that few stocked trout carried over to the following year, however increases in minimum flows required in the 1996 settlement agreement may now allow stocked trout to survive the summer months. Wild Brook, Brown, and Rainbow Trout were documented in the project area in the 1977 study report. Based on growth rates, the authors surmised that the Brook and Rainbow Trout were spawning in the tributaries and the Brown Trout were spawning in the Deerfield River.

Nexus to Project Operations and Effects

Project operations have the potential to directly impact fish species life history requirements, biological interactions, and habitat quantity and quality. For example, peaking operations could dewater important spawning or rearing areas, thus limiting productivity of important game fish species by direct impacts to their spawning or rearing success or indirectly by limiting the spawning or rearing success of forage fish species. Accordingly, a thorough understanding of the current wild trout population in the project area is needed in order to examine any potential Project-related impacts.

Proposed Methodology

Fish sampling, measuring length and weight, determining age and origin by reading scales, and calculating associated metrics are commonly used methods to determine fish assemblages and assess fish populations (Bonar et al. 2009).

Specific Methodology

Abundance estimate
Fish Sampling – Trout should be captured by electrofishing using a boat mounted with an electrofishing unit with the capacity to adjust the pulse rates between 30 – 120 pulses/second and vary voltage to accommodate ambient conductivity. A barge capable of negotiating riffles and shoals, similarly rigged with an electrofishing unit may be deployed for sampling in the shallower riverine habitats.
Electrofishing will be conducted in a downstream manner, following standardized methods developed specifically for large river quantitative electrofishing surveys (MBI, 2002, Yoder and Kulik, 2003). The start point, end point, and boat track for each sampling station shouldbe geo-referenced using a handheld GPS and transposed to corresponding topographic mapping software program to produce maps of areas sampled.
All captured fish should be measured for fork length (FL; mm), weighed (g), and recorded. Scales should be removed from trout for age and origin (wild/hatchery) determination. Untagged trout will be tagged with a passive integrated transponder (PIT) tag. The PIT tags should be injected into the coelomic cavity, just posterior to the pectoral fins (CBFWA 1999).

Abundance Estimation – Trout abundance estimates within the study area should be calculated using the closed models Mt-Darroch and Mt-Chao, provided in the computer program CAPTURE (Otis et al. 1978; White et al. 1982; Chao 1989; Rexstad and Burnham 1991) or equivalent. The model Mt-Darroch will be used when capture probabilities of trout are 10% or greater. Model Mt-Chao will be used when the data were <10%, because it performs better when data are sparse (Chao 1989). The standard error and 95% confidence intervals for the abundance estimates will also be calculated in CAPTURE. Precision of the estimates will be measured by calculating a coefficient of variation (CV), which is the ratio of the standard error of the estimate to the estimate (Hightower and Gilbert 1984).

Age and Origin Determination and Analysis – Scales are to be sampled from each fish from a position above the lateral line and posterior to the dorsal fin with a knife and stored dry within individually labeled scale envelopes. A subsample of scales from each individual will be wet mounted on glass slides then viewed under a microscope. Regenerated scales will be discarded, and annuli and spawning checks identified. Ages will be determined by counting annuli. Ages will be assigned to trout from which scales were not analyzed by constructing an age-length key for each year (Iserman and Knight 2005). Origin (stocked or natural) will be qualitatively determined by examining multiple scales for the presence of annuli within areas of the scale corresponding to its juvenile life stages. In general, naturally produced trout will be exposed to colder water temperatures and limited food availability in winter, which results in areas of constricted or overlapping circuli (annuli). In contrast, hatchery fish are reared in controlled environments and therefore display little to no variability in circuli spacing throughout the year. Therefore the presence of annuli near the center of the scale will indicate the fish is of natural origin while the lack of such annuli or the general appearance of constant circuli spacing throughout the interior of the scale will suggest that the fish was stocked. Areas of the scale corresponding to periods after an individual was stocked (age >2) will however display annuli, and should be ignored for the purposes of origin determination. However, individuals displaying constant scale growth within central areas of the scale (stocked fish) and displaying distinct annuli along scale margins could be classified as holdover fish.

Trout Spawning Ground Surveys

The primary purpose of this study is to verify the overall distribution and extent of trout spawning in the project affected area of the Deerfield River below Fife Brook Dam. A secondary purpose is to determine the extent to which spawning redds are subject to de-watering (stranding), relative to the current project operation procedures. Two surveys of the entire project affected area should be conducted, one during the peak spawning period (if flow and turbidity conditions allow) and one post-season survey that roughly corresponds to the timing of fry emergence. The determination of the exact timing of the surveys will be based on water flow and turbidity conditions in the river, which will be assessed weekly. Surveys should be conducted from a small boat, as well as on foot in selected sections of the river where spawning may be concentrated, documenting the numbers of fish and redds observed. The survey crew will also document spawning activity near the shorelines, where redds might be more prone to stranding by decreasing water levels. Efforts will be made to locate all areas of spawning within free-flowing reach. The approach for identifying spawning areas includes a combination of identifying redds as described above and investigation of channel margins for young-of-year trout when fry are expected to emerge (second survey). Although the intent is to cover as much of the study area as possible, the survey areas will depend on access to the river and safety.

The numbers of fish and redds will be summed over ¼ mile reaches of the river to characterize the magnitude of spawning activity relative to river reach location, and redd locations will be marked on maps of the river. The location of spawning activity will also be recorded with a hand-held GPS unit, either as individual redds (in areas of pocket spawning) or by recording GPS points around areas of extensive spawning activity. The number of redds within these larger areas will be enumerated for density estimates. At each spawning location, whether it contains a single or multiple redds the following information should be recorded: Date and time, habitat type, substrate, water velocity, width, length of red, water depth, water temperature,

In addition, as many visible redds as possible should be marked (e.g. with fluorescent painted rocks, or flagging markers) for subsequent identification. When possible, marking of redds should be conducted from a boat to minimize the physical disturbance of spawning areas. These sites should be resurveyed shortly afterward at minimum flow. The intent of this method is to determine the number of redds that are dewatered as water levels decline.

