Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
Southern Intertie Final Enviro Impact Vol 1 2002
Be Nae se Final Environmental Impact Statement A ee ee ee Z 7 7) a Of Ya Any, Rural Utilities Service, U.S. Department of Agriculture U.S. Fish and Wildlife Service, pry Tate mals U.S. Army Corp of Engineers, Department of Defense Aerial View of Kenai National Wildlife Refuge, Alaska Volume I July 2002 Southern Intertie Study Area aS ALASKA Fairbanks qs WARREN L. KROTKE, SR/WA Frere 3I9%-ES3F LAND FIELD SERVICES, INC. P.O. BOX 221649 P.O. BOX 72510 ANCHORAGE, ALASKA 99522 FAIRBANKS, ALASKA 99707 248-6740 452-1206 R EGEWWE 0) \ 9 2002 July 9, 2002 LM JUL 0 AIDEA/ AEF Mr. Robert Poe, Executive Director Alaska Industrial Development & Export Authority 813 W. Northern Lights Boulevard Anchorage, AK 99503-6690 Subject: Southern Intertie Final Environmental Impact Statement (FEIS) Dear Mr. Poe: Enclosed are | (one) copy and a CD of Volumes | and II of the FEIS for subject project. Availability of these documents will be advertised in the Federal Register and local papers on July . 11 and 12, 2002 respectively. At that time the document will also be accessible on RUS’s website, http://www.usda.gov/rus/water/ees/eis.htm. A 30-day review period will begin on July 12 and end on August 10, 2002. This review period is required by RUS regulations. No further public meetings or hearings will be held. Our consultants will assist RUS with analyzing the comments and preparing responses, which will be incorporated in the Record of Decision (ROD). RUS, as the lead agency for the preparation of the Environmental Impact Statement (EIS) and the cooperating agencies, US Fish and Wildlife Service (USFWS) and the US Army Corps of Engineers (COE) will then prepare their RODs, which will be published as one document in early December of this year. If you have any questions, please call me at 907-762-4626. Sincerely, Dora Gropp, P.E., Manager, Transmission & Special Projects Engineering Services Division Enclosure: Volume I, Volume II, CD. Ce: Mike Massin w/o Lee Thibert w/o W.O. #E9590081 RF ich Electric Association, Inc ¢ (907) 5¢ AOA 9 62-0027 « USDA acted United States Department of Agriculture Rural Development Rural Business—Cooperative Service + Rural Housing Service » Rural Utilities Service Washington, DC 20250 July 1, 2002 Dear Reader: Enclosed for your information is the Final Environmental Impact Statement (FEIS) for the Southern Intertie Project. Depending upon the interest you have expressed regarding this proposed project, you are receiving the FEIS in either hard copy format or in CD-ROM format. The FEIS analyzes the potential impacts of a 138 kV transmission line that has been proposed by the Intertie Participants Group between the Kenai Peninsula and Anchorage. The FEIS evaluates a number of routing alternatives and related system improvements between the substation connections, as well as alternative technologies and the no-action alternative. The public review period for the Draft Environmental Impact Statement (DEIS) extended from October 5, 2001 through December 5, 2001. As required by Title XI of Alaska National Interest Lands Conservation Act, three public hearings were held, one in the District of Colombia and two in the State of Alaska. Public testimony at the three hearings was received from 12 persons. During the 60-day comment period a total of 102 different comment letters were received from Federal, State, and municipal agencies, businesses, native corporations, non-profit organizations, and individuals. Two of the letters were email form letters signed by 158 and 907 individuals, respectively, and one letter was in petition format with 12 signatures. The FEIS incorporates information received on the DEIS and consists of the following volumes: « Volume I consists of an expanded Project Summary, responses to comments including copies of the original correspondence, supplemental information, and corrections to the DEIS. The USFWS Compatibility Determination and the USACE Draft Evaluation of the Section 404 (b)(1) Permit Application are appended to this volume. «Volume II consists of the mitigation plan that was developed to either eliminate or minimize impacts associated with the construction and operation the proposed project utilizing either the Enstar or Tesoro Routes. Rural Development is an Equal Opportunity Lender Complaints of discrimination should be sent to: Secretary of Agricutture, Washington, OC 20250 page 2 Copies of the FEIS have been sent to agencies, persons and organizations that have provided comments on the DEIS or were on the original project mailing list. Additional copies are available for review at the following public libraries in Anchorage: Z.J. Loussac Public Library Chugiak-Eagle Public Library Gerrish (Girdwood) Branch Library Mountain View Branch Library Muldoon Branch Library Samson-Dimond Branch Library Copies will also be available at these libraries on the Kenai Peninsula: = Hope Community Library = Cooper Landing Community Library m Soldotna Public Library = Kenai Community Library The FEIS is also available online at http://www.usda.gov/rus/water/ees/eis.htm. The FEIS is an informational document only. The purpose of the FEIS is to provide the public and decision-makers information on the potential environmental effects of the alternatives under consideration. The RUS, along with the USFWS and USACE will consider information contained in the FEIS in rendering their respective decisions, which will be published in each agency's respective Record of Decision (ROD). A copy of each agency's ROD will be provided to recipients of the FEIS. If you have any questions, please contact Lawrence R. Wolfe, Senior Environmental Protection Specialist, at (202) 720-1784 or at lwolfe@rus.usda.gov. Sincerely, Ano S Had), MARK S. PLANK Acting Director l Engineering and Environmental Staff Enclosure Final Environmental Impact Statement Southern Intertie Project Kenai Peninsula to Anchorage, Alaska July 2002 Lead Agency: Rural Utilities Service, U.S. Department of Agriculture Cooperating Agencies: USS. Fish and Wildlife Service, U.S. Department of Interior U.S. Army Corps of Engineers, U.S. Department of Defense Lead Agency Contact: Lawrence R. Wolfe USDA - Rural Utilities Service 1400 Independence Avenue SW - Stop 1571 Washington, DC 20250-1571 lwolfe@rus.usda.gov ABSTRACT The Southern Intertie Project Final Environmental Impact Statement (FEIS) provides public comments and responses, and supplemental information to the Draft EIS (DEIS). The DEIS describes the affected environment and environmental consequences of constructing and operating a new 138kV transmission line between the Kenai Peninsula and Anchorage. The project is being proposed by the Intertie Participants Group (Applicant) in order to improve the overall Railbelt electrical system reliability and energy transfer capabilities between the Kenai Peninsula and Anchorage. The primary federal action entails whether to approve the necessary permits to construct and operate the proposed project across federal lands administered by U.S. Fish and Wildlife Service (USFWS). The Applicant has filed for a right-of-way across federal lands on the Kenai National Wildlife Refuge (KNWR), a Conservation System Unit designated under the Alaska National Interest Land Conservation Act. The U.S. Army Corps of Engineers (USACE) will determine whether to issue a permit for regulated activities in waters of the United States; decisions made by the Rural Utilities Services determine whether or not to provide federal funding for the project. Volume I of the Southern Intertie Project FEIS contains a Summary, Chapter 1 - Public Comments and Responses, Chapter 2 — Supplemental Information, and three appendices. Appendix A contains the USFWS Compatibility Determination; Appendix B contains the USACE Draft Section 404(b)(1) Evaluation; and Appendix C contains the public notices distributed regarding the DEIS. Volume II of the FEIS defines and outlines the project Mitigation Plan. The document has been organized to enable the reader to review the comments received on the DEIS and the responses to those comments. Additional information contained in Chapter 2 supplements the responses to comments and issues discussed in Chapter 1. ‘ SOUTHERN INTERTIE PROJECT FINAL ENVIRONMENTAL IMPACT STATEMENT VOLUME I Rural Utilities Service, U.S. Department of Agriculture In cooperation with US. Fish and Wildlife Service, Department of the Interior U.S. Army Corps of Engineers, Department of Defense July 2002 TABLE OF CONTENTS VOLUME I FINAL ENVIRONMENTAL IMPACT STATEMENT Table of Contents ......<cs:sssasasasassssanaannsnasaanscscanisosssoxsansa.-sateosvesviowsvevornnniviiniehWieTRIN TE FEET ETrrsts2 i Mist Of Mablesee etre nesses sass rssencersessersecuenenvesvecsesvenatassrerceensurseesuccvsesasussenetenccescesesssesees li List of Figures iss iii Porn eid oat ead ee eee re eee cause sunensaetaeteceeees coeeteraraaeaneneeeeMrse eee Naan iti Mist OF ACTOMYMS...0.cecscsssccascencoessassscnsssscovoseetssvesssectssssuasesnenestesesasscsssssctaseususssusstseusueusotestossees iv General: Comment Tracking Indexi sii ssecssscsssncsscorsesnsssctescssscesesssosesosesssresstetsasssasessessssoccoaee=s Vi SUMMARY dese sasencsnecescsenccecsesssovevesarsonssaretecoresesere S-1 S.1 Introduction ...... S-1 S.2 Purpose and Need .... S-2 S.2.1 Project Need..... S-2 S.2.2 Project Objectives ... S-2 S.3 Alternatives Studied in Detail Including the Applicant’s Proposal .. S-4 S.3.1 No-Action Alternative... S-4 S.3.2 Applicant’s Proposal — Enstar Route ............sssssssssssssssssssesssssersrseseeneneeeeees S-6 $.3.3. Tesoro Route Alternative Bea) |) {S10 B84) PLO ]e CO Rac t ee eee ooo cece earner sauentausutensesetessectssusuetonvecsuectassssatameaeeaaea S-7 S.3.5 Construction Seasons S-8 S.4 Alternatives Eliminated from Detailed Study S48 S.4.1 Alternatives to a New Transmission Line Eliminated... S-8 S.4.2 Alternative Transmission Systems Eliminated ..............ccseseseseseseseseseseeees S-9 S.4.3_ Alternative Transmission Routes Eliminated eal S=10 S.5. Affected Environment and Environmental Consequences............s:sssecseseessseeseesees S-11 S.6 Scoping, Consultation, and Coordination on the DEIS ............ccsseeeeseeeeseeeeeeeee S-24 S:7/ ||| Public‘ Comments on'DEIS (rie ccccctererse-csesvsnetoscsceests S-24 S.8 Supplemental Discussion on Key Issues.. S-25 S.9 Mitigation Plan S-25 S.10 Agency Preferences and Decision to be Made... S-26 S.10.1 RUS Preferred Alternative .............. S-26 SHLODNWSHWSiPreferred Alternathve eer eerceserrcse reece eee eee S-26 S.10.3 USACE Least Damaging Practicable Alternative..............ccssseeesseeeseees S-26 S'10'4)| Decisionsitoibe) Made wien sess eeatasatesssessncsencgnsesusscuvsatstensncsssecsense teases S-26 Chapter 1 — Public; Comments and! Responses -:-.22-.-csssrecsscessensnessosnsasnseseesseseterseosesseneseeeeseses 1-1 1.1 Introduction 1-1 122))) (Public REView Process) :sccsccrseseocesesstsesscossesoreesesseosseecsecouseserseacanstestssencseceseccseececees 1-1 123)))| Comment Anal ysis) SUMIDALY cccreccascsesteesreccnccsssceessscsectsesersterescncarscossecescesesonseseecers 1-2 1.3.1 List of Key Topics and Issues .. 1-2 1e3'2)))) Responsesito written Comments) senescence scseseeesteseucacsusecereatacsasnsates 1-10 Southern Intertie Project Table of Contents Final EIS i July 2002 Table of Contents (continued) 1:33) Responses toi Verbal Comments iec7-cncsecsssasecssaceccnscsststsuasesscsosesoressorsersccesuss 1-13 Chapter.2 —'Supplemental Information <e-cn.-.coscrereseseenoseencesacecacasessevacsecesevavorececsestareestsasaroseees 2-1 Qe.) | MIMtOMUCtION ote esesteeeeecccrsuccseerossossocseswenrssesstesestasscssssesesseswasess a eo 22)|| Supplemental Information .:::1.1..:s.:.cssssesrsssscntencesssucnssscosssscecrstecesesecccesen eee 22:1 | (Project Costs and Benesitssrccccscsess-cseseesecessescccscssecoosnensenersese 2-1 2.2.2 Cost and Technical Comparison Discussion of Route Options 2-4 2.2.3. Underground Construction Costs.............0+ 2-11 2.2.4 Battery Energy Storage Systems.. 2-14 2.2.9 Updateon Beluga Whales:....:...:c:csssccssscssecsesesesesesesseseees 2-17 2.2.6 Update on Kenai Peninsula Brown Bears and Wolverines es) 28 2.2.7 Environmental Cost-Benefit Analysis Summary........... as) ||| 2-2 2.2.8 Avian Collision Mitigation.............scssssseseseeeees ess | |) 2-32 2:3 | (Updated Information iand Corrections .1t....ssc.-sse-ccssecscsetecsasesessecusscresesecerencencsecacsse 2-34 Appendices A USFWS Compatibility Determination B USACE Draft Section 404 (b)(1) Evaluation C Public Notices LIST OF TABLES S=1)) (ASGG Planning/and Operating Critenta-s..:..+-ssc-secessccecececssatuogessascossucaceescescreacesencesases=c S-3 S-2; || (Summary, Comparison of Alternatives <.2:502..:..-..ss.1.ssesescesesstussesccseeessestsstessececsreccseseoses S-17 S-3 Project Issues and Relative Degree Of Concerm..........s:csecssssssssessseseseneseneneseeeeneeneneeees S-25 1-1! |) Project Issnesjand. Relative Degree of Concertt ste -.n-s.a--r-s-sersssencnsecencetsncesecacseseeenseesase 1-3 1-2 Guide to Agencies, Organizations, and Individuals Who Provided Written (Comments On! DEIS facccreccssescccnseenstseccontacstesserensusecsoecusonsescensssssscusanascetscesessase 1-10 1-3 Guide to Agencies, Organizations, and Individuals Who Provided Werball Comments/Onj|DEIS iicccrssssccessccssecersstensestanscrersccecssasatausnsctsatiesstecstsecaceeseseusceenca 1-13 2>1,)|\ Summary of Costs;and (Gost/Benefit Ratios 2c.c.ssr.<ssccacscssa-nssecseacacersccncatescasnasuseessesnsaea 2-2 2-2 Summary of Life Cycle Costs by Route Option...............cceseeseeees 2-3 2-3 Tesoro Route Alternatives Pt. Possession to Pt. Woronzof Substation.. 2-5 2-4 Tesoro Alternative Comparison of Cost/Technical Factors .............+++ 2-8 2-5 Enstar Route Alternatives Soldotna North and South Route Options 2-9 2-6 Enstar Route Alternatives South Shore Turnagain Arm to International Substation... 2-10 2-7 Comparison of Overhead Versus Underground Through KNWR .........:c:cscesessessseeees 2-13 Southern Intertie Project ub Table of Contents Final EIS i July 2002 LIST OF FIGURES S-1) | }Altematives Studied in) Detail i cicscccscctsreseccsssesvscrssesecssenessesoness curecaressocectecarsscsesossnesss S-5 VOLUME II MITIGATION PLAN 1:0) | INtPOMUCHON (|... -tcscsensersoceosossessnsossasssstasenssntersvssurecssatesvetostsseshsetoeassscesscssssacsssatenssest® 1 210) || Mitigation \ Pam’ sist tsge sess iatc sete eee EER Sr debater toe 1 2.1 Standard Practice Project Mitigation.. 2 2.2 Selective Mitigation Measures.... as 2 2.3. Design and Construction Mitigation ................ A 10 2.3.1 Proposed Structure Types and Existing Utilities. Ess 10 2:3:2) Constiiction! Season! fit cssosecsecsersevoesenccsustensesscsresessesensacronssracssvresasssonses 10 2.3:3) Construction: Methods|and ACCESS 1..1c.c.sessecsecsasssssesussoseosscosneseesssonoressasesors 10 2.4 Selective Mitigation Measure Locations... Bt 11 D1) Selective Mitigation Data noccrcccscessecssceceessessscesnsosecsoccocsorensessasecsceacesarensasss ll 2-DP UMpacti Vit PAtOM SUINMALY re tscsctacccsesscesessrscetercceacsenscescsenternescersrseeeuesnsersersorace ll Southern Intertie Project ah Table of Contents Final EIS 11 July 2002 AC ADF&G AML&P ANCSA ANILCA ASCC B/C BEA CBA CEA CEQ CVM CWG DC DEIS DNR DSM EIS EMF EPA FAA FEIS GVEA HEA HVAC IPG ISER KPB kV ACRONYMS alternating current Alaska Department of Fish and Game Anchorage Municipal Light and Power Alaska Native Claims Settlement Act Alaska National Interest Land Conservation Act Alaska Systems Coordinating Council benefit/cost Bureau of Economic Analysis cost-benefit analysis Chugach Electric Association Council on Environmental Quality contingent valuation method Community Working Group direct current Draft Environmental Impact Statement Department of Natural Resources Demand-Side Management environmental impact statement electric and magnetic fields Environmental Protection Agency Federal Aviation Administration Final EIS Golden Valley Electric Association Homer Electric Association high voltage alternating current Intertie Participants Group Institute of Social and Economic Research Kenai National Wildlife Refuge Kenai Peninsula Borough kilovolt Southern Intertie Project Final EIS iv Table of Contents July 2002 MEA NEPA NERC NMFS Project RUS SRA USACE USFWS Matanuska Electric Association megawatt National Environmental Policy Act North American Electric Reliability Council National Marine Fisheries Service Southern Intertie Transmission Line Project Rural Utilities Service State Recreation Area U.S. Army Corps of Engineers U.S. Fish and Wildlife Service Southern Intertie Project Final EIS Table of Contents July 2002 GENERAL COMMENT TRACKING INDEX The Southern Intertie Project FEIS provides responses to comments received on the DEIS. To assist reviewers, the following General Comment Tracking Index provides references to where responses may be found in the DEIS and FEIS to the general topics of comments that have been received from agencies, special interest groups and individual members of the public. The index includes a Summary of Comments Received, and the DEIS and FEIS Response Index, which have been organized by the 14 issue topics that were identified in the DEIS. Specific responses to each of the comments received are provided in Chapter 1. GENERAL COMMENT TRACKING INDEX Issue Summary of Comments Received DEIS and FEIS Response Index The underlying need for the Project has been questioned in several m= FEIS, Section 1.3.1, Issue 1, pgs. 1-3 and 1-4 comments as summarized below: = DEIS, Section 1.3, Purpose and Need for the Project, pgs. 1-13 to 1-29 = = The no-action alternative should be selected because the m= DEIS, Section 2.3.1, No Action Alternative, pages 2-29 purpose and need had not been firmly established. and 2-30 == There are other alternatives to a new transmission line that m= FEIS, Section 1.3.1, Issue 14, pgs. 1-8 and 1-9 would meet the purpose and need with less environmental = DEIS, Section 2.2, Alternatives Studied and Eliminated Purpose impact. from Detailed Study, pgs. 2-1 to 2-25 and Need for the = ~The Project cost-benefit analysis should include long-term mu FEIS, Section 1.3.1, Issue 13, pg. 1-8 Project environmental costs associated with impacts to wildlife, = FEIS, Section 2.2.7, Environmental Cost-Benefit recreation, and other resource values on the KNWR. Analysis Summary, pgs. 2-21 to 2-32 m= ~The cost-benefit ratio is obscured by the inclusion of the state = FEIS, Section 2.2.1, Project Costs and Benefits, pgs. 2- grant. 1 to 2-4 = DEIS, Section 1.4.1, Construction and Life Cycle Costs, Table 1-12, pg. 1-31 = DEIS, Section 1.2, Project Background, pg 1-1 to 1-13 Comments were received on how the proposed and alternative routes a FEIS, Section 1.3.1, Issue 2, pg. 1-4 Urban and could potentially conflict with existing or future land uses. = DEIS, Section 3.6.3, Land Use and Recreation, Zz Rural Alternatives, Affected Environment and Environmental Land Use Consequences, pgs. 3-135 to 3-148 = FEIS, Volume II, Mitigation Plan Southern Intertie Project FEIS vi General Comment Tracking Index July 2002 GENERAL COMMENT TRACKING INDEX Issue Summary of Comments Received DEIS and FEIS Response Index = FEIS, Section 1.3.1, Issue 3, pg. 1-4 Because many areas near the proposed project are accessible only by = DEIS, Section 3.6.2, Land Use — Aviation, pgs. 3-132 to ‘Aviation aircraft, the concern was expressed that an overhead transmission line 3-134 3 would prohibit landing of private aircraft in remote areas. = See Section 3.6.3, Land Use, Affected Environment and Safety Envi - 4 nvironmental Consequences of Alternatives, pgs. 3- 135 to 3-148 = FEIS, Volume II, Mitigation Plan Concern was expressed that the Project would impact recreation and tourism on the Kenai Peninsula either by changing the visual quality of = FEIS, Section 1.3.1, Issue 4, pg. 1-5 Recreation an area and therefore preventing people from wanting to visit, or by = DEIS, Section 3.7.1, Long Term Tourism and 4 and increasing access to an area, which could either result in difficulty Recreation Impacts, pgs. 3-184 to 3-185 Tourism managing the area or closing access entirely to prevent too much human contact with sensitive species. The majority of the comments received expressed concern that the proposed project would conflict with existing management plans (in association with Issues 8 — Biology, and 14 — Alternatives), on the KNWR. = FEIS, Section 1.3.1, Issue 5, pg. 1-5 5 Manage- = Concerned that the proposed Enstar Route would conflict with = DEIS, Section 3.6.3, Land Use, Alternatives, Enstar to ment Plans the mandate to protect wildlife within the KNWR Chickaloon Bay, pgs. 3-142 to 3-145 = FEIS, Appendix A, USFWS Compatibility = = The presence of a transmission line would impact wildlife by Determination (June 2002) increasing access and preventing prescribed burning, which is = DEIS Section 3.8 Subsistence, pg. 3-205 critical for moose habitat, and will effect subsistence hunting. = = The presence of a new transmission line in the KNWR would prohibit future designation as a wilderness area. Southern Intertie Project FEIS Vii General Comment Tracking Index July 2002 GENERAL COMMENT TRACKING INDEX Issue Summary of Comments Received DEIS and FEIS Response Index There are numerous streams and rivers in the Project study area, which = FEIS Section 1.3.1, Issue 6, Pg. 1-5 provide food sources for many species such as the brown bear. m= DEIS Section 3.3.2, Water Resources, pg. 3-12 to 3-14; and Section 3.3.3, Alternatives, pg. 3-14 to 3-23 Watershed = Concern that construction activities could damage water (including Table 3-2, Impacts and Mitigation Common Manage- quality or cause soil erosion, which could in turn impact to Most Alternative Routes, pg. 3-15). 6 ment and feeding activities or fish spawning. = DEIS_ Section 3.5.5, Freshwater Environment, Soil Environmental Consequences and Mitigation, Erosion Anadromous Fish (pg. 3-100). = FEIS, Volume II, Mitigation Measures including specific locations of the anadromous streams crossed by the Project alternatives Several comments were received on visual resources. = Specifically on how the Project would effect views in a FEIS, Section 1.3.1, Issues 7, pg. 1-6 7 Visual recreational areas, and s DEIS, Section 3.9.2, Visual, Alternatives, pgs. 3-236 to Resources m= Views from residences. 3-263 m= Vegetation clearing and the presence of the transmission = FEIS, Volume II, Mitigation Plan structures. The combination of comments related to Issues 8 — Biology, 5 — a FEIS, Section 1.3.1, Issue 8, pg. 1-6 Management Plans, and 14 — Alternatives, constitute the most frequently mentioned topics, primarily related to impacts to the KNWR = DEIS, Section 3.5, Biological Resources, Affected and alternatives. Environment and Environmental Consequences, pgs. 3- 35 to 3-119 8 Biology = =©Most of the comments focused on potential impacts on the KNWR resulting from the Enstar Route. These impacts could m= FEIS, Chapter 2, Section 2.2.5, Update on Beluga result from increased access and associated increase in hunting Whales, pgs. 2-17 to 2-18 or bear/human contact, and restrictions in prescribed burns that would impact habitat. = FEIS, Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines, pgs. 2-18 to 2-20 Southern Intertie Project FEIS Vii General Comment Tracking Index July 2002 GENERAL COMMENT TRACKING INDEX Issue Summary of Comments Received DEIS and FEIS Response Index = Comments primarily focused on brown bears, moose, beluga m= FEIS, Section 2.2.8, Avian Collision Mitigation, Pg. 2- whales, and wetland habitats, although other sensitive animal 32 to 2-34 species (such as birds and waterfowl) or habitats also were mentioned. um FEIS, Appendix A, USFWS Compatibility Determination = Comments on potential conflicts with beluga whales, especially during calving season, focused on the submarine = FEIS, Appendix B, USACE Draft Section 404(b)(1) cable installation in Cook Inlet. Evaluation = FEIS, Volume II, Mitigation Plan = FEIS, Section 1.3.1, Issue 9, pg. 1-7 = DEIS Section 3.6.3, Alternatives, Bernice Lake to Pt. Possession — Route Option A (pg. 3-135). 