FOR IMMEDIATE RELEASE

WATERSHED COUNCIL SEEKS SONGS ABOUT TROPICAL STORM IRENE FLOODING

Greenfield, MA. May 14, 2012 – The Connecticut River Watershed Council, a conservation group based in Greenfield, MA, has announced it is soliciting songs inspired by the flooding from Tropical Storm Irene. These songs will be featured in a concert to be held on August 28, 2012, the first anniversary of the flood. Roads, bridges, homes and businesses were flooded or washed down the rivers in Western Massachusetts and Southern and Central Vermont. Idyllic brooks became raging torrents and whole towns were cut off from the world. Hurricane Irene had widespread damage up the entire East Coast but the affect in the Northeast was the result of a huge lingering rainstorm that overpowered the drainage system of the rivers. Some rivers experienced 100 year and 500 year events.

“Many people were affected by the Tropical Storm Irene flooding in deep ways: emotionally, economically and spiritually,” says Pat LaMountain, who, along with her husband, Tex, is producing the concert. The duo have been singing, writing, performing and harmonizing together for almost 35 years and have shared the stage with Bonnie Raitt, Jackson Browne, Pete Seeger and Arlo Guthrie. “This concert is meant as a way to make peace with the power of nature we witnessed and experienced.”

The concert will be a benefit for the Connecticut River Watershed Council’s annual Source to Sea Cleanup which this year takes place on September 29th. Pat and Tex also have a personal reason for wanting to support the Cleanup effort and give voice to Tropical Storm Irene’s impact.  “This year, some of the stuff being pulled out of the river will be parts of our barns and our summer place,” explains Tex LaMountain. “We lost all five buildings at our Hawley, MA retreat, the place we would go to write songs and watch grandchildren enjoy nature. It all went down the Chickley River on August 28^th.” “I’m still looking for my hula hoop, the silverware, everything. The river is so powerful. It’s just gone,” adds Pat.

To enter a song for consideration, go to the CRWC web site at www.ctriver.org. Deadline for submission is June 21, 2012 and there is a $10 processing fee. People may also make a donation for the concert. In 2008 and 2009 the Council held songwriting contests of river songs. In 2010 many of the winning songs were presented in a concert at the Academy of Music in Northampton. This year’s event is not a contest but a concert that brings together the community to celebrate, mourn, and come to terms with the impact that Tropical Storm Irene had on our community. The concert is also about supporting the local songwriting community.  “The Council knows how to support songwriters and give them a stage for their work in a conscious, careful way. We cater to songwriters because we are songwriters.” emphasized Tex LaMountain. To learn more go to www.ctriver.org.

END

]]> http://www.ctriver.org/newsroom/press_release_and_news_articles/?feed=rss2&p=229 0 http://www.ctriver.org/newsroom/press_release_and_news_articles/?p=235 http://www.ctriver.org/newsroom/press_release_and_news_articles/?p=235#comments Tue, 01 May 2012 17:00:06 +0000 David Deen http://www.ctriver.org/newsroom/press_release_and_news_articles/?p=235 Vermont.  May, 2012.  Experienced river users often refer to rivers, streams and lakes as being part of a watershed.  We use the word because we are familiar with the notion that all surface water is connected to itself and some larger watery ecosystem. The classic definition of a watershed is: “The land area that drains surface and groundwater into the same larger body of water.”

To figure out your watershed just think about a raindrop that falls on the land. That raindrop may travel down a small rivulet to an unnamed stream to join a small brook that joins with other streams until you have a named river like the Mascoma or Wells Rivers that join the Connecticut River that flows into Long Island Sound. The main river travels some 375 to 410 miles to the Sound depending on the source of your information but a healthy river never goes from here to there in a straight line so attaching a specific length to the river is a human conceit. The river is as long as it wants to be.

We seldom identify with a huge watershed like the Long Island Sound watershed, mostly we think about our local rivers. Towns, organizations and regions are named for their local watersheds. Saxtons River Village, the West and White River valleys, the Ammonoosuc Community Trust and Connecticut Lakes Region are a few examples.

Watershed characteristics usually change as rivers move from the highlands to the plains. This is certainly true about Connecticut River if you think about its whole length. In the North Country the Connecticut is small, seemingly wild and intimate but south of our border it welcomes more power boaters as it passes through large cities. But interestingly enough, our Connecticut Lakes Region and the tidal marsh area at the mouth of the river are both wild places that welcome explorers for enjoyable fishing, boating, birding and wildlife viewing.

The Connecticut River experiences rising and falling water levels on a daily basis throughout most of its length. In the North Country it is the effects of the dams producing electricity. In the southern reaches the river is tidal. The name Connecticut River is an Anglicized version of the first peoples name for the river, ‘Quonehtacut’ that meant the Long Tidal River. The seasonal flow determines both the extent of the reach of saltwater up river and the tidal rise. At low flows the river is tidal for 60 miles from Long Island Sound all the way to Windsor Locks, CT. During spring freshet when the river can be discharging up to 29 billion gallons a day there is little noticeable tide away from the Sound.  During dry times when the flow has lowered to 4.5 billion gallons a day the tide swing can be nearly 4 feet.

