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HomeMy WebLinkAboutS Intertie Enviromental Analysis Funding 1998CHUGACH ELECTRI ASSOCIATION, INC. Cine October 16, 1998 Alaska Indust il rial Golden Valley Electric Association, Inc. os Authority P.O. Box 71249 Fairbanks, Alaska 99707 Attention: Michael P. Kelly, General Manager Subject: Southern Intertie, EIS Process —- Chugach W.O. #E9590081 Additional Funding for the Environmental Analysis Dear Mr. Kelly: As part of their contract to perform the environmental assessment for the project our consultants, Power Engineers/Dames and Moore, have completed two drafts of the Environmental Analysis (EVAL). The final document is intended to form the basis for the Environmental Impact Statement (EIS) to be prepared by RUS’ consultant Mangi Environmental. The last draft (dated May 1998) incorporated changes to contents and format of the report as well as the maps requested by RUS and the cooperating agency, USFWS. We anticipated that its review would result in mostly “housekeeping” changes and that the final EVAL would be available by the end of July. During interagency meetings in June it became apparent, however, that the USFWS staff had not completed its review and that more time would be needed. When their comments became available at the end of July, major changes to the map presentations as well as the assessment approach were requested. New review meetings were scheduled in early September to reach agreement between the lead and cooperating federal agencies as to the formats to be used for the report and associated maps. PEI/Dames and Moore estimate the effort to comply with the agencies’ requests will add $118,193 to their expenses. Detailed documentation is included with PEI’s letter of October 13, 1998, which is enclosed with this letter. We agree with the consultants’ assessment that the EVAL preparation was severely impacted by the initial lack and subsequent repeated changes in direction from the federal agencies. We also feel very strongly that we need to produce an EVAL which addresses all agency concerns and can be adopted into the EIS without changes. Therefore, it is recommended that the IPG approve the increase in funding to PEI/Dames and Moore’s contract as requested. 5601 Minnesota Drive * P.O. Box 196300 ¢ Anchorage, Alaska 99519-6300 Phone 907-563-7494 © FAX 907-562-0027 Mr. Michael P. Kelly Page 2 October 16, 1998 Overall project funding will allow this expenditure without allocations, in addition to the $5,900,000 total for Phase I of the project as approved by AIDEA’s Board of Directors in June of this year. We will also remind USFWS and RUS of their obligations under the Memorandum of Understanding governing the NEPA process for the project, and request closer cooperation and regard for costs of changes. With this letter, I am requesting that an IPG meeting be scheduled at the earliest date to deal with this issue. Sincerely, CHUGACH ELECTRIC ASSOCIATION, INC. Fe et . Eugene N. Bjornstad General Manager ENB/DEG. jb C:\DATA\ANNALISA\WORDOCS\GROPP\ADD$1098.DOC Enclosure Lee Thibert Michael Massin W.O. E9590081, Sec.2.1.2.1 RF CHUGACH ELECTRIC ASSOCIATION, INC. ach Cin ASSOCIATION, INC. October 16, 1998 Homer Electric Association, Inc. 3977 Lake Street Homer, Alaska 99603 Attention: Norm Story, General Manager Subject: Southern Intertie, EIS Process — Chugach W.O. #E9590081 Additional Funding for the Environmental Analysis Dear Mr. Story: As part of their contract to perform the environmental assessment for the project our consultants, Power Engineers/Dames and Moore, have completed two drafts of the Environmental Analysis (EVAL). The final document is intended to form the basis for the Environmental Impact Statement (EIS) to be prepared by RUS’ consultant Mangi Environmental. The last draft (dated May 1998) incorporated changes to contents and format of the report as well as the maps requested by RUS and the cooperating agency, USFWS. We anticipated that its review would result in mostly “housekeeping” changes and that the final EVAL would be available by the end of July. During interagency meetings in June it became apparent, however, that the USFWS staff had not completed its review and that more time would be needed. When their comments became available at the end of July, major changes to the map presentations as well as the assessment approach were requested. New review meetings were scheduled in early September to reach agreement between the lead and cooperating federal agencies as to the formats to be used for the report and associated maps. PEI/Dames and Moore estimate the effort to comply with the agencies’ requests will add $118,193 to their expenses. Detailed documentation is included with PEI’s letter of October 13, 1998, which is enclosed with this letter. We agree with the consultants’ assessment that the EVAL preparation was severely impacted by the initial lack and subsequent repeated changes in direction from the federal agencies. We also feel very strongly that we need to produce an EVAL which addresses all agency concerns and can be adopted into the EIS without changes. Therefore, it is recommended that the IPG approve the increase in funding to PEI/Dames and Moore’s contract as requested. 