9 Cultural Comments on the DEIS regarding cultural resources were limited to = DEIS, Volume II, Appendix B, “Access to Area” Table Resources concerns regarding impacts to the Pt. Possession Village and native (pg. B-29) lands. a FEIS, Volume II, Mitigation Comments were received regarding concern that the additional right-of- = FEIS, Section 1.3.1, Issue 10, pg. 1 - 7 Right-of- way needed for the Project would impact property owned by an = DEIS, Section 3.6.3, Land Use and Recreation, 10 | Way individual or agency. Alternatives, pg. 3-135 to 3-148 Limitations m= DEIS Section 2.5.2, Right-of-Way Acquisition Process (pg. 2-51) a FEIS, Volume II, Mitigation Plan One comment was received on potential health impacts (i.e., EMF) = FEIS, Section 1.3.1, Issue 11, pg. 1-7 from the proposed project. ul cae ane = DEIS, Section 3.11, Electric and Magnetic Fields and y Noise, pg. 3-272 to 3-279 Southern Intertie Project FEIS Fi General Comment Tracking Index 1X July 2002 GENERAL COMMENT TRACKING INDEX Issue Summary of Comments Received DEIS and FEIS Response Index Avalanche Although this was an issue of great concern during the public scoping 12 for this Project, no comments were received on this issue during review No additional information provided in FEIS Hazards of the DEIS. = Several comments requested that a cost-benefit analysis that FEIS, Section 1.3.1, Issue 13, pg. 1-8 weighs the benefits of the Project with the cost of affected wildlife and habitat be completed for the proposed project. FEIS, Section 2.2.7, Environmental Cost-Benefit Analysis Summary, pgs. 2-21 to 2-32 1B Socio- = Other comments questioned the accuracy of statements that economics consumers would experience rate savings as a result of the DEIS Section 3.7.2, Socioeconomic Consequences of Project. the Proposed Action, Facility Impacts on Property Values (pg. 3-176) = Comments were also received on potential impacts to property values. The majority of comments received, almost 23 percent, focused on alternatives to the proposed project. These comments focused on the following topics: FEIS, Section 1.3.1, Issue 14, Pg. 1-8 to 1-9 = Several comments were related to Transmission alternatives to FEIS, Section 1.3.1, Issue 1, Pgs. 1-3 and 1-4 Alter- the Enstar Route (Tesoro and Quartz Creek routes), ; natives to ; _ / FEIS, Section S.10, Agency Preferences and Decisions 14 the = Others commented on alternatives to a transmission option, to be Made Brnposed Some individuals believe th ission line i dled FEIS, Appendix A, USFWS Compatibili Piaject = Some individuals believe that a transmission line is not neede » Appendix A, ‘compatibility at all, Determination = Finally, others suggested that options such as fuel cells should FEIS, Appendix B, Draft Section 404(b)(1) Evaluation be analyzed more thoroughly. DEIS, Section 2.2, Alternatives Studied and Eliminated from Detailed Study, pg. 2-1 through 2-25 Southern Intertie Project FEIS General Comment Tracking Index July 2002 SUMMARY S.1 INTRODUCTION The Intertie Participants Group (IPG), also referred to as the Applicant, is proposing to construct an electrical transmission line (the Enstar Route) between the Kenai Peninsula and Anchorage along the Enstar pipeline through the Kenai National Wildlife Refuge (KNWR) in south-central Alaska. This 138 kilovolt (kV) transmission line, known as the Southern Intertie Project (Project), is proposed as a system improvement project to increase the overall Railbelt electrical system reliability and transfer of energy capabilities between the Kenai Peninsula and Anchorage. Members of the IPG include Golden Valley Electric Association (GVEA), Matanuska Electric Association (MEA), Chugach Electric Association (CEA), Anchorage Municipal Light and Power (AML&P), Homer Electric Association (HEA), and the City of Seward. The Project is located within the Railbelt electrical system, a power grid that electrically connects central and south-central Alaska from Homer to Fairbanks. The system allows the six participating utility companies, also referred to as the Railbelt Utilities, to sell and buy power to and from each other, taking advantage of lower costs in other areas, and to provide back-up power to each other. The IPG was formed by the Railbelt Utilities to improve electrical reliability and coordination within the Railbelt by working together to improve the interconnected system through intertie improvements and cooperative energy projects. The Southern Intertie Project is one of these cooperative projects. This Southern Intertie Project Final Environmental Impact Statement (FEIS) has been prepared in response to public and agency comments on the Draft EIS (DEIS). This FEIS is in compliance with the National Environmental Policy Act of 1969 (NEPA), as amended (42 U.S.C. 4321- 4346) and the Council on Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of NEPA (40 CFR Parts 1500 through 1508). The Rural Utilities Service (RUS), an agency of the U.S. Department of Agriculture, is the lead federal agency for this FEIS because GVEA, an IPG member, plans to apply to RUS for financial assistance for its share of the proposed project. This FEIS is also required because the Applicant has filed for a right-of- way across federal lands on the KNWR, a Conservation System Unit designated under the Alaska National Interest Land Conservation Act (ANILCA). Rights-of-way across Conservation System Units for transportation and utility systems are governed by regulations (43 CFR Part 36) implementing Title XI of ANILCA. The U.S. Fish and Wildlife Service (USFWS) of the Department of the Interior and the U.S. Army Corps of Engineers (USACE) are cooperating agencies in the NEPA process. This FEIS summary presents information on the purpose and need for the Project, alternatives studied in detail including the Applicant’s proposal, alternatives eliminated from detailed study, the affected environment and environmental consequences of the Project, public scoping and consultation, public comments on the DEIS, supplemental discussion of key project issues, mitigation plan, and agencies’ preferences and decisions to be made. Southern Intertie Project S-1 Summary Final EIS July 2002 S.2. PURPOSE AND NEED 8.2.1 Project Need This Project is needed because the existing Railbelt electrical system is deficient south of Anchorage. The 115kV Quartz Creek transmission line currently provides the sole path for coordinating the operation of generation on the Kenai Peninsula with Anchorage area generation. The line also is used to provide back-up power in the case of outages in the Anchorage area or on the Kenai Peninsula. The Quartz Creek transmission line is limited in electrical transfer capability (70 megawatts [MW)]), and its ability to provide reliable back-up power during system outages is effected by outages from ice, wind, and snow loading. The line is also routed across active avalanche areas. To allow full use of the Kenai Peninsula generation, the intertie secure transfer capacity needs to be increased to 125 MW. The Project would provide the increased transmission capacity to make these higher transfers possible. The Project would also create a transmission loop that increases reliability and provides a second path for power to flow during an outage of the Quartz Creek transmission line. In addition, the limitation of 70 MW of power transfer capability along the existing Quartz Creek transmission line reduces the ability to fully utilize the 120 MW generating capacity of the Bradley Lake Hydroelectric Project, owned by the State of Alaska. At the time the Power Sales Agreement for the Bradley Lake energy was signed, it was recognized that additional transmission line (interties) would be needed between the Kenai Peninsula and Fairbanks for system reinforcement and the capability to transfer the Bradley Lake hydro power throughout the Railbelt system. The 1992 Kenai Peninsula Borough Comprehensive Plan acknowledged that to fully utilize the Bradley Lake Project, additional transmission line upgrades are needed to carry power to Anchorage and Fairbanks. 8.2.2 Project Objectives The systems and economic studies that were conducted on the Railbelt system identified several objectives that, if met, would correct the deficiencies and make the system run more economically and effectively. Specifically, the proposed Project would provide a second path for power to flow between the Kenai Peninsula and Anchorage and is needed to accomplish the following objectives: = increase the reliability of the interconnected Railbelt electrical system from the Kenai Peninsula to Fairbanks, and reduce the requirement for load shedding during system disturbances = increase the power transfer capacity between the Kenai Peninsula and Anchorage area = provide the capability to utilize the most economic generation mix available to reduce costs to consumers and allow generation capacity in one area to support the load in the other area Southern Intertie Project $-2 Summary Final EIS ~ July 2002 m reduce area requirements for spinning reserve generation, thereby reducing operating costs and increasing the life-span of generation plants = improve Railbelt electrical system stability = reduce transmission line losses for power transfers and reduce maintenance costs = provide adequate access to power entitlements from the Bradley Lake Hydroelectric Project for the utilities north of the Kenai Peninsula, and allow Bradley Lake generation to be more fully utilized The Alaska Systems Coordinating Council (ASCC), an association of Alaska’s electric power utilities, reviews the Alaska interconnected system on a continuing basis to promote reliable system operation through coordinated planning and operation of the system. In 1991, based on discussions with the North American Electric Reliability Council (NERC), ASCC adopted 12 coordinated interconnection planning and operating criteria (Table S-1), adapted specifically to Alaska from NERC’s industry-standard planning guides for bulk electric system planning. The Southern Intertie Project objectives would help the IPG meet 8 of the 12 ASCC criteria (numbers 1-6, 8 and 9 in Table S-1). TABLE S-1 ASCC PLANNING AND OPERATING CRITERIA 1. Balance Among System Elements - A balanced relationship shall be maintained among bulk electric system elements to avoid excessive dependence on any one element. 2. Contingencies - Additions to the interconnected system shall be planned and designed to allow the interconnected system to withstand any credible contingency situation without excessive impact on the system voltages, frequency, load, power flows, equipment thermal loading, or stability. 3 Emergency Support - Reserves shall be provided such that emergency support from adjacent systems is restricted to acceptable limits as determined by studies of the interconnected system. 4. Support From Adjacent Systems - Adequate transmission ties between adjacent systems shall be provided to accommodate planned and emergency power transfers. 5. Reactive Power Resources - Each control area shall provide sufficient capacitive and inductive resources at proper levels to maintain system steady state and dynamic voltages within established limits, including support for reasonable levels of planned and emergency power transfers. 6. Real and Reactive Power Margins - Margins in both real and reactive power resources are provided for acceptable dynamic response to system disturbances. & Recording System Parameters - Essential system parameters shall be recorded. 8. Reliability During Maintenance - System design shall allow for equipment maintenance without unduly degrading. 9. Switching Flexibility - Switching arrangements shall be provided to limit adverse effects and permit reconfiguration of the bulk power transmission system to facilitate system restoration reliability. 10. Protective Relaying - Provide sufficient relaying equipment such that the severity and extent of the system disturbances are minimized and malfunctions in the protective relay system do not jeopardize system reliability. a. Black Start-up - Black start-up capability is to be provided for individual systems. 12. Fuel Supply - Plans for generation additions shall consider fuel supply diversity. Southern Intertie Project s-3 Summary Final EIS July 2002 The benefits from construction and operation of the Project have been studied and evaluated in detail. Because the interconnected system operates in an integrated manner, benefits from the Project have been evaluated by reviewing the effect of the Project on the overall system. The benefits of the Project would include: capacity sharing economic energy transfer reliability spinning reserve sharing reduced line maintenance costs avoiding minimum combustion turbine generation on the Kenai Peninsula avoiding loading the line during bad weather or construction The value of the benefits from the Project can also be viewed as cost savings. If the Project is not constructed, the unrealized benefits would continue to be part of the overall cost of producing electricity, and those costs would be reflected in the rates for electricity paid by consumers. S.3. ALTERNATIVES STUDIED IN DETAIL INCLUDING THE APPLICANT’S PROPOSAL The following discussion provides a brief summary of the no-action alternative, the Applicant’s proposed Enstar Route, alternative Tesoro Route locations, associated project facilities, and construction seasons. 8.3.1 No-Action Alternative Implementation of the no-action alternative would mean that the Project would not be constructed and the Quartz Creek transmission line between the Soldotna Substation on the Kenai Peninsula and the University Substation in Anchorage would continue to be utilized as the only electrical connection between Anchorage and the Peninsula region (Figure S-1, see inset). There would be no improvements to the system to address the current electrical system deficiencies associated with this line. Overall, the Railbelt electrical system reliability and transfer of energy capabilities between the Kenai Peninsula and Anchorage would not be increased. Additionally, the cost savings that would accrue from construction of the Project would continue to be part of the overall cost of producing electricity, and those continuing costs would be reflected in the rates for electricity paid by consumers. Southern Intertie Project S-4 Summary Final EIS July 2002 TION. TaN Ten TaN uartz Creek Transmission Line ‘Anchorage A fe i Ne, YY ° DS | N reg Girdwood | i Mh Hope | yj Kenai National ut Wildlife Refuge | | Chugach & \ National ~ \ Nikisk Forest a Keani Sterli 4A me Faising aaa a Saree Cooper Ce Transimssxvn 4 Crogy {Lancing Lame ne ar : Aue ~JBemice Lake Substation Proposed * | Siting Area om ‘Transition Facility . Naptown Substation » te (~ Substation ALTERNATIVES STUDIED IN DETAIL SOUTHERN INTERTIE PROJECT FIGURE S-1 NPL Legend ===" Applicant’s Proposed Route === Enstar Route Options 3]| @"" Tesoro Route Options Chugach State Park Kenai National Wildlife Refuge (999) Chugach National Forest Private, Borough, or State Selected Lands Note: No-action alternative is shown ;| in inset in upper left-hand corner of map. ___ Scale in Miles _ Now Base Map Sources: Municipality of Anchorage (1994). Chu; National Forest (1995). Kenai Peninsula Borough (1994). USGS 1:63,360 and 1:25,000 Quads. Contour Interval: 200 Feet Contour Labeling in Feet Nei ov S.3.2 Applicant’s Proposal — Enstar Route The Applicant’s proposal is to construct a 138kV transmission line and associated facilities between the Soldotna Substation on the Kenai Peninsula and International Substation in Anchorage. The Applicant’s proposed route is the Enstar Route including Route Options E South, F, H, and K (see Figure S-1). This route begins with an overhead transmission line at the existing substation in Soldotna and replaces an existing 69kV line, running south and then east to the Enstar pipeline (Option E South). At this point the route parallels the Enstar pipeline north through the KNWR for approximately 38.3 miles along Route Option F to Burnt Island on the east side of Chickaloon Bay. An ANILCA application for the crossing of KNWR is on file with the USFWS and USACE. Submarine cables would be used to cross the Turnagain Arm to Oceanview Park on the southern end of Anchorage and from the landing point, underground cable would parallel the Alaska Railroad north to.120 Avenue (Route Option H). From there, an overhead line would continue to parallel the Alaska Railroad to the existing International Substation (Route Option K). The overall length of the proposed Enstar Route is 73.4 miles. A local Enstar Route alternative is shown on Figure S-1, in the Soldotna area (E North), that travels north and east from the Soldotna Substation. In addition, there are two alternative routing options across Turnagain Arm and in the Anchorage area (Route Options I, M, and G, J), as shown in Figure S-1. 8.3.3 Tesoro Route Alternative The Tesoro Route alternative is located between the Bernice Lake Substation on the Kenai Peninsula and the Pt. Woronzof Substation in Anchorage. The Tesoro Route includes Route Option A — Bernice Lake to Pt. Possession, in combination with any of three options that cross the Turnagain Arm and terminate at the Pt. Woronzof Substation (see Figure S-1). This route begins as an overhead transmission line at the existing Bernice Lake Substation near Nikiski (Route Option A), and parallels the North Kenai Road to the southern end of Captain Cook State Recreation Area (SRA). Underground cable would parallel the North Kenai Road through the Captain Cook SRA and would also occur where the route is adjacent to two local airstrips along the North Kenai Spur Road. The line would transition back to overhead beyond the northern end of the Captain Cook SRA and would be located in a transportation/utility corridor designated by the Kenai Peninsula Borough (KPB), including segments that parallel the Tesoro pipeline to Pt. Possession. In this area, the Tesoro Route would cross two areas of Native conveyed lands. One near Grey Cliff Lake (less than 1 mile) and one at Pt. Possession (approximately 1 mile). Section 22(g) of the Alaska Native Claims Settlement Act (ANCSA) permitting and regulatory requirements would apply to these lands. At Pt. Possession, three options (B, C and D) are available to cross the Turnagain Arm and terminate at the Pt. Woronzof Substation. Route Option D would cross the Turnagain Arm from Pt. Possession to Pt. Campbell using submarine cables. From the Pt. Campbell landing, underground cable would continue to parallel the Tesoro pipeline through Kincaid Park and Southern Intertie Project S-6 Summary Final EIS il July 2002 terminate at the Pt. Woronzof Substation (Route Option N). The total length of the Tesoro Alternative Route using this option is 62.0 miles (see Figure S-1). Route Option B crosses Turnagain Arm via Fire Island to the Pt. Woronzof Substation. The total length of the Tesoro Alternative Route using this option is 63.2 miles. Using Route Option C, which crosses the Turnagain Arm directly from Pt. Possession to a landing at the Pt. Woronzof Substation, the total length of the Tesoro alternative is 61.3 miles (see Figure S-1). S.3.4 Project Facilities The following five separate types of facilities and associated construction techniques are required for the Project: i Overhead Transmission Lines - Overhead transmission lines with the conductors supported on steel or wood structures are proposed for portions of the Anchorage area and the Kenai Lowlands. Underground Lines - Underground lines are high-voltage transmission line cables buried below ground surface in a duct bank. Underground lines are proposed for selected locations in the Anchorage area and in the Kenai Lowlands. Submarine Cable - Submarine cable is specially constructed to operate in a marine environment and is more rugged than the cables used on land. Submarine cable is proposed for crossing the Turnagain Arm. Transition Stations - A transition station is equipped to change a transmission line from one type to another. Transitions from overhead lines to underground or submarine cable, or from underground cable to submarine cable, would be required for the Project. Terminal facilities for the submarine cables are included in the transition stations. Transition stations would be required near the landfalls for the submarine cable, and at selected locations in the Kenai Lowlands and Anchorage area. Substations and Reactive Compensation - Substations are located at the ends of transmission lines and at generation plants, and are the points at which the electrical system is joined together to form a network. Reactive compensation involves installation of specialized equipment in a substation to provide voltage support for the system or to increase power flow across a transmission line segment. Modifications to existing substations would be required either at International or Pt. Woronzof substations in the Anchorage area, and at either Bernice Lake or Soldotna substations on the Kenai Peninsula. For the Enstar Route, a new substation would be required near Naptowne. Modifications would also be required at the Dave’s Creek Substation for either option. Southern Intertie Project Summary Final EIS S-7 July 2002 8.3.5 Construction Seasons It is intended that the majority of the construction activities would take place during the summer season (April to October). The exception to this is for the overhead transmission lines along the Tesoro Route north of the Captain Cook SRA, Enstar Route within the KNWR, and selected portions of the Soldotna E South Route option along the Kenai River Lowlands. In these areas, winter construction is proposed to minimize environmental impacts. S.4. ALTERNATIVES ELIMINATED FROM DETAILED STUDY Other alternatives considered were established through a comprehensive review of previous Project documentation and emerging energy systems. Through a comprehensive screening process, each alternative was assessed for its ability to meet the stated purpose and need, and as a result, some alternatives were eliminated from further consideration. Alternatives that initially were considered but eliminated are listed below and specifically described: = Alternatives to a new transmission line eliminated - battery energy storage systems - demand-side management and energy conservation - conventional new generation - wind generation - fuel cells - increasing spinning reserves = Alternative transmission systems eliminated - upgrade of the existing Quartz Creek transmission line - alternate voltage levels - underground transmission lines = Alternative transmission routes eliminated - Quartz Creek transmission route parallel - Sixmile Creek to Anchorage (Submarine) Route - Tesoro Route local options - Enstar Route local options 8.4.1 Alternatives to a New Transmission Line Eliminated Battery Energy Storage Systems - A Battery Energy Storage System (BESS) consists of a very large bank of electric batteries and automatically controlled electronic equipment to convert the electric energy stored in the batteries from direct current (DC) to alternating current (AC) that can be supplied to the electrical transmission system. A BESS is designed to supply electricity to the system during an interruption for only 20 to 30 minutes. Due to its limited storage capacity Southern Intertie Project S-8 Summary Final EIS July 2002 the BESS would only partially meet the purpose and need for the Project. See Chapter 2, Section 2.2.4 (pages 2-14 to 2-17) for further discussion on the BESS. Conventional Demand-Side Management and Energy Conservation - Demand-side management (DSM) consists of electric utilities planning, implementing, and monitoring activities designed to encourage consumers to modify their levels and patterns of electricity consumption. These DSM programs focus on managing a very small part of the load on the system, whereas the Project need is for improvements to the entire interconnected system. Therefore, DSM programs do not address the purpose and need for the Project and were not considered further as an alternative to the Applicant’s proposal. Conventional New Generation - Adding generation capacity on the Kenai Peninsula and/or in Anchorage was considered as an alternative to constructing a second line from the Kenai Peninsula to Anchorage. Adding the generation capacity would increase the generation resources available to serve load on the system; however, the overall system currently has an excess of generating capacity over electrical load. What is needed is an enhanced ability to use the existing generation resources in the most economical matter. This alternative, therefore, does not meet the Project purpose and need and was not carried forward for further consideration. Wind Generation - Harnessing the wind to provide electric generation resources has been successful in California and in other parts of the world. As noted earlier, additional generation is not needed and this alternative would not meet the Project purpose and need. Fuel Cells - Fuel cells are power-generating systems that produce electricity by combining hydrogen and oxygen in an electrochemical reaction. Additional generation is not needed and is not considered a viable alternative to the Project. Increasing Spinning Reserves - Spinning reserve is a portion of the operating reserves maintained by utilities. Spinning reserve is unloaded generation, which is synchronized and ready to serve additional demand (NERC 1996). One of the reasons the Project is being proposed as a system improvement is to reduce spinning reserve requirements. Consequently, increasing the amount of spinning reserves on the system was eliminated as an alternative. 8.4.2 Alternative Transmission Systems Eliminated Upgrade of the Existing Quartz Creek Transmission Line - One alternative that initially was considered was the upgrade of the existing Quartz Creek transmission line instead of constructing a second transmission line, to increase the power transfer capacity between the Kenai Peninsula and Anchorage. The high cost of reconstructing all of the intermediate substations along the line, minimal change in performance, and reliability and stability issues resulted in elimination of this option. Alternate Voltage Levels - Voltages of both 138kV and 230kV were studied for the second transmission line interconnection between the Kenai Peninsula and Anchorage. The 230kV Southern Intertie Project Final EIS Summary S-9 July 2002 alternative would require larger and more expensive equipment than the 138kV alternative without corresponding benefits and was eliminated; 138kV is proposed for the Project. Underground Transmission Lines - Underground transmission has been proposed only where required by regulations and/or to avoid hazards that would be associated with an overhead line. The cost of underground transmission typically is four to five times the cost of an overhead line, and the operational problems and outage durations are greater. When an outage to an underground line occurs, determining the cause and location of the damage, the replacement parts needed to repair the line, and actually repairing the line takes more time than for an overhead line. Repairs to an underground line are more expensive as well. While industry data indicate that the outage rate for underground transmission lines is lower than for overhead lines, this is offset by the longer duration outages and high installation and repair costs for the underground facility as compared to overhead lines. Therefore, overhead lines are preferred to underground lines. See FEIS Chapter 2, Section 2.2.3 (pages 2-11 to 2-14) for more information. 