Level of Effort and Cost
This study will require sampling of the Project-affected areas of during spring, summer, and fall. The cost of the study would be moderate to high as seasonal sampling with several types of gear would be required. Based on first year study results, a second year of sampling or specific studies examining impacts of Project Operations may be requested.

FirstLight estimated that their sea lamprey spawning survey, which covers a longer stretch of the Connecticut River, would cost them $125,000-150,000. CRWC therefore estimates this study downstream of Bear Swamp will cost $75,000.

CRWC Study Request #8. Impacts of Water Level Fluctuations on Riparian and Aquatic Vegetation Including Invasive Species and their Associated Habitats in the Fife Brook Impoundment and 17-Mile Reach Downstream of Fife Brook Dam
Conduct a study to quantify impacts of reservoir fluctuation on riparian, wetland, emergent aquatic vegetation (EAV), submerged aquatic vegetation (SAV), littoral zone and shallow water aquatic habitats in the Fife Brook impoundment (lower reservoir) and in the 17-mile reach downstream of Fife Brook Dam.

Goals and Objectives

The goal of this study is to obtain baseline information on riparian, wetland, emergent and submerged aquatic vegetation, and associated shallow water aquatic habitats (subject to operational inundation and exposure to near exposure) known to occur in the project-affected area. Information would be used to determine whether riparian, wetland, EAV and SAV, littoral, and shallow water (e.g., mid-river bars and shoals) habitats are impacted by current water level fluctuations permitted under the Bear Swamp Project license and whether these vegetation types and shallow water habitats can be protected and restored by modifications to project operations or other mitigation measures. This information is needed to determine whether the project operations affect plants, habitat, and wildlife in the project area, whether aquatic vegetation and its habitats can be enhanced by modifications to project operations or other mitigative measures, and whether there is any unique or important shoreline or aquatic habitats that should be protected.

The specific objectives of the field study, at a minimum, include:

1. quantitatively describe and map wetland types within 200 feet of the shoreline in the Fife Brook impoundment and in the 17-mile reach downstream of the Fife Brook dam, and describe associated wildlife;
2. delineate, quantitatively describe, and map all wetland types, including invasive species and wildlife observed (e.g., bald eagle nesting, water fowl nesting) within 200 feet of the shoreline, and the extent of this habitat if it extends beyond 200 feet; and
3. quantitatively describe (e.g., substrate composition, vegetation type and abundance) and map shallow water aquatic habitat types subject to project operation inundation and exposure, noting and describing additional areas where water depths at lowest operational range are wetted to a depth of less than one foot (flats, near shore areas, gravel bars, with very slight bathymetric change).

A second year of study may be required should river discharge in the first year prove to be atypical (outside of 25th to 75th percentile of average weekly flow values) during the study period.

The field study should produce a habitat inventory report that includes:

1. the results of the field study in the form of maps and descriptions;
2. an assessment of project effects on wetland, riparian, littoral zone vegetation and shallow water habitats, invasive plant species, and wildlife habitat at the project;
3. recommendations for any necessary plant, habitat type, or wildlife protection and/or invasive species control measures; and
4. recommendations for plant, habitat type, or wildlife protection and/or invasive species control measures, including riparian buffer restoration and protection and protection of key nest and roost trees for bald eagles.

Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in protecting natural communities in the Deerfield River watershed.

Existing Information and Need for Additional Information

In the PAD, BSPC states that no formal delineation of wetland, riparian, or littoral habitats has been conducted with the project boundary. Based on National Wetland Inventory (NWI) mapping, three wetland types occur within the project area: lacustrine, palustrine, and riverine wetlands. Of the 425 acres of wetlands mapped by NWI, 95 percent are lacustrine (the upper reservoir) or riverine (lower reservoir and river channel downstream of Fife Brook dam). The nearly 24 acres of palustrine habitat are located within the river channel or immediate floodplain of the river. In addition, the Massachusetts Natural Heritage and Endangered Species Program (NHESP) has identified four potential vernal pools within the project boundary. According to BSPC, no site-specific lists of plant or animal species known to occur in wetland, riparian, and littoral habitats are available.

While the PAD provides lists of plant and wildlife species whose native ranges overlap with the project area, it does not provide any baseline information on known occurrences of these species in the wetlands, riparian, littoral and shallow water habitats, within or adjacent to the project area. Plants and wildlife occurring in these habitats may benefit from protection, mitigation and enhancement (PMEs) measures, given the potential effects of continuing the current peaking operating regime.

Baseline information on the wetlands, riparian, and littoral resources within the project area is needed.

Nexus to Project Operations and Effects

The project consists of the Bear Swamp Pump Storage (BSPS) development and the Fife Brook development. BSPS uses an upper reservoir and lower reservoir (which is also the impoundment for the Fife Brook facility). Both reservoirs are allowed to fluctuate up to 40 feet in elevation, with no stipulations on the timing or frequency of those fluctuations (though typically they occur on a daily basis). The Fife Brook Station alternates between providing a minimum flow of 125 cfs and generation flows of up to 1,540 cfs to the Deerfield River downstream of the Fife Brook Dam. In addition, pursuant to Article 404 of the license, BSPC provides whitewater releases from Fife Brook Dam at a minimum flow level of 700 cfs for a duration of at least three continuous hours on 50 weekend days and 56 weekdays from April 1 to October 31 each year. In the PAD, BSPC states that the shoreline of the lower reservoir and the reach of the Deerfield River immediately below Fife Brook Dam are lined with rip rap. While this likely limits the amount of natural vegetation that can persist, the exact geographic extent of the artificial armoring is unclear.

