Two weeks after an unexpected shutdown of the McKay hydroelectric station that left portions of the West Branch of the Penobscot River below Ripogenus Dam at extremely low levels for an extended period, two hydro units remain out of service.
The station is operated by Brookfield Renewable Energy Partners.
The July 7 shutdown killed fish and aquatic life, and hampered fishing, boating and other activities that require higher, flowing water, according to the Maine Chapter of Trout Unlimited. It was especially “catastrophic” for the landlocked salmon that recently hatched in the river, the organization said.
“Essentially, the entire West Branch 2023 salmon year class was eliminated,” said Ed Spear, a retired fisheries biologist formerly employed by Great Northern Paper, an owner of the Ripogenus Dam before Brookfield. “The timing of this disastrous outage could not be worse as it occurred during the peak fish and aquatic growing season and a prime angling period and it occurred during daylight hours.”
Spear said alevin, salmon in the larval stage, have difficulty dealing with the kind of sudden change in water flow that occurred on the West Branch. He said the part of the river designated for fish reproduction and rearing and protected under the FERC license would have been left without water during the event.
According to Brookfield’s report on the incident to the Federal Energy Regulatory Commission filed on July 21, a lightning strike involving a Versant Power transmission line caused all of the hydro stations on the Penobscot River to go offline. That and other lightning strikes damaged lightning arrestors and hydro units at McKay Station, which is located 30 miles west of Millinocket.
Brookfield responded by shutting down two units at McKay Station, which was unable to maintain its required whitewater recreation water flows. According to Maine Trout Unlimited, Brookfield’s SafeWaters website posted a flow of only 100 cubic feet per second at 7 p.m. on July 7. The minimum flow on Fridays during the summer is set at 2,220 cubic feet per second.
The flow at McKay Station at 10 a.m. Monday was listed as 2,448 cubic feet per second. The condition persisted until Brookfield crews could open a deep gate located at Ripogenus Dam to increase the flows.
Evidence of the effects of the low water on fish in the river were noticeable the day after the McKay Station flow was slowed.
“From the boat I could only see part of the area, but I could see about 10 dead salmon, all about 10-inch fish lying on the bottom of the river, and I wondered how many salmon had perished due to the previous evening’s dewatering,” said Registered Maine Guide Todd Mercer of paddling near the facility.
Ripogenus Dam is currently in the relicensing process by FERC, which governs the regulations for the operation of such hydroelectric projects.
This isn’t the first time there has been water flow control problems at McKay Station, according to Maine Trout Unlimited. There were water drawdowns during the summers of 2020 and 2021 that rendered boat launches on Chesuncook Lake — including Ripogenus and Caribou lakes and Moose Pond — unusable, which made operating boats hazardous and hampered loon nesting.
“We are very concerned the severe drawdowns of the lakes under Brookfield’s operation of Ripogenus Dam and McKay Station are having a negative impact on the fish, aquatic communities, wildlife and recreational use and enjoyment of one of Maine’s premier lakes,” said Bill Houston, who represents the Chesuncook Caribou and Chesuncook Camp Associations.
In another incident in April 2022, seepage at the Ragged Lake Dam led Brookfield to conduct an emergency release of water that resulted in the washout of the Ragged Lake bridge leading to the Greenville Road, according to Maine Trout Unlimited.
Betsy Ward, who owns a camp on Ragged Lake, said they have had to drive an extra hour to reach Greenville Road via the Golden Road with the bridge out of commission.
“The dam was finally repaired last fall and water levels have been restored, although we are reaching the time of year when the dam owners will probably start drawing it down,” Ward said. “As for the bridge, it is scheduled to be rebuilt later this summer.”
At the request of Maine Trout Unlimited, Brookfield conducted a study last fall to help determine the amount of fish mortality and stranding that occurs after an event during which flows are reduced rapidly to 500 cubic feet per second.
“Stranded fish were observed throughout seven distinct reaches of the West Branch between McKay Station and the Nesowadnehunk Deadwater,” Brookfield reported. “Approximately 450 stranded fish were observed during the study, representing nine species.”
It estimated that approximately half of the fish observed died, among which 55 percent were landlocked salmon.
This, some said, is a preventable thing.
“FERC has the ability to prevent and/or minimize future catastrophic flow interruptions caused by outages,” Spear said. “Long-term and short-term mitigation measures are needed.”
Spear said FERC should require Brookfield to hire an employee to staff the station and that the company should re-engineer and maintain its emergency flow mechanism. He said part of the licensing process should include provisions for determining and administering emergency outage flows into the river.
“Long-term mitigation is needed to rebuild salmon stocks, notably the loss of 2023 hatchlings and aquatic insects,” Spear said.
We’ve been very active in monitoring local streams for the presence of “Salters,” Brook Trout that are biologically identical to their freshwater brothers and sisters, but spend much of their time in salt water environments. Our efforts have included Frost Gully Brook and Mill Stream in Freeport, Mere Brook in Brunswick, and Montsweag Brook in Wiscasset.
Our temperature monitoring project on Frost Gully Brook has led to partnering with local landowners and municipalities, and utilities to agree and fund the removal of three dams that block the migration of salters and warm the waters of this spring-fed stream.
November 1, 2022
VIA E.FILING.
