January 16, 2013

Paul Ducheney
Superintendent – Hydro
Holyoke Gas and Electric Department
99 Suffolk Street
Holyoke, MA 01040-5082

Re: Monitoring Report:  Upstream Fish Passage at HG&E’s Holyoke Dam Fishway, Spring and Fall, 2012

Dear Paul,

I have reviewed the agency review draft of Monitoring Report:Upstream Fish Passage at HG&E’s Holyoke Dam Fishway, Spring and Fall 2012, dated December 4, 2012 and prepared for HG&E by Normandeau Associates.  Annual reports and plans for the following year’s activities are required under the Settlement Agreement and the 401 Water Quality Certificate.  My comments on behalf of the Connecticut River Watershed Council (CRWC) follow.

  1. Would it be possible to count other species during the fall lift season, in addition to inspecting the hoppers for Atlantic salmon and shortnose sturgeon?  It would be interesting to know if resident fish were also passing during this time and if so, how many?
  2. Section 3.0 describes several creative solutions to counting fish during periods of low visibility.  The first bullet at the bottom of page 4 says “whither” when I think the word should have been “whiter.”
  3. Depending on the plans for Atlantic salmon stocking this coming spring, it may be worth considering a slight change in deciding when to shut the lifts down.  If the river flow levels allow for safe lift operation but the river is too turbid for accurate fish counts, it may be beneficial to shad to continue to run the lifts even if it means not counting some fish (salmon, shad, or other).
  4. CRWC appreciates the extra discussion in Section 3.1.1 on shad concentrations and crowding.  Certainly, we are happy that the shad numbers were high enough that crowding was an issue, and we are glad to read that HG&E shifted to lifting every 10 minutes to accommodate the crowds of fish waiting to go upstream.
  5. Each year, there is a small (but unknown mortality rate from fish getting caught in the moving metal parts of the lift operations.  During high passage years like 2012, we postulate that these kinds of occurrences may have been more common.  We wonder if there would be any easy ways of reducing this kind of mortality – would less water in the bucket mean fewer fish flopping out and about?
  6. In Table 3.1-2, the sum for American shad at 0800 seems wrong (10), given the mean is 413 and Figure 3.1-6 indicates the number is closer to 20,000.

Thank you for the opportunity to review the report and provide comments.

Sincerely,

Andrea F. Donlon
River Steward
Connecticut River Watershed Council