What is known as the “salt wedge”, the saltwater portion of the rising tide, extends all the way up river to Chester, CT, a distance of some 10 miles from the Sound.  It is called a wedge because saltwater is heavier than freshwater and lifts the freshwater to the top.  The saltwater mixes from the top down so at the leading edges of the tide the saltwater layer is the thinnest, hence the notion that the saltwater forms a wedge along the bottom of the river.

For those of us in the upper reaches of the river the most alluring place is the CT Lakes region where the headwater lakes start the river on its trip to the Sound.  Starting in a bog know as the 4^th CT Lake at the Canadian border the trickle that is the river joins with Indian Stream, Pauls Stream, the Mohawk River and by the time it reaches Colebrook, NH it is a real river. The country is wild, populated with moose and other critters that demand undisturbed habitat.  The Lakes area is rich with water and the watershed there forms a tangle of backwater ponds and small lakes all draining into the river.

For many of the people in the lower reaches of the river the most alluring places are in the tidewaters area.  In this reach of the river, because the river deposits so much silt and sand, no large port ever developed and the area was thought of as wasted land.  Despite efforts to drain and “reclaim” the land the marshes have persisted and the wild species, especially birds, have succeeded in this undisturbed habitat.  The tidewater area is recognized by the United Nations Ramsar Convention as “Wetlands of International Importance for birds.”  The marsh areas are wild and just witnessing the bird life is worth the trip.

As different as The Great River is at its start compared to its finish, it is all the same watershed and it is all available for you to experience. For more information about how to get on the river throughout its length you can get the CRWC Boating Guide at www.ctriver.org. You will also find links to other organizations that will help you experience the wonders of the Connecticut River, Source to Sea.

#          #          #          #

David L. Deen, River Steward for the Connecticut River Watershed Council. CRWC is celebrating 60 years as a protector of the Connecticut River.

Arthur S. Johnson
Massachusetts Department of Environmental Protection
Division of Watershed Management
627 Main Street, Second Floor
Worcester, MA 01608

Subject:           Proposed Massachusetts Year 2012 Integrated List of Waters

Dear Mr. Johnson,

I am submitting comments on the proposed Massachusetts Year 2012 Integrated List of Waters on behalf of the Connecticut River Watershed Council (CRWC).  CRWC is the principal nonprofit environmental advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed.  The Connecticut River and its tributaries (including the Deerfield, Millers, Chicopee, Farmington, and Westfield River basins) take up approximately one-third of the land area of Massachusetts.

The 2012 Integrated List does not contain much new for what we will call the “greater Connecticut River watershed,” consisting of the Connecticut River mainstem, Chicopee River, Deerfield River, Farmington River, Millers River, and Westfield River basins.  Therefore, our focus turned on the amount of listed impairments vs. the pace of preparing Total Maximum Daily Loads (TMDLs) for these impairments.  Below is our summary of the top eight impairments for Category 5 impaired river segments that do not yet have a TMDL.  As you can see, the number of river miles that are impaired for bacteria contamination, as well as total suspended solids/turbidity are quite high.

Top 8 impairments for Category 5 Impaired Waters in the Greater Connecticut River Watershed, as listed in the proposed 2012 Integrated List (units are in river miles).

We looked with interest at the proposed TMDL schedule for FY2012-13 shown on pages 22 and 23 of the proposed 2012 Integrated List.  We are disappointed to see no TMDLs for the greater Connecticut River watershed listed.  Only nitrogen loadings for Long Island Sound makes it onto a separate TMDL-related project list as getting high priority.

In reviewing what has been accomplished thus far, we see that on pages 16 and 17, all completed and approved TMDLs are listed.  Other than the northeast regional mercury TMDL, which covered many water bodies across the state, the following table lists completed TMDLs for the greater CT watershed.

In sum, no new TMDLs for water bodies in the greater Connecticut River have been completed in 9 years.  No impaired river segment in the greater Connecticut River watershed has ever had a TMDL completed.  We reviewed MassDEP’s TMDL priority document from 1998, which is still on its website today.  This laid out a timeline for completing all TMDLs across the state.  This document said,

“The State of Massachusetts is committed to developing TMDLs for all impaired water bodies where TMDLs are needed by the year 2012 (emphasis ours). To achieve this goal, the Department must effectively allocate resources and rely on all watershed stakeholders to work in partnership. As previously noted, public input and feedback on setting priorities within each watershed as well as on proposed strategies and implementation measures to address water quality impairments is a central component of the State’s approach to meeting its commitments of the Clean Water Act over the next decade. Given this, the Department is proposing to utilize the watershed teams to the maximum extent feasible during the 5 year watershed cycle to help prioritize listed waters for TMDL development. Prioritization will be based upon the relative importance of each water body within the watershed, the constituent of concern causing impairment, and the degree to which analytical methods are defined, accepted, and available to achieve problem resolution.”

