The Federal Energy Regulatory Commission is moving to open the fishway at the outlet of 14,360-acre West Grand Lake and let in three invasive species: sea run and landlocked alewives (technically the same species), as well as largemouth bass established in lakes downstream.

As Randy Spencer noted in his Northwoods Sporting Journal column, “If a private citizen were to do what FERC is recommending, it would result in steep fines and possibly jail time. Maine laws guard against the introduction of invasive species into Maine lakes with good reason. From baitfish to aquatic plants to exotic species, the record shows dire consequences can and do happen from such introductions.”

Eight fisheries biologists, now retired from long careers at Maine’s Department of Inland Fisheries and Wildlife, are helping local anglers and sporting camps fight FERC on this, but DIF&W itself is strangely silent. The agency did submit comments in opposition to the proposal, but those comments arrived at FERC many months late, and I’m not sure they have ever been considered by FERC.

When I asked DIF&W officials why they are not more active in fighting this issue, I got no response. They did send me the comments they originally prepared. Rick Jordan, one of the retired fisheries biologists fighting this move, told Spencer that DIF&W sent their comments to the Governor’s office last December, but for some reason FERC never received them.

One reason this is so important is that West Grand Lake is one of only four Maine waters that originally held Landlocked Salmon. Salmon brood stock from West Grand has supplied 75 percent of the salmon stocked in Maine lakes.

Rick Jordan told Spencer that FERC is recommending the West Grand fishway “be operated 365 days a year to pass any and all fish upstream and into the lake.” DIF&W has operated the gates to allow salmon, but not other species, to return to the lake.

Jordan also reported that, “All alewives carry an enzyme that causes early mortality syndrome in landlocked salmon,” These syndromes can lead to poorer vision, less prey capture, poor growth, reproductive failure, and a less immune fish, sometimes resulting in death of adults or juveniles.” Sounds bad, for sure.

DIF&W – Better late than never?

The department, in its testimony to FERC, explained the late arrival of its comments this way:

The Federal Energy Regulatory Commission (Commission) issued a Notice of Availability of the FEA for the West Branch Project and the Forest City Project in Aroostook, Hancock, Penobscot, and Washington Counties, Maine on January 20, 2015. Prior to this, the Commission issued a Notice of Availability of the Draft Environmental Assessment (DEA) on October 16, 2014, and requested that any comments be filed within 45 days from the date of the Notice. However, Maine Department of Inland Fisheries and Wildlife (MDIFW) staff could not locate the typical FERC DEA notification form that our Agency normally receives for other hydro projects—please note that we are not questioning whether or not the Commission mailed it, but given our Agency’s staff turnover in recent years, particularly as it relates to this and other long-standing hydro relicensing projects, it is possible that it was mailed but never ended up with the proper staff. Regardless, we were notified indirectly of the DEA through Woodland Pulp LLC (Woodland Pulp) in early December 2014, and with recent staff changes at the Governor’s cabinet level, our comments have not been able to be issued until now. While we understand and apologize that we are filing comments at a very late stage of the relicensing process, nonetheless we feel adamant that our concerns be entered into the administrative record.

I’m going to give you all of the agency’s testimony at the end of this column. Yes, it is very long, but if you care about this issue, it is worth reading. One key bit of the testimony summed up the issue for me:

The importance of maintaining West Grand Lake’s high salmon stocking numbers cannot be overstated. If the invasive landlocked alewives are allowed to access West Grand Lake and devastate the smelt forage for salmon, as they did at East Grand Lake, then salmon stocking rates will be drastically decreased affecting the overall catch rates for the lake, and the all-important drop down fisheries of Grand Lake Stream, Big Lake, Long Lake and the lower St. Croix River.

