Friends of Sebago Lake: November 2010

This letter informs FERC that the DEP has been irresponsible in its participation in the relicensing of Eel Weir dam, FERC project number 2984. This letter places on the official licensing record the impacts of the present post 1997 lake regulation on Sebago Lake, the Presumpscot River, Casco Bay, and the Gulf of Maine, global warming, and ocean acidification.

November 25, 2010
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission (FERC)
Mail Code: OEP, PJ 12.3
888 First Street, N.E.,
Washington, DC 20426

Re: Project No. 2984-080-Maine, Eel Weir Dam , S.D. Warren Company(SAPPI)
Friends of Sebago Lake (FOSL) request:
1. A return to the historic 1910-1986 uniform outflow policy.
2. Additional relicensing studies request including the impact of abnormal
outflows for sustained time periods affecting lake wetlands and silica
depletion in the Sebago Lake water continuum.

Dear Secretary Bose,

It is time for the FERC and the licensee, S.D. Warren Co., to restore the outflow policy provided below for Eel Weir Dam which will re-establish ecologically beneficial conditions for Sebago Lake, the Presumpscot River , the Presumpscot River Estuary, and Casco Bay.

1. Return to historic pre 1982 uniform outflow range flows and lake levels.
2. Outflows would only be adjusted for lake levels entering the 25th and 75th percentile and again at the 10th and 90th percentile. This would allow low, average or high water levels in any season as precipitation dictates, yet prevent extreme low outflows or damaging violations of the flowage easements.
3 Average flows must be adjusted upward if changing climatic conditions i.e. climate change, continues to cause increased annual rainfall averages.
4 End any “yo-yo” river level flow operation due to eel or fish passage.
5. When water levels reach the historic 1910-1986, 10th, 25th, 75th and 90th weekly percentiles, flow changes must be adjusted instantaneously.

page one

If the present FERC approved 1997 Lake Level Management Plan (LLMP) was replaced with the outflow policy outlined on page one, the following beneficial impacts would occur:

1. End the continuing multi million dollar losses from wasteful hydropower
spillage that has occurred over the past 14 years due to the present LLMP .

2. Increase flood prevention storage capacity and mitigate excessive spillage.

3. Decrease occurrences of above full pond episodes and destructive flowage
easements violations.

4. Reverse increasing trophic state trend and improve water quality.

5. Maintain adequate dry space of septic systems in low lying areas in the summer
and end the phosphorus contributions from presently flooded septic systems .

6. Restore healthy biodiversity and nutrient filtering
functions of lake wetlands.

7. Control and eradicate invasive species like milfoil naturally.

8. Restore Maine’s most outstanding inland beaches.

9. Reduce harmful silica retention in inland freshwaters and subsequent silica
depletion in Casco Bay.

10. Restore healthy saltwater diatom populations allowing suppression of harmful
algae blooms.

11. Reduce monetary losses of the shellfishery industry due to increased “red tide”
closures of shellfish beds.

12.High flow events and lake levels below the pre 1982 historic 25th percentile
would scrub the river bottom and restore the Songo River to natural clear
sandy bottom habitat suitable for salmon and trout propagation. A return to
clear, open, and non- milfoil choked stream habitat would deter the recently
introduced pike.

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13.End the erosion of millions of cubic feet of riparian glacial till, clays, beach deposits and topsoils due to increased water level averages and constant high lake levels that has occurred since the 1997 LLMP went into effect.

It is baffling that an unprecedented delaying hold for a FERC hydro relicensing {project number 2984-042} has occurred since 2005. The reason for this 5 year delay is a Maine Department of Environmental Protection (MeDEP) study to determine how much lower allowable Presumpscot River flows can be reduced in the summertime without dissolved oxygen levels failing to meet minimum Class C
standards. The MeDEP justifies their flow study because SAPPI’s S.D. Warren mill is no longer discharging pulp effluent into the Presumpscot River and Smelt Hill Dam at the Presumpscot River outlet has been removed. Now, DEP claims less outflow is needed to dilute the pollution and sustain minimum dissolved oxygen concentrations. The further reduction in Sebago Lake minimum outflows sought by MeDEP, at the bequest of high water interests would, during droughts, guarantee adherence to minimum lake level targets of the 1997 FERC ordered LLMP.

This MeDEP Presumpscot River flow study has set a precedent that an impact of outflow discharge volume on water quality (dissolved oxygen) downstream of Sebago Lake is part of the relicensing process and the purpose of the information gathered during the study is to modify the LLMP. During the 1,750 plus days since the FERC final p-2984 license document was readied for final State Water Quality Certification (WQC) new evidences are surfacing that indicate the impacts of the present FERC Sebago Lake LLMP are significantly more broad and harmful to the entire Sebago Lake water continuum than we ever could have imagined.