8.4.3 Alternative Transmission Routes Eliminated Quartz Creek Transmission Route Parallel - One alternative for the Project would be to parallel the existing 140-mile-long Quartz Creek transmission line corridor between Soldotna and Anchorage. The general types of issues associated with this alternative are summarized below: = conflicts with the Chugach National Forest and Chugach State Park; views from Seward Highway (National Scenic Byway), Cooper Landing, and several other environmentally sensitive areas m= avalanche hazards and problems due to ice, wind, and snow along the route have caused numerous outages to the existing Quartz Creek transmission line = opportunity to utilize an existing transmission line corridor = relative differences between the risks to the Quartz Creek transmission line due to the presence of avalanches, in comparison to the potential failures to the Tesoro Route due to adverse submarine conditions near Pt. Possession As a result of these concerns and the ensuing studies, the Quartz Creek Route was eliminated from further consideration for the following reason: = It would not meet the purpose and need for the Project because it would be exposed to the same avalanche, ice, snow, and wind conditions as the existing line, and system reliability and energy transfer capability would remain limited. Sixmile Creek to Anchorage (Submarine) Route - This alternative was presented as an option to utilize a portion of the existing Quartz Creek transmission line corridor, reduce avalanche Southern Intertie Project S-10 Summary Final EIS ai July 2002 exposure, and avoid Chugach State Park by locating the line in the Turnagain Arm from Sixmile Creek to Anchorage. This alternative would still be approximately 115 miles long (longer than either the Tesoro Route at 73.4 miles or the Enstar Route at 62.0 miles), which would increase costs of the Project substantially; therefore, it was eliminated from further consideration. Tesoro Route Local Options - The following local options were considered and have been eliminated, as listed below: = bury transmission line from Bernice Lake Substation to Moose Point = several alternatives were identified to avoid the Captain Cook SRA and Pt. Possession; they would result in significant impacts that could be mitigated by utilizing options that follow Kenai Road, and are located in a transportation/utility corridor designated by the KPB, including segments that parallel the Tesoro pipeline = Moose Point to Fire Island via submarine cable = use of a causeway that would connect Pt. Possession to Anchorage Enstar Route Local Options - The following local options were considered and have been eliminated, as listed below: = Enstar underground option - Bury the line through the KNWR = Alternatives from Pt. Possession to Anchorage via Enstar pipeline - Cross KNWR and/or Chickaloon Bay to Enstar pipeline at Burnt Island = South Anchorage route options eliminated - New and Old Seward highways from Potter Marsh to Rabbit Creek Interchange - Alaska Railroad/Ocean View Bluff S55 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES The character of the existing environment in the Project area and potential environmental consequences, or impacts, that could result from the proposed Project are summarized below and followed by an overview of an alternative route comparison and the environmentally preferred alternative route. Climate - The climate of south-central Alaska is transitional between maritime and continental. Heavy precipitation, cool summers, and mild winters characterize the maritime regions of the coast. The Cook Inlet basin experiences short periods of extreme cold in winter and high winds throughout the year. No impacts to climate are expected as a result of this Project. Southern Intertie Project Summary Final EIS S-11 July 2002 Air Quality - The majority of the study area is classified as an air quality attainment area with the exception of urban Anchorage (non-attainment for carbon monoxide) and the Eagle River area of Anchorage (non-attainment for particulate matter nominally 10 microns or less). Air quality impacts associated with the proposed project would be minimal and of a short-term nature, and would result from construction-related causes such as an increase in air emissions from construction equipment and motor vehicles. Earth Resources - The study area includes portions of two physiographic provinces within the southern mountainous belt of Alaska: Cook Inlet-Susitna Lowlands and Kenai-Chugach Mountains. Due to the active seismicity in the region, soils and surficial deposits in the study area are subject to several types of ground failure associated with earthquakes in addition to the more expected hazards of slope instability, erosion, settlement, permafrost, and frost heave. The study area contains a variety of nonmetallic mineral resources, including sand and gravel, clay, and coal. Impacts to soils will be minimal after standard mitigation measures are applied. These measures include preferential use of existing access roads, winter work when the ground is frozen, and use of tracked and low ground pressure vehicles or other special equipment. Additionally, to minimize surface disturbances, directional drilling techniques are proposed for the bluff areas where the submarine cable would make landfall. Water Resources - The Kenai River is the only glacier-fed river in the study area and has distinctive runoff characteristics. Nonglacial streams in the Kenai Lowlands and Anchorage Bowl originate from lowland lakes and tributaries of the western portion of the Kenai Lowlands and Chugach Mountains. These drainage channels are typically low-gradient, meandering systems that flow high in spring from snowmelt and high in late summer and autumn from rain. Impacts to streams will be minimal after standard mitigation measures are applied. These measures include spanning streams, suspending transmission lines beneath existing bridges, boring under streams, and scheduling installations during winter months. Submarine Environment - The physiography of the study area can be described as a large tidal estuary. The seafloor in this area comprises mudflats with tidal channels and deeper channels or depressions. At low tide, approximately 70 percent of the seafloor within Turnagain Arm is exposed as elongate bars dissected by braided tidal channels. Tides within Cook Inlet and Turnagain Arm are mixed, with two unequal high and low tides per tidal day. Conditions off of Pt. Possession include high sediment load, sea ice, submarine erosion, scoured bottom conditions, and boulder patches that can damage submarine cables. Expansive mud flats within Turnagain Arm provide an opportunity to embed submarine cables. ! Impacts to submarine environment would be minimal; however, with adherence to selective mitigation, the environmental impact would be further reduced to a non-significant level. Southern Intertie Project S-12 Summary Final EIS 1 July 2002 Biological Resources - The Project area supports diverse biological resources. The six major vegetation types present along alternative transmission line routes are habitats for many wildlife species. Thirty-three species of mammals, 127 species of birds, and 28 species of fish are expected to occur in the study area. Many of these same species also occur in the Anchorage area. Special status plant and wildlife species, species of concern to various agencies, are known or have the potential to occur along the alternative routes. The primary concern regarding biological resources is the effects on special status plants and wildlife species, vegetation (loss of habitat), and general wildlife. An area of special concern is the KNWR. Possible impacts could include collision hazards (birds), loss of habitat, and increased human access. Any significant impact on the KNWR will be considered nationally significant including effects to bald eagles, trumpeter swans, general waterfowl, brown bears, black bears, wolves, and lynx. Land Use_and Recreation - The study area includes lands administered by federal, state, borough, and municipal agencies; and lands privately owned in south-central Alaska. The alternative routes traverse portions of the Municipality of Anchorage and the KPB, along with portions of the KNWR. Urban land uses in Anchorage include parklands, residential, commercial, industrial, and areas managed for recreation and wildlife purposes. Significant impacts would occur on the KNWR due to potential affects to the KNWR management plans and qualification criteria for wilderness designation. The types of direct impacts on land uses include areas where the Project would create a direct conflict with residential, commercial, industrial, or transportation uses and those areas where severance of currently vacant parcels could affect future development. However, these impacts will not be significant, as mitigation measures have been identified to reduce impacts. These measures include utilizing existing access roads, closing access roads that are opened for construction but not needed for maintenance, avoiding sensitive features by spanning, shifting an alignment, or moving an alignment to the opposite side of existing lines (when paralleled). Socioeconomics and Tourism - The Project study area includes portions of the Municipality of Anchorage and the KPB. The population of the KPB increased by 22 percent between 1990 and 2000, reaching 49,691. Communities in the KPB that would principally be affected by one or another of the proposed power line alignments are Nikiski, Kenai, and Soldotna, whose populations in 2000 totaled approximately 15,000. The KPB has a diverse economy with the contribution of oil and gas, tourism, fishing and fish processing, transportation, timber, retail, and government sectors. The population of Anchorage has grown by 15 percent since 1990, reaching 260,283 in 2000. Anchorage is the state’s largest city and is the center of commerce for the state. The city has a diverse economy with oil and gas, finance and real estate, transportation, retail, services, communications, and government sectors represented. Potential impacts include temporary increases in population, employment and income during construction, and longer-term changes in or impacts on existing economic activities or land uses. Proposed winter construction on the Kenai Peninsula, however, will minimize or avoid conflicts with existing economic conditions during this time period. Southern Intertie Project $-13 Summary Final EIS it July 2002 Subsistence - There are no designated rural communities in the Anchorage Bowl portion of the study area. The subsistence analysis conducted for this FEIS focused on three communities near the study area whose residents do some subsistence harvesting within the study area: Ninilchik, Cooper Landing, and Hope. Data compiled in 1982 indicated that 92 percent of all Ninilchik households participated in subsistence harvests. Sample data compiled for 1990 to 1991 indicate that all households in Cooper Landing and Hope used subsistence resources. No negative impact on populations of relevant species that would impair subsistence practices is anticipated. Impacts on subsistence are not projected to be significant, and do not vary significantly among the alternatives considered. Therefore, subsistence resources are not a critical factor in selecting among the Project alternatives. Although the proposed project is likely to have adverse impacts on the moose population of the KNWR through impeded implementation of habitat improvement actions such as prescribed burning, it is not anticipated that such impacts to moose population will negatively affect subsistence opportunities on the refuge. Visual — The study area contains a variety of landscapes and viewing conditions, from the mostly urban environment of Anchorage to the natural and wilderness areas of the Kenai Peninsula. The surrounding regional landscape features, including the Cook Inlet and Turnagain Arm, Chugach Mountains, Alaska Range, and northern chain of the Aleutian Mountains, contribute to the scenic quality of the Project area. Developments on the Kenai Peninsula, such as Soldotna and Nikiski, occur in rural settings. The KNWR includes landscapes, which are heavily vegetated, consisting of coastal marshes, forested wetlands, shrub bogs, muskegs, upland spruce hardwood forests, and bottomland spruce poplar forests. There is the potential for visual impacts from project alternatives. In the City of Anchorage, visual impacts would result from views of the proposed Project from travelers and residences. Mitigation to impacts in Anchorage includes paralleling or rebuilding existing structures and utilizing existing rights-of-way. Visual impacts on the Kenai Peninsula occur in areas including Soldotna, Nikiski, and through the KNWR along the Enstar pipeline, resulting from the disruption of local residential viewsheds, right-of-way clearing, and associated ground disturbance. Mitigation to these impacts includes winter construction, variable right-of-way clearing, lowering tower heights, or altering the type of tower structure utilized in selected areas. Cultural Resources - More than 600 archeological and historical sites listed in the Alaska Heritage Resource Survey are present within the broad region in which the proposed Project is located. One of these, the Holy Assumption Church in Kenai, is designated as a National Historic Landmark. Forty-three of the more than 600 sites have either been determined eligible for or listed in the National Register of Historic Places. The nomination of 14 additional properties to the Register is pending. The alternatives avoid known archaeological and historic sites, and no high impacts are projected along any of the alternatives. The degree of variation in cultural resource impacts among the alternatives is not a major factor in choosing among the options. Detailed cultural resource surveys will be conducted along the route chosen for construction. Mitigation measures will be Southern Intertie Project $-14 Summary Final EIS il July 2002 developed in consultation with the State Office of History and Archaeology to reduce impacts to sites. Electric and Magnetic Fields and Noise - The two origins of transmission line electrical effects are electric and magnetic fields (EMF). Electric fields are due to the voltage on the transmission line and the magnetic fields are due to the current through the conductor. Electrical effects near transmission lines also include possible audible noise and radio/television interference. The line voltage and the distance of prospective line routes from residences reduce the likelihood of objectionable audible noise, radio interference, or television interference from the line. Impacts are expected to be minimal. Noises associated with operation and maintenance of the Project will be minimal, confined to localized, short-duration activity by maintenance crews. The EMF levels associated with the Project would be less than all existing EMF standards or guidelines. Therefore, EMF of the Project are not anticipated to cause adverse health or biological effects. Cumulative Impacts - Cumulative impact issues along the proposed Enstar Route center on potential land use, visual, and biological impacts. The existing and future foreseeable development along the western portion of the KNWR is occurring within the highest quality habitat for moose, wolves, lynx, black bears, and brown bears. The current estimate of the brown bear population on the Kenai Peninsula ranges from 250 to 300 bears (information provided in A Conservation Assessment of the Kenai Peninsula Brown Bear, Interagency Brown Bear Study Team, 2001). As this habitat gradually lowers in habitat quality, there will be additional importance to improve the quality of the area along the Enstar pipeline corridor with the prescribed burn program. Prescribed burns allow areas of mature spruce forests to be replaced by a mosaic of brush and early successional species that improves habitat for numerous species including moose. The Enstar Route would conflict with the prescribed burn program as well as increasing access in brown bear habitat. The cumulative effects on wildlife, vegetation, recreation, and visual resources within the KNWR along Route Option F are considered to be long term and significant. Any conflicts between the ability to diversify the habitat and presence of the proposed transmission line would be considered significant cumulative impacts. Cumulative impact issues that differentiate the Tesoro and Enstar alternatives are influenced by the uses associated with existing and foreseeable future development in the coastal area of the northern Kenai Peninsula versus impacts to the KNWR. The KPB has planned a transportation/utility corridor, a separate road, and several large residential parcels for rural development in proximity to the Tesoro pipeline along the western edge of the Kenai Peninsula, north of Nikiski. This development is planned along a strip of land that was withdrawn from the KNWR in order to provide transportation access between the Kenai Peninsula and Anchorage. Land use conflicts will be minimized or avoided by utilizing the rights-of-way of the North Kenai Spur Road, the planned transportation/utility corridor, and the Tesoro pipeline right-of- way. Visual impacts on existing and planned residents could be significant, although there is the potential for vegetation screening to reduce the effects. The quality of the wildlife habitat is in transition based on current and planned development on borough lands. Southern Intertie Project Final EIS Summary S-15 July 2002 Alternative Route Comparison - Table S-2 provides a comparative summary for the Tesoro and Enstar routes. This table provides information on key issues, Project description and costs, and environmental assessment results including the analysis of impact significance, short-term and long-term impacts, irreversible and irretrievable impacts, and cumulative impacts. There is a range of alternatives associated with both the Tesoro and Enstar routes as previously described and as illustrated on Figure S-1. For purposes of this comparison two alternative routes have been selected: the Applicant’s Proposal, which is the Enstar Route including Options E South, F, H, and K; and the Tesoro Route, including Options A, D, and N. The Tesoro Route alternative chosen for comparison describes potential impacts on the Kenai Peninsula and specifically in Anchorage. The environmentally preferred alternative, Options A and C, would avoid impacts to the Anchorage area. Expanded explanations of construction, operation, maintenance, and life cycle costs are provided in Chapter 2 of the FEIS (Section 2.2.1, pages 2-1 to 2-4). A detailed description of Project alternatives is provided in Table 2-6 of the DEIS. An expanded cost and technical comparison of alternatives is provided in Chapter 2 (Section 2.2.2, pages 2-4 to 2-11) of the FEIS, and a comprehensive environmental comparison of Project alternatives is provided on Table 2-11 of the DEIS including environmental preference. Following is a brief description of the environmentally preferred alternative. Environmentally Preferred Alternative - The environmentally preferred alternative is the Tesoro Route, Option A from Bernice Lake Substation to Pt. Possession, combined with a submarine cable crossing of the Turnagain Arm from Pt. Possession directly to Pt. Woronzof (Route Option C) for a total of 61.3 miles. This route is environmentally preferred because it exhibits on balance, lower overall environmental impacts than the other alternatives. Any of the other Tesoro Route alternatives would also exhibit overall lower environmental impacts than the Applicant’s proposed alternative and other Enstar Route options, primarily because of the impacts of the Enstar Route where it crosses the KNWR on the Kenai Peninsula. Route Option B is a submarine cable that includes a crossing of Fire Island that connects with Pt. Woronzof, which would minimize environmental impacts in the Anchorage area. Lower impacts in the Anchorage area for the Tesoro Route alternatives would also result from the underground route from Pt. Campbell to Pt. Woronzof (Route Option N), assuming appropriate mitigation. Southern Intertie Project S-16 Summary Final EIS July 2002 TABLE S-2 SUMMARY COMPARISON OF ALTERNATIVES Evaluation Tesoro Route (Route Options A, D, N)* Enstar Route Factors Key Issues Lead Federal Agency (RUS) Preferred Alternative Applicant’s Proposal (Route Options E South, F, H, K) Cost and Technical Considerations** Project Marine hazards = Total length is 62.0 miles = Total length is 73.4 miles Description associated with * — Parallels existing roads for 16.7 miles (including 0.5 mile | * Replaces or parallels existing transmission lines for 19 miles the ability to parallel to existing transmission line and 4.9 miles of = Parallels Enstar pipeline for 38.5 miles embed submarine underground) = Submarine crossing of the Turnagain Arm for 10.5 miles cables under the | * Parallels the Tesoro pipeline for 27.4 miles (totally embedded) Turnagain Arm = Submarine crossing of the Turnagain Arm for 13.9 miles | * Parallels the Alaska Railroad for 5.4 miles (including 0.5 mile in order to (5.8 miles embedded) of underground) maximize the life | * | Underground for 4.0 miles of the cable. Suitable locations for transmission facilities. Project Cost Potential to = Cable replacement for non-embedded cables includes = Cable replacement for non-embedded cables includes embed submarine replacing two single-phased cables or one three-phase replacing one single-phased cable or one three-phase cable cables and the cable twice during Project life once during Project life increased costs = Life cycle costs total $114.5 million (includes = Life cycle costs total $99.6 million (includes construction, associated with construction, operation, and maintenance and cable operation, and maintenance and cable replacement costs) assumed replacement costs) replacements affecting life cycle costs. Environmental Considerations Air Quality Degradation of Impact significance: Not significant Impact significance: Not significant air based on vehicle emissions and dust. Short term — Yes Long term — No Irreversible — No Irretrievable — Yes, construction phase Cumulative impacts - No Short term — Yes Long term —- No Irreversible — No Irretrievable — Yes, construction phase Cumulative impacts — No *Environmentally Preferred Alternative - Route Options A and C; ** refer to Chapter 2 for additional cost and technical information Southern Intertie Project Final EIS S-17 Summary July 2002 TABLE S-2 SUMMARY COMPARISON OF ALTERNATIVES Evaluation Tesoro Route (Route Options A, D, N)* Enstar Route Factors Key Issues Lead Federal Agency (RUS) Preferred Alternative | Applicant’s Proposal (Route Options E South, F, H, K) Geologic Soil loss, erosion | * Impact significance: Not significant = Impact significance: Not significant Resources and compaction = Short term — Yes, localized = Short term — Yes, localized based on clearing | * Long term — Minimal = Long term — Yes, potential for accelerated erosion and development | * Irreversible — No = — Irreversible — Yes, construction phase of access and = — Irretrievable — No = — Irretrievable — Yes, construction phase with potential tower sites. = Cumulative impacts - No lingering effects = Cumulative impacts - No Drainage Loss of = Impact significance: Not significant = Impact significance: Not significant Basins vegetation cover, | ® Short term — Yes, mainly localized = Short term — Yes, construction phase and soil erosion and = Long term — Minimal due to flat terrain = Long term — Slight increase in runoff and sedimentation due Watersheds resulting " Irreversible — No to presence of access and right-of-way clearing sedimentationin | * Irretrievable-No = Irreversible — No streams basedon | * Cumulative impacts - Yes = Irretrievable — Yes, construction phase with potential vegetative lingering effects clearing, = Cumulative impacts — Yes development of access and tower sites. Marine Degradation of = Impact significance: Not significant = Impact significance: Not significant Environment marine = Short term — Minor, during cable laying * — Short term — Minor, during cable laying environment during laying, embedding, or boring for cables during construction, and potential maintenance and repair activities, and replacement of cable. = Long term — Numerous hazard areas lead to potential for cable replacement twice