5601 Minnesota Drive ¢ P.O. Box 196300 * Anchorage, Alaska 99519-6300 Phone 907-563-7494 * FAX 907-562-0027 Mr. Norm Story Page 2 October 16, 1998 Overall project funding will allow this expenditure without allocations, in addition to the $5,900,000 total for Phase I of the project as approved by AIDEA’s Board of Directors in June of this year. We will also remind USFWS and RUS of their obligations under the Memorandum of Understanding governing the NEPA process for the project, and request closer cooperation and regard for costs of changes. With this letter, I am requesting that an IPG meeting be scheduled at the earliest date to deal with this issue. Sincerely, CHUGACH ELECTRIC ASSOCIATION, INC. Cpe Voi teat Eugene N. Bjornstad General Manager Mp) ENB/DLG:jb CADATA\ANNALISA\WORDOCS\GROPP\ADD$1098.DOC Enclosure Cc: AIDEA — Randy Simmons, Executive Director Lee Thibert Michael Massin W.O. E9590081, Sec.2.1.2.1 RF CHUGACH ELECTRIC ASSOCIATION, INC. October 16, 1998 Matanuska Electric Association, Inc. P.O. Box 2929 Palmer, Alaska 99645 © Attention: Wayne D. Carmony, General Manager Subject: Southern Intertie, EIS Process — Chugach W.O. #E9590081 Additional Funding for the Environmental Analysis Dear Mr. Carmony: As part of their contract to perform the environmental assessment for the project our consultants, Power Engineers/Dames and Moore, have completed two drafts of the Environmental Analysis (EVAL). The final document is intended to form the basis for the Environmental Impact Statement (EIS) to be prepared by RUS’ consultant Mangi Environmental. The last draft (dated May 1998) incorporated changes to contents and format of the report as well as the maps requested by RUS and the cooperating agency, USFWS. We anticipated that its review would result in mostly “housekeeping” changes and that the final EVAL would be available by the end of July. During interagency meetings in June it became apparent, however, that the USFWS staff had not completed its review and that more time would be needed. When their comments became available at the end of July, major changes to the map presentations as well as the assessment approach were requested. New review meetings were scheduled in early September to reach agreement between the lead and cooperating federal agencies as to the formats to be used for the report and associated maps. PEI/Dames and Moore estimate the effort to comply with the agencies’ requests will add $118,193 to their expenses. Detailed documentation is included with PEI’s letter of October 13, 1998, which is enclosed with this letter. We agree with the consultants’ assessment that the EVAL preparation was severely impacted by the initial lack and subsequent repeated changes in direction from the federal agencies. We also feel very strongly that we need to produce an EVAL which addresses all agency concerns and can be adopted into the EIS without changes. Therefore, it is recommended that the IPG approve the increase in funding to PEI/Dames and Moore’s contract as requested. 5601 Minnesota Drive * P.O. Box 196300 * Anchorage, Alaska 99519-6300 Phone 907-563-7494 © FAX 907-562-0027 Mr. Wayne D. Carmony Page 2 October 16, 1998 Overall project funding will allow this expenditure without allocations, in addition to the $5,900,000 total for Phase I of the project as approved by AIDEA’s Board of Directors in June of this year. We will also remind USFWS and RUS of their obligations under the Memorandum of Understanding governing the NEPA process for the project, and request closer cooperation and regard for costs of changes. With this letter, I am requesting that an IPG meeting be scheduled at the earliest date to deal with this issue. Sincerely, CHUGACH ELECTRIC ASSOCIATION, INC. aw Eugene N. an General Manager ENBDK Gj CADATA\ANNALISA\WORDOCS\GROPP\ADD$1098.DOC Enclosure c: AIDEA - Randy Simmons, Executive Director Lee Thibert Michael Massin W.O. E9590081, Sec.2.1.2.1 RF CHUGACH