Originally, DEP set out with an ambitious plan to complete all TMDLs by this year.  We certainly understand that DEP’s funding has been significantly reduced since then, which no doubt has had an effect on getting numerous things done across the disciplines.  What we don’t understand is how watersheds taking up one-third of the state would be de-prioritized to such an extent that not a single river mile would have a TMDL prepared at the end of the 14-year management period.  Not only has there been no public input on prioritization within watersheds, but there has been no public input on prioritization of watersheds.  We think this is most unfortunate.

We respectfully request that DEP review its prioritization of TMDLs and look towards covering a wider area of the state.  We are waiting for the day when our rivers will be fishable and swimmable out here.  Thank you for the opportunity to comment on the proposed Massachusetts Year 2012 Integrated List of Waters.

Sincerely,

Andrea F. Donlon

River Steward

cc:

Christine Duerring, MassDEP basin planner for Connecticut, Westfield, Farmington, and Deerfield Rivers
Alice Rojko, MassDEP basin planner for Millers and Chicopee Rivers
Julia Blatt, Massachusetts Rivers Alliance
Mary Garren, USEPA

Secretary Richard K. Sullivan, Jr.
EOEEA, Attn: MEPA Office
Holly Johnson, EOEA No. 14089
100 Cambridge Street, Suite 900
Boston, MA  02114

Subject:           Final Environmental Impact Report for EOEA# 14089 Palmer Motorsports Park –Palmer, Massachusetts

Dear Secretary Sullivan,

I am submitting comments on the Final Environmental Impact Report (FEIR) for the Palmer Motorsports Park in Palmer on behalf the Connecticut River Watershed Council (CRWC).  CRWC is the principal nonprofit environmental advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed.  The proposed motorsports park will alter more than 65 acres of land, and will create more than 20 acres of impervious surface.  As you are well aware, work done as part of the Sustainable Water Management Initiative (SWMI) has identified impervious cover as being an important factor explaining alterations of flow and fluvial fish assemblages in rivers and streams statewide.  Given the high degree of impervious cover that will be created in a currently-wooded area, we focused almost exclusively on this detail in our review of the FEIR.

Looking at the SWMI data viewer (http://www.mass.gov/dep/water/resources/swmi.htm), the site appears to be located in one sub-basin that drains towards the Ware River and another sub-basin that drains to the Quabog River.  Both sub-basins are category 3 in biological alterations (15-35% altered) and category 2 in flow alteration (3-10% altered).  The biological category at level 3 is cause for concern, because this site could further degrade the fish habitat in the sub-basin.

The large map titled “Well & Outfall Location Plan” in the FEIR shows detention basins #3 and #4, plus something called a finger basin and a “small outlet.”  It is not clear how these areas correspond to the drainage areas A through G identified in the DEIR.  In fact, it would be helpful to see the catchment areas delineated in a pre-construction map and a post-construction map.  I have not been able to find a map that would show which drainage areas drain towards the Ware River and which towards the Quabog.  The Secretary’s Certificate for the Draft EIR (DEIR) on page 4 asked for a map of sufficient scale to show the stormwater discharge locations (see Water section).  Though the detention basins were shown on the map, no information is given as to where the basins drain.

Stormwater calculations were included in more detail in the DEIR, but the results were summarized in Appendix A of the FEIR.  The source of climate data included in the DEIR or FEIR was not given, but in the last several years, there has been an update to the 1960’s climate data in New England and New York.  The Northeast Regional Climate Center has created an interactive web tool online at http://precip.eas.cornell.edu/.  It appears that the data particularly for the 50- and 100-year storm are quite a bit higher in Palmer than that given in the FEIR.  See summary table below and printout from the database attached.  Many people recognize that climate change has already started to occur, therefore CRWC recommends that stormwater calculations be updated to reflect the more recent numbers.

Next, we tried to make sense of the printouts from the DEIR that led to the numbers shown in Appendix A of the FEIR.  There appear to be discrepencies, perhaps.  Drainage area acreages changed from pre-construction to post-construction in some areas, and without a map showing this, it’s hard to tell if this is intended or if the model has missed something.  It also is unclear how the model arrived at post-construction runoff volumes.  For example, in drainage area 5R (also called E), the 2-year storm predicts a pre-development peak discharge of 33.9 cubic feet per second (cfs), whereas the post-development peak discharge is given as 35.6 cfs.  The drainage diagram shown in the DEIR indicates the post-development conditions will consist of two catchments, with one having two small ponds.  Perhaps it’s a lack of understanding on our part, but we aren’t clear why the flow out of 5R isn’t the two sub-catchments added together (12.81 + 24.41 = 37.26) rather than the amount modeled as 35.59 cfs.  The model does not show any reduction of peak flows from the two ponds, which we would have thought would lead to reduced flows.  Similarly, we thought the post-development flow in area 6R would be 17.70+1.14+2.74 = 21.59 cfs, rather than 19.86 cfs, as compared to pre-development flows modeled at 17.78 cfs.  See information taken from the DEIR below.