over the life of the Project = Irreversible - No * — Irretrievable - No = Cumulative impacts - No " Long term — Embedded cable results in the potential for cable replacement once over the life of the Project = Irreversible — No = — Irretrievable —- No = Cumulative impacts —- No Southern Intertie Project Final EIS S-18 Summary July 2002 TABLE S-2 SUMMARY COMPARISON OF ALTERNATIVES Evaluation Tesoro Route (Route Options A, D, N)* Enstar Route Factors Key Issues Lead Federal Agency (RUS) Preferred Alternative Applicant’s Proposal (Route Options E South, F, H, K) Biology Vegetation and | Loss of = Impact significance: Not significant = Impact significance: Significant impacts due to clearing Wetlands vegetative cover |" Short term — Yes, construction phase upland vegetation and compaction of wetlands on KNWR and disturbance = Long term — Approximately 453 acres of upland = Short term — Yes, during construction phase to wetlands based vegetation removed. = Long term — Approximately 530 acres of upland vegetation on vegetation = — Irreversible — Yes removed clearing for right- |" Irretrievable — Yes, Project life = Irreversible — Yes of-way, access = Cumulative impacts - Yes = Irretrievable — Yes, Project life and towers, and = Cumulative impacts — Yes compaction. Birds including | Disturbance = Impact significance: Potential for locally significant = Impact significance: Potential for local and nationally Bald Eagles, during impacts due to tree clearing near nest sites and collision significant impacts on KNWR due to tree clearing near nest Trumpeter construction, loss hazards near large lakes and at stream crossings. sites and collision hazards near Chickaloon Bay, large lakes Swans and of habitat, Mitigation would substantially reduce potential for bird and at stream crossings. General increased access, collision. = Short term — Can be avoided through seasonal construction Waterfowl and potential = Short term — Can be avoided through seasonal = Long term — Yes, clearing within proximity to bald eagle nest increase in mortality due to presence of the line. construction = Long term — Yes, clearing within proximity to bald eagle nest sites (three within 0.25 mile) ® — Irreversible — Yes = Irretrievable — Yes, Project life = Cumulative impacts - Yes, trumpeter swans and general waterfowl; potential, bald eagles sites (two within 0.25 mile) " Irreversible — Yes = Irretrievable — Yes, Project life = Cumulative impacts — Yes, trumpeter swans and general waterfowl; potential, bald eagles Southern Intertie Project Final EIS S-19 Summary July 2002 TABLE S-2 SUMMARY COMPARISON OF ALTERNATIVES Evaluation Tesoro Route (Route Options A, D, N)* Enstar Route Factors Key Issues Lead Federal Agency (RUS) Preferred Alternative Applicant’s Proposal (Route Options E South, F, H, K) Large Mammals | Disturbance = Impact significance: Not significant = Impact significance: Nationally significant impacts to brown including during = Short term —- Temporary displacement of moose and bears, black bears and moose on the KNWR Brown Bears, construction, disturbance to denning black bears during construction = Short term — Temporary displacement of moose and Black Bears, conflicts with phase disturbance to denning black bears during construction phase Moose and management and | ® Long term — Yes, mortality due to increased access = Long term — Yes, mortality due to increased access and Caribou habitat plans, loss | * _ Irreversible— No potential disruption to moose/habitat management plan and of habitat and = Irretrievable — No fire management plans within KNWR potential increase | * Cumulative impacts - No = — Irreversible — Yes, on KNWR for mortality = Irretrievable —- Yes, on KNWR based on access = Cumulative impacts — Yes, significant improvements. Predators Disturbance = Impact significance: Not significant = Impact significance: Nationally significant impacts on including during = Short term — Yes, temporary displacement during KNWR Wolves and construction, loss construction phase = Short term — Yes, temporary displacement during Lynx of habitat and = Long term — Increased harvest minimal in low abundance construction phase potential for wolf and lynx habitat = Long term — Increased harvest minimal in low to moderate increased = — Irreversible — No for wolf, and unknown for lynx abundance habitat for wolf and lynx mortality based = Irretrievable — No for wolf, and unknown for lynx * — Irreversible — No for wolf, and unknown for lynx on access = Cumulative impacts — Not expected * — Irretrievable — No for wolf, and unknown for lynx improvements. = Cumulative impacts — Not expected Southern Intertie Project Final EIS S-20 Summary July 2002 TABLE S-2 SUMMARY COMPARISON OF ALTERNATIVES Evaluation Tesoro Route (Route Options A, D, N)* Enstar Route Factors Key Issues Lead Federal Agency (RUS) Preferred Alternative a Proposal (Route Options E South, F, H, K) Fish Loss of = Impact significance: Not significant Impact significance: Not significant vegetative = — Short term — Yes during construction phase Short term — Yes, during construction phase thermal cover, = Long term — No Long term — Potentially yes due to presence of access and soil erosion and = Irreversible — No right-of-way clearing resulting ® Irretrievable — No Irreversible — No sedimentation in | * Cumulative impacts - No Irretrievable — Yes, during construction phase streams based on Cumulative impacts - Unknown vegetative clearing, development of access and tower sites. Marine Disturbance = Impact significance: Not significant Impact significance: Not significant Mammals during = Short term — Temporary disturbance during construction Short term — Temporary disturbance during construction including the construction, loss phase, avoids conflicts with calving areas through phase, avoids calving areas Beluga Whale of habitat and seasonal construction Long term — Temporary disturbance during any repairs increased = Long term — Temporary disturbance during any repairs resulting from cable failure (projected to happen twice over mortality. resulting from cable failure (projected to happen once the life of the Project) over the life of the Project) = Irreversible — No = Irretrievable — Unknown, during construction phase = Cumulative impacts — Unknown Irreversible — No Irretrievable — Unknown, during construction phase Cumulative impacts - Unknown Southern Intertie Project Final EIS S-21 Summary July 2002 TABLE S-2 SUMMARY COMPARISON OF ALTERNATIVES Evaluation Tesoro Route (Route Options A, D, N)* Enstar Route Factors Key Issues Lead Federal Agency (RUS) Preferred Alternative Applicant’s Proposal (Route Options E South, F, H, K) Land Use and __| Disturbance, = Impact significance: Not significant = Impact significance: Nationally significant impacts to Recreation displacement of = — Short term — Yes, during construction phase recreation and land use on the KNWR. use(s) and = Long term — No = Short term — Yes, during construction phase potential conflicts | "Irreversible — No = Long term — Yes, conflicts with KNWR management plans with management | ® _ Irretrievable — Yes, during construction and qualification criteria for wilderness designation plans. = Cumulative impacts - No = Irreversible — Yes = Irretrievable — Yes, Project life = Cumulative Impacts — Yes, significant Socioeconomics | Regional and = Impact significance: Not significant = Impact significance: Not significant local = Short term — Yes, benefits based on employment = Short term — Yes, benefits based on employment employment, opportunities opportunities stability in = Long term — Yes, benefits from rate reductions = Long term — Yes, benefits from rate reductions region’s power * — Irreversible — Yes = — Irreversible — Yes supply. = Irretrievable — Yes, benefits for Project life " — Irretrievable — Yes, benefits for Project life = Cumulative impacts — Minor positive cumulative effects = Cumulative impacts — Minor positive cumulative effects Subsistence Disturbance to = Impact significance: Not significant = — Impact significance: Not significant wildlife, increased access for hunting and trapping. = Short term — Yes, potential disruption to hunting and trapping during construction phase Long term — Minimal based on increased access Irreversible —- No Irretrievable — No Cumulative impacts - No Short term — Yes, potential disruption to hunting and trapping during construction phase Long term — Minimal based on increased access Irreversible — No Irretrievable - No Cumulative impacts - No Southern Intertie Project Final EIS S-22 Summary July 2002 TABLE S-2 SUMMARY COMPARISON OF ALTERNATIVES Evaluation Tesoro Route (Route Options A, D, N)* Enstar Route Factors Key Issues Lead Federal Agency (RUS) Preferred Alternative Applicant’s Proposal (Route Options E South, F, H, K) Visual Degradation of = Impact significance: Significant impacts (approximately = Impact significance: Significant impacts, including nationally natural scenic 21 miles) total including consideration for landscape significant on KNWR (approximately 32 miles total including quality and visual scenery and residential, recreational, and travelway consideration for landscape scenery, and residential, intrusion to views). Mitigation would result in variable visual impacts recreational, and travel way views) residential, to developing area north of Captain Cook SRA. = Short term — Yes, presence of equipment during construction recreational, and | * Short term — Yes, presence of equipment during phase travelway views. construction phase = Long term — Yes, presence of towers, conductors and access = Long term — Yes, presence of towers, conductors and roads access roads " — Irreversible — Yes = Irreversible — Yes = — Irretrievable — Yes = Irretrievable — Yes = Cumulative impacts — Yes, nationally significant = Cumulative impacts — Yes, locally significant Cultural Disturbance or = Impact significance: No determination prior to = Impact significance: No determination prior to consultation Resources removal of sites consultation with State Office of History and with State Office of History and Archaeology, low to or fossils. Archaeology, low to moderate impact potential Short term — Unknown Long term — Unknown Irreversible - Unknown Irretrievable - Unknown Cumulative impacts - Unknown moderate impact potential Short term — Unknown Long term — Unknown Irreversible - Unknown Irretrievable - Unknown Cumulative impacts — Unknown Southern Intertie Project Final EIS S-23 Summary July 2002 S.6 SCOPING, CONSULTATION, AND COORDINATION ON THE DEIS In accordance with the requirements of NEPA, RUS published a Notice of Intent in the Federal Register in October 1996. The notice announced the intent of RUS to prepare an EIS for the Project and the schedule for the three public scoping meetings, which were conducted in Anchorage on November 12, Cooper Landing on November 13, and Soldotna on November 14. In addition to the public scoping meetings, RUS conducted an interagency meeting on November 6, 1996 in Anchorage. In addition, the Applicant and its consultants contacted agencies and organizations having jurisdiction and/or specific interest in the Project. A series of agency and interagency meetings as well as two public meetings (January and February 1996) were conducted. Two community working groups (CWGS) were developed, one on the Kenai Peninsula and the other in Anchorage. Each group met five times at key milestones during the process. S.7_ | PUBLIC COMMENTS ON DEIS The DEIS was filed with the Environmental Protection Agency (EPA) and made available to the public on October 5, 2001. A Federal Register notice of availability and intent to conduct public hearings was published on October 3, 2001 (Volume 66, Number 192, page 50396-50397), which initiated the 60-day public review period. As required by Title XI of ANILCA, public hearings were held in the District of Columbia and the State of Alaska. These hearings were held in Washington, DC on October 30, 2001; Anchorage, Alaska on November 13, 2001; and Soldotna, Alaska on November 14, 2001. Twelve people provided verbal comments at these hearings. During the comment period a total of 102 comment letters were received. Two of these letters were form letters signed by 158 and 907 people respectively and one letter was in a petition format with 12 signatures, bringing the actual total of commentors to 1,174. To ensure that all public comments would be received in a timely manner all DEIS recipients were contacted by letter on December 5, 2001. This letter served to notify all DEIS recipients that comments sent via U.S. Postal Service may not have been received in Washington D.C. due to new mail screening requirements, and invited comments to be sent again via email or fax. To accommodate this delay in mail delivery, comments received after the deadline were considered in the preparation of the FEIS. Fourteen issues were identified during the scoping process conducted for this Project. For consistency of analysis, these issues were used to categorize public comment received on the DEIS. Table S-3 below demonstrates the number of comments received on each issue, and the associated relative degree of concer over each issue. Southern Intertie Project $-24 Summary Final EIS July 2002 TABLE S-3 PROJECT ISSUES AND RELATIVE DEGREE OF CONCERN Total Relative Degree of Issue Comments Concern (%) Issue 1 - Purpose and Need for the Project 16 47 Issue 2 - Urban and Rural Land Use 13 3.8 Issue 3 - Aviation Safety 1 0.3 Issue 4 - Recreation and Tourism 43 12.6 Issue 5 - Management Plans 61 18.0 Issue 6 - Watershed Management and Soil Erosion 2Z 0.6 Issue 7 - Visual Resources 39 LS) Issue 8 - Biology 66 19.4 Issue 9 - Cultural Resources 2 0.6 Issue 10 - Right-of-Way Limitations 4 1.2 Issue 11 - Health and Safety 1 0.3 Issue 12 - Avalanche Hazards 0 0 Issue 13 - Socioeconomics 13 3.8 Issue 14 - Alternatives to the Proposed Project 79 23.2 Total* 340 100 *Total of 340 reflects total issues listed within individual letters. For example, if a commentor listed concerns over several animal species, they received one tally for biology, rather than several. Also, form letters were counted only once, rather than multiplied by number of signatures. S.8. SUPPLEMENTAL DISCUSSION ON KEY ISSUES Additional and more detailed information has been added to the FEIS to supplement the DEIS and address comments and information requests received during the public comment period on the DEIS (in particular from the EPA and Special Interest Groups). The information includes (1) additional information on project cost and benefits, (2) a cost and technical comparison of route options, (3) additional information regarding undergrounding of transmission lines, (4) expanded explanation on elimination of BESS as an alternative to the Project, (5) update on beluga whales, (6) update on Kenai Peninsula brown bears and wolverines, (7) environmental cost-benefit analysis review summary, and (8) additional information on avian collision mitigation. Information on these topics may be found in Chapter 2 (Section 2.2) of the FEIS. S.9 MITIGATION PLAN A detailed mitigation plan (see Volume II) was prepared in consultation with federal, state, and local agencies. Key elements of the plan include descriptions of the types of mitigation measures proposed, the specific locations where each would be implemented, and their effectiveness in avoiding or reducing adverse environmental effects. Southern Intertie Project 5-25 Summary Final EIS ii July 2002 S.10 AGENCY PREFERENCES AND DECISIONS TO BE MADE Section S.10 provides a description of the RUS and USFWS preferred alternatives, and the USACE least damaging practicable alternative. This is followed by a discussion of the decisions to be made based on each agency in their Record of Decision. S.10.1 RUS Preferred Alternative The RUS preferred alternative is the Tesoro Route, consisting of Route Options A, D, and N. The section between the Bernice Lake Substation and Pt. Possession was identified in the DEIS as part of the environmentally preferred alternative. The Turnagain Arm crossing from Pt. Possession to Pt. Campbell with the overland route to Pt. Woronzof is preferred over the other Turnagain Arm crossing alternatives (Options B or C) based on economic, environmental, and technical considerations. S.10.2 USFWS Preferred Alternative Based on the analyses of potential impacts to fish and wildlife resources contained in the DEIS, the USFWS has identified the Tesoro Route including Roite Options A and C, as the environmentally preferred alternative. In accordance with regulations (50 CFR 26.41, 65 FR 62458) implementing the National Wildlife Refuge System Administration Act, the USFWS has prepared a Compatibility Determination (Appendix A) in response to the IPG right-of-way application, which finds that construction of the Project along the Enstar Route as proposed would not be compatible with the purposes for which the KNWR was established. S.10.3 USACE Least Damaging Practicable Alternative The IPG submitted an application to USACE to construct the 138kV transmission line following Route Options E-South, F, H, and K, collectively known as the Enstar Route. A Draft Section 404(b)(1) Evaluation (see Appendix B) indicates that construction of the transmission line along the Tesoro alternative (Route Option A) with any of the three Turnagain Arm crossing options (B, C, or D/N) is a less damaging practicable alternative to the applicant’s Enstar proposal, without significant impacts to aquatic resources. Following the FEIS 30-day public review period, the Alaska District Engineer will present a Record of Decision. This permit decision will be based on consideration of public interest factors and the Final Section 404(b)(1) Evaluation. S.10.4 Decisions to be Made Section 1.6 of the DEIS provides details regarding each agency’s decision factors. As described on pages 1-35 to 1-37 of the DEIS, each agency (RUS, USFWS, and USACE) will prepare a Southern Intertie Project S-26 Summary Final EIS July 2002 concise public Record of Decision for the Project. According to 40 CFR 1505.2 of NEPA, each Record of Decision will: m state the decision = identify all alternatives considered by each agency in reaching its decision including the environmentally preferred alternative (an agency may discuss preferences among alternatives based on relevant factors including economic and technical considerations and agency statutory missions including any essential considerations of national policy) = state whether all practicable means to avoid or minimize environmental harm from the alternative selected have been adopted Southern Intertie Project $-27 Summary Final EIS ~ July 2002 CHAPTER 1 PUBLIC COMMENTS AND RESPONSES CHAPTER 1 — PUBLIC COMMENTS AND RESPONSES 1.1 INTRODUCTION Comments on the DEIS were received from federal, state, and local agencies, special interest organizations, and individuals. The format of these comments included letters, emails, and oral testimony. 1.2 PUBLIC REVIEW PROCESS In August 2001, a newsletter (see Appendix C) was issued that updated the Project status and announced the future availability of the DEIS. The mailing list included almost 375 agencies and individuals. Notices of availability of the DEIS were published in the Federal Register on October 3, 2001 (Volume 66, Number 192, pages 50396 and 59397) by RUS and on October 5, 2001 (Volume 66, Number 194, page 51036) by EPA. The RUS notice contained the dates, times, and locations of public hearings, and requested that written comments be addressed to the RUS contact in Washington, D.C. by December 5, 2001. Copies of the RUS and EPA Federal Register notices are contained in Appendix C. In accordance with RUS procedures, the applicant published DEIS availability notices in the following newspapers: Anchorage Daily News, Alaska Star, Frontiersman, Homer News, Peninsula Clarion, Seward Phoenix Log, and Daily News Miner. As required by Title XI of ANILCA, public hearings are required in the District of Columbia and the State of Alaska. Due to increased security measures following September 11, 2001, the District of Columbia meeting was moved to USFWS Headquarters in Arlington, Virginia. Public hearings for the DEIS were held on the following dates, times, and locations: = October 30, 2001, 2:00 to 4:00 p.m., Arlington, Virginia = November 13, 2001, 7:00 to 9:00 p.m., Anchorage, Alaska = November 14, 2001, 7:00 to 9:00 p.m., Soldotna, Alaska Notices of the public hearings were placed in the Anchorage Daily News, Peninsula Clarion, and Seward Phoenix Log during the week of the public hearings. Approximately 110 copies of the DEIS were sent to federal, state, and local government agencies, institutions, organizations, and individuals. Copies were also placed in the public reading rooms of the following libraries: Mountain View, Chugiak/Eagle River, Cooper Landing, Hope, Kenai, Muldoon, Samson-Dimond, Z.J. Loussac, Gerrish Branch, Soldotna, and Alaska State. The DEIS was distributed in both hard copy and CD ROM format. The complete document was also available on the RUS website. Public testimony at the three hearings was received from 12 persons. During the 60-day comment period, a total of 102 different comment letters were received from federal, state, and municipal agencies, businesses, native corporations, non-profit organizations, and individuals. Southern Intertie Project Chapter 1 — Public Comments and Responses Final EIS 1-1 July 2002 Two of the letters were email form letters signed by 158 and 907 individuals respectively and one letter was in petition format with 12 signatures. The actual total number of commentors was 1,174. In compliance with the requirements of the CEQ Regulations implementing NEPA, all comments received must be assessed and a response provided. All public testimony and comment letters have been reproduced in this chapter. Letters have been organized by the commentor’s affiliation and given a tracking number. Responses are located adjacent to each comment letter. To ensure that all public comments would be received in a timely manner, all DEIS recipients were contacted by letter on December 5, 2001, the concluding date for all public comments. This letter served to notify all DEIS recipients that comments sent via the U.S. Postal Service may not have been received in Washington, D.C. due to new mail screening requirements. Recipients were encouraged to resubmit their comments via email or fax. To accommodate this delay in mail delivery, comments received after the deadline were considered in the preparation of the FEIS. 1.3 COMMENT ANALYSIS SUMMARY The comments in response to the DEIS have been organized and summarized in a way that allows reviewers to understand the principal issues of public concern. The lead and cooperating agencies analyzed and considered all comments and responded specifically to those substantive comments that presented new data, questioned findings of analyses, or raised questions or issues relevant to the potential environmental impacts of the proposed project and alternatives, as required by NEPA and associated regulations. Both verbal and written comments were categorized based on the issues addressed in the DEIS. No new issues were raised by commentors. The following sections provide responses to key issues and comments raised during the public review of the DEIS, as follows: = Section 1.3.1 —List of Key Topics and Issues = Section 1.3.2 — Responses to Written Comments = Section 1.3.3 — Responses to Verbal Comments 1.3.1 List of Key Topics and Issues Fourteen issues were identified during the scoping process conducted for this Project. For consistency of analysis, these issues were used to categorize public comment received on the DEIS. Table 1-1 demonstrates the number of comments received on each issue, and the associated relative degree of concern over each issue. Southern Intertie Project Chapter 1 — Public Comments and Responses Final EIS 1-2 July 2002 TABLE 1-1 PROJECT ISSUES AND RELATIVE DEGREE OF CONCERN Total Relative Degree Issue Comments of Concern (%) Issue 1 - Purpose and Need for the Project 16 47 Issue 2 - Urban and Rural Land Use 13 3.8 Issue 3 - Aviation Safety 1 0.3 Issue 4 - Recreation and Tourism 43 12.6 Issue 5 - Management Plans 61 18.0 Issue 6 - Watershed Management and Soil Erosion 2 0.6 Issue 7 - Visual Resources 39 11.5 Issue 8 - Biology 66 19.4 Issue 9 - Cultural Resources 2 0.6 Issue 10 - Right-of-Way Limitations 4 12 Issue 11 - Health and Safety 1 0.3 Issue 12 - Avalanche Hazards 0 0 Issue 13 - Socioeconomics 13 3.8 Issue 14 - Alternatives to the Proposed Project 79 23:2 Total* 340 100 *Total of 340 reflects total issues listed within individual letters. For example, if a commentor listed concerns over several animal species, they received one tally for biology, rather than several. Also, form letters were counted only once, rather than multiplied by number of signatures. A summary description of each of these issues and a general response are provided below. Issue 1 — Purpose and Need for the Project The underlying need for the Project has been questioned in several comments as summarized below: = The no-action alternative should be selected because the purpose and need had not been firmly established. = There are other alternatives to a new transmission line that would meet the purpose and need with less environmental impact. = The Project cost-benefit analysis should include long-term environmental costs associated with impacts to wildlife, recreation, and other resource