ELECTRIC ASSOCIATION, INC. Cikne October 16, 1998 City of Seward Light & Power Division P.O. Box 167 Seward, Alaska 99664 Attention: Dave Calvert, Utility Manager Subject: Southern Intertie, EIS Process —- Chugach W.O. #E9590081 Additional Funding for the Environmental Analysis Dear Mr. Calvert: As part of their contract to perform the environmental assessment for the project our consultants, Power Engineers/Dames and Moore, have completed two drafts of the Environmental Analysis (EVAL). The final document is intended to form the basis for the Environmental Impact Statement (EIS) to be prepared by RUS’ consultant Mangi Environmental. The last draft (dated May 1998) incorporated changes to contents and format of the report as well as the maps requested by RUS and the cooperating agency, USFWS. We anticipated that its review would result in mostly “housekeeping” changes and that the final EVAL would be available by the end of July. During interagency meetings in June it became apparent, however, that the USFWS staff had not completed its review and that more time would be needed. When their comments became available at the end of July, major changes to the map presentations as well as the assessment approach were requested. New review meetings were scheduled in early September to reach agreement between the lead and cooperating federal agencies as to the formats to be used for the report and associated maps. PEI/Dames and Moore estimate the effort to comply with the agencies’ requests will add $118,193 to their expenses. Detailed documentation is included with PEI’s letter of October 13, 1998, which is enclosed with this letter. We agree with the consultants’ assessment that the EVAL preparation was severely impacted by the initial lack and subsequent repeated changes in direction from the federal agencies. We also feel very strongly that we need to produce an EVAL which addresses all agency concerns and can be adopted into the EIS without changes. Therefore, it is recommended that the IPG approve the increase in funding to PEI/Dames and Moore’s contract as requested. 5601 Minnesota Drive * P.O. Box 196300 « Anchorage, Alaska 99519-6300 Phone 907-563-7494 ¢ FAX 907-562-0027 Mr. Dave Calvert Page 2 October 16, 1998 Overall project funding will allow this expenditure without allocations, in addition to the $5,900,000 total for Phase I of the project as approved by AIDEA’s Board of Directors in June of this year. We will also remind USFWS and RUS of their obligations under the Memorandum of Understanding governing the NEPA process for the project, and request closer cooperation and regard for costs of changes. With this letter, I am requesting that an IPG meeting be scheduled at the earliest date to deal with this issue. Sincerely, CHUGACH ELECTRIC ASSOCIATION, INC. Eee SU. yt Eugene N. Bjornstad General Manager 7) ENB/DLG:jb C:\DATA\ANNALISA\WORDOCS\GROPP\ADD$1098.DOC Enclosure Cc: AIDEA — Randy Simmons, Executive Director Lee Thibert Michael Massin W.O. E9590081, Sec.2.1.2.1 RF CHUGACH ELECTRIC ASSOCIATION, INC. Cen ketric October 16, 1998 Anchorage Municipal Light and Power 1212 East First Avenue Anchorage, Alaska 99501 Attention: Ms. Meera Kohler, Utility Manager Subject: Southern Intertie, EIS Process — Chugach W.O. #E9590081 Additional Funding for the Environmental Analysis Dear Ms. Kohler: As part of their contract to perform the environmental assessment for the project our consultants, Power Engineers/Dames and Moore, have completed two drafts of the Environmental Analysis (EVAL). The final document is intended to form the basis for the Environmental Impact Statement (EIS) to be prepared by RUS’ consultant Mangi Environmental. The last draft (dated May 1998) incorporated changes to contents and format of the report as well as the maps requested by RUS and the cooperating agency, USFWS. We anticipated that its review would result in mostly “housekeeping” changes and that the final EVAL would be available by the end of July. During interagency meetings in June it became apparent, however, that the USFWS staff had not completed its review and that more time would be needed. When their comments became available at the end of July, major changes to the map presentations as well as the assessment approach were requested. New review meetings were scheduled in early September to reach agreement between the lead and cooperating federal agencies as to the formats to be used for the report and associated maps. PEI/Dames and Moore estimate the effort to comply with the agencies’ requests will add $118,193 to their expenses. Detailed documentation is included with PEI’s letter of October 13, 1998, which is enclosed with this letter. We agree with the consultants’ assessment that the EVAL preparation was severely impacted by the initial lack and subsequent repeated changes in direction from the federal agencies. We also feel very strongly that we need to produce an EVAL which addresses all agency concerns and can be adopted into the EIS without changes. Therefore, it is recommended that the IPG approve the increase in funding to PEI/Dames and Moore’s contract as requested. 