Examples of two drainage areas, calculation of 2-year, 24-hour rain event

Section 4 of the FEIR describes the stormwater controls, but there is no associated map showing where the Stormceptors will be located, nor where the existing wetlands or surface water resource areas are located, or perhaps they are shown but not labeled.  Roadway drainage swales are not shown on a map.  It is difficult to evaluate the overall stormwater management plan without seeing the location of each component.

Page 20 of the FEIR states that Appendix C includes a summary of the location of each Stormceptor unit and the sizing criteria utilitized.  Appendix C does show in the comments section what area the Stormceptor is intended for.  For example, we see that Detention Basin 3 is drainage area F.  It says that the total area is 4.3 acres.  However, area F or 6R in the model, has 38 acres (1,681,500 ft²), so once again it is difficult to determine how this information corresponds with the drainage diagrams in the DEIR.

Our last observation is that approximately one-third of the septic system discharge area appears to be covered with pavement.  Is this acceptable?

We thank EOEEA for the opportunity to comment on this project.

Sincerely,

Andrea F. Donlon

River Steward

Dear Paul,

The Connecticut River Watershed Council, Inc. (CRWC) agrees that the work proposed by HG&E as discussed on the March 8, 2012 conference call is aimed at meeting the Settlement goal for downstream shortnose sturgeon passage at the Project, and CRWC agrees that HG&E should move forward with design and permitting.

Some of the key elements of the design as agreed upon currently are summarized as follows:

• Installation of a new angled bar rack in front of the turbines, with 6-inch rack bars and a 2-inch clear space.
• Solid overlays will be placed on the rack over units 1 and 2 on the full width of the rack down to a bottom elevation of 95 ft.
• Solid overlays will be added on the horizontal section of the rack just upstream of the weir and on the adjacent sloping portion of the rack next to the dam, down to the third structural member (as shown in Figure 1 in the February 2010 narrative for new CFD runs 21 and 22.  Note the committee decided this was preferable than Figure 2).
• A cut-off wall will be added between the weir and the Unit 1 intake to prevent fish from entering the low velocity eddy in that region.
• HG&E proposes to install a new turbine at Hadley Unit 1.  The unit proposed has a radial clearance of 0.085 inches, thicker entrance edges for the runner blades, and a smoother operation during high flow, new wicket gates to provide smoother passage through stationary water passage components.
• A potential flow allocation plan under the inclined rack configuration was distributed to us dated March 2012.
• At the downstream end, plunge pool will be designed according to revision 3 as modeled in CFD model Run L dated June 2011.

The current design is the best attempt over the course of more than five years of studies, designs, modeling, and comments by HG&E, their consultants, and the CCT.  The design has not been tested in the field, so we do not know for sure that sturgeon will find and use this passage route, and we also only have estimates of passage survival.  As we have discussed in meetings, concerns related to lateral flow to the weir, flows across the depth of the water column, success in regard to getting sturgeon to swim to the surface in order to reach the weir, impingement and entrainment of eels, and fish reaction to the corner near the weir entrance will be addressed in the context of post-construction monitoring.

Sincerely,

Andrea F. Donlon, M.S.

River Steward

Subject:  Environmental Status and Planning Report for EOEA# 11202 – MassDOT Snow and Ice Control Program

Dear Secretary Sullivan,

I am submitting comments on the Environmental Status and Planning Report (ESPR) for the Massachusetts Department of Transportation’s (MassDOT’s) Snow and Ice Control program on behalf the Connecticut River Watershed Council (CRWC).  CRWC is the principal nonprofit environmental advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed.  Because the Connecticut River and its major basin tributaries take up approximately one-third of Massachusetts, MassDOT’s approach to snow and ice removal has a significant effect on our watershed.  We recognize the challenge in keeping roadways safe, yet trying to apply de-icing chemicals in a quantity that is not overly detrimental to the environment.  We submitted a comment letter on the Generic Environmental Impact Report (GEIR) in 2006 and the ESPR Work Plan in 2008.

Our comments on the ESPR document are below.

Operational Changes

CRWC is supportive of MassDOT’s proactive approach to anti-icing that focuses on pre-treating roadways prior to, or at the onset of, a winter storm event.  We are also supportive of the use of new spreader technology improvements, including the requirement for all hired contractors to have pre-wetting equipment on their spreader trucks.

CRWC applauds MassDOT for reducing the use of sand in Districts 1 and 2 by as much as 75 and 95 percent, respectively, over the last five years in comparison to the previous five years.  That reduction has environmental benefits, and we suppose there is a cost savings as well.