Outside of a two month period in 2014, BSPC has provided no data on the operation of the BSPS and Fife Brook plants. The PAD contains no information on the timing, frequency and magnitude of reservoir fluctuations over the course of a year and how that relates to aquatic plant species establishment, growth, survival, littoral zone or other shallow water habitat fish spawning periods and their effects on these fishes (reproduction success and subsequent recruitment) in available and utilized habitat, and how the quantity and quality of these shallow water habitats are effected by project operational manipulation/alteration, as currently permitted or proposed.

Water level fluctuations due to project operations could affect EAV and SAV habitat as well as the quantity and quality of littoral and shallow water habitat. These operational water level fluctuation effects (in both of the reservoirs and the riverine reach downstream of the dam) are expected to impact fish species’ use of these habitats and may affect spawning fishes reproductive success and subsequent population recruitment, including to fallfish and the state listed special concern longnose sucker.

The current operating mode may affect wetland, riparian, littoral and other shallow water habitats, and promote the introduction and expansion of invasive plant species through fluctuating water levels. A study the explains the relationship between the proposed mode of operation and the type and quantity of wetland, riparian, littoral, shallow water habitats, and invasive species affected would help inform a decision on the need for protection and/or control of these resources in the license.

Riparian buffers provide for river bank stability, reduction in nutrient and sediment from runoff, shading and reduced solar heating of river waters and wildlife habitat (including eagle nesting and roosting habitat) and movement corridors. Management of the project’s shorelines are within the scope of project review and a Shoreline Management Plan may be required. Incorporation of riparian resource protection and enhancement into this plan will require baseline information on existing conditions.

Proposed Methodology

The PAD currently contains maps portraying general wetland types from the upper end of the lower reservoir to a point 7.5 miles downstream of the Fife Brook Dam. The proposed study should expand the survey area, but utilize existing information in conjunction with field surveys designed to describe the characteristics of each mapped wetland, riparian, littoral and shallow water habitat, including plant species composition, relative abundance/density, habitat quality, and land use. These surveys should be conducted to describe these habitats under low water level conditions (i.e., minimum reservoir elevations and minimum flows below Fife Brook Dam). Information collected should include:

1. Plant species composition, and their relative abundance/density and condition/structure (e.g., seedlings);
2. Structured data, including estimates of average heights and aerial cover of each vegetation layer (specifically denoting invasive species);
3. Aquatic habitat substrate composition, quantity (i.e., percent types and area), wood structure (relative abundance measure applied by area), water depths (inundated, exposed, and water less than one foot);
4. Predominant land use(s) associated with each cover type;
5. Wildlife sightings should be noted and any active nest or roost trees utilized by bald eagles, or potentially used during the term of the upcoming license as the eagle population increases, should be identified and geo-referenced; and
6. Field-verified wetland, riparian, and littoral and shallow water habitats and invasive species occurrences should be geo-referenced as polygons and overlain on orthophotos at a suitable scale.

Level of Effort and Cost

The study likely will take one growing season to complete. A similar study being undertaken by FirstLight as part of the relicensing of its Turners Falls (FERC No. 1889) and Northfield Mountain Pumped Storage (FERC No. 2485) projects was estimated to cost $60,000 to $80,000. As the scope of the two studies are similar in size, CRWC estimates it will cost BSPC $60,000 to $80,000 to complete the requested study.

BSPC has identified wetland, riparian and littoral habitat mapping as a potential study, but has not committed to undertaking such a study. Likewise, the objective of that study would only focus on select or critical areas within the project boundary, without providing guidance on what criteria it would use to determine whether an area was critical or not. As outlined in the expected framework (Table 6.3-1 of the PAD), CRWC does not believe BSPC’s proposed study would achieve the objectives identified herein.

CRWC Study Request #9. Baseline Study of Terrestrial Wildlife and Botanical Resources
Conduct a study to obtain baseline information on terrestrial wildlife and botanical resources within the project boundary.

Goals and Objectives

The goal of this study is to characterize and describe the terrestrial wildlife and botanical resources that use representative upland habitats within and adjacent to the project boundary in order to evaluate potential project impacts from current or future operations and maintenance activities.

The specific objectives of the field study, at a minimum, include:

1. Survey and inventory overall existing upland wildlife habitats;
2. Note the occurrence of wildlife sighting during the course of the surveys;
3. Survey and inventory vegetation cover classes and land use;
4. Survey and evaluate the presence of targeted rare, threatened, and endangered (RTE) species or associated habitats; and
5. Survey and inventory the nature and extent of upland invasive and exotic vegetation species.

Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in protecting natural communities in the Deerfield River watershed.

Existing Information and Need for Additional Information

The PAD provides no specific information on the botanical resources within the project area, only descriptions of the dominant vegetative communities found within the watershed. While Table 5.5-1 provides a list of invasive plants found within the Deerfield River watershed, none are explicitly identified as occurring within the project area. Likewise, the lists of mammals, birds, amphibians and reptiles are only those that potentially may occur within the project area.

Baseline information on terrestrial and wildlife resources within the project area is needed in order to meet the goal of evaluating project effects. Plants and wildlife occurring in these habitats may benefit from protection, mitigation and enhancement (PMEs) measures, given the potential effects of current and future operations and maintenance activities.

Nexus to Project Operations and Effects

The project consists of the Bear Swamp Pump Storage (BSPS) development and the Fife Brook development. BSPS uses an upper reservoir and lower reservoir (which is also the impoundment for the Fife Brook facility). Both reservoirs are allowed to fluctuate up to 40 feet in elevation, with no stipulations on the timing, frequency or duration of those fluctuations (though typically they occur on a daily basis).