5601 Minnesota Drive * P.O. Box 196300 * Anchorage, Alaska 99519-6300 Phone 907-563-7494 © FAX 907-562-0027 Ms. Meera Kohler Page 2 October 16, 1998 Overall project funding will allow this expenditure without allocations, in addition to the $5,900,000 total for Phase I of the project as approved by AIDEA’s Board of Directors in June of this year. We will also remind USFWS and RUS of their obligations under the Memorandum of Understanding governing the NEPA process for the project, and request closer cooperation and regard for costs of changes. With this letter, I am requesting that an IPG meeting be scheduled at the earliest date to deal with this issue. Sincerely, CHUGACH ELECTRIC ASSOCIATION, INC. Eugene N. whe A General Manager ENB/DIIG:ib C:\)DATA\ANNALISA\WORDOCS\GROPP\ADD$1 098.DOC Enclosure Cc: AIDEA — Randy Simmons, Executive Director Lee Thibert Michael Massin W.O. E9590081, Sec.2.1.2.1 RF “ . TOWER October 13, 1998 RECEIVED OCT 14 1998 Dora L. Gropp, P.E. aes Manager, Transmission & Special Projects TRAN ION & Chugach Electric Association, Inc: SPECIAL PROJECT 5601 Minnesota Drive, Bldg. A D0. ERSFOO oY’ Anchorage, AK 99518 bee zu) Subject: 120376-05 Southern Intertie, Phase IB - Chugach Contract #95-208 Power Project 120376 - Additional Work Scope to Respond to USFWS Comments and Direction Dear Ms. Gropp, As you are aware, our recent communications and meetings with the US Fish and Wildlife Service (USFWS) on September 8-10, 1998 resulted in new direction from USFWS for the Final EVAL. Revision of the 2“ Draft EVAL to respond to USFWS direction will require substantial rework of the document, in order for the content and format of the Final EVAL to be acceptable to the USFWS. USFWS’s comments and direction centered around the biology sections of Chapters 3 and 4 of the 2™ Draft EVAL, and in the formatting, content, and presentation of the maps. Substantial rework of the text will be required, consistent with the changes in the maps. The attached memo to me from Tim Tetherow outlines the background of Dames and Moore’s previous coordination and consultation with the USFWS over the past 2 years, and details the changes that are now required to respond to the current USFWS direction. A budget for the additional scope of work in the amount of $118,193. is attached. The additional funding would allow us to revise the EVAL document in compliance with USFWS direction. As you will recall, it was agreed at the September meetings that because of the substantial revisions to the document, we would submit the revised biology sections and maps to USFWS for a final review in November. They would only be reviewing those sections, not the entire’ document as before. Ifno further changes to the draft EVAL document are requested during this next review of the biology sections, this additional funding will allow us to complete the Final EVAL. It is important to realize that RUS intends to attach the Final EVAL to the EIS document as an appendix. As agreed to in the MOU between the agencies and the IPG, the EVAL is to serve as the basis for preparation of the EIS. The NEPA process is agency directed, and the EIS will address the issues deemed pertinent by the lead and cooperating agencies, in a manner acceptable to the agencies. As an appendix to the EIS, the Final EVAL must be consistent with the EIS. It is therefore our recommendation that the changes to the EVAL document directed by the USFWS at the September meetings be incorporated into the Final EVAL. DEN 26-708 (10/13/98) ukk POWER Engineers, Incorporated eR SO A la RR Sh NATL AT RR A a SS 3900 South Wadsworth Boulevard, Suite 700 Phone (303) 716-8900 Lakewood CA 80726 Chugach Electric Association, Inc. October 13, 1998 Page 2 Summary of attachments included with this letter: 1. Budget Summary 2. Memorandum from Tim Tetherow, Dames & Moore, to Randy Pollock, Power Engineers dated October 13, 1998, including the following attachments: A. Table: Key Project Events Summary B. Notes: Changes in Direction from USFWS C. Memorandum: Impact Assessment