Policy and Procedural Changes

We think establishing an internal Snow and Ice Materials Usage Review Committee to periodically review data, policies and procedures to identify changes that would result in greater material usage efficiency.  Based on the January/February 2012 issue of Stormwater magazine (online at http://www.stormh2o.com/SW/Articles/Ice_School_15792.aspx), we have the following suggestions:

• This article suggests that if a spreader truck moves at speeds over 30 miles per hour, 30% of the salt coming off the truck’s distribution spreader will bounce off the side of the road before doing anything to enhance safety.  We didn’t see anywhere in the ESPR where the issue of spreader speed was addressed.  Has MassDOT considered recommending maximum travel speeds for spreader trucks when spreading dry salt?
• One person from Illinois interviewed in the article advocated for a policy of loading only the precise amount of salt needed on each assigned route.  According to the article, the approach can provide an instant reduction with a simple change in behavior, since drivers tend to use up what is loaded.  This sounds like an idea worth considering, if it hasn’t been considered already.
• CRWC is curious if MassDOT has analyzed how hired contractors are paid, and whether the system lends itself to wasteful salt application.  For example, if they are paid for every pound of salt spread, this would be a built-in incentive to use more salt than truly needed.  We could not find any information about this in the ESPR.

Historical Salt Usage vs. Winter Severity Index

CRWC finds the FY 2011 statewide salt usage numbers encouraging, given the severity of the winter.  However, as the saying goes, “one year does not a trend make.”  We’ll need more years of data to see how DOT’s policies have resulted in comparative salt application reductions.

MassDOT reports an average rate of 240 lbs per lane mile, but says that depends on the road and storm conditions at the time.  In looking at Appendix F, which presents the policies for each reduced salt zone in the state, they all say the application rate for 50:50 salt sand is 240 lbs/lane mile.  This doesn’t imply a maximum application rate, or that it’s decided on a case-by-case basis.  Therefore, we wonder what other states are doing and if, given the pre-wetting practice, whether MassDOT could have an application rate notched down slightly, say to 225 lbs/lane mile and see how that goes.

Table 1-3 shows the average salt usage for each district between FY 2002 and FY2011.  Because of the addition of District 6 in FY 2011, the 10-year average for the whole state should be taken from the totals at the bottom of each year.  This number should be 503,566 rather than 502,825.

Comparison of Other New England State’s Snow and Ice Control Practices

We’d like to see an updated table similar to Table 2.6-2 from the 2006 Snow & Ice Control GEIR.  In particular, this table included costs/lane mile by state, tons/lane mile by state, and use of hired equipment.  This information was not included in the 2012 draft ESPR for other states.

Reduced Salt Zones

CRWC supports the idea of using less sand and also less salt in Reduced Salt Zones.

Emerging Technologies

Compared to the 2006 GEIR, MassDOT seems to be more knowledgable and more flexible about trying out new technologies and techniques that could lead to reductions in sand and salt, as well as fuel, use.

Bridge Washing

CRWC appreciates the maintenance advantages to this practice but wonders how bridge washing would be done in a way that minimizes discharges directly to water bodies.

Environmental Effects

For section 2, we also recommend the article by Corsi et al., “A Fresh Look at Road Salt: Aquatic Toxicity and Water-Quality Impacts on Local, Regional, and National Scales” Environ. Sci. Technol., 2010, 44 (19), pp 7376–7382. Online at http://pubs.acs.org/doi/full/10.1021/es101333u

Page 2-20 of the ESPR summarizes the results of the salt TMDL in New Hampshire, which identified commercial parking lots as a major source of salt in impaired water bodies near the I-93 corridor in New Hampshire.  The ESPR concludes that commercial property owners and contractors who maintain their parking lots would also need to be fully involved with implementing measures to reduce salt usage.  That prompted CRWC to wonder how Massachusetts highway rest area parking lots are maintained, and if MassDOT could at least be a guide to reducing impacts from these parking lots.

Recommendations

We think many of the recommendations offered in section 6 are good ideas.  We like the idea of an Annual Report, which could give those interested in the subject of salt application a regular update on how the state is doing.

We aren’t sure what intervals the Snow & Ice Program is to be reviewed through the MEPA office, but it would be nice to get a more detailed update like this ESPR every five years or so.

Thank you for the opportunity to comment on the ESPR.

Sincerely,

Andrea F. Donlon

River Steward

cc:      Laurene Poland, MassDOT

Anne Capra, Pioneer Valley Planning Commission

Kimberly Noake McPhee, Franklin Regional Council of Governments

Michele Cobban Barden
USEPA Region 1
5 Post Office Square, Suite 100 (OEP06-1)
Boston MA 02109-3912

Subject:    South Hadley Wastewater Treatment Plant NPDES Permit
Permit Number: MA0100455, Public Notice MA-009-12

Dear Ms. Barden,

I am submitting comments on the draft National Pollutant Discharge Elimination System (NPDES) permit for the South Hadley Wastewater Treatment Plant (WWTP) on behalf the Connecticut River Watershed Council (CRWC).  The Connecticut River, an American Heritage River, is a regional resource that merits the highest level of protection.  The Connecticut River downstream of the Holyoke dam is listed as an impaired water body due to priority organics (PCBs), pathogens, and total suspended solids.  CRWC is particularly interested in improving water quality in the Connecticut River so that it can support a high quality fishery as well as existing primary and secondary contact uses, even during wet weather.  Our comments are below.