I also noted DIF&W’s specific recommendations:

We recommend that the West Grand Lake Dam fishway only be open for the portion of the year between June 20th and August 13th to allow adult and juvenile salmonids to migrate from Grand Lake Stream into West Grand Lake. • We recommend that when the West Grand Dam fishway is open between June and August, the 20-inch hydraulic jump must be operated to prevent the access of invasive largemouth bass and landlocked alewives. MDIFW strongly believes that it is critical that fishway operations continue to be secured at the Grand Lake Stream Dam to prevent invasive species from ascending into West Grand Lake and to Sysladobsis Lake upstream. • We recommend that an eel ramp be installed at the West Grand Lake Dam and operated year round so the juvenile American eel can migrate into West Grand Lake and further up into the West Branch of the St. Croix’s headwaters.

Let’s hope that FERC, despite the fact these comments were not delivered on time, responds to them in a favorable manner and doesn’t do anything to allow invasive species into West Grand Lake where they were be disastrous for the important Landlocked Salmon fishery there.

DIF&W’s Comments

West Branch Project–Aquatic Resources Background on Invasive Species and MDIFW Fisheries Management MDIFW does not agree with the Commission’s recommendation of year-round operations of fish passage at the West Grand Lake Dam without mechanisms in place to block upstream passage of invasive species within this drainage.

Landlocked alewives and largemouth bass have been documented downstream and pose a serious threat to the West Grand Lake fisheries, the fisheries management, and Letter to Kimberly D. Bose, Secretary Comments RE: Notice of Availability of Final Environmental Assessment (FEA) for the West Branch Project (FERC No. 2618- 020) and the Forest City Project (FERC No. 2660-024) May 5, 2015 Page 2 of 7 the economically-significant commercial angling guide industry that is established in the region.

West Grand Lake Dam is currently equipped with a vertical slot or Hell’s Gate fishway, and fishway operation dates and procedures should be prescribed annually by MDIFW to ensure that landlocked alewives are kept out of West Grand Lake because of potential serious problems this invasive species poses to landlocked salmon management.

MDIFW desires the fishway to be open only from mid-June through the end of July with a hydraulic jump of 20-inches at the upper end to deny passage to landlocked alewives and largemouth bass. This hydraulic jump structure should be fitted with eel passage ramps to allow access of American eels to headwater habitats. A discussion regarding fish passage needs and of the needs to deny fish passage to these invasive species follows.

Landlocked alewives: Landlocked alewives are an invasive species in the St. Croix drainage. They first appeared in another St. Croix watershed lake, East Grand Lake, in the mid-1990’s by means of an illegal introduction by an angler. As East Grand’s landlocked alewife population expanded by natural reproduction, the lake’s rainbow smelt population levels fluctuated widely over time. Because rainbow smelt are the primary forage species for landlocked salmon, growth of salmon at East Grand declined, both in terms of fish condition and maximum size, presenting many challenges to successful fisheries management in this highly popular Maine lake.

Stocking rates were drastically reduced, resulting in fewer salmon available to anglers as well as lower catch rates. Largemouth bass In early June 2011, MDIFW received the first report of an angler catching largemouth bass in the St. Croix River system in the mouth of Tomah Stream at Grand Falls Flowage. In the following weeks additional reports of largemouth bass were received, and on June 25, 2011, a female largemouth bass was collected by a guide in the same area of Tomah Stream. The fish was taken to the Passamaquoddy Fish & Wildlife Office and was confirmed to be a 10-inch female largemouth bass.

In the aftermath of that discovery, MDIFW implemented an emergency rule to implement a no size or bag limit regulation on largemouth bass throughout the St. Croix Drainage. During the 2012 rulemaking for fishery regulations to take effect in 2013, a no size or bag limit regulation on largemouth bass was proposed for the entire St. Croix drainage. That regulation was adopted and has been in place since.