Methodology D. Response from USFWS on Impact Methodology E. September 8-10, 1998 USFWS Meeting minutes e Table: Map Revisions e Notes: Biological Issues After you have had opportunity to review these materials, I will call you to see if further clarification or discussion is needed. Randy Pollock, P.E. Sr. Project Manager RP/ukk Enclosures cc: Mike Walbert (PED Tim Tetherow (D&M) File: 120376-05-55-00-30 DEN 26-708 (10/13/98) ukk RLU Southern Intertie Project Budget Summary Task 5 Scope Additions to Respond to USFWS Comments and Direction Power Engineers } Dames and Moore | Totals Labor 2% | Subtotal | [| 8 $12,502 $18,112 | $362 | $18,474 |] $18,474 IEVAL Revisions no ' $14,131 | $535 | $14,666] $293 | $14,959 }] $14,959 $90,577 | s9a6e_| $40081 $40.82 $19,254 | $2,930 | $22,184 22,628 |} $22,628 9 | 2,778 | $1,830 | $4,608 || $2,829 $4,355 || $8,963 | $11,097 si230 | $12327f fs frotarRequesed =i 813,875 | $3,060 | 16,935 | $79.293 | siv.979 | s99.272 | $1,985 [si0i.2s8l[ s118,193 Notes: 1. All of the work included as part of this proposed budget is either directly or indirectly related to the EVAL map and text revisions associated with the direction provided by the USFWS, resulting from the September 8-10, 1998 meetings. Please refer to the attached meeting minutes from those meetings and the Dames & Moore memo for more detailed information on the changes to the EVAL required. 2. Workscope for Dames & Moore is as described in the attached memo from Tim Tetherow to Randy Pollock dated October 6, 1998. 3. Work Item numbers correspond to the five tasks described in Tim Tetherow's memo, except PEI, which is Power Engineers work. 4. Workscope for Power Engineers (PEI) includes time for Randy Pollock to work with Dames & Moore to complete the required EVAL changes. Also included in the budget for Randy Pollock is one trip to Phoenix to review the changes to and assist in completion of the EVAL, and one trip to Anchorage to meet with the IPG (if required). $12,327 DEN 26-709 (10/13/98) 120376-05 Memorandum DAMES & MOORE A DAMES & MOORE GROUP COMPANY 7500 North Dreamy Draw Drive Suite 145 Phoenix, Arizona 85020 602 371 1110 Tel 602 861 7431 Fax Action Info File Randy Pollock, POWER 09203-009-050 Engineers, Inc. From Tim Tetherow, Dames & Moore, DEN Date 13 October 1998 Subject Southern Intertie Project - Budget Request for Additional Mapping and Required Supporting Analysis The purpose of this memo is to document the budget requirements to respond to requests by the US. Fish & Wildlife Service (FWS) for additional EVAL maps and analysis for the Southern Intertie project. Included in this memo is background information, requirements to revise the maps, estimated costs and attachments. Because of the complexity of these topics, the information provided in this memo is general, and is supported by five attachments that are referenced in the following sections. These attachments include: Key Project Events Summary Notes: Changes in Direction from FWS Memorandum: Impact Assessment Methodology Response from FWS on Impact Methodology September 8-10 Meeting Minutes * Table: Map Revisions * Notes: Biological Issues NOOO p> Background Every effort has been taken to gain agency direction for and acceptance of the Southern Intertie environmental studies by the FWS from the project inception. Our goal has been to follow a process that would result in an efficient and cost-effective study. We recognized from the start that this would be a difficult task because of the location of the project, the amount of Federal lands involved, and the range of environmental issues. Our proposed participation and approach planned to involve FWS at each stage of the study (Tasks 1 through 5). Review of the project by the FWS began in early 1996 with their comments on environmental studies and mapping for the Phase 1 Alternative Corridor Selection studies. Following the Phase 1 Studies, the first step in the EVAL/EIS studies was to develop a scope of work and mapping requirements for each resource study (including geology and soils, water, marine, O:\PEOPLE\UKK\FOOTER LOG\26-713.DOC DEN 26-713 ery Memorandum (Gi October 13, 1998 arms Page 2 biology, land use, socioeconomic, visual and cultural resources). These were documented in the project Work Plan (June 1996). The scope of work for the EVAL and study results have been reviewed with the FWS over an extended period of time, beginning in November 1996. The approach and general scope of work was first presented at the Interagency Scoping meeting that was held in November 1996. At that time we summarized the proposed