values on the KNWR. = The cost-benefit ratio is obscured by the inclusion of the state grant. General Response — The purpose and need for the Project and the benefits resulting from the Project have been evaluated extensively and confirmed repeatedly through numerous studies. Between 1987 and 1999, a series of 14 engineering, economic, and environmental studies were conducted to confirm the need, identify reasonable alternatives, determine accrued benefits, and establish key cost and technical parameters (refer to DEIS Table 1-2). The no- Southern Intertie Project Chapter 1 — Public Comments and Responses Final EIS 1-3 July 2002 action alternative does not meet the purpose and need for the Project (DEIS, Section 2.3.1, No Action Alternative, pgs. 2-29 and 2-30). RUS did conduct an independent review of the purpose and need and alternatives considered for the Project in 1998 and found that the need and alternatives sections as written in the DEIS adequately describe and justify the need for the Project. The DEIS adequately addresses impacts to wildlife, habitats, and other resource values in the KNWR, and a cost evaluation of these impacts is not required (see Issue 13, Socioeconomics). The cost-benefit ratio for the Project has not been obscured by the state grant. Table 1-12 on pg. 1-31 of the DEIS lists the cost-benefit ratios for the Project with and without the $46.8 million dollar state grant. The purpose and need for the Project are discussed in detail in Chapter 1 of the DEIS, Sections 1.2 and 1.3. Chapter 2, Section 2.2.1 in the FEIS provides more information on Project costs and benefits. Issue 2 — Urban and Rural Land Use Comments were received on how the proposed and alternative routes could potentially conflict with existing or future land uses. General Response — Conflicts with existing and future land use have been avoided through the siting of facilities within existing rights-of-way, existing and planned utility corridors, and the undergrounding of facilities in sensitive areas. See Section 3.6.3 of the DEIS and the Mitigation Plan in Volume II of the FEIS. Issue 3 — Aviation Safety Because many areas near the proposed project are accessible only by aircraft, the concern was expressed that an overhead transmission line would prohibit landing of private aircraft in remote areas. General Response — Compliance with Federal Aviation Administration (FAA) regulations such as 14 CFR Part 77 Standard for Determining Obstructions and FAA Advisory Circular 70/7460-1G (pg. 3-132 of the DEIS) will occur prior to construction. In addition, land use studies identified local airstrips and aircraft use. Mitigation, such as undergrounding the transmission line in certain areas and the marking of the line with high visibility devices, will alleviate many concerns. See Section 3.6.3, Alternatives (DEIS beginning on pg. 3-135) for airstrips identified on specific routes, and the Mitigation Plan in Volume II of the FEIS for the location of underground line segments in association with these airstrips. Southern Intertie Project Chapter 1 —- Public Comments and Responses Final EIS 1-4 July 2002 Issue 4 — Recreation and Tourism Concern was expressed that the Project would impact recreation and tourism on the Kenai Peninsula either by changing the visual quality of an area and therefore preventing people from wanting to visit, or by increasing access to an area, which could either result in difficulty managing the area or closing access entirely to prevent too much human contact with sensitive species. General Response — Impacts to visual resources (Issue 7), management practices (Issue 5), and sensitive resources (Issue 8) are acknowledged. However, socioeconomic analysis concluded that “the Project would not seriously damage the area’s tourist and recreation trade” (DEIS pg. 3-184) and recreation and tourism should not experience significant impacts. Issue 5 - Management Plans Many commentors were concerned that the proposed project would conflict with existing management plans. Comments reflected the concern that the proposed Enstar Route would conflict with the mandate to protect wildlife within the KNWR, and that the presence of a transmission line would impact wildlife by increasing access and preventing prescribed burning, which is critical for moose habitat. Concern also was expressed that the presence of a new transmission line in the KNWR would prohibit future designation as a wilderness area, and effect subsistence hunting. General Response — The DEIS describes the conflicts between the proposed the Enstar Route and management plans on the KNWR including future wilderness designation of the Chickaloon Flats and Two Indians areas (pg. 3-143 of the DEIS). See the USFWS Compatibility Determination in Appendix A of the FEIS. Effects to subsistence are described in Section 3.8 (pg. 3-205 of the DEIS). Issue 6 - Watershed Management and Soil Erosions There are numerous streams and rivers in the Project study area, which provide food sources for many species such as the brown bear. Comments expressed concern that construction activities could damage water quality or cause soil erosion, which could in turn impact feeding activities or fish spawning. General Response — Anadromous fish streams are protected under state law. Spanning or drilling under the streams and minimizing vegetation removal at stream crossings will avoid impacts. See DEIS Section 3.5.5, Freshwater Environment, Environmental Consequences and Mitigation, Anadromous Fish (pg. 3-100). See also Table 3-2, Impacts and Mitigations Common to Most Alternative Routes (pg. 3-15). Mitigation measures including specific Southern Intertie Project Chapter 1 — Public Comments and Responses Final EIS 1-5 July 2002 locations of the anadromous streams crossed by the Project alternatives may also be found in the Mitigation Plan in Volume II of the FEIS. Issue 7 — Visual Resources Several comments were received on visual resources, specifically on how the Project would affect views in recreational areas or from residences. Comments were related to both vegetation clearing and the presence of the actual transmission structures. General Response — Visual impacts associated with the Project would be long term, remaining over the life of the Project and it is recognized that there would be significant impacts to recreational viewers on the Enstar Route and residential viewers on the Tesoro Route. However, mitigation measures will be taken to reduce impacts where possible. For more information see Visual Resources (Section 3.9.2 in the DEIS) and the Mitigation Plan in Volume II of the FEIS. Issue 8 — Biology Biology was the second most frequently mentioned topic receiving 19.4 percent of the comments. Comments primarily focused on brown bears, moose, beluga whales, and wetland habitats, although other sensitive animal species (such as birds and waterfowl) or habitats also were mentioned. Most of the comments focused on potential impacts on the KNWR resulting from the Enstar Route. These impacts could result from increased access and associated increase in hunting or bear/human contact, and restrictions in prescribed burns that would impact habitat. Comments on potential conflicts with beluga whales, especially during calving season, focused on the submarine cable installation in Cook Inlet. General Response — Mitigation measures have been incorporated to reduce potential impacts to vegetation and wildlife to the greatest extent possible by avoiding sensitive areas and construction timing, minimizing tree clearing and limiting new access (see the Mitigation Plan in Volume II of the FEIS). Impacts to wildlife on the KNWR would be considered nationally significant due to the mandate to protect wildlife on the KNWR. The USFWS has concluded that the Enstar Route would not be compatible with the purposes for which the KNWR was established. See Appendix A in the FEIS for the Compatibility Determination. The USACE has indicated that the Tesoro Route is a less damaging practicable alternative than the proposed Enstar Route. See Appendix B for the Draft Section 404(b)(1) Evaluation. Impacts to beluga whales are not expected to be significant. Scheduling cable laying during July and August avoids the calving season in compliance with recommendations from National Marine Fisheries Service (NMFS) and Alaska Department of Fish and Game (ADF&G). The cable laying operation is not expected to have in-water noise that would disturb the whales other than the barge vessel and water jet excavation/trenching machine. Also, activities will be conducted in accordance to practices as outlined in Chapter 2, Section Southern Intertie Project Chapter 1 - Public Comments and Responses Final EIS 1-6 July 2002 2.2.5 of the FEIS. NMFS has concurred with the Applicant’s proposed mitigation. See DEIS, Section 3.5.9, Marine Environment, Environmental Consequences and Mitigation, Marine Mammals (pg. 3-113) for more information. Issue 9 — Cultural Resources Comments on the DEIS regarding cultural resources included concerns regarding impacts to the Pt. Possession Village and native lands and other potential archaeological sites such as the Denai’na Indian cultural sites. General Response — The Tesoro Route alternative would be underground parallel to the pipeline on the edge of the Pt. Possession property. The transmission line was sited in this location to be in conformance with the KPB’s planned transportation/utility corridor and avoids the Pt. Possession Native Village. See DEIS Section 3.6.3, Alternatives, Bernice Lake to Pt. Possession — Route Option A (pg. 3-135). See also Appendix B, “Access to Area” Table (pg. B-29) in the DEIS, and the Mitigation Plan in Volume II of the FEIS. Prior to initiating Project construction, formal consultation will be initiated with the Alaska Department of Natural Resources (DNR), Office of History and Archaeology. Areas recommended for archaeology surveys will be identified and appropriate mitigation for identified sites will be developed. Issue 10 — Right-of-Way Limitations Comments were received regarding concern that the additional right-of-way needed for the Project would impact property owned by an individual or agency. General Response — The Project alternatives have been located in a manner that minimizes impacts to property owners. As described in the DEIS, Section 3.6.3, facilities have been located within existing rights-of-way, and existing and planned utility corridors to the greatest extent possible. Mitigation measures including selective tower placement and realignments have further reduced impacts to property owners (see Volume II of the FEIS). In addition, the Applicant will coordinate with agencies and private entities in the acquisition of right-of-way. See DEIS Section 2.5.2, Right-of-Way Acquisition Process (pg. 2-51). Issue 11 - Health and Safety One comment was received on potential health impacts (i.e., EMF) from the proposed project. General Response — Studies on EMF have been inconclusive regarding potential health effects. However, the proposed Project would be typical of facilities that have been operated for many decades, and EMF levels from the Project would be less than existing EMF Southern Intertie Project Chapter 1 — Public Comments and Responses Final EIS 1-7 July 2002 standards or guidelines (DEIS, pg. 3-278). See DEIS, Section 3.11, Electric and Magnetic Fields and Noise (pg. 3-272) for more information. Issue 12 - Avalanche Hazards Although this was an issue of great concern during the public scoping for this Project, no specific comments were received on this issue during review of the DEIS. Issue 13 — Socioeconomics Several comments requested that a cost-benefit analysis that weighs the benefits of the Project with the cost of affected wildlife and habitat be completed for the proposed project. Other comments questioned the accuracy of statements that consumers would experience rate savings as a result of the Project, or expressed concern that property values would be affected. General Response — Qualitative evaluation is appropriate according to Section 1502.23 of CEQ regulations for implementing NEPA, which states “the weighing of the merits and drawbacks of the various alternatives need not be displayed in a monetary cost-benefit analysis and should not be when there are important qualitative considerations.” The DEIS provides an adequate database for the lead and cooperating agencies to adopt the Tesoro Route as the preferred alternative (see FEIS, Summary Section S.10). This decision is based on qualitative evaluation of unquantified impacts, values, and amenities as described in Section 1502.23. This decision is consistent with comments received from EPA (see comments 1A and 1F —- EPA regarding Least Damaging Alternative/Preferred Alternative). Further information on this topic is also provided in the FEIS Chapter 2, Section 2.2.7, Environmental Cost-Benefit Analysis Summary. The Project is expected to result in rate savings. Property values are discussed in the DEIS, Section 3.7.2, pg. 3-176, Facility Impacts on Property Values. Issue 14 - Alternatives to the Proposed Project The majority of comments received, over 23 percent, were regarding alternatives to the proposed project. These comments focused on two different topics: transmission alternatives to the Enstar Route (Tesoro and Quartz Creek routes), and alternatives to a transmission option. Some individuals believe that a transmission line is not needed at all, and other options such as fuel cells should be analyzed more thoroughly. Other people believe that the Tesoro Route or Quartz Creek Route should be selected to prevent additional impacts on the KNWR. General Response — Section 1502.14a of CEQ Regulations for Implementing NEPA requires that a DEIS “Rigorously explore and objectively evaluate all reasonable alternatives, and for Southern Intertie Project Chapter 1 — Public Comments and Responses Final EIS 1-8 July 2002 alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.” The DEIS is in compliance with that requirement. Section 2.2, Alternatives Studied and Eliminated from Detailed Study (DEIS pg. 2-1 through 2-25), describes a number of alternatives that were considered and eliminated from further study. In that section, for example, alternatives to a transmission line that were considered but eliminated include BESS, DSM, energy efficiency/conservation, new generation, distributed generation, wind generation, fuel cells, and increased spinning reserves. These Project alternatives were not reasonable because they do not meet the purpose of the Project as described in Section 2.2. Each of these alternatives and the reasons for their elimination are briefly described in this section of the DEIS. Additionally, the route selection process identified two new transmission options in addition to upgrading the existing 115kV Quartz Creek line or constructing a second line parallel to the existing line. The process concluded that a second transmission line along either the Tesoro or Enstar routes were the only reasonable alternatives identified as being responsive to both the purpose and need for the Project. These two alternatives were evaluated in detail. The no-action alternative does not meet the purpose and need for the Project (see Issue 1). Based on this information, RUS has determined that the range and scope of other alternatives have been adequately studied, and the proposed project, a second intertie from the Kenai Peninsula to Anchorage, is the only alternative that meets the Project need. The RUS has selected the Tesoro Route, Alternatives A, D, and N as the preferred alternative, while USFWS has identified the Tesoro Route (Alternatives A and C) as the preferred route. The USFWS has concluded that the Enstar Route would not be compatible with the purposes for which the KNWR was established. See Appendix A in the FEIS for the Compatibility Determination. The USACE has indicated that the Tesoro Route is a less damaging practicable alternative than the proposed Enstar Route. See Appendix B for the Draft Section 404(b)(1) Evaluation. Southern Intertie Project Chapter 1 — Public Comments and Responses Final EIS 1-9 July 2002 1.3.2 RESPONSES TO WRITTEN COMMENTS 1.3.2 Responses to Written Comments This section provides responses to individual written comments received from specific agencies, interest groups, and individuals. Table 1-2 is organized by comment source (federal, state, special interest groups, or individuals), showing who provided written comments on the DEIS, and general topics of comment (by issue number). TABLE 1-2 GUIDE TO AGENCIES, ORGANIZATIONS, AND INDIVIDUALS WHO PROVIDED WRITTEN COMMENTS ON DEIS Letter Number Name/Affiliation Issues Commented On Federal Agencies 1 Judith Leckrone Lee, Manager, Geographic Implementation Unit, 1, 2,4, 7, 8, 14 EPA Region 10 2 Marcia Combes, Director, Alaska Operations Office 1, 8,14 EPA Region 10 3 Pamela Bergmann, Regional Environmental Officer, Alaska - U.S. Department of Interior 4 Clarence Goward, FAA - 5 Matt Eagleton, NMFS 8,14 6 Stuart Hirsh, Group Manager, Realty, BLM Anchorage Field Office [10 7 Ann Rappoport, Field Supervisor, USFWS 6, 8, 14 7A L. John Jani, Regional Administrator, EPA Region 10 8,14 State Agencies 8 Jennifer Wilson, Regional Planning Manager, Alaska DOT 2 9 Don Perrin, Project Review Coordinator, Alaska DGC 4, 5,6, 8,9, 11, 14 10 Don Perrin, Project Review Coordinator 5 Alaska DGC ll Jennifer Wilson, Regional Planning Manager, Alaska DOT 2 [12 Stewart Seaberg, Alaska Department of Fish and Game 5, 8, 14 Special Interest Groups and Individuals 13 Michelle Wilson, Alaska Center for the Environment 1,5, 8, 13, 14 14 Various signers, form letter from Alaska Center for the Environment | 2,5, 8, 14 15 Stephen Conn, Executive Director 1, 2, 13, 14 Alaska Public Interest Research Group 16 Noah Matson, Refuge Program Manager 5 Defenders of Wildlife ny: John Schoen, PhD, Senior Scientist 5,7, 8, 14 Audubon Alaska 18 Jack Hession, Senior Regional Representative 1,5, 14 Sierra Club Alaska 19 Sarah Leonard, Executive Director 2, 4,5, 8, 13, 14 Alaska Wilderness Recreation & Tourism Association 20 Nicole Whittington-Evans, Assistant Regional Director, Alaska, The | 1, 4,5, 8, 13, 14 Wilderness Society 21 Various signers, form letter from The Wilderness Society 4, 5,7, 8, 14 22 Bob Baldwin, President 5,14 Friends of Kenai National Wildlife Refuge 23 Ted Whip, Northern District Eastside Setnetters Association 25:10;13 Southern Intertie Project Final EIS 1-10 Chapter 1 — Public Comments and Responses July 2002 TABLE 1-2 GUIDE TO AGENCIES, ORGANIZATIONS, AND INDIVIDUALS WHO PROVIDED WRITTEN COMMENTS ON DEIS Letter Number Name/Affiliation Issues Commented On 24 Norman Kallander, President 3,7, 13, 14 Pt. Possession, Inc. 25 Kassie Siegel, Staff Attorney, Center for Biological Diversity 1,5, 8, 14 26 George Matz, President, Anchorage Audubon Society 1, 4, 5, 8, 13, 14 2; John Martin, Alaska Representative, National Wildlife Refuge 4,5,7, 8,14 Association 28 Cathy Kropp 4,5, 7, 8,14 29 Daniel Cooke 4, 5,7, 8,14 30 Kathleen and Richard Huneke 4, 5,7, 8,14 31 Eric Horstman 4, 5,7, 8,14 32 Ashlin Tucker 4, 5,7, 8,14 33 Tony DeFalco 4, 5,7, 8,14 34 Daniel James 4, 5,7, 8,14 35 Amanda Cluck 4, 5,7, 8,14 36 Monika Willisegger 4, 5,7, 8,14 37 Kristin Hjelle 4, 5,7, 8,14 38 Bernise Tuck 4, 5,7, 8,14 39 Christopher Lish 4, 5,7, 8,14 40 Garold Faber 4, 5,7, 8,14 41 Lance McCardle 4, 5,7, 8,14 42 Norma and Victor Tompkins 4, 5,7, 8,14 43 Laurel Gove and Stuart Higgins 4, 5,7, 8,14 44 David Morgan 4, 5,7, 8,14 45 Paul Black 4,5,7, 8,14 46 Carolyn Bishop 4, 5,7, 8,14 47 Timothy McGovern 4, 5,7, 8,14 48 Ryan Carlson 4, 5,7, 8,14 49 Susan Brown and Mustafa Top 4, 5,7, 8,14 50 Cora Sutterlin 4, 5,7, 8,14 51 Monika Walker 4, 5,7, 8,14 52) Trudy Gillette 4,5, 7, 8,14 53 Deborah Longman-Marien 4, 5,7, 8,14 54 Brian Parks 4,5, 7, 8,14 55 Heidi Blankenship 4,5, 7, 8,14 56 Terry Burns 5,14 oe Lorraine Streckfus 5,8, 14 58 Daniel Brendle 5,8, 14 59 James Oakes 4, 5,7, 8,14 60 Mel and Joanne Ackerman 14 61 Carol Jensen 8, 10, 13, 14 62 Frank Norris 14 63 Michael Funke 4 64 Theodore Bailey 2,'5,'8,,13514 65 Joey Lee 2,5, 14 66 Don Hagey 5, 8, 14 67 Karl Frederick = 68 Ron Sutherland 1,7, 14 Southern Intertie Project Final EIS 1-11 Chapter 1 — Public Comments and Responses July 2002 TABLE 1-2 GUIDE TO AGENCIES, ORGANIZATIONS, AND INDIVIDUALS WHO PROVIDED WRITTEN COMMENTS ON DEIS Letter Number Name/Affiliation Issues Commented On 69 Deborah Ebersold 5,8, 14 70 Elizabeth Brobst 14 71 Maegan Williams = 72 Mimi McMillen 2, 14 a3 Nina Wouk 5 74 John Bartolini - iS Ted Kennel 5,8, 14 76 LeAnne Chism 8, 14 71 Eldon Hiebert - 78 David Marlin 14 79 - Robert Dolan : 14 80 Karen Gray 14 81 Karen Case 4,8 82 Ronda Kay = 83 Angie Sanchez = 84 Mike Link 8 85 Richard Strong 14 86 Vincent Lucid - 87 Chris Renee 5,8, 14 88 Donna Heeney on 89 David Pisaneschi 5, 8, 14 90 David Rhode 4,14 91 Carl Holmgren 14 92 Bill Stockwell 1,5, 8, 14 93 Jack Dean 152,558, 10514 94 Thane Harpole Ts. 14 95 John Wahl 8, 14 96 Daniel Golden 7 97 Mike McKeown (with 11 other signatures on letter) 4,7, 8, 14 98 Henry Lange 1 99 Steve Beardsley 6,7 100 Mitchell Cline 5, 8, 14 101 Hope Cline 5, 8, 14 Each letter is assigned a comment number. Within each letter, each comment or issue is bracketed and assigned a letter code. Responses to those comments are assigned the same letter code, and are provided next to the corresponding comment. Comments and responses are organized by federal agencies, state agencies, special interest groups, and individuals. It is important to note that to avoid repetition, responses have been prepared for each specific comment. Where comments are similar between different commentors, responses are referenced back to the initial common response, or to specific sections of the DEIS. Where appropriate, responses to selected comments have been referenced ahead to the supplemental information provided in Chapter 2; or to Volume II, Mitigation Plan; Appendix A, USFWS Compatibility Determination; or Appendix B, USACE Draft Section 404(b)(1) Evaluation. Southern Intertie Project Chapter 1 — Public Comments and Responses Final EIS 1-12 July 2002 FEDERAL AGENCIES ane & } UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 Pa 1200 Sixth Avenue Seattle, Washington 98101 December 5, 2001 Keply To Ref: 96-0076-RUS Am Of ECO-088 Lawrence R. Wolte USDA - Rural Utilities Service 1400 Independence Avenue SW - Stop 1571 Washingtov, DC 20250-1571 Dear Mr. Wolfe: ‘The Environmental Protection Agency (EPA) has completed our review of the draft Environmental Inpact Statement (FES) for the proposed Southern Intertie Project (CEQ No. 010365) in accordance with our authorities and responsibilities under the National Environmental Policy Act (NEPA) and Scction 309 of the Clean Air Act. The draft EIS evaluates the no action alternative and 2 action altematives to improve the overall Railbelt electrical system reliability and energy transfer capabilitios between the Kenai Peninsula and Anchorage, Alaska, The draft EIS does not identify an agency-preferred alternative. Rased on our review and evaluation of the draft EIS, we have assigned the following ratings based on the environmental impacts of each of the ection alternatives and the adequacy of the impact statement in analyzing and disclosing the effects of the alternatives. Alternative Rating Enstar Route E0-2 (Environmental Objections - Insufficient Information) 1A The EPA's objection to the Enstar Route is noted. A Draft Tesoro Route EC-2 (Environmental Concems - Insufficient Information) Section 404 (by(1) Evaluation Prepared by the USACE Ig ; — — 5 provided in Appendix B of the FEIS, which identifies the No Action LO (Lack of Objections) Tesoro Route alternative as the least damaging practicable Our objections to the Enstar Route Alternative relate to the expected significant and alternative for aquatic resources. See response to 1F (below) irreversible impacts to vegetation and wetlands, birds (eagles and waterfowl, including tcumpeter for more information on the agency-preferred alternatives. swans), large mammals (bears and moose), predators (wolves, lynx), recreation and land use on 1A the KNWR, and visual quality, Additionally, the construction and operation of the Enstar Route Alternative may have substantial and unacceptable impacts (direct and indirect) on an Aquatic Resources of National Importance (ARNI). Finally, there exists a less environmentally damaging alternative (the Tesoro Route) that should be pursued, consistent with the direction of the NEPA. regulations 10 “use alll practicable means...to...avoid or minimize any adverse effects.”