The MDEP has ignored the harmful impacts of a double digit fold increase in river low flow events from 1997-2009 as compared with the period from 1910-1986 (23. Kasprzak). A comparable freshwater flow change on any northeast U.S. river would have “profound” impacts on the river estuary (22. Nixon et al). In addition “a twenty-six fold increase in high flow events” during the same time period is disrupting the natural abilities of Casco Bay’s estuarine systems to process nutrients and pollutants (25. Kasprzak). FOSL requests that impacts of the present unnatural regulation regarding silica depletion (DSi) in the Sebago Lake water continuum (Presumpscot River Estuary-Casco Bay) and the significant physical impacts of river-estuarine flow changes be studied and analyzed.
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FERC recommended in the 2005 Environmental Assessment for p-2984 that Sebago Lake wetlands be studied on a 5 year cycle. The last lake wetland
monitoring studies occurred in 2002. My request for new wetland plant studies,
biogeochemical assessment of wetland soils, and determination of dissolved silica concentrations and ratios with the other elements of nitrogen, phosphorus and iron is consistent with FERC’s 2005 Final Environmental Assessment p-2984
recommendation. FERC’s recommendation:

“Therefore, we recommend that S.D. Warren monitor wetlands around
Sebago Lake consistent with the program required for the 1997 LLMP, but
on a 5-year cycle. This monitoring program would afford S.D. Warren
the opportunity to document any long-term changes in wetland
cover and plant diversity. “(13. p.91 Federal Energy Regulatory
Commission Final Environmental Assessment
FERC Project 2984 Eel Weir Dam)

In depth wetland studies should commence as soon as possible because no Sebago Lake study exists that provides information on lake wetland vegetation changes since 1997 Lake Regulation Plan was implemented (21. Wilcox "Site Visit and Evaluation of Wetland Conditions at Sebago Lake"). Wetland vegetation is a key determinant of biogenic silica recycling.

The current unnatural freshwater flows of The Federal Energy Regulatory Commission’s current Sebago Lake LLMP, FERC hydro project number p-2984-Eel Weir Dam, create the chemical, physical and biological conditions that reduce the flow of sufficient dissolved silica. The increased depletion of dissolved silica is resulting in degradation of Sebago Lake, the Presumpscot River, the Presumpscot River estuary, Casco Bay and is harming fisheries in the Gulf of
Maine.

Below is a list of some impacts of the present unnatural regulation of Sebago Lake that contribute to dissolved silica depletion factors in Sebago Lake, the Presumpscot River and Casco Bay.

The reduced summertime outflow volume necessary to maintain near full pond lake levels result in a longer flow retention time of Sebago Lake and the Presumpscot River waters. This additional seasonal water residence time of lake and river waters allows for increased freshwater diatom population growth and
silica deposition (3. Ragueneau et al). Higher freshwater diatoms numbers
page four
contribute to additional depletion of the available lake and river reservoir of
dissolved silica (15. Stoermer ). The present lake regulation compounds the
existing impacts of other dams in the Presumpscot River for dissolved silica
retention and depletion. This impact is a commonly known part of the “artificial
lake effect’(4. Wang).
Reduced lake level fluctuation and constant high summer water levels increase anoxia in lake wetlands and lake sediments. This is now the case for Sebago Lake’s wetlands because now significant tracts of the lake wetland bottom sediments are never exposed to the air especially in the warm months. This lack of oxygen prevents dissolution of biogenic silica found in dead diatom shells and
some plant matter buried in the sediments. This recycling of biogenic silica is
lost to the water continuum because the diatom shells and dead plant matter
silicate is permanently sequestered in the wetland bottom sediments. Biogenic
silica is readily recycled under oxygenated conditions (16.Allanson, 6. Struyf).
The constant higher summer lake levels with reduced fluctuation reduces groundwater charge inflow to the lake. Groundwater is significantly higher in dissolved silica than surface water. The reduced summer groundwater charge lowers the available dissolved silica in the summer time 10. Hurley et al). Less lake level fluctuation as is presently the case leads to less contact of surface waters with soils and groundwater in the riparian zone and thus reducing weathering fluxes (19. Humborg et al). It is obvious that dissolved silica influx would be reduced. In addition, the constant high summer lake levels increase phosphorus contribution from septic systems in low lying beach areas thus further increasing diatom growth and uptake of dissolved silica ( 24. C-E Groundwater Study).
The present increases in low flow events affects the rheotaxis of anadromous fish. The anadromous fish species and the fish that pursue them for food up the estuaries stir the sediments. This piscatory stirring of estuary and river sediments thus helps to supply silica and other vital nutrients to coastal waters(1.Yahel et al).
Elevated phosphorus levels in the lake water column increase the uptake of dissolved silica by freshwater diatoms. The unnatural regulation increases phosphorus concentration to the lake due to shoreline erosion and diminished functions of wetlands to safely store nutrients. The lake’s natural buffering mechanisms that safely process nutrients are compromised. Lake wetlands of Sebago Lake are inundated through the summer months. Lake bottom sediments with increased layers of organic deposition have reduced exposure to the air. As a result the sediments become anoxic. Under the anoxic conditions phosphorus is released from the soils instead of being safely and permanently sequestered in
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the sediments.(9.Salki). Freshwater diatom populations will increase until
dissolved silica is depleted. When this happens non-silica algae dominate(12.
Struyf). Often, this is why algae blooms occur in late summer when summer
diatom growth tends to reduce silica concentrations.
Unnatural lake regulation changes the population of aquatic plant species(18. Changes in the Emergent Plant Cover Netly-Libau Marsh). Cattails and variable leaf milfoil thrive under the present unnatural lake regulation while native
species do not. Newspaper articles describe “enormous recent growths of milfoil
in the lower Songo River (20. Portland Press Herald July 15, 2010). Also,
monocultures of cattails will eliminate other plant species important for
maintaining high water quality (17. DCR Massachusetts). Explosive growth of
variable leaf milfoil in Sebago Lake’s coves and tributary river outlets has
harmed the historic ecosystem habitat. These invasive plants reduce oxygenation
of bottom sediments which increase phosphorus releases which further fuel
freshwater diatom growth. This compounds the harmful impact of
creating anoxic sediments and waters by creating geochemical changes in the
sediments which affects the dissolution and recycling
of biogenic silica.