The majority of lands associated with the project currently are protected through conservation restrictions (CR) conveyed to the Massachusetts Department of Environmental Management (MADEM). The CR protects 1,257 acres, including 1,056 acres at the upper and lower reservoirs and 201 acres of “river corridor” downstream from Fife Brook dam. The CR stipulates that the protected property shall not be used for purposes other than agricultural, forestry, educational, non-commercial recreation, open space and electric transmission and hydroelectric generation purposes. The CR expires concurrent with the existing license, and future intentions for this land are therefore not certain.

The project area contains habitat suitable for northern long eared bat (NLEB). In addition, according to the Massachusetts Natural Heritage and Endangered Species Program (NHESP) database, 27 state-listed species may occur in the vicinity of the project.

BSPC states it is not proposing any new construction, changes to current land management practices, or new land management activities as part of this licensing proceeding. However, the PAD provides no description of the types of land management practices that BSPC currently employs. Without knowing what terrestrial resources and wildlife occur in the project area, or what types of land management and/or maintenance activities BSPC routinely undertakes, CRWC is unable to determine if impacts are occurring currently or if they may occur under any new conditions that could be imposed on a new license (e.g., additional recreational amenities such as trails).

Proposed Methodology

CRWC recommends that BSPC follow the methodology detailed in FirstLight’s Study Plan 3.4.1, as described in the Revised Study Plan for the Turners Falls Hydroelectric Project (No. 1889) and Northfield Mountain Pumped Storage Project (No. 2485) filed with FERC on August 14, 2013. Pursuant to the Study Plan Determination issued on September 13, 2013, FERC approved FirstLight’s proposed methodology; therefore, we assume it is consistent with accepted practice.

In general, the study consists of two tasks. The first task is a literature review to collect information needed to develop vegetation type maps and calculate percent acres of each vegetation type present in the study area. The second task is to conduct field surveys to document wildlife habitat and occurrence, vegetative cover types and invasive plant species in the project area.

There are anecdotal accounts of bald eagles nesting and roosting along the Deerfield River in the vicinity of the project. During the field surveys, biologists should document the occurrence of any bald eagle nesting and roosting sites and provide an assessment of the status (healthy, diseased, etc.) and level of protection (e.g., within a right-of-way, on protected conservation land) of each site. Potential sites should also be identified, since it is expected that the bald eagle population will continue to increase during the 30-50 year term of the next license. Where encountered, actual and potential bald eagle nests and roosting trees should be GPS located and photo-documented.

The study report should include:

1. Maps of the project area showing locations and extent of habitats, vegetative cover, locations of invasive species, and known eagle roosting and nesting trees (as both polygons and point locations, as appropriate);
2. Tabular summaries of the data;
3. An assessment of project effects (operations, maintenance activities, potential future recreational amenities, etc.) on terrestrial habitat and wildlife at the project;
4. Recommendations for any necessary plant, habitat type, or wildlife protection and/or invasive species control measures, including riparian buffer restoration and protection of key nest and roost trees for bald eagles.

Level of Effort and Cost

The study likely will take one growing season to complete. A similar study being undertaken by FirstLight as part of the relicensing of its Turners Falls (FERC No. 1889) and Northfield Mountain Pumped Storage (FERC No. 2485) projects was estimated to cost $60,000 to $80,000. As the scope of the two studies are similar in size, CRWC estimates it will cost BSPC $60,000 to $80,000 to complete the requested study.

BSPC has identified terrestrial wildlife and vegetation cover type mapping as a potential study, but has not committed to undertaking such a study. Likewise, the objective of that study would only focus on the 7.5 miles reach downstream of Fife Brook Dam. This would omit the majority of upland project lands. CRWC does not believe BSPC’s proposed study outlined in Table 6.3-1 of the PAD would achieve the objectives identified herein.

CRWC Study Request #10. Baseline Mussel Survey
Goals and Objectives

The goal of this study is to characterize the distribution, abundance and species composition of the freshwater mussel community in the upper end of the lower reservoir and in the 17-mile reach of river downstream of the Fife Brook Dam in order to evaluate potential project impacts from current or future operations and maintenance activities.

The specific objective of the field study is to conduct surveys for freshwater mussels in the upper Fife Brook impoundment and downstream-affected reach to determine presence/absence of mussels, relative abundance, location and habitat preference.

Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in protecting natural communities in the Deerfield River watershed.
In 2006, CRWC published Ethan Nedeau’s book, “Freshwater Mussels and the Connecticut River Watershed.” This book was referenced in the PAD. Funding for the book was provided by all four states in the watershed as well as several private and nonprofit organizations. Books are available for free from our office and through our website, www.ctriver.org.

Existing Information and Need for Additional Information

In the PAD, BSPC states that four species of freshwater mussels are known to occur within the Deerfield River watershed: eastern elliptio (Elliptio complanata), eastern pearlshell (Margaritifera margaritifera), eastern floater (Pyganodon cataracta), and alewife floater (Anodonta implicata). However, no site-specific surveys have been conducted to determine whether any mussel species are present within the area impacted by project operations. This information is needed in order to determine whether project operations are impacting the diversity, distribution and/or abundance of the mussel community in the upper portions of the Fife Brook impoundment and the 17-mile-long riverine reach below the dam. BSPC has not proposed any studies to address this deficiency; therefore CRWC is submitting a request for such a study.

Nexus to Project Operations and Effects

The project consists of the Bear Swamp Pump Storage (BSPS) development and the Fife Brook development. BSPS uses an upper reservoir and lower reservoir (which is also the impoundment for the Fife Brook facility). Both reservoirs are allowed to fluctuate up to 40 feet in elevation, with no stipulations on the timing or frequency of those fluctuations (though typically they occur on a daily basis). The Fife Brook Station alternates between providing a minimum flow of 125 cfs and generation flows of up to 1,540 cfs to the Deerfield River downstream of the Fife Brook Dam. In addition, pursuant to Article 404 of the license, BSPC provides whitewater releases from Fife Brook Dam at a minimum flow level of 700 cfs for a duration of at least three continuous hours on 50 weekend days and 56 weekdays from April 1 to October 31 each year.

