Free the Andro has submitted the following comments to the Federal Energy Regulatory Commission as a result of discussions with Brookfield (BWPH), federal and state agencies, and other stakeholders on the subject of upstream fish passage at the Brunswick dam. Much of this discussion has revolved around upstream passage alternatives to study and explore. While Brookfield has sought to narrow the scope of study, FTA and several government agencies have advocated for the investigation of a broader range of options.<\/p>\n
FTA strongly urges the Commission to require BWPH to incorporate these MDMR-calculated design populations as the standard that any credible analysis should aspire to for all upstream fish passage alternatives analyses. The 2020 NOAA Comprehensive Plan specifically identifies the Androscoggin River as capable of supporting substantial runs of all of these species, and these are the populations that the new license conditions must be designed to serve.1<\/sup> Scaling passage alternatives to meet these populations is a prerequisite to a valid Phase 2 feasibility analysis.<\/em><\/p>\n FTA concurs with MDMR\u2019s position that modifications to the existing fishway have not been demonstrated to address current passage impacts.3<\/sup> [Modification of the Existing Vertical Slot Fishway] should remain in the analysis only as a baseline for comparison, not as a standalone solution capable of meeting any reasonable performance standard for the design populations identified above.<\/em><\/p>\n FTA supports carrying Alternative [New Vertical Slot Fishway] forward into Phase 2 feasibility analysis, but has significant concerns about both its design parameters and the process by which it is being developed. NMFS has stated a preference for 24-inch vertical slots at a first-dam-on-the-river site,4<\/sup> while the current conceptual design uses 18-inch slots per USFWS guidance,5<\/sup> which the available footprint constrains to an excessive number of switchbacks. MDMR has specifically flagged the number of switchbacks as a concern for American Shad passage effectiveness.3<\/sup><\/em><\/p>\n FTA supports carrying Alternative [New Fish Lift] forward into Phase 2 feasibility analysis. NMFS indicated a preference for this option at the March 5, 2026 meeting.4<\/sup> However, FTA agrees with MDMR\u2019s concern that fish lifts are non-volitional and are subject to operational shutdowns during portions of the passage season, reducing their reliability relative to passive fishways.3<\/sup> As with [New Vertical Slot Fishway], entrance siting for [New Fish Lift] must await the Project Interaction Study results. MDMR has suggested investigating \u201cover-unit entrances\u201d if behavioral data supports that approach,4<\/sup> and that determination cannot be made without Phase 2 empirical data.<\/em><\/p>\n FTA\u2019s most significant concern with the upstream alternatives matrix is the apparent effort by BWPH to screen out the Nature-Like Fishway (NLF) alternatives before a rigorous feasibility analysis has been conducted. The Revised Study Plan, in section 5.2.2, explicitly committed to Phase 1 providing \u201ca comprehensive report of potential measures for upstream and downstream passage at the Project without discussion of costs or implied preferences.\u201d2<\/sup> BWPH must be held to that commitment<\/em>……<\/em>An NLF at this site would represent the most ecologically effective passage solution \u2014 providing truly volitional passage for all species, including those difficult to attract to mechanical fishways.<\/em><\/strong><\/p>\n And much more interesting stuff in here…<\/p>\n <\/p>\n