The Disruption of the Silica Cycle by Unnatural Freshwater Flow(abnormal dam outflow discharges)

Freshwater diatom populations increase due to various impacts of unnatural lake regulation. Lake wetlands that never dry out or gain exposure to the air during the growing season have become anoxic. This results in the transport of phosphorus from bottom sediments which increases diatom population growth. These freshwater diatoms absorb available dissolved silica and biogenic silica to form their frustules (shells). Freshwater diatom frustules are larger than saltwater
diatoms and generally require larger volumes of dissolved silica than saltwater
diatoms. When diatoms die they sink to the bottom sediments. Now that lake and lake wetland sediments are more anoxic because of constant water inundation due to the present unnatural lake regulation, the biogenic silica both from plant matter and diatoms is not readily recycled as would occur under naturally fluctuating water levels and subsequent oxygenated conditions. In addition, the increased retention time of lake waters because of reduced outflows in the warm months of the year gives more opportunity for silica to be buried in sediments and
permanently removed from the silica cycle. When less dissolved silica reaches
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coastal waters, saltwater diatom populations can not maintain sufficient numbers. Healthy saltwater diatom populations suppress harmful algae blooms like red tide. Diatoms are the gold of the food chain and responsible for the historic superior
fishery of the Gulf of Maine. Watersheds with ten percent or greater lake area are already subject to natural silica depletion. Dams further the reduction of dissolved silica in the water continuum (18. Conley et al). Because of these existing factors, coastal waters are sensitive to the additional limitations of dissolved silica by the present flow regulation. Diatoms are regulators of ocean acidity and atmospheric carbon dioxide. Unnatural freshwater flows on a global scale may be one of the
larger contributors to climate change, to the demise of the ocean fishery, and to increased ocean acidity. Unnatural freshwater flow is a growing world wide problem but is essentially unnecessary in Maine.

Request for Additional Studies

Friends of Sebago Lake requests that FERC require additional studies for the
presently delayed relicensing of Eel Weir dam, FERC Project number 2984 to determine the impacts of the present lake regulation on silica depletion of Sebago Lake, the Presumpscot River, the Presumpscot River Estuary and Casco Bay.
The following impact studies of the present Sebago Lake LLMP regarding silica depletion should include:
Aeration and redox changes in wetland bottom sediment geochemistry affecting biogenic recycling of silica from wetland sediments (2.Struyf)
Lake wetland aquatic plant species population changes and resulting impacts on
diatom growth.Lake groundwater contributions of dissolved silica comparisons
with post 1997 lake management and pre-1986 management.
Identifying post 1986 flow regulation induced sources of increased phosphorus contribution to lake waters and subsequent effects on diatom populations and DSi.
4.Estimation of additional growth of diatom populations from longer summer
water flow retention time.
5.Determining seasonal dissolved silica concentrations in various areas of Sebago
lake waters .
Effect of increased low flows on rheotaxis of anadromous fish and subsequent
loss of stirring of silica rich estuary and river sediments. Reductions of
freshwater flow are generally associated with an overall negative impact on the
fishery.
7. Relationships of changes in lake regulation and increased occurrences of
page seven