Kimberly D. Bose
Secretary Federal Energy Regulatory Commission
888First Street N.E, Washington, D.C. 20426
Re: Comments of Merrymeeting Bay Chapter of Trout Unlimited on the Worumbo Hydroelectric Project (FERC No. 3428)
Summary of Initial Study Report Meeting Dear Secretary Bose; Merrymeeting Bay Chapter of Trout Unlimited (MMBTU) submits these comments regarding the Summary of the Initial Study Report (ISR) for the Worumbo Project (FERC No. 3428) submitted October 4,2022, by Eagle Creek Renewable Energy, LLC (Eagle Creek or Licensee) for its subsidiary Brown Bear Hydro on behalf is its 321 members in south-central Maine. The project in located squarely in MMBTU’s membership area. Its members regularly use the Androscoggin River for fishing and other recreational activities. The mission of Trout Unlimited is: “…to bring together diverse interests to care for and recover rivers and streams so our children can experience the joy of wild and native trout and salmon…” The Worumbo Project is fully contained within designated critical Atlantic Salmon habitat. MMBTU sees restoration of Atlantic Salmon to the Androscoggin Watershed as a top organizational priority.
The following comments respond to elements of the discussion during the meeting:
- Timing for sharing of study results: Eagle Creek noted that of the 12 studies included in its Revised Study Plan (RSP), no data analyses were completed or reportable. This is due to timing of the ISR filing date relative to the study season. The licensee is required to provide final reports on the studies in the RSP by November 4,2023. Several attendees commented that this timing was problematic given that the field study season for 2023 would be essentially over by that date. If results are unknown until then, this limits any ability for meaningful feedback from Federal or State Agencies having jurisdiction or from Non-Governmental Organizations QrIGO) with public welfare concerns on study efficacy and/or suggested revisions during 2023. The Licensee recognized these concerns and stated that it anticipated communicating with stakeholders regarding study results in advance of this filing in either Q2 or Q3 of calendar 2023. MMBTU appreciates the Licensee committing to this effort and strongly encourages that wherever possible results be shared in Q2 of 2023. Ability to make changes to study methods or gather further data is very important to the understanding of environmental impacts at the site and future licensing stipulations. Preliminary reporting should be strongly encouraged by the Commission.
- Androscoggin Reclassification from Class C to Class B: Kyle Olcott of the Maine Department of Environmental Protection noted that the under current law as approved by a a & t s til a the Maine Legislature in March 2022, the Androscoggin River is now classified as Class B per Maine’s Water Qualify Standards (38 M.R.S. $464(4XF) in the vicinity of the Worumbo project. The implicalion being that any studies related to water quality must now take this into consideration. The Licensee acknowledged that it was aware of this recent reclassification. MMBTU appreciates that this is clearly recognized by the Licensee and looks forward to the results of the relevant water quality studies when compared to Class B requirements.
- Upstream American Eel passage: Andrew O’Malley as representative of the lead study consultant, Gomez and Sullivan Engineers, reported that while eels were observed on the dam, initial observations show that very few eels appear to be using the engineered eel passage. This issue was further clarified through questioning from Casey Clark of the Maine Department of Marine Resources. In summary, observations and initial data seem negative or at least inconclusive regarding successful eel passage using the engineered eel passage. MMBTU appreciates the transparency in sharing these initial data. It must note that fully understanding eel passage by whatever means the animals use and solutions for improvement at the site must be incorporated into all further licensing proceedings. It should also be noted that lack of provision for upstream eel passage at the Brunswick Project located downstream from Worumbo is likely a significant contributing factor for the lack of eels generally observed at the Worumbo Project, and that situation should be corrected if/when the project is relicensed in 2l29.
- Anadromous Fish Passage: Participants generally agreed that the Licensee had made good efforts with fish tagging for shad and tracking however due to the timing of flnal results in Q2 or Q3 of 2A23 there was concern voiced by Don Dow of the National Marine Fisheries Service about the ability to conduct additional tagging studies in2023 if needed and he suggested a way to correlate time stamps for the telemetry data with other sources of tracking dat4 perhaps for example, trap counting data from the Maine Department of Marine Resources to inform whether Atlantic salmon had passed through the project, MMBTU strongly encourages this type of analysis if deemed of value by the agencies of jurisdiction.
- Fish Stranding Evaluation: It was reported by the Licensee that the proposed low-flow demonstration had been delayed due to field conditions experienced in the summer and fall of 2022. It was suggested by Don Dow that the Licensee consider pushing the flow demonstrations to the next field season preferably during the upstream passage season for anadromous fish if no additional tagging studies are occurring. Casey Clark cautioned that if that were to occur Atlantic Salmon could be present in the project area creating an intentional stranding situation that may not be ideal. MMBTU is supportive of gathering data during likely periods of anadromous fish movement near the site and understands that there may be a risk to some species. It requests that the Licensee keep all interested parties informed of planning decisions around flow demonstration and how they relate to potential Atlantic Salmon and other anadromous fish strandings. This study will provide important data and is worthwhile if dip nets or other tools are used during observations to prevent incidental mortality to anadromous fishes, especially Atlantic Salmon, by immediate release of stranded fish. Every fish of this endangered species must be treated as important and special care taken to prevent incidental taking where ever possible. a MMBTU appreciates the opportunity to submit comments on the Summary of Initial Study Report Meeting for the Worumbo Project, especially given its importance to the restoration of endangered Atlantic salmon to Maine.
Sincerely,
Charles J. Spies III
Member, Merrymeeting Bay Trout Unlimited