. IB [ While it would result in significantly less environmental impacts than the Enstar Route orion on nacycwa rover IB 1c 1D 1E Altemative, we have environmental concems with the Tesoro Route Alternative in that it would also result in significant and irreversible impacts to vegetation and wetlands, birds, large mammals (bears), and visual quality. We believe, however, that many of these impacts could be reduced with the development of more project-specific mitigation measures. Presuming that more project-specific mitigation would be developed, we recommend that the lead and cooperating agencies select and present the Tesoro Route altemative (combined with the Option C crossing of the Turnagain Arm) as the agency-preferred alternative in the final EIS. We have no objections to the No Action alternative as no adverse environmental effects would result with its selection. We believe that additional information should be included in the EIS to provide the public and decision maker with a clearer understanding of the costs, effects, and means of mitigating the effects of the project alternatives. These topics are discussed in greater detail in the attachment to this letter. A summary of our comments and an overall rating of EO-2 will be published in the Federal Register. We have enclosed a copy of the rating system used in conducting our review for your reference. Thank you for the opportunity to provide comments on the draft EIS for the Southern Interie Project. | urge you to contact Bill Ryan of my staff (206-553-8561) at your earliest opportunity to discuss our comments and how they might best be addressed in the final EIS for the project. Sincerely, h Leckrone Lee, Manager . ggraphic Implementation Unit Enclosures ce: Robin West, USFWS, KNWR, Soldotna John Olson, NMFS, Anchorage Suzanne Fisler, ADNR-KRC, Soldotna Glenda Landua, ADFG-KRC, Anchorage Daniel Bevington, KPB, Soldotna John Mohorcich, KPB-KRC, Soldotna Tim Rumfelt, ADEC, Anchorage Jennifer Wing, ADGC, Anchorage Jack Hewitt, Corps of Engineers, Anchorage 1B 1c 1D 1E As a point of clarification, significant and irreversible impacts were not identified for vegetation, wetlands, or large mammals along the Tesoro Route, as shown on Table 2-1 1A (pg. 2-67) of the DEIS. The DEIS identified significant impacts to visual resources, and the potential for significant impacts to birds along the Tesoro Alternative. The mitigation measures identified in the Mitigation Plan, Volume II of the FEIS would substantially reduce the potential for bird collision. Visual impacts to planned development in the Moose Point, Grey Cliffs and Point Possession Subdivisions will be variable as result of locating the Tesoro alternative in the Kenai Peninsula Borough’s planned Transportation Utility Corridor, and the use of selective mitigation to reduce visual contrast. Refer to response 1G (below). See comment IF (below) for more information on the agency-preferred alternatives. See response to 1H (below) regarding costs. Responses are also provided to the attached EPA comments. IF 1G EPA Comments on the Draft Environmental Impact Statement (EIS) for the Southern Intertie Project Introduction a The draft EIS evaluates the effects of two action alternatives as well as the no action alternative. The applicant's proposed project, referred to as the Enstar Route, is comprised of an overhead transmission line from the Soldatna Substation on the Kenai Peninsula through the castern portion of the Kenai National Wildlife Refuge (KNWR) parallel to the existing Enstar pipeline, an undersea cable crossing of the Turnagain Ann, and a combination of underground and overhead cable to the Intemational Substation in Anchorage. The other action alternative, the ‘Tesoro Route, would include overhead and underground transmission cable between the Bernice Lake substation and Point Possession on the Kenai Peninsula, an undersea cable crossing of the Tumagain Ann, and terminate at the Point Woronzof substation in Anchorage. The EIS docs not identify an agency-preferred alternative. Least Damaging Alternative/Preferred Alternative The draft EIS clearly states, in summary form and in detail, that the applicant's proposed project (the Enstar Route) would have significant and irreversible impacts on vegetation and wetlands, birds (cagles and waterfowl, including trumpeter swans), large mammals (bears and moose), predators (wolves, lynx), recreation and land use on the KNWR, and visual quality. The drafl EIS also clearly indicates that selection of the Tesoro Route altemative would result in less overall impacts to biological and environmental resources, particularly those on the KNWR, than the applicant's proposal, While the overall costs of the project would be approximately 15% higher for the Tesoro Route alternative when compared to the Enstar Route, we believe that the additional costs are reasonable when weighed against the significant adverse environmental effects that would be reduced or avoided altogether. Based on this information and the presumption that more project-specific mitigation measures would be developed, we recommend that the lead and cooperating agencies select the Tesoro Route alternative (combined with the L_Option C crossing of the Turnagain Arm) as the agency-preferred altemative in the final EIS. __ Mitigation Measures Regardless of which alternative is ultimately selected, there appear to be additional opportunities to minimize the adverse impacts associated with this project. While the draft EIS describes mitigation measures such as winter construction, underground placement of the transmission line and marking the wires at certain locations, these measures are not described or analyzed sufficiently in the EIS to determine if they will adequately reduce adverse impacts. We suggest that the lead and cooperating agencies, along with the applicant, convene a meeting among interested parties to address mitigation needs for this project. We believe that such a discussion would be a constructive format for identifying information needs and mitigation IF 1G Route preferences and recommendations are noted. A description of the agency preferred alternative(s) is provided in the Summary of the FEIS. The RUS and USFWS have selected the Tesoro Route as their preferred alternative. With regard to route options between Point Possession and the Point Woronzof Substation, the agency preferences vary between the lead and cooperating agencies. RUS has identified route Options D and N. The USFWS has identified Option C as their preferred alternative. The Applicant’s ANILCA application for the Enstar Route is under review by USFWS. A Compatibility Determination has been prepared by USFWS and is included in Appendix A of the FEIS. The USACE has indicated that the Tesoro Route is a less damaging practicable alternative than the proposed Enstar Route (including Options B, C or D and N). A Draft Section 404(b)(1) Evaluation has been prepared and is included in Appendix B of the FEIS. Refer to FEIS Summary Section S.10 — Agency Preferences and Decision to be Made (pg. S-26) for more information. The lead and cooperating agencies, along with the Applicant, have held discussions and convened meetings (March 26 and 27, 2002) among interested federal, state, and local agencies to address mitigation needs and assist in the development of a Mitigation Plan for the Project. The types, locations and effectiveness of the measures are presented in the Mitigation Plan in Volume II of the FEIS. 1G 1H measures. The results of this effort should be integrated into the design of the project and documented in the EIS. Overall, the EIS should provide description of the specific mitigation measures that would be used for the project, the locations where they would be applied, and the effectiveness of the measures in reducing or avoiding adverse affects. As an example, there are numerous placcs in the EIS that indicate that in areas of potential collision hazard, wire would be marked within 1,312 fect of water where there is no forest between open water and the transmission linc. The EIS does not clearly identify where these areas are located nor does it describe how the lines would be marked, the basis for the 1,312 foot distance, or the effectiveness of this method in reducing hird-wire collisions. Consequently, it is difficult to determine whether (or to what extent) the proposed mitigation measure will serve to reduce bird-wire collisions. We recommend that the EIS be revised to disclose specific locations where all the mitigation measures would be applied, along with an assessment of their ability to reduce or climinate adverse effects. While we believe the mitigation practices presented in Appendix D reflect generally good guidelines to reduce effects, the EIS needs more information that allows the public and the decision maker to understand where such practices, particularly the “selective mitigation measures.” would be applied along the intertie alignments currently being evaluated. Because the decisions to be made for the project will be specific to project alignment and effects, the EIS should reflect, with sufficient specificity, mitigation measures that would be used to avoid, reduce, or offset identified impacts. We recommend that the EIS identify the locations where the mitigation measures presented in Appendix D would be applied to demonstrate that all practicable means have been made to avoid or minimize possible adverse effects (see 40 CFR 1500.2(f)). We support the development of a detailed mitigation plan, but we are concerned with the statement in Appendix D that indicates that such a plan would be developed after issuance of any Record of Decision (ROD) for the project. The implementing regulations for NEPA require the ROD to contain a “statement of whether all practicable means to avoid and minimize environmental harm from the selected alternative have been adopted, and if not, why they were not” (see 40 CFR 1505,3(c)). In order to make such a statement, mitigation commitments for the project must be included in the ROD, We recommend that the appropriate, site-specific mitigation that would be committed to in the ROD be developed, evaluated and reported in the EIS. This will ensure that the decision maker will have sufficient information to determine L_ whether all practicable means have been taken of avoid or reduce impacts. Economic Information We strongly recommend that the EIS be revised to include additional cconomic information and analysis related to the construction, operation, and maintenance of the proposed intertie and alternatives to it, beyond the information presented in Table S-2. This information is vitally important in determining whether an alternative is reasonable or practicable, as it must be 1H For additional economic information and analysis including a refined breakdown related to mitigation strategies and the construction, operation, and maintenance of the Project alternatives see Chapter 2, Project Benefits and Costs (Section 2.2.1, pgs. 2-1 to 2-4) Cost and Technical Comparison Discussion of Route Options (Section 2.2.2, pgs. 2-4 to 2-11), and the Mitigation Plan in Volume II of the FEIS. weighed against technical feasibility, environmental effects and other considerations. Economic information is also needed to support decisions not to evaluate alternatives in detail. This 1H information would also serve in determining reasonable mitigation measures, particularly the use of underground lines to offset potential visual, safety or wildlife impacts. We recommend that the EIS present a breakdown of the construction, operations and maintenance costs to provide the public and the decision maker with a clearer understanding of how these costs would vary with cach alternative. A discussion of the differing costs should also be presented in the EIS. Alternatives Eliminated from Detailed Study The EIS should provide additional information that supports the elimination of the following information. fe Underground Transmission Lines - While the EIS does indicate that costs associated with underground transmission is four to five times greater than that of overhead line, and that repairing damaged underground lines would take longer and be more costly, the EIS should provide a clear justification for why this approach has been eliminated from consideration (except where required by regulation), Consistent with direction in the implementing regulations for NEPA to “assess the reasonable alternatives...that will avoid or minimize any possible adverse actions,” we believe that the use of underground lines would serve to minimize or avoid adverse visual, safety (aircraft collisions), and wildlife (bird collisions, habitat fragmentation) effects. Consequently, climination of the Bt use of underground lines should be supported with information that demonstrates that use of such lines is prohibitively costly and/or technically infeasible, thereby making it an unreasonable alternative to pursue further in the EIS. We recommend that the EIS include economic information related to installation, operation and maintenance of underground lines (contrasted with the same economic information for overhead lines), as well as an assessment of the types of failures (and expected frequencies of such failures) for underground lines (again, contrasted with overhead lines). This analysis should also evaluate failures of underground lines and amounts of time and costs needed to repair them in the context of having a second, redundant transmission system (the existing transmission line). This information will provide the public and the decision maker with a clearer understanding of the technical and fiscal trade-offs associated with the two transmission options. This information will also aid in determining the reasonableness of using underground lines in select sections of the project as mitigation for visual, safety or wildlife impacts. Battery Energy Storage Systems (BESS) - The use of a BESS would eliminate the need to construct a new transmission line entirely and, consequently, would be consistent with the VW direction in the NEPA implementation regulations to “use all practicable means...to...avoid or minimize any possible adverse effects..." (See 40 CFR 1500.2(f). Therefore, we recommend that the discussion presented in Section 2.2.1 of the draft EIS be revised to more clearly demonstrate that pursuit of this alternative is technically and/or economically infeasible. We suggest that the EIS be revised to clarify the ll lJ Comment noted. A discussion of underground construction has been included in Section 2.2.3 (pgs. 2-11 to 2-14) of the FEIS. This statement is incorrect. A BESS would not eliminate the need to construct a new transmission line. Refer to Chapter 2, Section 2.2.4 (pgs. 2-14 to -17) of the FEIS for more information. IK discussion of the technical viability of the BESS by indicating if (and/or how) the to make this alternative viable. Economic information related to installation, operation and maintenance of BESS should also be included and contrasted with other alternatives. IJ i technical difficulties (system instabilities, 3 BESS on a single system) could be overcome Effects Analyses Page 3-41 of the draft EIS describes the use of snow and ice making for creating a winter cover over the ground. Sources of water for this activity should be identified and the effects associated with their use assessed, especially dewatering of areas important for over-wintering fish, mammals and birds, Mitigation measures should be developed to offset any adverse effects from this activity. Page 3-72 of the draft EIS asserts that waterfowl! north of the Captain Cook State that use freshwater habitats during the day and raft on Cook Inlet at night. During the winter large rafts of resting waterfowl can be observed on Cook Inlet. These birds could be at special risk of collision with an overhead transmission line because they are flying at dusk into a setting sun and may be unlikely to see transmission lines. This potential effect should be evaluated in the EIS. Recreation Area would not likely cross the transmission line route due to absence of lakes, ponds IL or saltmarsh west of the Tesoro route. The draft EIS does not seem to take into account birds construction and maintenance activities. We recommend that the EIS be revised to describe the measures that have been taken to identify bear denning sites. The EIS should also identify the f Pages 3-74 and 3-90 indicate that bear dens could be potentially disturbed during winter 1M measures that would be employed to avoid these sites, the edge of the Chickaloon Flats to reduce the likelihood of bird strikes. The EIS should identify any other locations where this approach would be employed. We recommend that the EIS include the rationale for selecting this mitigation measure for the Chickaloon Flats along with a discussion of why this method (or others) does not appear to be proposed for use elsewhere in the L Page 3-88 of the draft EIS indicates that shorter power poles (70 feet) would be uscd at IN project alternatives. important migration corridors of birds and terrestrial mammals along with identified potential collision hazard areas. With the identification of these areas, relative to the intertie alignments currently under consideration, the public and the decision maker will be provided with a clear understanding of the locations where effects to wildlife are likely to be the greatest. This will serve to focus the identification and evaluation of mitigation measures needed to eliminate or reduce those effects. The assessment of the effectiveness of these measures should be included in the EIS. Identify important migration corridors/potential collision hazard areas We recommend that the EIS be revised to include maps that identify locations of 10 IK IL 1M IN 10 If snow conditions are insufficient to create a winter cover over the frozen ground to reduce impacts to wetland vegetation, snow and/or ice would be obtained off site and transported to the Project site. In the case of a warm winter where frozen conditions are insufficient to mitigate impacts to aquatic resources, construction would be postponed until appropriate conditions exist. Winter concentrations of waterfowl using Cook Inlet are likely sea ducks, which would not be expected to use fresh water resources at that time of the year. However, wintering waterfowl (primarily goldeneyes, mergansers, and mallards) have been observed in ice-free portions of the Kenai River, and in Cook Inlet near the mouth of the Kenai River. Presumably these birds move between Cook Inlet and the river, although they would not be expected to routinely cross the Tesoro alternative transmission line, which begins at the Bernice Substation, which is approximately 11 miles north of the mouth of the Kenai River in the Nikiski area. Refer also to Chapter 2, Section 2.2.8 (pgs. 2-32 to 2-34) of the FEIS. There is no written protocol for conducting preconstruction den surveys or avoiding bear dens. Den surveys on the KNWR are conducted using an airplane with spotters flying at 700-800 feet. Measures to avoid bear dens would be based on characteristics of the site, but may include avoidance of an active den area during the denning season. The only migration corridor currently identified along either route is associated with the waterfowl concentration area at Chickaloon Bay. Once staging has maximized, birds leave the bay, flying south along the Mystery Mountains toward Seward. This particular migration route would make these birds more susceptible to transmission line strikes, hence the recommendation for lower poles at this location on Links E9 and E10 (70” in height) so that the top of the pole and wires would be at and below tree height. See also Mitigation Plan in Volume II of the FEIS and FEIS Section 2.2.8 (pgs. 2-32 to 2-34). The only migration corridor currently identified along either route is associated with the waterfowl concentration area at Chickaloon Bay. Although it is known that land mammals (moose, bears, wolverine, etc.) migrate east and west (between lowlands and the Mystery Mountains), no specific migration routes have been identified at this time. For additional information regarding potential collision hazard areas and mitigation measures including seasonal construction, refer to the Mitigation Plan in Volume II of the FEIS and FEIS Section 2.2.8 (pgs. 2-32 to 2-34). 2A 2B Ory UNITEU STATES ENVIRONMENTAL PROTECTIONAGENCY REGION 10 } ALASKA OPERATIONS OFFICE Room §37, Federal! ma 222 W. 7* Avonuo, #19 Anchorage, Alaska 99613-7688 December 3, 2001 Colonel Steven T. Perrenot Alaska District Engineer U.S. Army Corp of Engineers P.O, Box 898 Anchorage, Alaska 99506-0898 Attn: Jack Hewitt Re: Public Notice 2-991212, Turnagain Arm 45 Dear Colonel Perrenot: ‘This letter responds to yous public notice received on October 18, 2001 of a proposal by the Intertic Participants Group of Anchorage, Alaska, to build an electrical transmission line from Soldotna to Anchorage through the Kenai National Wildlife Refuge. Based upon the likelihood that the project could have substantial and unacceptable impacts on aquatic resources of national imponance, and that there are alternatives that would have less adverse impact, we recommend that you deny the permit. Pursuant to Part IV, Paragraph 3(a) of the August 11, 1992, Memorandum of Agreement between our agencies, we hereby notify you that, in our opinion, the proposed project may have substantial and unacceptable impacts on an aquatic resource of national importance (ARNI). Our concems regarding this project involve the likely effects on wi fe populations and habitat i in and surrounding the Kenai National Wildlife Refuge Thy Environmental Impact Statement (DEIS) for this project esa documents that a less damaging alternative exists. Therefore, the project does not comply with the 404(b)(1) Guidelines. These concems are expanded upon below. Ce iance wi 4 Significant Impacts: The DEIS clearly states, in summary form and in detail, that the proposed project will have significant and irreversible impacts on aquatic resources. Because the impacts are clearly spelled out in the DEIS we will not list them all here. Please refer to pages S-16 through $-22 of Volume | of the DEIS for a summary table of impacts due to this project. Detailed descriptions are given in Volume 1, Chapter 3, The 404(b)(1) Guidelines require that no discharge of dredged or fill material be permitted which will cause significant degradation of waters of the United GD prmnea on Recycled Paper 2A 2B Refer to comment response 1A — EPA letter (12/05/01). Refer to comment response 1 A — EPA letter (12/05/01). 26 2D 2E 2F 2G 2H States (40 CFR 230.10(c)). Therefore, a permit for this project should be denied. Altematives: The DEIS further documents that a practicable alternative exists that will have less adverse impact on the aquatic ecosystem, The above referenced portions of the DEIS contain a comparison of the proposed “Enstar” route with the alternate “Tesoro” route. The information shown clearly documents that the Tesoro route is less damaging. The 404(b)(1) Guidelines require that no discharge be permitted if there is a practicable alternative which would have less adverse impact on the aquatic ecosystem (40 CFR 230.10(a)). Therefore, a permit for the proposed project should be denied. tional Concerns Regardless of which alternative is selected, there appears to be additional opportunity to minimize the adverse impacts associated with this project. The DEIS describes mitigation measures such as winter construction, underground placement of the transmission line and marking the wires at certain locations. Additionally, we are concemed that these measures are not well cnough described in the DEIS. We are unable to determine if mitigative measures will adequately reduce adverse impacts. Further discussion is needed regarding mitigation for this project. We suggest that, before a permit is issued, the applicant convene a dialogue among interested partics to address mitigation needs for this project. We belicve that such a discussion would be a constructive format for identifying information needs and mitigation measures. In the meantime, we have the following specific questions and points: 1) Are there specific migration routes across the project site for birds migrating from the Kenai Peninsula, and from other locations? Where are these routes? What birds are using them and when? This information is important when identifying appropriate mitigation measures. 2) The power poles at Chickaloon Bay are described as being tree height (70 feet) to reduce the likelihood of bird strikes. At what other locations is this method being proposed? Why is this method not proposed for the entire project? 3) The DEIS describes the use of snow and ice making for creating a winter cover over the ground. We are concemed that this activity could de-water areas important for overwintering fish, mammals and birds. Sources of water for this activity should be identified and the effects associated with their use assessed. 4) The DEIS asserts that waterfowl! north of the Captain Cook State Recreation Area would not likely cross the transmission line route due to absence of lakes, ponds or saltmarsh. The DEIS fails to take into account birds that use freshwater habitats during the day and raft on Cook Inlet at night. During the winter, large rafts of resting waterfowl can be observed on Cook Inlet. These birds could be at special risk of collision with an overhead transmission line because they are flying at dusk into a setting sun and may be unlikely to sce transmission lines. This potential effect should be evaluated. 5) What measures have been taken to identify bear denning sites? What measures would 2¢ 2D 2E 2F 2G 2H Refer to comment response 1G — EPA letter (12/05/01). Refer to comment response 10 — EPA letter (12/05/01). Refer to comment response 1N — EPA letter (12/05/01). Refer to comment response 1K — EPA letter (12/05/01). Refer to comment response 1L — EPA letter (12/05/01). Refer to comment response 1M — EPA letter (12/05/01). 