numbers and intensities of red tide events in Casco Bay. Red tide events have
increased in numbers and intensity since the 1970’s. In the 1970’s the Maine
Legislature passed legislation promoting lake regulation that maintains high
lake levels with reduced annual fluctuations.
Relationship of silica depletion in the Presumpscot River- Sebago Lake water
continuum and the quality of the fishery in Casco Bay. Present unnatural flow
regulation is increasing lake temperature due to longer retention time of warm
summer upper epilimnetic water, reduced “colder” groundwater flow in the
summer and fall and subsequent increased “warmer” groundwater flow in late
fall and early winter. No doubt exists that earlier ice- outs, non iced-over winters
and warmer summer lake waters are a result of climate change. However, the
1997 lake level regulation plan is adding to increased lake temperatures and
accentuates the impact of climate change. The question arises is how much does
the lake regulation increase lake temperatures in addition to climate change and
what is the impact on freshwater diatom growth and dissolved silica uptake.

Because the MeDEP has steadfastly placed the relicensing of Eel Weir dam on hold for the last eight years and ignored evidence of growing profound degradation in the Sebago Lake continuum, we officially request of the FERC to additionally require investigation and study of the gravity of the environmental impacts of Sebago Lake’s unnatural freshwater outflows on Casco Bay, the Gulf of Maine, and the economies that depend on their health. It is critically important for ecological and economic considerations that scientifically appropriate lake, lake wetland and silica depletion studies as described in this letter be required before the final issuance of the Eel Weir Dam p-2984 license as proposed in the Final 2005 Environmental Assessment. If the LLMP was returned to the proposed historic uniform outflow policy outlined on page one, these additional studies would not be necessary.
Thank you.

Sincerely,
Roger Wheeler

Roger Wheeler, President of Friends of Sebago Lake
PO box 385
Fryeburg, Maine 04037

page eight

cc: Nancy Skancke (SAPPI)
Dana Murch MeDEP)
Steve Kasprzak (FOSL)
Douglas Watts (FOSL)
Paul Lepage (State of Maine)
Beth Nagusky (MeDEP)
Ted Tibbals (FOSL)
Olympia Snowe
Susan Collins
Brad Goulet (SAPPI)

page nine
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1. Fish activity: a major mechanism for sediment resuspension and organic matter remineralization in coastal marine sediments, Gitai Yahel1,6,*,**, Ruthy Yahel1,2,**, Timor Katz3,4,**, Boaz Lazar3, Barak Herut4, Verena Tunnicliffe1,2,51Department of Biology, University of Victoria, PO Box 3020, Victoria, British Columbia V8W 3N5, Canada -2VENUS, University of Victoria, PO Box 1700, Victoria, British Columbia V8W 2Y2, Canada 3The Institute of Earth Sciences, The Hebrew University, Givat Ram, Jerusalem 91904, Israel -4Israel Oceanographic and Limnological Research, Haifa 31080, Israel -5School of Earth & Ocean Sciences, University of Victoria, PO Box 3055, Victoria, British Columbia V8W 3P6, Canada -6Present address: School of Marine and Environmental Science, Michmoret 40297, Israel
Silica: an essential nutrient in wetland biogeochemistry,Eric Struyf and Daniel J Conley -GeoBiosphere Science Centre, Department of Geology, Lund University, Lund, Sweden-Department of Biology, Ecosystem Management Research Group, University of Antwerp, Antwerpen, Belgium
Responses of Coastal Ecosystems to Anthropogenic Perturbations of Silicon Cycling, Olivier Ragueneau, Daniel J. Conley,Aude Leynaert, Sorcha Ni Longphuirt, and Caroline P. Slomp
A Promising style of growth velocity model of green algae and diatoms in local lake area ,Zhihong Wang, Fuyi Cui, Wenxuan Chen and Jie Jia , Chinese Journal of Geochemistry Volume 25, Supplement 1,
Freshwater marshes as dissolved silica recyclers in an estuarine environment (Schelde estuary, Belgium) Eric Struyf 1 Contact Information, Stefan Van Damme1, Britta Gribsholt and Patrick Meire (1)Department of Biology, Environmental Management Research Group, University of Antwerp, Universiteitsplein 1C, B-2610, Wilrijk, Belgium
KNAW), Korringaweg 7, 4401 NT Yerseke, The Netherlands Journal Hydrobiologia Issue Volume 540, Numbers 1-3 / May, 2005
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7.Silica fluxes and trapping in two contrasting natural impoundments of the upper
Mississippi River, by: L. Triplett, D. Engstrom, D. Conley, S. Schellhaass
Biogeochemistry, Vol. 87, No. 3. (26 March 2008), pp. 217-230.