Outside of a two month period in 2014, BSPC has provided no data on the operation of the BSPS and Fife Brook plants. Freshwater mussels, if present, could be negatively impacted by project operations. If mussels occur in the lower reservoir, routine drawdowns associated with peaking operations could strand them, leaving them vulnerable to desiccation or predation. Likewise, rapidly changing habitat conditions between base flows and generation flows below the project could restrict mussels from otherwise suitable habitat, limiting and/or stressing these sensitive populations.

CRWC requests that PSPC conduct a survey of the upper portion of the Fife Brook impoundment and the reach downstream of Fife Brook Dam in order to determine the diversity, abundance, and distribution of freshwater mussels. Results of the survey would be used, in conjunction with the Instream Flow Study, to determine an appropriate below-project flow prescription, as well as to recommend an appropriate water level management protocol for the headpond (e.g., limiting impoundment fluctuations to protect mussel populations).

Proposed Methodology

CRWC requests a mussel survey be conducted at the project. Because field identification of freshwater mussels can be quite difficult, we recommend that the Applicant hire a freshwater mussel expert to perform the assessment. The methodology should be similar to that used in recent licensing proceedings, such as those on the Connecticut River.

In general, the survey should follow standard protocols developed by the Massachusetts Natural Heritage Endangered Species Program. For the headpond, the survey should occur along the uppermost 1,300 feet of the lower reservoir. Given the length of the downstream reach, a subsampling procedure may be appropriate; however, particular attention should be given to the island complexes. Results should include the number of each mussel species observed, relative abundance (catch per unit effort) by species, the location and condition of each mussel, and the habitat it was found in.

Level of Effort and Cost

The study likely will take 2 to 3 weeks to complete. A similar study being undertaken by FirstLight as part of the relicensing of its Turners Falls Project (FERC No. 1889) was estimated to cost $20,000 to $30,000. As the scope of that study was broader than this one, CRWC estimates it will cost BSPC $20,000 to complete the requested study.

The Applicant did not propose any studies to meet this need in the PAD.
CRWC Study Request #11. Controlled-flow Recreation Study
Conduct a study to assess the angling, paddling, and floating experiences on the Deerfield River from the lower section of the “Dryway” (sometimes referred to as the “Dragons Tooth Section”), lower reservoir, pump storage upper reservoir, and for areas below Fife Dam to assess the impacts of current and proposed project operations. The study should include assessment of power company operations, relationships and level of cooperation and communication protocols by and between Brookfield/Bear Swamp and Transcanada, for the purpose of improving recreational experiences.
Goals and Objectives
The goal of the flow study is to assess the presence, quality, flow information needs, and preferred flow ranges for river-based uses. The information to be obtained can be generally characterized as quantitative and qualitative descriptions.
• Assess the effects of a range of optimal and acceptable flows on whitewater recreation opportunities for whitewater paddling at the top of the Bear Swamp Reservoir and below the Fife Brook Development;
• The impact of the Bear Swamp Reservoir on whitewater flows in the natural river channel above Fife Brook Dam;
• The frequency, timing, duration and predictability of optimal and acceptable paddling flows under current, modified run-of-release (project inflows from the TransCanada No. 5 Dam are generally equal to Project outflows), and proposed alternative operations;
• The optimal timing for whitewater releases from Fife Brook Dam so as to maximize recreational use for both boaters and anglers;
• The location, challenge, and other recreational attributes associated with specific rapids and other river features;
• The access needs of whitewater boating use and the current and potential river access options for whitewater and other paddling;
• The flow information needs of whitewater boating and the current and potential flow information distribution system.
• Identify flows that are acceptable and safe for anglers;
• Identify ramping up/release levels that are acceptable and safe for anglers;
• Identify ramping down levels that are acceptable and safe for anglers;
• Identify impacts of hydro-peaking and flow fluctuations on angler access, enjoyment, and safety;
• Identify impacts on access, enjoyment, and safety of the angling experience as a result of the current notice protocol for releases;
• Assess communication processes and protocols by and between Brookfield/Bear Swamp and Transcanada with regard to un-anticipated/un-scheduled releases

Thus, the information to be obtained for controlled flow study is a combination of user-generated flow preferences and other data, information on current and proposed operation (e.g. discharges), geographic information and basic recreational information.

Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in recreational use of the Deerfield River.
Existing Information and Need for Additional Information

Available information in the PAD does not indicate how project operations affect recreation experiences throughout the project area including up and down river of Fife Dam. Users are not allowed to access Lower Reservoir excepting the confluence of the Dry Way. No access at all is allowed in the pump storage upper reservoir. Various river access points on the river below Fife Dam are unsafe and need to be improved for easier angler access.

In preparation for the 1994 Deerfield Settlement Agreement, no controlled-flow whitewater study was done of the reach below the Fife Brook Dam, nor of the concealed rapids in the upper Fife Brook impoundment.

The only controlled-flow study on the Deerfield River was conducted on the Monroe Bridge section by Clark Associates in 1990, over twenty-five years ago. There has never been a controlled-flow study on the Fife Brook section, nor on the rapids submerged beneath the impoundment. A study of these resources is now relevant in terms of participant usage, and should be conducted using metrics and the present-day evaluation criteria that are now available for this type of recreational and resource assessment.

Current and historic project operations have resulted in significant information gaps and virtually eliminated all stable low and moderate flows from the reach under the impoundment. While there is limited anecdotal information on the rapids beneath the impoundment and substantial experience with flows below the dam, a controlled-flow study utilizing methods proscribed by Whittaker, et al. (2005) is necessary to provide FERC with a qualitative analysis of the resource.

