“The “In Reply” piece by Jim Steets, communications manager of Entergy Nuclear (“Nuclear plant not to blame for shad decline in Hudson ,” June 7) that was in response to your editorial (“Missing in action: A ‘chicken-or- egg’ riddle for the Hudson deserves real inquiry,” May 20) is riddled with slippery logic and false statements.

Steets contends that the New York State Department of Environmental Conservation found that Indian Point has had “no appreciable influence on the Hudson River American shad.” In fact, the DEC’s May 2008 plan for the recovery of Hudson River American shad states that young shad are lost to the cooling water intake structures of power plants. Moreover, one of the agency’s three primary strategies to reduce the mortality of shad is to “reduce or eliminate losses of all shad life stages to Hudson River power generating plants.”

Steets’ focus on shad cleverly diverts attention from the overall results of the report conducted by Pisces Conservation Ltd., which implicated Indian Point and other Hudson River power plants as significant contributors to the decline of Hudson River fish. His statement that fish are protected by a fish-return system designed by experts for Riverkeeper is patently false. It is true that former Riverkeeper board member and scientist Ian Fletcher advised Consolidated Edison, Indian Point’s previous owner, on a so-called “fish return” mechanism. Unfortunately, the fish return strategy didn’t work, and Indian Point’s cooling system falls far short of meeting the Clean Water Act requirement that such plants use the “best technology available to minimize environmental impacts.” As Gov. David Paterson said in a May 28 press statement, the majority of 1.2 billion fish eggs and larvae, and 1.18 million fish that come into contact with Indian Point’s antiquated cooling system each year, likely die.

Steets’ charge that the Pisces study contradicts information on Riverkeeper’ s Web site about an increase in striped bass is false and disingenuous. Of 13 species examined by the report, striped bass were one of only three that are increasing in number. This is attributable to particular circumstantial changes that happen to favor them – for example, the closure of the commercial striped bass fishery due to PCB contamination, as well as size limit restrictions on the recreational fishery.

Steets’ reference to the analysis of scientific data collected over several decades that has “shown no negative impact on any Hudson River fish” was conducted by the power plant operators themselves – hardly a reliable source given their financial incentive to play down the impacts of their cooling systems on the river’s aquatic life. In fact, the report’s findings are supported by the data and by biologists from the DEC Fisheries unit, and do nothing more than confirm the link between power plants and fishkills established long ago by the DEC and independent scientists.

The Pisces study was designed to analyze the power plant operators’ data and determine long-term trends for the 13 species studied, as required by the DEC. Given the clear downward trends for most of these fish, the next step is for the DEC to conduct a more in-depth analysis to determine what role various factors – climate change, overfishing, sewage, habitat loss, invasive species and power plants – are playing in the decline of each of these fish. However, we currently know enough to definitively link Indian Point and other power plants with some of these declines. Each year, we know that virtually 100 percent of the 13,380,000 shad, 326,666,667 bay anchovy, 466,666,667 river herring, 158,000,000 striped bass and 243,333,333 white perch entrained in Indian Point’s cooling system die. If 95 percent of these fish had avoided being destroyed by Indian Point’s intakes, as they would have were the plant equipped with the “best technology available,” the river’s fish populations would certainly be stronger than they are today.

It is way past time for Entergy and the other out-of-state power plant operators to stop slaughtering our fish. And if Entergy is truly committed to being a “good neighbor,” the company should invest in upgrading its Indian Point facility to meet the clear requirements of the Clean Water Act, rather than in a well-funded campaign to blanket the Hudson Valley with misleading and dishonest propaganda.”

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