project, Phase 1 study results and issues, and a process that was planned to revolve around an Interdisciplinary Team (ID). We also requested informal direction from the FWS as an Interagency ID team member prior to the completion of a Memorandum of Understanding (MOU), which would establish formal agency direction for the studies. The work plan and study approaches were reviewed in detail by the FWS during the preparation of the MOU. The final work plan became an attachment of the MOU, which the FWS signed in June 1997. (See Attachment A, Key Project Events Summary). The purpose of the MOU is to “establish an understanding between the Lead Agency and Cooperating Agencies, and Applicant regarding the conditions and procedures to be followed in the preparation of the Environmental Impact Statement (EIS) through a joint Applicant/ Agency effort.” The responsibilities of the Lead and Cooperating Agencies include: providing direction the Applicant’s Consultant in the preparation of the EVAL; and ensuring that the DEIS is based on the Applicant’s EVAL. Over the eight-month period that the MOU was prepared, 18 drafts were produced, along with six versions of the work plan. Technical Direction from FWS In addition to the scoping process, we have been working with the FWS since November 1996 to develop of the work plan and MOU. We have also received technical input from the FWS on biological resource data, issues, study approaches, mapping results, assessment of impacts, and preparation of the EVAL drafts. A listing of general and technical project activities are listed on the attached Key Project Events. While the FWS has offered assistance through the series of meetings and comment reviews, there have Key Project Events Summary for a listing of also been changes in direction that have required revisions to the EVAL studies as the involve the KNWR. The following summarizes some of the selected points in the project when we were given specific direction from FWS for the preparation of the EVAL. (See Attachment B, meeting notes regarding Changes in Direction from FWS for additional detail): e FWS participated in an interagency biological impact assessment meeting in Girdwood with the Forest Service on April 22, 1997 to discuss biological impact issues and select the species for detailed studies. The selected species identified for detailed investigation included brown bear, black bear, moose, caribou, bald eagle, trumpeter swan, ducks and geese, beluga whale, and anadromous fish. Key impact issues included access, loss of habitat through clearing and bird strikes. The results of that meeting became the focus of the biological assessment studies for the EVAL. The general approach to the assessment was discussed, but not finalized. e D&M’s proposed impact assessment methodology was distributed for review on August 4, 1997. FWS reviewed and commented on the impact assessment approach and a nine-point impact scale on August 14, 1997 (see Attachments C and D for the Impact Assessment Methodology Memo and the Response from FWS on Impact Methodology). FWS O:\PEOPLE\UKK\FOOTER LOG\26-713.DOC DEN 26-713 ens Memorandum (Gq October 13, 1998 fm Page 3 direction on the assessment set the direction for the assessment of all environmental resource impacts along alternative routes. The results of the biology assessment were presented to FWS at meetings in Anchorage and Soldotna on October 2 and 3, 1997, respectively. At those meetings, the maps, biology impact models, and impact results were presented to the FWS and Alaska State Division of Fish and Game (ADFG). Our approach for impacts to selected species had been to provide comprehensive mapping of wildlife habitat for the selected species within the study area on the Kenai Peninsula. We were informed that our mapping for brown bears, black bears, caribou and moose was not current with current KNWR understanding of those species. They informed us that neither the KNWR nor ADFG had any better comprehensive mapping for use in the EVAL. They directed us not to use the comprehensive mapping we had compiled from available sources for the four species mentioned above. For brown bears, they directed us to only use corridor level mapping that D&M had prepared. Direction at those meetings from the FWS and ADFG provided the basis of the biological studies that were documented in the first draft of the EVAL (November 1997). 