MDIFW has strong reasons for keeping these species out of West Grand Lake, as well as the other lakes in the upstream flowage, including Sysladobsis Lake. Because of West Grand Lake’s status as a renowned salmon fishery, any threat of landlocked alewives or largemouth bass is taken seriously as it could potentially be devastating to the established, economically-critical landlocked salmon fishery. The importance of maintaining West Grand Lake’s high salmon stocking numbers cannot be overstated. If the invasive landlocked alewives are allowed to access West Grand Lake and devastate the smelt forage for salmon, as they did at East Grand Lake, then salmon stocking rates will be drastically decreased affecting the overall catch rates for the lake, and the all-important drop down fisheries of Grand Lake Stream, Big Lake, Long Lake and the lower St. Croix River.

In addition, West Grand Lake is one of Maine’s most important landlocked salmon fisheries, and one of only four watersheds in Maine where landlocked salmon populations were indigenous. The West Grand strain of landlocked salmon is Maine’s only remaining pure native strain. Approximately 80% of Maine’s annual landlocked salmon egg take comes from West Grand Lake salmon, and it is important to safeguard this population because it is the source of most of Maine’s highly important salmon stocking program. If landlocked alewives were to gain access to and colonize West Grand Lake, the rainbow smelt population would likely experience wide variations in abundance, similar to what was documented in East Grand Lake, yielding highly variable growth and condition of salmon, and potentially lowering the number of eggs per female and ultimately lowering overall reproductive success.

Landlocked alewives contain high levels of thiaminase, an enzyme that breaks down thiamine. When landlocked salmon feed heavily on landlocked alewives, thiaminase levels rise in their eggs, resulting in Early Mortality Syndrome which elevates the level of mortality in both eggs and fry. Clearly, this situation must be prevented at West Grand Lake because of its highly important salmon brood stock population that is vital to Maine’s salmon stocking and management program, because eggs taken from West Grand’s landlocked salmon produce hatchery-reared spring yearlings that are stocked in numerous Maine lakes annually to sustain their salmon fisheries.

West Grand Lake’s outlet, Grand Lake Stream, flows for 2.75 miles to Big Lake. Each fall, hundreds of landlocked salmon spawn in this stream. Most overwinter in the stream and re-enter West Grand Lake in mid-to-late June when water temperatures are warming in the stream. A highly popular spring fishery for salmon exists in Grand Lake Stream, comprised mostly of these hold-over post-spawners, along with a lesser percentage of fresh, bright, fatter salmon that have moved into the stream in the spring, either from West Grand Lake or Big Lake. MDIFW recommends that the fishway only be open during the time period when salmon are attempting to move upstream into West Grand, which corresponds to the period from mid-June through mid-July.

Annual selection of the date when the fishway is first opened is based on warming water temperatures–this period typically occurs around June 20. The most important procedure of fishway operation involves adjusting the gate near the top of the fishway to create a 20- inch turbulent overflow (hydraulic jump), which salmon easily jump over, but landlocked alewives are denied access to West Grand Lake because they are unable to negotiate the hydraulic jump due to the swift current speed and turbulence of bubbles in the overflow. Within two hours of opening the fishway each June, MDIFW biologists have observed salmon leaping over the hydraulic jump at rates of at least 60 salmon per minute. The fishway is closed by August 1.

Comments and Recommendations on Farm Cove Dam Operation: Currently the upper portion of Grand Lake Brook and its tributary, Scott’s Brook, have limited production of wild brook trout and landlocked salmon. American eels also use this secondary outlet to access West Grand Lake and other headwater lake habitats. In light of the confirmed presence of the two invasive species and their ability to access West Grand Lake and it’s headwaters through this secondary outlet, we recommend that an external hydraulic jump be installed (an internal structure in the fishway was explored in 2011 and found to be incompatible) at the top of the ledge located immediately down-stream of the entrance to the Farm Cove Dam fishway. The hydraulic jump would be a fixed structure of 20-inches in height and would prevent access by landlocked alewives and largemouth bass to the Farm Cove Dam fishway and the waters above.

The hydraulic jump structure should be fitted with eel passage ramps to allow access of American eels to headwater habitats. MDIFW strongly believes that it is critical that fishway operations continue to be secured at the Farm Cove Dam to prevent invasive species from ascending into West Grand and Sysladobsis Lakes upstream.

