Friday September 21, 2012

A recent letter submitted by Richard Schmidt (an Entergy employee from Westmoreland, N.H.), has a few bloopers in it and I want to deal with those quickly so we can talk about the science behind the Connecticut River Watershed Council's recently released reports.

(Editor's note: That letter ran in the Sept. 13 edition of the Reformer.)

Mr. Schmidt mischaracterizes our funding sources. A variety of foundations fund CRWC, none of which identifies themselves as antinuclear and we never applied for grants to undertake antinuclear activities. These funding sources and the members of CRWC, through their dues and donations, have funded us to protect the river and not to mount an antinuclear campaign.

Contrary to Mr. Schmidt's claim otherwise, federal and state fisheries biologists have voiced strong concerns about the effects of the heated water from Vermont Yankee nuclear power plant on resident and migrating fish. In a March 2012 letter to Secretary of the Agency of Natural Resources, the very fisheries biologist Mr. Schmidt referenced said "River water temperature is one of the single greatest cues and physical variables to influence fish behavior, physiology, migration, movement, feeding, growth, maturation, spawning, egg and larval development, resilience to pathogens (stress) and survival." He went on to write that "There are too many unknowns and concerns related to Entergy's thermal water discharge to assume that it is not having a negative impact on these juvenile migratory fish especially in the absence of any good science to show otherwise.


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Lastly, Mr. Schmidt's letter implies that Florida fish could enter a New England river and vice versa. Diadromous fish return to their natal rivers so fish from Florida are not coming to the Connecticut River and those in Florida are acclimated to the local natural temperature regimes. Not at all the case here, where the elevated temperatures shad face in the Connecticut River are anything but natural.

Mr. Schmidt challenges our science. In response, I would like to explain that CRWC commissioned three independent studies done by respected and experienced scientists to look at key aspects of the science Entergy used to justify their thermal pollution discharge. When we commissioned the reports it was a bit nerve-racking for us because we did not know the answers to our questions ahead of time, but we went ahead because we wanted to know the truth in the interest of the river.

What did we find?

-- Beyond the clearly problematic Entergy assertion that their discharge affects only the pool behind Vernon Dam and no further downstream than that, Entergy refuses to release the water quality model they relied on to justify their claim of no impact on the river. Consequently, independent reviewers have not been able to -- After a close review of temperature data from in river temperature loggers deployed by Entergy and the USF&W Service, it is clear that the water temperature below the plant is hotter than Entergy's permit allows between 50 and 70 percent of the time.

-- There is no information, despite requests by CRWC to ANR that shows Entergy has used the equation that governs their thermal discharge limits correctly because of missing data held by Entergy and not made available to ANR.

-- Entergy selected a heat tolerant suite of fish that does not reflect the full makeup of species in the Connecticut River to test the impact of their thermal pollution discharge. We suggested a more robust methodology that uses current science and a more representative list of species based on an EPA funded fishery survey of the river conducted in 2008 and 2009.

We made our reports available to ANR so they can evaluate them and if appropriate, ANR can use them as part of their work to draft a renewal permit limiting Entergy's thermal pollution discharge. We have made these reports available to the public through news stories and on our web site (www.ctriver.org). We have made the reports available to Entergy and asked to meet with them to discuss our findings. Entergy stonewalled us and no conversations have taken place, except of course through the press via Mr. Schmidt's letter to the editor. Unfortunately, his letter relied only on bloopers and anecdotal quotes used out of context. What has not happened is an honest exchange with Entergy.

Based on our reports we have again requested that ANR issue a permit that requires Entergy to use their cooling towers all of the time in a closed cycle cooling mode. A closed cycle requirement would mean there would be no discharge of hot water to the Connecticut River. A simple enough request backed by reliable critiques of the faulty information presented by Entergy. We hope others will make the same request of ANR.

David Deen is the River Steward of the Connecticut River Watershed Council and is Westminster's representative in the Vermont State House and the chairman of the House's Fish, Wildlife and Natural Resources Committee.