9 FWS provided nine pages of comments on the first draft of the EVAL on February 9,199%. In the cover letter they stated that “In general, it appears that the document adequately identifies the range of issues associated with this proposed project, and that ample opportunity was provided for agency and community input. However, in the event that the IPG files a right-of-way application with the Service, the additional public process required under Title XI of the Alaska National Interest Lands Conservation Act may lead to the identification of additional issues.” Included was a request to analyze two additional species for detailed mapping and assessment - wolf and lynx. They also requested the inclusion of a new Interagency Brown Bear map. We responded to all of the FWS comments in the second draft of the EVAL. Meetings were held with the Kenai National Wildlife Refuge (K NWR) staff on December 10 and 11, 1998, and March 12, 199% to discuss their comments and approaches prior to finalizing the second draft of the EVAL. FWS comments on the second draft of the EVAL (submitted in May 1998) were received on July 24, 1998, after the June meetings. Over 40 pages of additional comments were submitted by FWS, including requests for extensive revisions in the assessment approach, additional maps and map changes. Two rounds of meetings have been held to discuss their comments (June 23 — 25 and September 8 — 10, 1998). The most recent meetings in September resulted in additional data requests that were not included in their July 24 comments. These included new direction for biological mapping, reformatting of map data, and new direction in the approach and display of impacts. A summary of the direction from FWS in the recent September meetings is provided below. September 1998 Meetings The meetings held in Soldotna this September represent the most recent direction from FWS. There were substantial requests for additional data and analyses by FWS in the recent September 1998 meetings that were not provided in their July 24 comments. This information was not previously available from FWS. They acknowledged that we were being “bounced around” in terms of conflicting requests by the agency. Included were substantial changes to the cumulative O:\PEOPLE\UKK\FOOTER LOG\26-713.DOC DEN 26-713 envy Memorandum (Gs October 13, 1998 Page 4 impact assessment approach, and mapping content and format. The following are some of the key points to the meeting that will result in substantial changes to the EVAL (see attachment E for meeting minutes which include the table of Map Revisions, and the summary of Biological Resource Issues discussed at the meetings): = One of the more discouraging map change requests centers on the formatting of the data for maps on the Kenai Peninsula. The first draft of the EVAL combined the routes and data for alternatives on the Kenai Peninsula on one sheet for each resource topic. Environmental impacts were presented on separate maps for clarity purposes. When, Mangi Environmental Group (Mangi), RUS’s Third -party EIS contractor, requested separate small panel map sheets for the second draft of the EVAL, FWS did not object at the June meetings. The new maps were prepared to replace the large original maps. At that time, FWS concurred with Mangi’s comments on map changes. At the September 1998 meetings, FWS stated emphatically that they did not like the small separate maps, and demanded the large sheet format that had been prepared for the first draft of the EVAL. = In addition, they requested that impacts be combined with the inventory maps. " Finally, they demanded that the nine-point impact scale be dropped, regardless of the direction from FWS last August. The format and scale for the impact maps is the same as those that we have prepared for EIS’s for several other transmission line projects. This is in response to NEPA requirements for a “rigorous analysis of alternatives.” » New map data were provided for wildlife habitat, the KNWR boundary, and ownership patterns within the refuge. Summary In summary, FWS has not tracked with the agreed-upon MOU and project work plan, which explicitly outlined a format, topics and schedule for participation in an interagency ID team during Tasks 1 through 5. Instead, input has been inconsistent with the majority coming over the last few months, as summarized in the attached notes on biological impact from FWS. We are committed to complete a high-quality document that will satisfy FWS and provide the basis for the project EIS. We understand that additional funding for preparing the EVAL is a very sensitive issue. We have appreciated the project funding increases that the IPG has authorized so far, and have tried to be as effective as possible in the preparation of the EVAL