Comments and Recommendations on West Grand Project Fish Passage and Grand Lake Stream: Grand Lake Stream is a 2.75 mile long outlet of West Grand Lake and is one of the top riverine landlocked salmon fisheries in the State of Maine that annually meets or exceeds statewide goals for a landlocked salmon fishery. Salmon caught in the stream average 18-inches in length and weigh 2 pounds, which are above the state goals of 16.5 inches and 1.5 pounds. The catch rates in the stream range from 0.84 to 3.13 fish per angler day, compared to a statewide average of 0.29 fish per angler day. Landlocked salmon successfully reproduce and contribute to the fishery, but 95% of the fishery is sustained from hatchery fish stocked in West Grand and Big Lakes.

Annually, 400 to 600 spring yearling hatchery brook trout are stocked directly into the stream and provide a put-and-take fishery that augments the salmon fishery. Occasionally lake trout and lake whitefish drop into Grand Lake Stream from West Grand Lake and are rarely caught by stream anglers. The fishway in the West Grand Lake Dam is operated in partnership between MDIFW and Woodland Pulp, and is opened for salmonid passage from June 20th through August 1. For the duration of when the fishway is open, an adjustable scissor gate hydraulic jump operates with a 20-inch vertical jump to prevent access of landlocked alewives and largemouth bass that have been documented downstream in Big Lake.

To ensure fish passage is maintained for these important resources, we make the following recommendations regarding the operations of the West Grand Lake fishway and downstream flows to enhance downstream angling: • We recommend that the West Grand Lake Dam fishway only be open for the portion of the year between June 20th and August 13th to allow adult and juvenile salmonids to migrate from Grand Lake Stream into West Grand Lake. • We recommend that when the West Grand Dam fishway is open between June and August, the 20-inch hydraulic jump must be operated to prevent the access of invasive largemouth bass and landlocked alewives. MDIFW strongly believes that it is critical that fishway operations continue to be secured at the Grand Lake Stream Dam to prevent invasive species from ascending into West Grand Lake and to Sysladobsis Lake upstream. • We recommend that an eel ramp be installed at the West Grand Lake Dam and operated yearround so the juvenile American eel can migrate into West Grand Lake and further up into the West Branch of the St. Croix’s headwaters. Minimum Flow for Grand Lake Stream • We recommend that the West Grand Lake Dam minimum flow standards be set at 100 cfs. If environment circumstances (i.e. climatic conditions) dictate a lower flow, we recommend that it be done in consultation with the Maine Department of Inland Fisheries and Wildlife to prevent stranding of fish.

Ramping Down Flows from West Grand Lake Dam for Protection of Juvenile Landlocked Salmon in Grand Lake Stream • We recommend that ramping down flows are reduced at four hour intervals by 20 percent when five gates are open; 25 percent when four gates are open; 33 percent when three gates are open; 50 percent when two gates are open; and to the minimum flow or above of 100 cfs when one gate is open. Grand Lake Stream landlocked salmon angling flows To enhance landlocked salmon angling in Grand Lake Stream, we make the following seasonal flow recommendations:

From April 1st and April 15th, flows in Grand Lake Stream should be between 300 – 500 cfs to enhance the spring’s landlocked salmon kelt fishery. • From April 16th to May 1st, flows in Grand Lake Stream should be between600 and 910 cfs to bring in “bright salmon” from West Grand and Big Lakes. Flows should not exceed 910 cfs during this period. • From May 1st to July 5th, flows in Grand Lake Stream should be between 300 – 500 cfs to enhance the spring’s bright salmon fishery. • From September 25th to October 20th, flows in Grand Lake Stream should be between 300 – 500 cfs to optimize fall angling. Grand Lake Stream landlocked salmon spawning flows To enhance landlocked salmon spawning in Grand Lake Stream, we make the following seasonal flow recommendation:

From October 21st to November 20th, flows in Grand Lake Stream should be 300 cfs to optimize landlocked salmon spawning. Grand Lake Stream landlocked salmon kelt retention flows To enhance the landlocked salmon kelt fishery, we make the following seasonal flow recommendation: • From December 1st to March 31st, flows in Grand Lake Stream should not exceed 1,300 cfs to maximize the retention of landlocked salmon kelts overwintering in the stream so that they will be present on April 1st for the stream’s fishery.