Changes in project ownership over the years have also resulted in inconsistent and somewhat unreliable timing of flows in the Fife Brook Section. The result has been flows too low or too late to paddle or fish, and generally river-runners and anglers have received inconsistent information about the river at low flows.

Nexus to Project Operations and Effects

The Project controls flows in the Deerfield River by fluctuating water levels in the impoundment as a result of the current mode of operation at the BSPS. In addition, the Fife Brook Development limits the paddling opportunities throughout each year as a result of the timing and velocity of generational flows. This includes the reduction or virtual elimination of valuable and regionally needed paddling opportunities several days each week during the summer. The Deerfield River is a high quality paddling and angling resource, and since both activities are flow dependent activity, the project operations directly affect recreation and the economic benefits of the Deerfield River.

Safety concerns from project operations are documented by emergency response episodes by the Charlemont Fire Department. In addition, Trout Unlimited member anglers have experienced and observed many accounts of anglers being stranded on the wrong side of the river when confronted with unexpected sudden releases.

As a result of operations detailed above, this is also having a negative impact on the local economy. Disillusioned anglers who no longer fish on the Deerfield River are spending their money at other fishing destinations. Local restaurants, hospitality, and other businesses that service anglers are suffering loss of business. There are no less than six fly fishing guide professionals who regularly bring clients to the river from just below Fife Dam all the way to the confluence with the Connecticut River. Without accurate, timely, and reliable flow information these guides regularly have to make adjustments to client fishing locations.

Results of the study will be used to determine appropriate project operations/release levels and protocols that will protect and/or enhance angler safety, access, and enjoyment.
Proposed Methodology

Whitewater methods

The study on the Bear Swamp Reservoir impoundment and the Fife Brook Section should follow the standard methodology as described in Whittaker, et. al. (2005). This methodology is designed to assess the presence, quality, and preferred flow ranges for river-based boating resources in a step-wise manner. The process steps are generally 1) desktop analyses, 2) on-land feasibility assessment, 3) on-water single flow assessment, 4) on-water multiple flow assessment. We request that on-water multiple flow assessments be conducted with multiple types of paddlers and floaters.

One study should focus on the reach below the Fife Brook Dam. The other study should focus on the lower reservoir’s submerged whitewater drops at various impoundment levels and flows. This whitewater boating study methodology has been used on dozens of other FERC regulated reaches, including recent studies on the Connecticut River.

Angling methods

The flow study should include various release levels at the Project to evaluate angling at a range of flow conditions. A specified group of study participants should be invited to fish the river at minimum flow and at no less than three (3) additional flow/release levels, and then assess their experiences. The area of concern for this release study would be limited to the first 7.5 miles below Fife Dam, as this is the area of most concern for river safety issues. Recreational anglers and guides would assist in identifying the appropriate more popular areas for angling, and would participate in the study.

The flow survey should elicit specific responses to: whether the level of the initial warning release/ramped up flow was sufficient to warn of impending danger from peak flow, how well suited the level of release was for different skill levels, whether a higher or lower flow was correlates to a better angling experience, and overall angling experience.

A survey of anglers should be done to determine their overall experience on the river, or in the case of anglers that have decided not to fish the river the reasons why. This survey should include a ranking of angling experience characteristics, ranking of flows in order of preference, overall evaluation of flows, and assessment of Waterline information sought and relied upon.
Level of Effort and Cost

CRWC estimates this study will cost approximately $45,000-75,000. The Licensee PAD proposes no controlled flow analysis. We currently do not know the relationship between specific low and moderate flows and the paddling, floating, and angling experiences they provide. A desktop analysis cannot generate this information. Without this information we cannot fully define the project impacts, nor propose and consider provision of releases that provide targeted recreational experiences.
CRWC Study Request #12. Recreation Site Inventory, Use, and Needs Assessment
Goals and Objectives

The goal of this study is to identify and study the quantity, quality, and adequacy of the land-based recreational facilities associated with and in close proximity to the Fife Brook Dam and the Bear Swamp pumped storage facility. The study should evaluate facilities for the Bear Swamp and the Fife Brook developments for non-motorized use by commercial rafting companies, private whitewater boaters, paddlers and floaters, hikers, and anglers. This study should include put-in and take-out facilities especially for canoeing and kayaking, portage routes, campsites, multi-use trails, parking and road access, seasons of operation, maintenance, and sanitary facilities. The study should examine the facilities that are necessary for boat access to the river and to the Bear Swamp Reservoir, parking lot size consistent with projected usage, erosion control, electrical service for both outfitters and private users, and those whose needs are characterized under the “Americans with Disabilities Act” or ADA.

The goals of this study are to:

• obtain information about the condition of existing recreation facilities and access sites at and in close proximity to the project and along project-affected reaches of the Deerfield River;
• obtain information about existing recreation use and opportunities, access, and present and future use estimates for sites within the project-affected area;
• conduct an assessment of the need to enhance recreation opportunities and access at the project;
• present the recreation use and opportunities at the project within the larger context of regional opportunities; and
• lay the foundation for preparation of a Recreation Management Plan (RMP) for the Project that will be included in the license application.

Key objectives associated with the various components of this

Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in recreation in and around the Deerfield River.

Existing Information and Need for Additional Information

Section 5.9 of the PAD provides information on recreation facilities and opportunities provided on project lands and in the vicinity of the project. Section 5.9.1 of the PAD cites a 1991 study that estimated 50,000 visitors annually to the Fife Brook and Zoar Gap area. BSPC’s Form 80’s for Bear Swamp and Fife Brooks filed with FERC on March 27, 2015, however, estimates 13,321 annual visitors to Fife Brook and 1,301 visitors to Bear Swamp. There is no accurate, recent information on the number of recreational users in the area and the adequacy of the facilities currently available.