21 [e be employed to avoid these sites? We feel that it is important that the information above be provided before a permit is issued, Other interested parties undoubtedly have concerns we have not addressed. Again, we suggest that the applicant convene a series of gatherings to identify additional information needs and mitigation measures. In summary, the proposed project does not comply with the 404(b)(1) Guidelines because ; it will result in significant adverse impacts to aquatic resources of national importance on the Kenai National Wildlife Refuge. It also fails to comply because there are practicable alternatives 7 to the proposed project that will have less adverse impacts. Additional information is needed to understand and identify mitigation opportunities to minimize adverse impacts of the project. Thank you for the opportunity to comment on this project. If you have any questions regarding this letter, please call me at 271-5083, or Phil North at the Kenai River Center in Soldotna at 260-4882. Marcia Combes, Director Alaska Operations Office cc: Robin West, USFWS, KNWR, Soldotna John Olson, NMFS, Anchorage Suzanne Fisler, ADNR-KRC, Soldotna Glenda Landua, ADFG-KRC, Anchorage Daniel Bevington, KPB, Soldotna John Mohorcich, KPB-KRC, Soldotna Tim Rumfelt, ADEC, Anchorage Jennifer Wing, ADGC, Anchorage Don Martin, EPA, Seattle Judith Lee, EPA Seattle Phil North, EPA-KRC, Soldotna 21 Refer to comment responses 1A, 1G, IF — EPA letter (12/05/01). United States Department of the Interior OFFICE OF THE SECRETARY Office of Environmental Policy and Compliance 1689 C. Screet, Room 119 Anchorage, Alaska 99501-5126 ER 01/893 November 27, 2001 Mr. Lawrence R. Wolfe USDA - Rural Utilities Service 1400 Independence Ave. SW - Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe: 3A Comment noted. Statement for the Southem Intertie Project: Kenai Peninsula to Anchorage, Alaska. We have no 3A [ Department of the Interior has reviewed the September 2001, Draft Environmental Impact comments to offer at this time. Sincerely, ‘a Paaeaee Pamela Bergmann Regional Environmental Officer - Alaska 4A Federal Aviation Administration --Original Measage-- From: Clarence Goward (mailto:Clarence.Goward@faa.gov) Sent: Monday, December 10, 2001 9:29 To: lwolfe@rus.usda.gov Subject: FW: Southern Intertie DEIS have been scanned for s. This E-Mail and or attachment: and found free of known viru: -----Original Mussage- From: Goward, Clarence Sent: Monday, December 10, 2091 9:06 AM To: ‘Larry Wolf’ Subject: Southern Intertie DELS Larry, I have reviewed the Draft FIS for the Southern Intertie Project. No formal changes to air traffic routes or procedures that would require additional environmental documentation are anticipated as a result of this project. Wwe will further evaluated it for potential hazard to air navigation upon receipt of the Notice of Proposed Construction or Alteration, FAA Form 7460-1, once an alternative is selected. Possible marking, lighting or other mitigation required. measures may bi hanks for the opportunity to comment on thia project. cG Ir 4A See the General Response to Issue 3 in Chapter | (pg. 1-4) of the FEIS. National Marine Fisheries Service Western Alaska Field Office 222 West 7" Avenue, #43 Anchorage, Alaska 99513 eae Date: 1a, hi Total Pages (Including cover): 2 » FAX Laveey holbe- To: ca hl Auideesons From: Mate ¢ « 4\ rte Phone: Phone: (907) 271-5006 Fax: Fax: (907) 271-3030 Comments: hewn € (262) 720 0%20° Bria (GA, Pb ~ 390/ 5A SB SC Dec.12- 2001 12:27PM NMFS Nosdei Fe ee ny NMFS attended a pre project workshop and offered informal comments. Also, we have looked over the DEIS package. Our comments are summarized as follows: Intertie Corridor ae NMFS prefers the line(s) be located within the utility corridor A (that was established for utilities) along L_the eastem edge of Cook Inlet and cross at 8, C, or D. Anadromous Waters (Salmon) Any corridor: any anadromous water (Chickaloon River or other stream) crossing should first be avoided or be drilled under the bed or suspended as not to influence the channel. Anadromous fish are commercial resources and are also important prey source for Beluga whales. . Cook Inlet Beluga Whales a We recommend timing and operations of inwater work or line laying follow: - low tide window for construction activities on/near tidal flats. - an observer will be posted aboard the ship during laying operations. The observer will keep lookout for beluga whales. Operations cease when beluga whales are sighted within 2,000 feet of the activity. |_Activities can resume when whales leave . NMFS expects that beluga whales will migrate through the area fairly quick and will be moving on the head of the ebb tide and the tail of the flow tide. This email faxed to: Larry Wolf, USDA, at (202) 720-5093; Brain Anderson, USFWS, (907) 786-3901. SA SB SC Route preference is noted. Refer to responses to comment 1F — EPA letter (12/05/01). Anadromous fish streams are protected under state law. Impacts will be avoided by spanning or drilling under the streams. See DEIS Section 3.5.5, Freshwater Environment, Environmental Consequences and Mitigation, Anadromous Fish (pg. 3-100). See also DEIS Table 3-2, Impacts and Mitigation Common to Most Alternative routes (pg. 3-15), and the Mitigation Plan, Volume II, FEIS, which includes specific locations of the anadromous streams crossed by the Project alternatives. Impacts to beluga whales in context with transmission line alternatives are discussed on pgs. 3-115 through 3-117 of the DEIS. For an update on Beluga whales refer to Chapter 2, Section 2.2.5 (pgs. 2-17 to 2-18) of the FEIS. 6A E>, XA United States Department of the Interior BUREAU OF LAND MANAGEMENT ANCHORAGE FIELO OFFICE 6881 Abbott Loop Road Anchorage, Alaska 99507-2599 2801 (040) shh December 13, 2001 Lawrence R. Wolfe USDA - Rural Utilities Service 1400 Independence Ave. SW - Stop L571 Washington, DC 20250-1751 Re: Southern Intertie Project Dear Mr. Wolfe, Thank you for the opportunity to comment on the DEIS for the Southem Intertie Project. BLM administers scattered tracts of public land between Anchorage and terminus of the transmission line on the Kenai Peninsula. Please beware that if the final alignment of the transmission line crosses lands administered by BLM, a right-of-way pursuant to sections 303 and 310 of the Federal Land Policy and Management Act (FLPMA) will be required. In the event a FLPMA right-of-way is required, NEPA documentation will have to meet BLM standards. You may reach me at my letterhead address or at 907-267-1252 if you have any questions or concems regarding possible BLM involvement in this project. Sincerely, Stuart Hirsh, CPL Group Manager, Realty 6A No lands administered by the BLM would be crossed by either the Enstar or Tesoro alternatives. 7A United States Department of the Interior FISH AND WILDLIFE SERVICE Ecological Services Anchorage 605 West 4th Avenue, Room 62 Anchorage, Alaska 99501-2249 WAES DEC -4 xOr Colonel Stephen T. Perrinot District Engineer, Alaska District U.S. Army Corps of Engineers P.O. Box 898 Anchorage, Alaska 99501 Re: 2-991212 Turnagain Arm 45 Dear Colonel Perrinot: We have reviewed this Public Notice concerning the application of the Intertie Participants Group (IPG) for authorization, under Section 404 of the Clean Water Act, to proceed with implementation of activities identified within the Draft Environmental Impact Statement (DEIS) for the Southern Intertie Project. We note “this Public Notice only describes the applicant's preferred alternative” (page 2, PN2-991212, emphasis added), referred to as “the Enstar Route.’ : As described, this project proposes construction and placement of a 74-mile electrical transmission line stretching between Soldotna on the Kenai Peninsula, and the City of Anchorage. The described Enstar Route crosses the Kenai National Wildlife Refuge, and the IPG has applied to the Service for a right-of-way permit to construct the proposed project across refuge lands. Evaluation of the application is governed by regulations at 43 CFR Part 36 implementing Title X1 of the Alaska National Interest Lands Conservation Act (ANILCA), which prescribes a process for Federal authorization of transportation and utility systems across Conservation System Units. For this project, a memorandum of understanding (May 2000) was established among the Corps, Service, and Rural Utilities Service regarding agency cooperation toward compliance with the National Environmental Policy Act (NEPA) and ANILCA requirements. As a result, in addition to the Corps’ evaluation of the applicant's proposal through the Section 404 process, three other Federal decision points are pending: NEPA through the EIS and its subsequent Record of Decision; the Refuge Compatibility Determination; and the Title XI right-of-way process. Given that the Service has not concluded its evaluation of the applicant's proposal and alternatives to that proposal, it would not be appropriate for the Service to render a final recommendation to the Corps through our comments in response to the current Public Notice. We do recommend that the Corps reopen the public comment period following issuance of the ROD, allowing the Service and the public an additional opportunity to provide comments and recommendations TA Recommended activity is permitting-related and is not directly related to the NEPA process. 7B The following comments are submitted in accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended: 16 U.S.C. 661 et seq.) and constitute the report of the Department of the Interior. They are also intended for use in your determination of 404(b)(1) guidelines compliance (40 CFR 230) and in your public interest review (33 CFR 320.4) relating to protection of fish and wildlife resources. Fish and Wildlife Resources and Project Impacts Identified in the DEIS The DEIS identifies significant adverse impacts to fish and wildlife resources associated with the proposed Enstar Route through the Kenai NWR and its associated connecting routes into the Anchorage metropolitan area. These impacts are summarized briefly as follows: Potential increased human access along the Enstar Route would adversely affect brown bear, wolf, and lynx. The presence of the transmission line would preempt the ability of refuge managers to apply habitat management programs for moose and other species, such as prescribed burning. Seasonal migration between the Kenai Mountains and lowlands could be adversely affected for brown bear and other species, The Enstar Route crosses seven anadromous fish streams on the Kenai Peninsula, further affecting high quality brown bear habitat. Unacceptable impacts to wetlands and the Anchorage Coastal Refuge would occur as the route emerges from Turnagain Arm and is 7B routed into any one of several Anchorage based connection points. Additional possible impacts include an increase in pollution or eroding sedimentary runoff from the expansion of paved and unvegetated surfaces. Habitat loss will also result from brush removal along the path that will be maintained for safety purposes in both the Kenai and Anchorage areas. Shrub, forest, and riparian habitat of breeding songbirds may be lost to transmission line route clearing, Large spruce and cottonwood trees which serve as perch sites for bald eagles and smaller birds may be lost. Bald eagles, which are protected under the federal Eagle Protection Act (16 U.S.C. 668-668c), may nest in or near the proposed construction corridor. Bird strikes with the transmission lines and associated towers are a potential source of mortality. Finally, the Enstar Route submerges at Chickaloon Bay, a beluga whale concentration and suspected calving area. Threatened and Endangered Species Based on our records, we believe there are no federally listed or proposed species and/or proposed or designated critical habitat under the responsibility of the US Fish & Wildlife Service within the proposed project area. In view of this, we believe that the requirements of section 7 of the Endangered Species Act (Act) have been satisfied for these types of actions. However, obligations under section 7 of the Act must be reconsidered if: (1) new information reveals project impacts that may affect listed species or critical habitat in a manner not previously considered; (2) this action is subsequently modified in a manner which was not considered; or (3) new species are listed or critical habitat is determined that may be affected by the identified action, Recommendations We concur with the finding in the DEIS that the Tesoro Route (Routes A and C) is the environmentally preferred alternative. Comment noted. Because the subject Public Notice does not request consideration or approval of alternatives other than the Enstar Route, we are not providing specific or detailed recommendations for those alternatives at this time. However, in keeping with the provisions of the Fish and Wildlife Coordination Act, we offer the following generic early suggestions for consideration should a new or revised Public Notice addressing other alternative routes be issued for this project: 7B [el Migratory birds utilize the coastal zone and areas of the Kenai Peninsula as a staging area and transit route to the Turnagain Arm en route to Prince William Sound and points south, Bird strikes into transmission towers and suspended power lines have become a serious source of mortality for many migratory bird 7c species. Information describing high use routes along the Kenai coast and peninsula may be available and useful for developing mitigation measures for transmission line placement and limited burial of the lines to reduce the likelihood of such mortality, Staff from the Kenai NWR, the Anchorage Ecological Services office, and our Migratory Bird Management Office remain interested in working with the applicant and your staff to develop specific and detailed mitigation measures to protect migratory species across these regions. . Site specific mitigation should be devised to reduce the likelihood of disturbance or taking of bald eagle nests and disruption of swan breeding areas. Measures to reduce or eliminate impacts to subtidal and intertidal zones and the Anchorage Coastal Wildlife Refuge should be carefully considered. In this regard, we note that Route B and especially Route C across the Tumagain Arm, both with landfalls at Point Woronzof, pose relatively lower impacts to sensitive natural resources and wetlands within the Anchorage Bowl, than any other alternatives, 7D The Service prefers ultimate selection of the proposed Tesoro Route Alternative "C" for the intertie crossing of Turnagain Arm and subsequent landing in Anchorage. Option "C" crosses Turnagain Arm directly from Pt. Possession to a landing at the Pt. Woronzof Substation. Option "C" adequately minimizes impacts to wetland and upland environments by: 1) routing the cable subsurface in its entirety, and avoiding land crossings across Fire Island (Option "B") and Kincaid Park (Option "D"), and 2) minimizing the length of the Tesoro Alternative to 61.3 miles versus 63.2 miles for Option "B" and 62.0 miles for Option "D". We believe that this alignment accommodates the project purpose while minimizing impacts to the natural environment and our trust resources. ll Conclusions: Given that the Service, through the final EIS and ROD, Title X1 right-of-way process and Refuge Compatibility Determination, will render a decision on the acceptability of the applicant's proposed route in the next several months, it would be premature to formalize a recommendation to the Corps on the acceptability of one specific alternative at this time. The following conclusions are preliminary, and could be modified by determinations made in the Service’s processes cited above. 7C 7D See FEIS Section 2.2.8 (pgs. 2-32 to 2-34) and Mitigation Plan in FEIS Volume 2. RUS’s preferred alternative is provided in FEIS Summary Section S.10 — Agency Preferences and Decisions to be Made (pg. S-26). TE We believe the project as proposed will have significant adverse impacts on important fish, wildlife, and habitat resources, and we are advising you in accordance with the procedural requirements of the 1992 404(q) MOA, Part IV.3(a), that the proposed work may result in substantial and unacceptable impacts to aquatic resources of national importance, Moreover, we agree with the DEIS that the Tesoro Route (Routes A and C) is the environmentally preferred alternative for this project purpose. At this time, three other federal decision points as referenced above are pending: NEPA through the EIS and its subsequent Record of Decision; the Refuge Compatibility Determination; and the Title XI right-of-way process. Therefore, we recommend that the Corps hold its permitting process in abeyance pending completion of these other decision points, as each will affect the chosen altemative, and hence, what action should be proposed in the Corps Public Notice. Public comments on the DEIS are due in December 2001. Those comments will be considered and incorporated as appropriate in the final EIS. We expect that the Compatibility Determination and Service right-of-way decision will be attached to the final EIS, which is scheduled to be published in June 2002. At that point, it would be reasonable for the Corps to provide an additional public comment period, preferably with a reissuance of the Public Notice if the applicant is willing to pursue authorization for another alternative route. Weare willing to meet with your agency and the applicant again to explore practicable alternatives where mitigation of fish, wildlife, and their habitat values can be achieved, and to achieve a schedule more in line with the ongoing NEPA process. If you intend not to accept this recommendation, please advise us before permit issuance in accordance with the Memorandum of Agreement of 1992 between our Departments. If you have specific questions about our concems or wish to discuss project modifications or permit conditions, please contact Mr. Dana J. Seagars, Wildlife Biologist, at 271-2781, or me at (907) 271-2787. Sincerely, nc ial Ann G. Rappoport Field Supervisor cc: NMFS, ADFG, EPA, Applicant TE Ue Comment noted. A Draft Section 404(b)(1) Evaluation prepared by the USACE is included in Appendix B of the FEIS, which identifies the Tesoro Route alternative as the least damaging practicable alternative for aquatic resources. TAA 7.AB gO, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY : , REGION10 &! 4200 Shah Avenue ; Seattle, WA 98101 DEC 1 9 2001 ecRIVED Reply To ‘At Of BCO-083 JAN 9 1 I ‘ eas Bite, Corps of Colonel Steven T. Perrenot Alaska District Engineer U.S. Army Corp of Engineers P.O, Box 898 Anchorage, Alaska 99506-0898 Attn: Jack Hewitt Re: Public Notice 2-991212, Turnagain Arm 45 Dear Colonel Perrenot: ‘This letter responds to your public notice received on October 18, 2001 of a proposal by the Intertie Participants Group of Anchorage, Alaska, to build an electrical transmission line from Soldotna to Anchorage through the Kenai National Wildlife Refuge. Based upon the likelihood that the project could have substantial and unacceptable impacts on aquatic resources of national importance (ARNI), and that there are alternatives that would have less adverse impact, we recommend that you deny the permit. Pursuant to Part IV, Paragraph 3(b) of the August 11, 1992, Memorandum of Agreement (MOA) between our agencies, we hereby notify you that, in our opinion, the proposed project will have substantial and unacceptable impacts to an ARNI. Our December 3, 2001 letter included detailed, site-specific information supporting our position that the aquatic ecosystem on the Kenai National Wildlife Refuge constitutes an ARNI. ‘The Draft Environmental Impact Statement (DEIS) prepared by the applicant clearly outlines an alternative to the proposed powerline route (the Enstar Route). The DEIS describes the alternative (the Tesoro Route) as being practicable and environmentally less damaging. We also Suggest that mitigation to offset the impacts associated with Tesoro Route is necessary. We are available for discussion about this with all interested parties, atic resources. We therefore maintain our recommendation that you deny a permit. In 71¢ [= As proposed, we believe that this project will result in an unacceptable loss of valuable j aq accordance with the MOA, please notify me if you choose not to accept our recommendations. 7.1A Refer to comment response 1A — EPA letter (12/05/01). 7.1B Refer to comment responses IF and 1G — EPA letter (12/05/01). 7.1C Comment noted. We are willing to meet with your office, and/or the applicant.and other resource agencies, to attempt to resolve these issues. Please feel free to call me, at (206) 553-0479 to discuss this matter, or have your staff contact Mr. Phillip North, at (907) 283-6608. Sincerely, Antani Regional Administrator cc: ADEC, Anchorage ADBG, Anchorage ADNR, Kenai River Center, Soldotna ADGC, Anchorage EPA, Wetlands Division, Washington, D.C. FWS, Ecological Services, Anchorage NMBS, Anchorage Kenai Peninsula Borough, Soldotna STATE AGENCIES 8A STATE OF ALASKA epsom P.O, BOX 196900 DEPARTMENT OF TRANSPORTATION AND PUBLIC FACILITIES ANCHORAGE, ALASKA 99519-6900 (TOD 269-0473) CENTRAL REGION - PLANNING (907) 269-0520 (FAX 269-0521) November 26, 2001 Re: Turnagain Arm 45 Reference No: 2-991212 RECEIVED Mr. Jack Howitt U.S. Army Corps of Engineers ee Alaska District v Regulatory District (1145b) Aluata Diatlet, Compa of Engine PO Box 898 Anchorage, Alaska 99506-0898 Dear Mr, Hewitt: The Department of Transportation and Public Facilities (ADOT&PF) has reviewed the proposed electrical transmission line inter-tic between the Kenai Peninsula and the City of Anchorage. The preferred alternative presented in the Application for Permit has the potential for impacting all three trail alternatives for the South Extension of the Coastal Trail. Further, conflicts with overhead cable, underground cable, submarine cable and transition stations would occur at the following locations presented in the Draft Environmental Impact Statement: Point Campbell/Kincaid Park (Routes D & N) Victor Road/Klatt Road (Routes G and J) Oceanview Park/ARRC Corridor (Routes H and K) Potter Marsh/Old Seward Highway (Routes | and M) SS Exact location of this electrical transmission line inter-tie would have to be carefully coordination with the Department, because of our inhcrent interest and potential impacts to our facilities, Thank you for the opportunity to comment on this permit application. Sincerely, D> ares Von ~ Jennifer Wilson, AICP Regional Planning Manager SLC:bh ce; Jim Childers, P.E., Preliminary Design & Environmental Diana Rigg, AICP, Transportation Planner Bill Strickler, Chief, Utilities 8A Refer to comment response 1 1A — Alaska DOT and PF letter (12/04/01). STATE OF ALASIE [moe onme OFFICE OF THE GOVERNOR | OFFICE OF MANAGEMENT AND BUDGET DIVISION OF GOVERNMENTAL COORDINATION @ SOUTHCENTRAL REGIONAL OFFICE CENTRAL OFFICE Gi PIPELINE COORDINATOR'S OFFICE 580 W. 7TH AVENUE, SUITE 1660 PO. BOX 110030 411 WEST 47H AVENUE, SUITE ANCHORAGE. ALASKA 99501 JUNEAU, ALASKA 99811-0030 ANCHORAGE, ALASKA 99501-2343 PI: (907) 869-747 Q/FAX: (907) 269-908 1 PH: (907) 468-3502*AX: (907) 485-3076 PH: (907) 271-431 /FAX: (907) 272-9829 December 5, 2001 OF-AISLH Lawence R. Wolfe Senior Environmental Protection Specialist USDA, Rural Utilities Service Engineering and Environmental Staff, Room 2240 1400 Independence Ave. SW, Stop 1571 Washington, DC 20250-1571 Dear Mr. Wolfe SUBJECT: Southern Intertie Project Draft Environmental Impact Statement (DEIS) Alaska Coastal Management Program - Preliminary Comments The Division of Governmental Coordination (DGC) has coordinated a State agency review of the Draft Environmental Impact Statement (DEIS), including the US Army Corp of Engineers (COE) permit public notice Tummagain Arm 45. The US Department of Agriculture Rural Utilities Service (RUS), in cooperation with the US Fish and Wildlife Service and the COE, has prepared the DEIS to satisfy the requirements of the National Environmental Policy Act (NEPA). BACKGROUND The NEPA document is necessary, in part, because the applicant (Intertic Participants Group) has filed for a right of way across the Kenai National Wildlife Refuge (KNWR) to construct a 138kV transmission line and associated facilities between the Soldotna Substation on the Kenai Peninsula and the International Substation in Anchorage. The DEIS examines three alternatives in detail: the no action; the applicant’s proposal of constructing a new 73-mile-long transmission line between the Kenai Peninsula and Anchorage along and adjacent to the existing Enstar pipeline route through the KNWR; and the alternative of constructing a new line between the Kenai Peninsula and Anchorage along the Tesoro pipeline route. The two action alternatives would require permits subject to review for consistency with the Alaska Coastal Management Program (ACMP). No State or federal agency can issue an authorization before DGC issues the final consistency determination. The DGC will coordinate a consistency review upon receipt of a ©) wvetetonreeyoa supe 9A 9B DEIS Souther Intertie Project 2 December 5, 2001 signed consistency certification statement and supporting information, and publishing of all necessary public notices. The DGC has coordinated this review to preliminarily address potential ACMP consistency issues of this project as well as issues related to the Alaska National Interest Lands Conservation Act (ANILCA). The comments in this letter do not necessarily represent a consensus among 9A review participants and thus are organized to first, provide State