8.Biogenic silica in freshwater marsh sediments and vegetation (Schelde estuary,
Belgium) E Struyf, S Van Damme, B Gribsholt, JJ … - 2005 – vliz.be

9.The world's 10th largest lake under threat: Lake Winnipeg, the
economic mainstay of Manitoba, Canada.
Author: Mr. Alex Salki, Freshwater Institute Fisheries and Oceans, Canada

10.Ground Water as a Silica Source for Diatom Production in a Precipitation-
Dominated Lake
JAMES P. HURLEY 1, DAVID E. ARMSTRONG 1, GALEN J. KENOYER 2, and CARL J.
BOWSER Water Chemistry Program, University of Wisconsin, Madison 53706
Department of Geology and Geophysics, University of Wisconsin

11.VARIATION OF SILICA AND DIATOMS IN A STREAM
WUN-CHENG WANG ,RALPH L. EVANS
Water Quality Section, Illinois State Water Survey,

12.The Global Biogeochemical Silicon Cycle Eric Struyf & Adriaan Smis & Stefan Van Damme &
Patrick Meire & Daniel J. Conley

13. Federal Energy Regulatory Commission Final Environmental Assessment
FERC Project 2984 Eel Weir Dam, p.91
“S.D. Warren proposes to replace the existing wetlands
monitoring program with a similar monitoring program, having a 5-
year monitoring cycle. Our analysis in section V.C.4
(Terrestrial Resources) shows that, in the 5 years after
implementation of the 1997 LLMP, wetlands have changed little.
In addition, we do not expect our recommended changes to the LLMP
to have any significant effects on wetlands. Thus, continuing to
monitor wetlands annually is unnecessary. Therefore, we
recommend that S.D. Warren monitor wetlands around Sebago Lake
consistent with the program required for the 1997 LLMP, but on a
5-year cycle. This monitoring program would afford S.D. Warren
the opportunity to document any long-term changes in wetland cover and plant
diversity”.
page eleven

14.The Role of Freshwater Inflows in Sustaining Estuarine Ecosystem Health in the San
Antonio Bay Region, www.harc.edu Contract Number 05-018 September 15, 2006
page eight
15.Stoermer, E.F. and J.P. Smol, The Diatoms: Applications for the Environmental and Earth
Sciences, page 159 June 1999, Cambridge University Press

16. Some factors governing the water quality of microtidal estuaries in South Africa,
BR Allanson
Institute for Water Research, Rhodes University, Grahamstown 6140, South Africa

17. www.mass.gov/dcr/watersupply/lakepond/factsheet/Variable%20Milfoil.pdf
Changes in the Emergent Plant Cover Netley-Libau Marsh Between 1979 and
2001 Delta Marsh Field Station(University of Manitoba) Occasional
Publication No. 4 , November 2004

18. The Transport and Retention of Dissolved Silicate by Rivers in Sweden
and Finland, by Daniel J. Conley, Per Stalnacke, Heikki Pitkanen and
Anders Wilander © 2000 American Society of Limnology and
Oceanography.

C. Humborg, M. Aigars,M.RTH and V. Ittekkot, Decreased silica lad-
sea fluxes through damming in the Baltic Sea catchement-
significance of particle trapping andhydrological alterations August
2005

20. “Weeding out Trouble”, Portland Press Herald July 15, 2010

21. Dr. Douglas Wilcox,"Site Visit and Evaluation of Wetland Conditions at
Sebago Lake." 2008

22. Scott Nixon, Stephen B. Olsen, Elizabeth Buckley, Robinson Fulweiler,
Managing Freshwater inflows to estuaries Lost to the Tide: The Importance of
Freshwater Flow to Estuaries 2004 Final Report submitted to the Coastal
Resources Center, Narragansett, RI: University of Rhode Island, Graduate
School of OceanographyFi

Steve Kasprzak letter to Susan Collins June 9, 2010 Friendsofsebago.blogspot.com

Sebago Lake Groundwater Study, C-E Environmental, Inc. prepared for Portland Water District, September 1991
page twelve

Steve Kasprzak letter to Beth Nagusky, Acting Commissioner of MeDEP,
Nov. 4,2010

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