1. The protection of existing uses is required under 40 CFR 131.12(a)(1).  Below is our understanding of existing uses on the Connecticut River in the vicinity of the outfall, which is located downstream of the Holyoke dam, just over the South Hadley/Chicopee town line in Chicopee.

• The Perjovski state ramp is a small state-owned boat launch just upstream of the outfall pipe.  This spot is used mostly by boaters and anglers.

• A boat launch owned and operated by the City of Holyoke is located directly across the river from Chicopee’s Jones Ferry CSO Treatment Facility, a little over three miles downstream of the outfall.  This site, the Jones Ferry River Access Center, has a newly built meeting room and picnic area, and is the launching point for a group called Holyoke Rows (http://www.holyokerows.org/), which offers rowing, kayaking, and canoeing programs for children and adults.  The general public uses this site as a launching point, mainly for canoes and kayaks.  In addition, anglers use the wooden docks at this access point as a fishing spot.

• A state-owned boat ramp (Medina Street) is located in Chicopee about 4½ miles downstream of the outfall.  This boat ramp is extremely busy with motor boat launching on most weekend days in the spring, summer, and fall.  This is especially true during the height of the spring fish migration period.

2.   We commend the town of South Hadley for eliminating their CSOs in 2007.  This was a significant investment by the town and has been a boon to the river.

3.   We support the increased frequency in testing for total residual chlorine, especially because of the frequent violations.

4.   We are very supportive of the addition of brook trout (Salvelinus fontinalis) for whole effluent toxicity testing.  It is re-assuring to see a species added that is a closer reflection of the types of fish present in the Connecticut River and that matches the restoration goals for the entire watershed.

5.   We support the increased testing frequency for total phosphorus and nitrogen compounds.

6.   Page 10 of the Fact Sheet describes the 7Q10 and dilution calculation for the Connecticut River at the outfall pipe.  It would be nice to verify this 7Q10 because the outfall pipe is located across from the Holyoke canals, and though there are several discharges from the canal upstream of this point, the full river flow is probably not present at this spot.  The new location for the USGS gage downstream of the Holyoke dam has been in place for 10 years and there should be a reasonable 7Q10 by now.  Perhaps the old USGS gage would produce a more representative flow because that location was upstream of the canal discharge.

7.   The Fact Sheet at page 13 explains that five bacteria violations over the past 24 months were due to mechanical failure of the chlorine pump, which has been replaced.  This would lead us to believe that not enough chlorine was used to kill the bacteria, but the fact sheet at page 14 indicates that there have been 11 exceedences of the maximum daily total residual chlorine (TRC) limit in the last 24 months.  The Fact Sheet explains the permittee’s difficulty with TRC control, saying pumps were replaced, but that plant staff have also been unable to pinpoint a cause for communication errors in the SCADA system.  Until this problem is fixed, it seems to us that TRC and bacteria will continue to be a problem.

8.   The Fact Sheet on page 23 says that the Town of South Hadley estimates an average of 770,000 gallons of infiltration and inflow (I/I) per day that flows into the treatment plant.  That is a high amount of I/I.  The Fact Sheet also gives detailed information on the I/I Control Plan and past studies.  However, what is missing is the amount of progress on I/I reductions over the years, since the Town first surveyed I/I 20 years ago.  Their plan was developed approximately 5 years ago – has the plan helped them reduce volumes at all?

9.   Section B of the permit stipulates special conditions for nitrogen, requiring the permittee to complete an evaluation of alternative methods for operating the facility to optimize the removal of nitrogen.  The permit expects the facility to discharge less than the “existing” annual average discharge load of 793 lbs/day.  This number is based on 2004-2005 data, and many NPDES permit fact sheets include a table showing all municipal NPDES permits in MA, NH, and VT with average total nitrogen concentrations, average flow amounts, and the loading values. This table (not provided in this Fact Sheet, but we referred back to Chicopee’s Fact Sheet), indicated that in 2004-2005, South Hadley had the 9^th largest discharge volume of wastewater treatment plants in the Massachusetts part of the Connecticut River watershed, but was 4^th highest in terms of nitrogen load.  In fact, the average concentration of nitrogen was the second highest in the MA part of the watershed.

