Evidence of presence of shortnose sturgeon in NH, VT, and MA waters impacted by the Bellows Falls (FERC No. 1855), Vernon (FERC No. 1904), Northfield Mountain (FERC No. 2485), and Turners Falls (FERC No. 1889) projects

Connecticut River Conservancy Clean water. Healthy habitat. Resilient communities
 PO Box 445, Alstead, NH 03602
603.931.2448 · www.ctriver.org

16 Oct 2024

Debbie-Anne Reese Acting Secretary Office of the Secretary

Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

Re: evidence of presence of shortnose sturgeon in NH, VT, and MA waters impacted by the Bellows Falls (FERC No. 1855), Vernon (FERC No. 1904), Northfield Mountain (FERC No. 2485), and Turners Falls (FERC No. 1889) projects

Dear Secretary Reese,

I am writing to you to make you aware of recent findings by the Connecticut River Conservancy (CRC) and collaborators demonstrating the presence of the endangered shortnose sturgeon (Acipenser brevirostrum) in the reaches of the Connecticut River in between the Turners Falls and Vernon hydroelectric projects, as well as between the Vernon and Bellows Falls hydroelectric projects. The Turners Falls impoundment also contains the intake for the Northfield Mountain Pumped Storage facility. All of these facilities are currently undergoing relicensing, and this new information is relevant to FERC’s Endangered Species Act consultation obligations as well as consideration in the drafting of the Environmental Impact Statement.

CRC is conducting an ongoing study utilizing environmental DNA (eDNA) techniques to survey for shortnose sturgeon presence upstream of the Turners Falls dam, all the way to the Bellows Falls dam. This area encompasses approximately 45 to 50 additional miles of river north of established existing shortnose sturgeon habitat areas below the Turners Falls dam. The study was inspired in part by multiple anecdotal reports of community members observing sturgeon in the river in NH/VT waters, as well as two verified sightings years apart. One of these verified sightings (in 2017) triggered a prior eDNA study conducted in the Turners Falls impoundment, which did not yield any positive detections.¹ However, the 2017 study sampled surface water, which we contend was an inappropriate methodology for detecting a benthic species like the shortnose sturgeon in a large river system. Our ongoing study utilizes bottom water samples to have the best chance of detecting eDNA from a rare, mobile, benthic species.

We conducted our initial sampling efforts in June and July of 2024 and received data from these samples in August 2024. The data indicate positive “hits” for shortnose sturgeon eDNA at four sampling locations, three in between the Turners Falls and Vernon dams, and one in between the Vernon and Bellows Falls dams. A positive “hit” is indicative of shortnose sturgeon DNA in the water sample taken at that location, and thus the presence of shortnose sturgeon in the river upstream of the sampling location.

The data show that shortnose sturgeon are present in the sampled reaches, validating unofficial observations of sturgeon upstream of the boundary of their assumed habitat range. We shared these initial findings with NOAA, USFWS, MA Heritage, NH Fish and Game, VT Fish and Wildlife, and USGS on Aug 26. We collected a second round of water samples in September, are in the process of analyzing these samples, and will again provide results to the relevant resource agencies when the data are available.

This new information effectively expands the range of shortnose sturgeon in the Connecticut River. Shortnose sturgeon are a federally listed endangered species as well as state listed in Massachusetts and New Hampshire. FERC must take this species into account as part of its Section 7 consultations² with NOAA Fisheries for the Bellows Falls (P-1855), Vernon (P-1904), and Turners Falls (P-1889) hydroelectric projects, as well as the Northfield Mountain Pumped Storage facility (P-2485). All of these projects impact the Connecticut River where we sampled and where the eDNA data indicate shortnose sturgeon are present.

We also request that FERC incorporates this new information into the analysis informing the preparation of an Environmental Impact Statement (EIS), anticipated to be released in draft form for comment in December 2024. The EIS is designed to look at the cumulative impact of all five facilities currently undergoing relicensing, and as four of those five are now known to have project areas that overlap with shortnose sturgeon habitat, this information is both relevant and important to FERC’s National Environmental Policy Act (NEPA) analysis.

Further inquiries may be addressed to CRC’s NH River Steward as well as CRC’s Director of Policy and Advocacy/VT River Steward at the following:

Kate Buckman kbuckman@ctriver.org 603-931-2448

Kathy Urffer kurffer@ctriver.org 802-258-0413

Respectfully,

Dr. Kate Buckman River Steward, NH

¹ FERC Accession Number 20181108-5089, Report of FirstLight Hydro Generating Company under P-1889, et. al. https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20181108-5089&optimized=false

² 50 CFR Part 402 Subpart B – Endangered Species Act – Interagency Cooperation – Consultation Procedures