West Grand Lake: Smallmouth Bass Spawning Lake Level Window for Reproduction Success • To optimize spawning success of smallmouth bass, we recommend that water level drawdowns be maintained within a 1-foot range between June 1st and July 15th. West Grand Lake–Lake Trout Spawning and Egg Incubation Lake Level Window for Reproduction Success • For the best protection of lake trout spawning and egg incubation, we recommend that West Grand Lake not be drawn down lower than 297.2 feet above MSL from October 20th to April 1st . West Grand and Pocumcus Lakes Improvement of Public Access To enhance public access and increase angling opportunity, we make the following recommendations: • It is recommended that the public boat launch on the west side of West Grand Lake Dam be improved to become ADA compliant.

It is recommended that the public boat launch at Pocumcus Lake (Elsmore Landing) be improved to become ADA compliant. West Branch Project–Terrestrial Resources MDIFW agrees with the Commission Staff alternative for lake level management, specifically: “limiting impoundment fluctuations at Sysladobsis and West impoundment to less than a 6-inch increase and 1- foot decrease during common loon nesting from May 15 to July 15” at the West Branch Project. This measure will minimize loon nest failures due to fluctuating water levels from Project operations. However, we recommend that the dates be broadened, if possible, to accommodate all waterbirds by initiating actions beginning on May 1.

While this precedes ice out during many years, those parts of the lake where shallows and wetlands occur usually see the ice begin to recede and open water conditions develop earlier. The earlier dates proposed would better accommodate the return and initiation of the reproductive cycle of certain species of waterfowl. Forest City Project—Aquatic Resources • To optimize spawning success of smallmouth bass, we recommend that a license requirement of a June 1st to July 15th spawning window to optimize smallmouth bass spawning, rather than the current voluntary agreement.

We recommend that an Impoundment Operation Modification Plan consultation process be established for both smallmouth bass and lake trout spawning impoundment-level discussions. • We agree with Commission Staff that an upstream fishway American eel be constructed • We agree with Woodland Pulp’s recommendation to improve boat landings on the Forest City impoundment (East Grand Lake), and would suggest that the Forest City access site as being in greater need of attention than the Greenland Point site. Forest City Project–Terrestrial Resources MDIFW agrees with the Commission Staff alternative for lake level management, specifically: “limiting impoundment fluctuations at Forest City impoundment to less than a 6-inch increase and 1-foot decrease during common loon nesting from May 15 to July 15” at the Forest City Project. This measure will minimize loon nest failures due to fluctuating water levels from Project operations.

However, we recommend that the dates be broadened, if possible, to accommodate all waterbirds by initiating actions beginning on May 1, if not April 15. While this precedes ice out during many years, those parts of the lake where shallows and wetlands occur usually see the ice begin to recede and open water conditions develop earlier. The earlier dates proposed would better accommodate the return and initiation of the reproductive cycle of certain species of waterfowl.

To help ensure that our Agency responds in a timely manner in the future, please mail future notifications to: Environmental Review Coordinator Maine Department of Inland Fisheries and Wildlife 284 State Street, 41 SHS Augusta, ME 04333-0041. Finally, MDIFW staff now subscribes to the FERC Online website and will be receiving email notifications on these two Projects in the future. Thank you for your consideration and please feel free to contact my office if you have any questions regarding this information, or if I can be of any further assistance. Best regards, John Perry, Environmental Review Coordinator.