studies and documents. It is regrettable that we need to make additional funding requests at this time. Map Requirements New maps, and maps requiring revisions are listed below (see attachment E, Map Revisions Table). An assumed level of effort to prepare each map is also provided (difficult — 3 to 4 days; average — 2 to 3 days; minor — 1 day): New Maps * Subsistence - minor O:\PEOPLE\UKK\FOOTER LOG\26-713.DOC DEN 26-713 envy Memorandum (Gd October 13, 1998 Game Page 5 * Cumulative Development — difficult * Caribou Habitat and Impacts— average * Moose Abundance Areas and impacts — average ¢ Brown Bear Habitat and Impacts — difficult Revised Maps ¢ Earth Resources and Impacts— average * Vegetation Cover/Wetlands and General wildlife Habitat Inventory and Impacts — average * Anchorage Area Vegetation Cover/Wetlands and General Wildlife Habitat Inventory and Impacts— minor Duck and Goose Concentration Areas and Impacts— difficult Eagle Habitat and Impacts— average Swan Nesting Areas and Impacts — average Wolf Abundance Areas and Impacts — average Lynx Abundance Areas and Impacts — average Anadromous Fish Streams and Beluga Whale Habitat and Impacts — average Jurisdiction and Ownership - minor Land Use and Impacts— minor Anchorage Area Land Use and Impacts— minor Recreation Use and Management Areas and Impacts — average Anchorage Area Views from Residences and Visual Impacts - minor Anchorage Area Recreation Facilities and Impacts— minor Views From Residences and Visual Impacts— average Anchorage area views from Recreation Areas and Travel Ways and Visual Impacts— minor Landscape Scenery and Impacts Anchorage Area Landscape Scenery and Impacts Construction Methods — minor Anchorage Area Construction Methods - minor Construction Season — minor Proposed Structure Type and Existing Utilities — minor Anchorage Area Proposed Structure Type and Existing Utilities - minor The preparation of these maps will require an estimated one and one-half GIS persons for a 5- week period (280 hours) in order to meet a November 2 draft completion date. Following FWS review, some clean-up time is expected (40 hours). In addition to the GIS staff involvement, biology and project management support will be required to create these new and revised maps. There also will be text additions required to incorporate the map results into the EVAL. Tasks and Estimated Costs The additional work for completion of the EVAL, Task 5, has been organized into the following five subtasks: e Comment organization —- The FWS requested the attendance of D&M’s biology staff at the O:\PEOPLE\UKK\FOOTER LOG\26-713.DOC DEN 26-713 envy Memorandum 9m October 13, 1998 mum Page 6 meetings held in Soldotna in September. The complexity and timing of the comments on the biology map comments required considerable preparation prior to the meetings, and on-going follow-up analysis to determine the proposed approach for each map. Changes to existing text, tables and analysis of impacts will be required as a result of the new maps and changes to existing maps. This has required ongoing meetings between project management, the project biologists and GIS staff. In addition to the biology maps, there has been additional effort to organize the approach to revising the other maps in the EVAL that will require changes, which includes every map in the document. EVAL Revisions — This task is necessary to make the EVAL text changes that correspond to the map changes. Data re-formatting and assessment refinements will be required, preparation of new tables to quantify impacts, and extensive changes to the content and format of the biology sections of Chapters 3 and 4. Map Revisions — This task will be to make the changes to the maps by the GIS staff. Finalize EVAL — The changes to the Biology sections of the EVAL will be reviewed by the FWS in November. We plan to finalize the EVAL by December 1998. However, this schedule is dependent on the timeliness and usability of the data to be supplied by FWS. This task is planned in response to the anticipated effort to finalize the maps and corresponding document changes. IPG Meeting - Attendance at IPG meeting to discuss status of EVAL. Estimated costs for the five subtasks 5a — Se are summarized below: * 5a- Comment organization $18,112 * 5b-EVAL Revisions $14,666 * 5c - Map Revisions $40,041 * 5d - Finalize EVAL $22,184 * 5Se-—IPG Meeting $4,269 Total Estimated Costs $99,272 All of these tasks are either directly or indirectly related to the map revisions. Details will be provided in the supporting meeting notes. O:\PEOPLE\UKK\FOOTER LOG\26-713.DOC DEN 26-713