The PAD provides an inventory of camping and sanitary facilities available to kayakers, canoeists, anglers, and other river users available at Mohawk Trail State Forest, Savoy State Forest, and Mohawk Park. However, all facilities are either state-run or private and are usually over-booked. There are currently no camping facilities provided by Bear Swamp Power and Brookfield. Under “TABLE 5.9-2 PUBLIC ACCESS AREAS ALONG THE DEERFIELD RIVER” there are no sanitary facilities listed. While we acknowledge that some sanitary facilities do exist at several access points, they are in woefully poor condition, unsanitary, and inadequate to support the volume of usage.

The information on the Form 80’s submitted by BSPC in March, 2015 are in conflict with information presented in the PAD. A complete inventory of recreational access and use is needed.

Site-specific information on visitor perceptions and identified needs at the project, and whether existing access facilities in the area are meeting current and expected future recreation demand has not been collected. There is no information available about whether some user groups avoid the area because of project operations or the condition of recreational facilities.

The area up river of Charlemont, being approximately 8 miles of river does not have cellular phone service. Some fishermen, even those that have a wealth of experience, have been caught on the wrong side of the river when an unknown and un-expected 800-900 cfs release arrives at their location. This is causing some to run the risk of wading across or having to hike sometimes in excess of 1-2 miles to gain access to a bridge. This unsafe situation is a recurring problem. As a result many anglers have abandoned fishing the Deerfield River.

Nexus to Project Operations and Effects

As a result of the 1997 amendment to the license that established whitewater releases, much has changed on the Deerfield River. Rafting companies have flourished. Tubing has become wildly popular. On the other hand, fly fishing has apparently suffered. This study would provide new information regarding adequate access and facilities for a diverse cross-section of river enthusiasts. This study is vital to defining access facilities that can best be adapted for whitewater boaters, anglers, hikers, hunters, and other potential user groups. FERC and the applicant should be aware of the conditions on the ground, and the needs of user groups, before a new license is issued.

Proposed Methodology

Methods used for this study should be similar to that proposed by TransCanada in their Revised Study 30 for the relicensing of the Vernon, Bellows Falls, and Wilder Dams on the Connecticut River (Revised study plan dated August 13, 2014 and approved by FERC with modifications on September 19, 2013). The study should be broken down into three components.

We feel that accurate counts should be made of recreational use of the river from Bear Swamp Reservoir down to the Deerfield #4 Dam. This would include all users on the river including kayakers, canoeists, rafters, solo rafts, tubers, and whatever. It should include all forms of recreation including fishing, bird watching, hikers, and so forth.

A. Recreation Site Inventory

An inventory form should be used for site visits at all publicly accessible sites within the project-affected area to document existing facilities and resources. These will include project sites and informal sites.

Amenities at each site, such as the presence and type of restrooms, types of activities supported, parking spaces, and parking surface, will be recorded along with digital photos and GPS points. This inventory will identify and characterize public facilities and resources, and the conditions of those facilities. Formal and informal river access sites will be visually assessed and photographed to record any opportunities or challenges for craft or anglers. The inventory should be one of the first tasks of the study.

The inventory will include the feasibility of incorporating a portage route around the Fife Brook Dam. The study should review land ownership surrounding the project area and investigate shoreline slope conditions (e.g., steepness, length) for alternative take-out and put-in options.

The results of the inventory will provide baseline information regarding existing recreation facilities and resources at the projects and along project-affected riverine reaches. The inventory information will be assessed in conjunction with a visitor intercept survey.

B. Recreation Use and Needs Survey

The use and needs assessment will document recreation activity types known to occur or potentially occurring at in the project-affected area.

Use Survey: Three components should be used to collect existing and potential (future) recreational visitor use data:
1) existing public use (traffic counters, spot counts, and visitor intercept interviews);
2) potential visitors (mailed and/or online questionnaire); and
3) use from outfitters (e.g., whitewater companies like Zoar Outdoor as well as professional fishing guides on the river). Data should be collected year-round, with an emphasis on the peak season (April 1 to October 31).

The use survey on the river should break down use by type of watercraft – personal canoe, personal kayak, multi-person float boat, inner tube, stand-up paddle board, etc.

An estimate also should be made as to the decrease in angler days on the Deerfield River as a result of the practice of hydropeaking. Prior to electricity deregulation, scheduled releases on the Deerfield were mitigated by the practice of adhering for the most part to a schedule of releases that was made publically available. Thus, anglers were able to fish the River on mornings, evenings and weekend hours with some degree of confidence that when they arrived the water levels would be as scheduled in advance. That is no longer the case, and no assessment has been done to date on the estimate of the decrease in angler days or to the non-use of the resource.

An additional component of this study is the Waterline Flowcast. The study should capture the information provided on the Waterline Flowcast on a daily basis throughout the study period (http://www.h2oline.com/default.aspx?pg=si&op=255123). This information should then be compared to the actual flow information on the river, both at the Charlemont USGS gage and just below Fife Brook dam. The study report should show a separate graph with Flowcast vs. actual flow information at 15-minute increments for each week of the study period.

Needs Assessment: The needs assessment will address: 1) existing paddling, angling, hunting, hiking, and camping opportunities within the project-affected areas and nearby; 2) the feasibility of providing additional public access within the lower reservoir and in downstream reaches (potential locations, type of facilities and access, and any associated costs); 3) the feasibility of providing small walking bridges (such as those commonly available in Europe) over the river for hikers and anglers to use when stranded on the “wrong side” of the river; and 4) visitor perceptions of the adequacy of recreation facilities and access in the project areas during summer, fall, and winter sport seasons; and 4) .

