Connecticut River Conservancy has been engaged in the 12-years-and-counting hydropower relicensing process for 5 facilities on the Connecticut River – the Vernon, Wilder, and Bellows Falls dams in VT/NH, and the Turners Falls dam and Northfield Mountain Pumped Storage Station in MA. A few months ago, CRC shared a milestone update, and since then our focus has turned to the next phase in the process, which are the 401 Water Quality Certifications (WQC’s).
Along the way in recent months an ongoing investigation led by the Connecticut River Conservancy (CRC) has for the first time detected DNA from the endangered shortnose sturgeon (Acipenser brevirostrum) in the Connecticut River between Turners Falls, MA, and Bellows Falls, VT/Walpole, NH. The study was initiated by CRC’s River Steward for New Hampshire, Dr. Kate Buckman, in partnership with James Garner, a PhD candidate at the University of Massachusetts with expertise in environmental DNA (eDNA) techniques.
In light of this, and with a specific focus on the hydropower facilities in Massachusetts, CRC has sent a letter to MassDEP urging the agency to consider the new evidence as part of their obligation under section 401 of the Clean Water Act in hydropower relicensing.
Below are the first two paragraphs of the letter, which is available in its entirety here.
Dear Timothy Jones, and David Hilgeman,
The Connecticut River Conservancy (“CRC”) writes to raise concerns regarding the impacts of Turners Falls Dam (FERC No. 1889) and Northfield Mountain pump storage station (FERC No. 2485) (collectively “Turners Falls Project”) on endangered shortnose sturgeon (Acipenser brevirostrum). While CRC has been consistently concerned about the impacts of the Turners Falls Project, the direct impetus for this letter comes from two recent events that constitute new evidence not previously analyzed by any of the regulatory agencies responsible for licensing or permitting the Turners Falls Project. First, two shortnose sturgeon were discovered stranded in isolated pools below the dam in separate incidences in the summer of 2024. Second, scientists have documented environmental DNA (“eDNA”) evidence of the presence of shortnose sturgeon above the Turners Falls Dam in the Turners Falls impoundment.
As the state agency responsible for water quality, the Massachusetts Department of Environmental Quality (“MassDEP”) has the obligation under § 401 of the Clean Water Act (“CWA”) to condition federal licenses in order to meet state water quality standards, including protecting and enhancing aquatic life uses.1 CRC takes the opportunity to write now,2 while MassDEP is finalizing a draft 401 certification for public comment, to place squarely before MassDEP the new sturgeon evidence. CRC maintains that this evidence supports its position that increased flows below Turners Falls Dam from July 1 through November 15 are not only needed to protect shortnose sturgeon, but also required by state water quality standards. Moreover, the newly found eDNA evidence of shortnose sturgeon above the Turners Falls Dam requires MassDEP to analyze the potential impacts on sturgeon of the operations at Northfield Mountain, including erosion impacts and impingement and entrainment at the intake structures.
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