My addendum comment filed for ways to eliminate the massive Lake Fairfield Fish Kills
I looked into when we know LGC was publicly informed of TPWD fish kill findings. As a result I filed the attached addendum to my TCEQ comments this evening.
I hope LGC can prepare and operate an acceptable key parameter measuring and control system such that TPWD can agree with a defined particular physical or biochemical parameters for the necessary water quality. So as soon as practical TPWD feels comfortable resuming Lake Fairfield fish stocking and not have to wait several years of no fish kills as a practical demonstration that habitat conditions are suitable to resume fish stocking.
Addendum to my prior comments:
1. TPWD had been communicating publicly about the cause of these recurring Lake Fairfield kills for years. TPWD issued press releases in 2009, 2010, and 2011 links provided below publically describe TPWD findings for the Lake Fairfield kills. These releases provide a lot of background information, history of fish kills, facts and numbers about fish kills, explanations of things like low dissolved oxygen and Trinity River make-up water and the nutrients in river water makeup.
http://www.tpwd.state.tx.us/newsmedia/re...earch=Fairfield,
http://www.tpwd.state.tx.us/newsmedia/re...earch=Fairfield,
http://www.tpwd.state.tx.us/newsmedia/re...arch=Fairfield.)
Of particular note and quoting with Bolding and Italics where content is thought to be significant from the 2009 TPWD press release:
Anglers fishing the lake the morning of September 13th noticed the dead fish and notified the TPWD 24-hour Communication Center at (512) 389-4848. Unlike previous kills, notification was received early enough that TPWD personnel were able to get to the scene while fish were still dying. This allowed them to collect fish that were stressed but not yet dead and take water samples in several areas of the kill.
Main locations of dead fish were along the shoreline of a cove immediately northwest of the dam to the spillway and in the cove south of the dam, but also extending up the shoreline to mid-reservoir. The fish appeared to have died no earlier than Saturday, September 12th.
TPWD personnel returned to the lake on Monday the 14th and Tuesday the 15th to collect water samples and conduct a thorough investigation and enumeration of the kill. Water quality field data were measured both in and out of the area where dead fish were observed. Dead fish were distributed along approximately 10 miles of shoreline. A series of detailed counts were conducted along approximately 0.75 miles of that shoreline to allow estimation of the total kill.
Water quality datasondes (electronic data gathering devices) were deployed in the northwest and south coves where the main kills occurred. These datasondes were able to collect temperature and oxygen concentration every 30 minutes for the following 14 days.
Water quality field data collected on Sunday the 13th indicated extensive areas of lower than normal oxygen and abundant phytoplankton (chlorophyll a) in the areas where the fish kill occurred. Using information on oxygen concentration from the datasondes, water quality data collected the day of the kill, and information on sunlight level from a local weather site, TPWD biologists began to piece together a theory on the cause or causes of the kill.
Normally photosynthesis (oxygen production) by phytoplankton during daylight hours increases oxygen concentration enough to compensate for respiration (oxygen use) by those same phytoplankton as well as bacterial decomposition at night. However, during periods of cloudy weather sunlight (measured as solar radiation) is reduced; oxygen consumption remains high but oxygen production is greatly reduced. When cloudy weather lasts for several days and oxygen concentration falls below the minimum level to support aquatic life, fish begin to die.
A good rule of thumb is at oxygen concentrations below 5 milligrams per liter (5 mg/L) many species become stressed, and at concentrations below 3 mg/L most species can die from oxygen deprivation. These concentrations are also known as the daily mean and minimum dissolved oxygen criteria for high aquatic life use in the Texas Surface Water Quality Standards. Although oxygen levels may stay above the minimum level during the day, it only takes a few minutes below the minimum at night to be fatal to fish.
Cloudy weather in the Fairfield area began on Thursday, September 10th. By Saturday the 12th solar radiation was only 1/3 of the normal for that time of year, and fish began dying before dawn on the 13th. By the time KAST personnel deployed the datasondes on the afternoon of the 14th the sun had begun to break through the clouds, and oxygen levels had begun to temporarily climb back above 5 mg/L.
This reprieve was short-lived; cloud cover reduced solar radiation on the 15th, 16th and 17th and oxygen concentrations remained below the minimum level. By the 18th the weather pattern had improved and oxygen production in the north cove remained above the minimum level. Oxygen production in the south cove lagged several days behind due to its higher phytoplankton level, but by Sunday the 20th abundant sunshine was once again allowing phytoplankton to produce high levels of oxygen in both areas. Another short period of cloudy weather from the 22nd to the 25th reduced oxygen concentration again but was of short enough duration that no substantial fish kill occurred.
By combining oxygen data from the datasondes with solar radiation data from the weather station, TPWD biologists now had the critical information needed to understand the complex dynamics of the repeated kills at Lake Fairfield.
In September, water temperature and bacterial activity are still high but day length has been getting shorter incrementally since the summer solstice on June 21 (the date in the Northern Hemisphere when daylight hours are longest relative to dark). Extremely high phytoplankton levels due to high nutrient levels produce sufficient oxygen during sunny days to compensate for lack of production at night; however, when early fall cool fronts and cloudy weather limit solar radiation, oxygen levels drop rapidly and fish may die.
extracted paragraph that quantifies the fish killed counts
Water samples and tissue samples from live but stressed fish collected during the day of the kill have not shown the presence of any toxicant that could be responsible for the kill.
2. Further I am glad to learn that TPWDs Mr. Melinchuk November 11, 2011 letter included a carbon copy to Luminants manager Ms. Shawn Glacken. Therefore GLC was again informed of TPWDs fish kill cause conclusions. Hence there can be hope GLC has been working on a permit revision solution since receiving TPWDs re-enforcement of their massive fish kill cause findings.
3. While there were known prior meetings and phone discussions between and LGC and/or TXU staffs with the TPWD staff preceding the 2009 fish kill; it possible from just publicly available information to minimally date when TPWD informed the power company that oxygen depletion was the symptom that caused the Lake Fairfield massive late summer fish kills. Hence by using the TPWD letter table 1 the stock values lost in 2010 and 2011 occurred after GLC was publicly minimally informed, and amounts to a value no less than slightly over $4.4 million plus the TPWD multiple years investigation costs. To my knowledge the 2004 to current TPWD investigation cost remains un-valued by TPWD. The restocking of the lake with adult size fish LGC should be supplying should minimally include $4.4Million plus the cost of all the TPWD fish kill investigations. A responsible corporate citizen would have already restocked the lake with the aquatic life lost after October 2009 and paid TPWD for the value LGC derived for those investigations.
4. For filing a permit application failing to accurately inform:
a. TCEQ that there were periods of significant fish mortality events, and clearly stating there were none and,
b. for somehow not having any water quality tests results from samples taken during these fish killing periods, and
c. with the common knowledge of GLC had to haul away multiple dumpsters or truck loads of dead fish mass suspended solids but submitting an permit application claiming no such events beyond 70% of normal ever occurred since the 2007 renewal.
d. Then I feel it is appropriate that a TCEQ fine LGC for all post October 2009 press release fish kills for a fine value amount sufficient to offset:
i. All the all investigation expenses cost TPWD had to divert from the sportsmans license and use fees to investigate for fish kill causes for all the 2004 to present massive fish kill years, and deliver that conclusion to LGC, plus
ii. The expense TCEQ has to afford to hear these comments on LGCs false permit application statements, and then reconsider any amended permit application again.