Because the current permit has been in place for five years and has required monthly nitrogen sampling, CRWC took a look at more current data available for the facility as provided in the EPA ECHO database.  To get monthly average concentrations for total nitrogen, we added TKN and nitrate+nitrite together.  We then calculated a monthly loading value by taking the monthly average total nitrogen concentration, multiplying it by the monthly average effluent flow, and using conversion factors to get the units right.  We then averaged those numbers over a calendar year for 2009 and 2010, the two most recent years that have data for the entire year available online.  We calculated an annual average discharge load of 304 lbs/day in 2009 and 397 lbs/day in 2010.  If our calculations are correct, then we question whether using 2004-2005 as a baseline in this permit is the most appropriate, for two major reasons:

• The 793 lbs/day limit proposed in this permit is so much higher than what seems to be the actual current loading range for this plant, that the limit and the required nitrogen reduction loading plan is immediately rendered meaningless.
• We all know Long Island Sound is impaired and additional nitrogen reductions are needed.  Why not take credit for reductions that have already taken place, and work to get meaningful reductions in the most cost-effective ways possible?  If towns like South Hadley have already reduced nitrogen inputs and could do more relatively easily, won’t this be less costly for tax-payers and ratepayers in general than trying to identify and implement a variety of other projects like stormwater BMPs in the watershed?

Thank you for an opportunity to comment on the draft permit for the South Hadley Wastewater Treatment Plant.

Sincerely,

Andrea F. Donlon

River Steward

cc:

Kathleen Keohane, MassDEP

Christine Duerring, MassDEP

Cindy Delpapa, Massachusetts Riverways program

Betsey Wingfield, CT DEEP

Melissa LaBonte, South Hadley Water Pollution Control Compliance Manager

For immediate release – March 27, 2012

WHO: Based in Greenfield, the Connecticut River Watershed Council works to improve water quality and native fisheries in the Connecticut River’s 11,000-square mile watershed in the four states of Massachusetts, Connecticut, New Hampshire and Vermont.  Through its web site and publications – such as the popular Connecticut River Boating Guide – the 60-year-old nonprofit organization promotes conservation, recreation, and a sensible balance between the needs of human and natural communities.  www.ctriver.org

WHAT: Connecticut River Watershed Council has been selected by Whole Foods Market in Hadley, MA as the beneficiary of its 5% Day. Four times a year, Whole Foods Market of Hadley, MA donates 5% of the day’s sales to a selected local charity, and on March 28, 2012, the Connecticut River Watershed Council will be the featured non-profit organization. Connecticut River Watershed Council will staff an information table inside the store leading up to the 5% Day. In addition to learning more about CRWC’s programs, you can also meet special guest Connie Rivers, a gigantic inflatable fish that will be “swimming” around the store reminding people to shop on March 28 to benefit CRWC. A portion of the funds received from the 5% day will be used to replant trees lost during the storms of 2011, particularly in Monson, MA which suffered significant tree losses.

WHEN: Wednesday, March 28 from 8 a.m. – 10 p.m.

WHERE: Whole Foods Market, 327 Russell Street Hadley, MA 01035

HOW: For more information about Connecticut River Watershed Council or the 5% Day at Whole Foods Market, call 413-772-2020, or visit www.ctriver.org.

# # #

Contact:

CRWC: Chelsea Gwyther, CRWC President 413-772-2020 ext 202 (work); 413-658-8552 (cell); cgwyther@ctriver.org

Whole Foods Market: Ann Walsh (413) 586-9932

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

Re:    COMMENTS
Application for a Preliminary Permit, FERC #13273-001
Proposed Canton Hydroelectric Project
Farmington River, Hartford County, CT

Dear Secretary Bose,

This responds to your public notice, dated January 19, 2012, regarding the application for preliminary permit for the Canton Hydroelectric Project, located on the Farmington River in Hartford County, Connecticut. Thank you for the opportunity to provide comment on this project, which would potentially involve the Upper and Lower Collinsville Dams on the Farmington River. I am submitting these comments on behalf of the Connecticut River Watershed Council (CRWC), a nonprofit organization established in 1952 to advocate for the sustainable use of the Connecticut River throughout the entire four-state watershed that is home to more than 2.5 million people. We work to conserve, protect and restore water quality and quantity, habitat and recreational access within the Connecticut River watershed.

The Farmington River is a beautiful and important tributary to the Connecticut River system, and we greatly value its role as a cold water fishery. CRWC supports the development and operation of hydropower facilities that can minimize and mitigate impacts to aquatic ecosystems as well as generate clean sources of electricity. The CRWC takes particular interest in any new hydropower project that may significantly impact aquatic habitat, fish passage and/ or recreation. Of importance to us when reviewing the pre-feasibility study prepared by GZA GeoEnvironmnetal, Inc. were the following:

1) the specific additional data needed to gauge anticipated changes to wetlands
2) FERC’s EA recommendation of preserving vegetation below the new water line in the Lower impoundment
3) the need for field surveys to be conducted to follow-up on the possible presence of listed state threatened species and species of special concern
4) consultations necessary to assess impacts to wildlife and to stipulate appropriate construction windows
5) BMPs for sedimentation and erosion control must be employed and proper handling must be performed in the event that contaminated sediment is found at the project
6) mitigatory measures needed to control flow fluctuations
7) recommended pre and post-water quality studies for effects on dissolved oxygen and temperature.