The following issues should also be included:
• Access to the whitewater rapids in the Lower Reservoir when the pool height is at its lowest levels;
• Access to the shoreline areas surrounding the lower reservoir for hiking and angling;
• Access to the water in the lower reservoir for boating;
• Portage around the Fife Brook Dam;
• Adequacy of access at put-in areas below Fife Brook Dam;
• Adequacy of access at take-out area above Zoar Gap Rapid;
• Adequacy of access to put-in/take-out area below Zoar Gap Picnic Area;
• Adequacy of access to put-in/take-out at Shunpike Area on MA-Rte. 2;
• Adequacy of access at informal put-in and take-out locations;
• Adequacy of parking facilities at all formal and informal put-in/take-out locations;
• Adequacy of the Waterline Flowcast;
• Adequacy of camping opportunities;
• Need for electrical service to reduce the noise from generators; and wi-fi access at Fife Brook Dam and Zoar Gap Picnic Area so boaters and anglers can get up-to-date river flow and other pertinent user information that can change;
• River access by disabled individuals whose needs are characterized under the “Americans with Disabilities Act.”
• Adequacy of places to cross the river safely for recreational users

C. Future Use Assessment

Future use estimates should be calculated by assessing future demand for recreation activities and population trends for the expected term of the new license. Growth in recreation activities and recreation use projections for the anticipated growth in recreational use through 2060 should be developed using Outdoor Recreation in American Life: A National Assessment of Demand and Supply Trends (Cordell et al., 1999), Outdoor Recreation Participation in the United States – Projections to 2060 (Bowker et al., 2012), and Outdoor Recreation Trends and Futures: A Technical Document Supporting the Forest Service 2010 RPA Assessment (Cordell, 2012). Current use estimates should be projected with indexed values of expected changes in the number of recreation days for given activities at the projects to estimate future recreation use in the project for 10-year increments out to 2050.

Level of Effort and Cost

TransCanada has estimated that their Study 30 will cost $390,000. The TransCanada study covers three projects on the Connecticut River. The Bear Swamp facility covers a much smaller geographic area, and CRWC estimates that the requested study will cost $175,000-$225,000.

BSPC has proposed to characterize recreational facilities and conditions in the project boundary and nearby areas. We believe there is justification to include the information requested here.

References

Bowker, J.M., A.E. Askew, H.K. Cordell, C.J. Betz, S.J. Zarnoch, and L. Seymour. 2012. Outdoor Recreation Participation in the United States – Projections to 2060. July.
Cordell, H.K. 2012. Outdoor Recreation Trends and Futures: A Technical Document Supporting the Forest Service 2010 RPA Assessment. March.
Cordell, H.K., C. Betz, J.M. Bowker, D.B.K. Englis, S.H. Mou, J.C. Bergstrom, R.J. Teasley, M.A. Tarrant, and J. Luomis. 1999. Outdoor Recreation in American Life; A National Assessment of Demand and Supply Trends.

CRWC Study Request #13. Economic Analysis of Project Operations and Recreation
The Deerfield River is an important recreational and economic resource to the northwestern region of Massachusetts. The river maintains its pristine water quality and at the same time remains a remarkable recreational resource. Its value reaches far beyond the river itself.

We therefore request that Bear Swamp Power and Brookfield undertake an independent analysis to quantify the economic impact of river-based activity on the Deerfield River.

Goals and Objectives

The economic study should analyze the impact in economic terms of the 1997 Settlement Agreement recreation enhancements and of river use since then. This study will establish a baseline explaining the economic results of the Settlement Agreement and of present operations.

Relevant Resource Management Goals
Not applicable. Requester is not an agency or Indian tribe.
Public Interest Consideration If Requester Is Not a Resource Agency
Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. The Deerfield River is valued public resource. The public has a strong interest in recreational opportunities in the Deerfield River watershed. Regional economic benefits derived from high quality outdoor recreation stabilize local economies and spin off other economic activity.

Existing Information and Need for Additional Information

During the 1994 Settlement Agreement, a contingent valuation study was done of whitewater releases from the #5 Dam at Monroe Bridge. Among other findings, the study said that for every $1 of foregone power generation, $24 of regional economic value was derived from the recreational releases. Instead of requesting a contingent valuation study—which is, after all, an attempt to predict the future related to license conditions—we would like to see a study of the actual benefits from that Settlement Agreement. The study proposed here would examine the actual benefits that have been produced by the whitewater recreational releases from the Fife Brook Dam and other provisions of the agreement. This is important information for regional planners, and for FERC in considering license requirements and mitigation.

It would also examine economic losses from less angler use on the river. More recently an increasing number of anglers have come to avoid the Deerfield River entirely as they have become unwilling to travel to the River only to discover that it is essentially unfishable due to high water from unscheduled releases. The result is that the number of angler days has dropped significantly and the value of the recreational fishery on the Deerfield has been severely impacted.

The Form 80 responses from the applicant are significantly flawed in methodology. This study should fill in the gaps created by that inappropriate methodology.

Nexus to Project Operations and Effects

The economic analysis will tie project operations to public benefits. FERC can use the analysis in determining appropriate provisions in the license as well as mitigation. The project operating changes in the 1997 Settlement Agreement that produced 106 whitewater releases created a new whitewater community and economy, as well as benefits for recreational anglers. There is a direct connection between project operations and impacts on the regional economy.

Proposed Methodology

The economic analysis should be done with a broad understanding of the way a recreational resource can have wide impacts. Since the Deerfield Settlement Agreement, the whitewater rafting companies such as Zoar and Crab Apple have built multi-million dollar businesses that are a tremendous benefit for this depressed area of Massachusetts. Fishing guides have grown in number. What have been the net economic benefits/losses to the area from the Deerfield Settlement Agreement recreation enhancements, and what might we expect from extending and enhancing those opportunities?

The previous study request, recreational site inventory, use and needs assessment, will estimate a decrease in river angler days. This study will estimate the value of lost angler days in order to estimate the economic losses to the Deerfield recreational fishery.

Level of Effort and Cost

The economic study involves desktop work, consultations with rafting companies and fishing guides, and analysis of before-and-after town and state tax documents and other useful information. This study may cost $150,000.