We strongly encourage early initiated and continued collaboration with appropriate agencies and community groups to assess project impacts to wildlife and recreation so that choices may be made in the preliminary and planning phases that minimize negative impacts and maximize potential benefits for all parties.

We are supportive of all the comments submitted and recommendations made by the USF&WS. We believe the details they have given about fish and wildlife, cultural and recreational considerations are very worth paying attention to. The comments point to the need for consideration of freshwater mussels and for fish passage plans to account for all migratory fish species presently under management goals, not just Atlantic salmon. This kind of holistic thinking is critical to the sustainability of diverse ecosystems. The Council is very supportive of work by the CT DEEP to create biological criteria for all our waters. This important work will contribute to scientifically robust water quality criteria that ensure that the many millions of dollars we are investing are targeted precisely and money is allocated as efficiently as possible. This particular project may have significant effects on the ecosystem but if planned with holistic thinking and consideration that healthful waters support diverse aquatic life, those effects may be minimized.

We are especially supportive of the recommendation to carefully consider the findings of the GZA prefeasibility study, particularly the finding that development of just the Upper Dam yields the best output per financial investment. This course of action seems to lead to win-win situation in which the Town could maximize its generation at the Upper Dam while providing safe and adequate fish passage and the Lower Dam could be removed, thus providing migratory habitat, enhancing connectivity and potentially mitigating some of the effects of development at the Upper Dam. The two Collinsville Dams were among all the dams ranked by the Nature Conservancy’s Dam Prioritization model, which seeks to identify which dam removals would provide the most benefit by looking at factors such as connectivity and migratory fish habitat created. The model placed the two Collinsville Dams in the top 10% bin for all dams in the 11 northeastern states.

Given the high resource values of the Farmington River and the high priority scores assigned to these two dams, it is very important that fish passage requirements for any new hydropower facility be based on 2012 standards and experience. If pending legislation does allow for a transfer of the Summit License as a cost savings measure, the resource agencies should be free to utilize fish passage conditions of 2012 standards and not be bound to employ the old license’s 1990 standards.

We look forward to staying involved as this project progresses and would value communication with the town and interested stakeholders. I work out of Middletown, CT and can be reached via email: jtalbot@ctriver.org or telephone: 860.704.0057.

Thank you for your time, consideration and stewardship of our water resources.

Sincerely,

Jacqueline Talbot, Lower River Steward
Connecticut River Watershed Council
deKoven House, 27 Washington Street, Middletown, CT 06457
860.704.0057  jtalbot@ctriver.org

Re:  Survey for Upstream American Eel Passage at Holyoke Dam, Connecticut River, Massachusetts, 2011, FERC Project No. P-2004, Agency Review Draft

Dear Paul,

I reviewed the agency review draft Survey for Upstream American Eel Passage at Holyoke Dam, Connecticut River, Massachusetts, 2011 dated February 2012 and prepared for HG&E by Normandeau Associates.  Below are comments submitted on behalf of the Connecticut River Watershed Council.

2011 was an odd year for eel passage, since the South Hadley side was not very operational and most eels passed on the Holyoke side.  We note that last year’s report recommended eliminating the spillway ramp on the Holyoke side because eels could easily climb to the stilling basin.  It is a good thing the spillway ramp was not eliminated, as this was the location of the largest number of eels caught (5,141, with the stilling basin second at 4,332).

The Executive Summary of the report on page ES-2 hypothesizes that a good portion of the eels that might have been collected by the South Hadley ramp continued searching until they found the Holyoke ramps.  In looking at the limited visual observations on the South Hadley side, there were more than 100 eels climbing and swimming at the South Hadley leakage site on 7/20 and 7/27, but no other dates.  Table A1-1 on page 44 shows a small spike in eels caught on the Holyoke side on 7/25 running into 7/27.  However, very few eels were caught for another month.  Did it take the eels a month to find the Holyoke side and then get captured?  I think the hypothesis does not hold up that well.  If we had all felt one side of the river was sufficient for capturing all the eels, we probably would have stopped testing all these spots and tweaking the techniques several years ago

Page 16 of the report says that in the summer of 2011, eels were presumably attracted to decaying American shad after the anadromous fish passage season.  We wonder how this might be different than other years.

In Section 6, Normandeau Associates, 2011 incorrectly cites the 2009 report rather than the 2010 report.

We have seen comments submitted by Don Pugh of Trout Unlimited.  We think he has offered a number of useful suggestions, such as testing a ramp at the canal bypass sampler.  Thank you for the opportunity to review the report and provide comments.

Sincerely,

Andrea F. Donlon, M.S.

River Steward