of Alaska agency comments, followed by comments of the Municipality of Anchorage and Kenai Peninsula Borough coastal districts, and then finish with ANILCA-related comments. STATE AGENCY COMMENTS The Alaska Department of Fish and Game (ADF&G) considers that the placement of the transmission line along the Enstar Route will have significantly more fish and wildlife impacts than the placement of the line along the Tesoro Route. Route segments A and C are the alternative route segments that will have the least impact to fish and wildlife resources. The ADF&G is also concerned that the DEIS does not adequately address potential impacts and permitting requirements for the submarine routes within the Anchorage Coastal Wildlife Refuge. The development of the Enstar route would likely have relatively more detrimental impacts on brown bears. The Interagency Brown Bear Study Team (IBBST) has recommended against the Enstar route due primarily to habitat fragmentation and human access to the developed transmission line corridor. Brown bears require large expanses of unfragmented habitat and the Enstar corridor bisects the seasonal migratory routes of brown bears moving between mountain and lowland habitats. The development of the Enstar transmission line route would likely result in increased human access to the brown bear habitat which may increase the number of brown bears killed in defense of life or property. Waterbirds will also be subjected to impacts by the location of the transmission line in areas adjacent to waterfowl concentration areas, such as the Chickaloon Flats and the Anchorage Coastal Wildlife Refuge. The Enstar route will cross the eastem portion of Chickaloon Flats, which is heavily utilized by waterbirds as a spring and fall staging area as well as a nesting concentration area, Limiting construction activities in the Chickaloon Flats to the period from October 15 through April 1 will mitigate construction impacts, however; waterbirds will be susceptible to an increased frequency of collisions with transmission lines, guy wires, static lines and towers for the life of the project because these structures will be elevated above the 9B surrounding terrain. The Enstar route has more anadromous fish streams within the corridor when compared with the Tesoro route. The ADF&G recommends that all stream crossings, regardless of route selection, be conducted on permanent bridges placed to accommodate construction traffic and all future traffic by maintenance vehicles or general motorized vehicle use by the public. Further explanation on RUS’s preferred alternative is provided in FEIS Summary Section S.10 — Agency Preferences and Decision to be Made (pg. S-26). In areas where submarine route alternatives are within the ACWR, installation of submarine cables will be horizontal directionally drilled under the vegetated tidal flats, and project facilities will be constructed and be consistent with the requirements of the Anchorage Coastal Management Plan as specified in the DEIS on pgs. 3-129 — 3-130. Submarine transition stations will be located inland, outside of the ACWR. Project team members met with the IBBST in 1999 to discuss potential impacts to brown bears (pg. 3-61), and the DEIS acknowledges that the Enstar Route could result in increased defense of life and property deaths (pg. 3-68). As noted in DEIS pgs. 3-65 — 3-66, segments of the route where potential for bird collision is high would be marked. This has proven to be effective in reducing bird mortality, In addition, construction on Links E9 and E10 would occur parallel to the pipeline on the hillside east of the flats and would not occur during nesting season. As illustrated in the mitigation plan, tower heights would be reduced to 70 feet in this area along the Enstar Route. Also refer to Section 2.2.6 (pgs. 2-18 to 2-19) and Section 2.2.8 (pgs. 2-32 to 2-34) of Chapter 2 in the FEIS for updated information on brown bears and avian collision mitigation. Temporary ice or man-made snow bridges will be adequate for construction and maintenance activities; permanent bridges would not be used as they would result in increased access and potential impacts on streams. See DEIS Section 3.5.5, Freshwater Environment, Environmental Consequences and Mitigation, Anadromous Fish (pg. 3-100). See also Table 3-2, Impacts and Mitigations Common to Most Alternative Routes (pg. 3-15), and the Mitigation Plan in FEIS Volume II. SC 9D 9E 9C_ If snow conditions are insufficient to create a winter cover over the DEIS Souther Intertie Project =) December 5, 2001 The DEIS also states that snow or ice could be made on site to protect vegetation (page 3-41). Winter flows on most waterways within both route corridors are minimal. It is unlikely that large amounts of water will be available for withdrawal and use for ice roads. The use of water from any fish-bearing stream would require authorization from the ADF&G. 9D Section 3.4.6 of the DEIS also discusses horizontal directional drilling (HDD) to avoid impacts to the bluff slopes, salt marshes and vegetated intertidal areas within the Anchorage Coastal Wildlife Refuge (ACWR). Figures B-22 through B-24 and Figure MV LB depict the approximate location of the HDD and trenching proposed. The shore-tail will be located within the boundaries of the ACWR and will require a Special Area Permit from the ADF&G. ADF&G recommends that the HDD be lengthened to place the shore-tail as far from shore as possible. In general, refuge habitat vatues decrease the further offshore from the vegetated tidelands. However, at low tidal stages the mud flats are utilized by shorebirds, including sandhill cranes. The shore-tail work should be planned to be conducted during the period from October 15 through April 1. The Alaska State Division of Parks and Outdoor Recreation (DOPOR) has outlined concerns and comments below that would preliminarily address potential ACMP consistency issues. There are three state parks that are listed as being affected by the creation of the intertie 9E transmission line: Funny River State Recreation Site, Bings Landing State Recreation Site (SRS) and Captain Cook State Recreation Area (SRA). The DEIS correctly states (Table 4-7, page 4- 22) that a Special Park Use Permit will need to be obtained through DOPOR prior to any work within a state park. Funny River and Bings Landing SRS would be minimally affected by the Enstar Route, having only a small, glancing visual impact on the park users who are already impacted by residences and several residential power lines in the area. Captain Cook SRA would be subject to impacts on several levels should the Tesoro Route be selected. The DEIS correctly describes the process that will need to take place for the route to travel through the park. In 1971 and 1980 Federal Land and Water Conservation Funds (LWCF) were used to develop the majority of the facilities for the park (roads, campgrounds, boat launches, latrines, etc.). Federal LWCF laws stipulate as part of the conditions for eligibility for LWCF funding that no aboveground power lines be constructed in LWCF areas. The DEIS correctly states that in order for the power line to proceed through the park the line will have to ‘be buried. This will still require working with DOPOR and National Park Service LWCF staff in resolving how the value of the land conversion from a recreational to a non-recreational use will be resolved. If the transmission line is located along the Tesoro route near or under the Kenai Spur Highway, summertime line construction, as the DEIS 2.50 states, will impact users of the park, limiting or preventing access to park facilities for the duration of the construction. Detours and closures will displace assorted types of recreation including picnicking, swimming, boating, fishing and frozen ground to reduce impacts to wetland vegetation, snow and/or ice would not be made using water from area streams, rather it would be obtained off site and transported to the Project site. In the case of a warm winter where frozen conditions are insufficient to mitigate impacts to aquatic resources, construction would be postponed until appropriate conditions exist. It is acknowledged that a special area permit will be required from ADF&G in this area and the HDD will be located in a manner to avoid disturbance to vegetated tidelands. See the Mitigation Plan in Volume II of the FEIS. Submarine cable construction must occur when the Turnagain Arm is free of ice. Construction of the HDD under the bluff and vegetated intertidal area will occur during the period between the ice melting off the Arm in the spring and the end of August. Installation of the submarine cable across the Turnagain Arm would occur during the months of July and August per direction of NMFS in order to reduce conflicts with beluga whales. Comments noted. As presented in Volume II of the DEIS, Appendix B, Table B-6, underground construction through Captain Cook State Recreation Area (CCSRA) during the summer season includes the months of April to October. During this period the Applicant intends to construct during early spring or late fall to avoid conflicts with recreational use in the CCSRA, and will work directly with DOPOR in this regard. Underground cables are proposed to be installed in the CCSRA along the Kenai Spur Road during the summer season (DEIS page 2-50) because the cross-linked polyethylene cable and accessories (splices and terminators) become stiff in the winter and more difficult to handle and install. Winter construction would impose additional requirements and costs on the construction process. For example (1) the adding of an antifreeze component to the concrete or slurry casing fill to prevent the slurry from freezing before it is pumped into the casing, (2) temporary heating of buildings or tents for cable reel staging to allow the cable temperature to rise to minimum installation temperature, (3) temporary HVAC equipment for use at the concrete vaults for cable splicing, and (4) more expensive excavation due to the frozen ground. Also, difficulty with backfilling and compaction due to the frozen material would be expected. 9E OF 9G 9H 91 DEIS Southern Intertie Project 4 December 5, 2001 camping. Wintertime construction would have much less impact on the park users, and is scommended. Wintertime uses are limited to snowmachine park use, snowmachine access to iray Cliffs properties, ice skating, and ice fishing on Stormy Lake. he Tesoro route has high potential to disturb known or potential archaeological sites. The wanson River and Bishop Creek are both known locations of Denai’na Indian cultural sites and erhaps earlier settlements. Any route through the park will need to be reviewed by the Alaska |_tate Office of History and Archaeology for sensitive sites. Although the DEIS shows that DOPOR would oppose any land conversion for the Tesoro Route in regards to the LWCF requirements (Table 4-1, page 4-3), it also is willing to reconsider its position to prevent further impacts on the Kenai National Wildlife Refuge (KNWR). DOPOR considers that the impacts that the Tesoro Route would have to Captain Cook SRA are less critical than the cumulative impacts resulting from the Enstar Route upon the KNWR. The correct address for DOPOR is 550 West 7” Avenue, Suite 1380, Anchorage, AK 99501- 3561. Please correct this in the DEIS table 4-7, page 4-26. The DNR Division of Mining Land and Water (DMLW) provided comments on the COE public notice Turnagain Arm 45. Based on the information provided in that public notice, it is not possible to ascertain the exact status of all land involved. However, it appears likely that authorization(s) would be required from DNR/DMLW for activities on state-selected and submarine lands. The applicant is advised that DNR/DMLW must authorize activities on state- owned land, including land below the ordinary high water line of navigable streams, rivers and lakes, and below the mean high tide line seaward for three miles. The applicants are responsible to ascertain whether their proposed project or activity is located on state land, The applicants should contact the DNR Public Information Center at 550 W. 7th Avenue, Suite 1260; Anchorage AK 99501-3564 or call (907) 269-8400 if assistance is needed to confirm which [segments of their proposed project is located on state land. COASTAL DISTRICT COMMENTS The Municipality of Anchorage has reviewed the DEIS and provided the following comments. It appears that in the environmental assessment of potential impacts from the siting and construction of each of the two main routes within the Municipality, shorebirds were not addressed. Because these intertidal landings include potentially high value shorebird habitats, impacts to this group, especially staging and migrant shorebirds, must be addressed. This would have to include impacts during peak shorebird use, which centers around the periods April 15- June 1 and July 1-September 1. Consistency with the Anchorage Coastal Management Plan, relative to these and other wildlife impacts in these coastal habitats might include additional mitigating measures in the final design. oF 9G 9H so) Coordination with the Alaska Office of History and Archaeology will occur regarding culturally sensitive areas. The Applicant is aware of the sites near the Swanson River and Bishop Creek. See DEIS Section 3.10, Cultural Resources, specifically 3.10.2, Inventory Results (pg. 3-267) and 3.10.4, Alternatives, Tesoro Route (pg. 3-269). See also Table 1, Measures 6 and 7 in the Mitigation Plan in FEIS Volume II. Comments noted regarding DOPOR preference for the Tesoro Route. Address has been corrected as indicated in the FEIS, Chapter 2, Section 2.3 (pg. 2-43). Comment noted. State lands were identified in Figure MV-18 in Volume II of the DEIS. Where applicable the Applicant will comply with all authorizations that would be required by DNR/DMLW. General impacts of alternatives associated with the Anchorage Coastal Wildlife Refuge, including saltmarsh, waterfowl and shorebirds are discussed in Section 3.5.3 on pages 3-64 through 3-67. Impacts associated with alternatives are discussed in 3.5.4, pages 3-77, 3-79, 3- 80, 3-81, and 3-92 to 3-94. Bird species including shorebirds are listed in Table 3-6, pgs. 3-50 — 3-51 of the DEIS and described on pg. 3-53. Impacts to coastal waterfowl and shorebirds are not expected to be significant after mitigation. See DEIS Section 3.5.3, Terrestrial — Wildlife, Environmental Consequences and Mitigation, Wetland Vegetation (pg. 3-40). In these locations, horizontal drilling under the saltmarsh habitats associated with marine crossings would avoid damage to the wetland community. In addition, winter construction on shore near Burnt Island or Pt. Possession would avoid staging and migrating shorebirds. Mitigation measures for salt marsh habitat are also presented in the Mitigation Plan, Volume II of the FEIS. 9J 9K 9L 9M ON 90 DEIS Souther Intertie Project 5 December 5, 2001 The final design and actual location of the electric line within the Municipality will be subject to the outcome of the Conditional Use Approval of this project, per standards of Anchorage’s Land Use Code (AMC 21.50). Prior to construction, the applicant will be required to obtain Conditional Use Approval for this alignment and design from the Planning and Zoning Commission. Final location, design and construction methods and site restoration may be adjusted as a result of this review. The Conditional Use Approval will also serve as a secondary review for consistency with Anchorage’s Coastal Management Plan. While the Municipality concurs with the applicant’s statements of purpose and need for this line, the environmental and community impacts associated with the Tesoro route’s submarine landing and shorter overland connection have always been the Planning Department’s favored route. This route was also preferred by the general public, community councils and local members of the Working Group. The Kenai Peninsula Borough (KPB) provided the following comments based on its review of the DEIS. The applicant’s preferred route (Enstar route) may result in minimizing exposure of some KPB residents to electric, magnetic, and noise impacts associated with the transmission line, thereby possibly resulting in reduced health risks. [There are numerous river and wetlands crossings along the preferred route, which should occur with proper timing, by consistent means. Normally, the Kenai Peninsula Borough Coastal Management policies lead to the recommendation that tracked or wheeled vehicles would not be operated in such waters, and that timing of activities occur when ground is frozen and covered by sufficient snow depth. The KPB offer the following measures in order to assure project |_consistency with the KPB policies. 1) According to KPB GIS records, rivers, crecks, and wetlands occur throughout the project area. Some of these are, or contribute to important anadromous streams, including the Kenai River and Funny River. This project shall avoid disturbance to river, creek, and wetlands areas to the greatest extent feasible and prudent. Preferably, (KPBCMP Enforceable Policies 5.4, Habitat Protection); 2) This project will, to the extent feasible and prudent, be conducted in a manner so as to avoid disturbances to fish and wildlife populations, habitats, and harvests. Staff recommends that adherence to seasonal restrictions to reduce potential adverse impacts. Ground vehicle use shall be limited to existing roads whenever possible, other off-road and all-terrain vehicle use within wetlands and riparian areas shall be avoided unless there is sufficient snow depth or ground frost to prevent damage to the vegetation (KPBCMP enforceable policies 5.2 Water Resources, 12.0 Fish and Wildlife Habitat); | » In order to protect water quality and habitat, which are highly susceptible to petroleum 9J 9K 9L 9M ON Comment noted. Prior to construction the Applicant will obtain conditional use approval for alignment and design from the Planning and Zoning Commission. It is acknowledged that final location, design and construction methods and site restoration may be adjusted as a result of this review. The Municipality's preference for the Tesoro Route is also noted. See DEIS Summary (pg. S-6), and Section 2.6.2, Environmentally Preferred Alternative (pg. 2-59) for information on the Tesoro Route. Further explanation on RUS’s preferred alternative is provided in FEIS Summary Section S.10 —- Agency Preferences and Decisions to be Made. Coordination with the Municipality of Anchorage and the airport authority will determine the exact location of the transition station and underground cable route between Pt. Campbell and the Pt. Woronzof Substation in this area. Adverse health and noise impacts are not expected to occur along either the Enstar or Tesoro routes. See DEIS Section 3.11, Electric and Magnetic Fields and Noise (pg. 3-272). Comment noted. Construction activities as presented in Volume II of the DEIS, Appendix B, identify the winter season as November to March provided there is sufficient snow cover. If snow conditions are insufficient to create a winter cover over the frozen ground and reduce impacts to wetland vegetation, snow and/or ice would be obtained off site and transported to the Project site. In the case of a warm winter where frozen conditions are insufficient to mitigate impacts to aquatic resources, construction would be postponed until appropriate conditions exist. As described in the DEIS, the Project shall avoid disturbance to river, creek, and wetland areas to the greatest extent feasible and prudent. See Section 3.3.2, Water Resources, and Table 3-2, Impacts and Mitigations Common to Most Alternative routes (pg. 3-15). See also Section 3.5.5, Freshwater Environment, Anadromous Fish (pg. 3-100), and the Mitigation Plan in FEIS Volume II. As described in the DEIS, the Project will be constructed in a manner to avoid disturbances and adhere to seasonal restrictions. See DEIS Section 2.5.1, Construction Seasons (pg. 2-50). See also Section 3.5.1, Terrestrial — Vegetation, Environmental Consequences and Mitigation (pg. 3-39) through 3.5.5, Freshwater Environment, and the Mitigation Plan in FEIS Volume II. DEIS Southem Intertic Project 6 December 5, 2001 contamination, petroleum storage and storage of other hazardous products in conjunction 90 with the project shall be located a minimum of 100 fect from the mean high water line of any river, creek, or wetland, and shall be placed in impermeable bermed basins capable of retaining 110 percent of storage capacity plus 12 inches of free board. (Rationale: KPBCMP Enforceable Policies 13.2 (b) (c), Storage of Petroleum and Petroleum Products, 5.2 (a) Water Resources.); 9p 4) Without proper precautions, toxic or deleterious substance run-off from spills or leaks may enter critical habitat. Therefore, spill response equipment/supplies shall be stored onsite to handle accidental leaks or spills of oil, gas, or other toxic materials. (Rationale: KPBCMP Enforceable Policies 5.2 (a) Water Resources); v! 2 Activities shall be conducted in such a way as to avoid harming or disturbing bald eagles 9Q or their nest sites in accordance with the Bald Eagle Protection Act (16 USC 668) (KPBCMP 12.9 Bald Eagles and Nest Sites); When soils that have become disturbed, or where vegetative mats are damaged or OR destroyed in uplands, wetlands, or other habitats the applicant and its representatives shall accomplish habitat restoration measures. Any inadvertent bank cuts, slopes, fill or other exposed earthwork attributable to the project shall be immediately stabilized to the greatest extent feasible and prudent, and retumed to pre-project contours. (KPBCMP Enforceable Policies 5.4, Habitat Protection); ell =I All waste generated during the project shall be removed and disposed of appropriately in 9S accordance with existing laws and regulations. This includes, but is not limited to, human waste, trash, garbage, litter, oil drums, petroleum/petroleum products, ashes from burned materials, and discarded equipment. The project location(s) shall be kept clean at all times. (KPBCMP Enforceable Policics 5.4, Habitat Protection, 12.0 Fish and Wildlife Habitat); || The use and storage of hazardous substances by the permittee and its representatives shall be done in accordance with existing laws and regulations. Hazardous substances must be oT removed from the project site and properly managed according to existing laws and regulations. Debris (such as soils) contaminated with motor oils, solvents, or other chemicals may be classified as hazardous and shall be recovered from the sited and managed and disposed of in accordance with existing state and federal law (KPBCMP Enforceable Policies 5.2 (a) Water Resources, 5.4, Habitat Protection, 12.0 Fish and Wildlife Habitat, 13.2 Storage of Petroleum and Petroleum Products); Sediment and water quality control measures shall be appropriately placed and maintained at all work sites to maintain existing flow putterns, including groundwater flow and prevent the introduction of sediments and other contaminants into surrounding wetlands and other waterbodies (such as in the appropriate use of silt fences and other %» SI 9U 90 oP 9Q OR 9S oT 9U . Standards will.be complied with for storage of petroleum. See Table 1, Measures 13 and 14 in the Mitigation Plan in FEIS Volume II. KPBCMP Enforceable Policies (a) Water Resources will be complied with for the Project. See FEIS Volume II, Mitigation Plan, Table 1, Measures 14 and 18. Provisions of the Bald Eagle Protection Act will be followed. See DEIS Section 3.5.3, Terrestrial — Wildlife, Raptors (pg. 3-54), and General Environmental Consequences and Mitigation for Wildlife, Birds (pg. 3- 64). See also the Mitigation Plan in Volume II of the FEIS. Disturbance to soils and vegetation will be minimized through mitigation. See DEIS Section 3.5.1, Terrestrial — Vegetation, Environmental Consequences and Mitigation (pg. 3-39). See also standard and selective mitigation measures in the Mitigation Plan in Volume II of the FEIS. Laws governing disposal of waste and equipment will be followed. See DEIS Section 2.5.5, Operation Maintenance, and Abandonment (pg. 2-55). See also Table 1, Measures 13, 14, and 17 in the Mitigation Plan in Volume II of the FEIS. Laws governing use and storage of hazardous substances will be complied with for the Project. See the Mitigation Plan in Volume II of the FEIS. Sediment and water quality control measures will be followed. See DEIS Section 3.3.3, Alternatives, specifically Table 3-2, Impacts and Mitigations Common to Most Alternative Routes (pg. 3-15). See also standard and selective mitigation measures in the Mitigation Plan in Volume II of the FEIS. DEIS Souther Intertie Project 7 December 5, 2001 measures). (KPBCMP Enforceable Policies 5.2 (a) Water Resources, 5.4, Habitat Protection, 12.0 Fish and Wildlife Habitat). As an advisory, the following rivers are further protected by a Kenai Peninsula Borough habitat ordinance, certain activities in vicinity of such rivers may require permitting. For information please contact the Kenai River Center at (907) 260-4882. Anchor River Fox River Anchor River, North Fork Kasilof River 9U Bishop Creek Ninilchik River Bradley River Seldovia River Chickaloon River Seven Egg Creek Stariski Creek Deep Creek Swanson River English Bay River ANILCA COMMENTS Page 3-143, of the DEIS states, Construction of the proposed project would widen the existing transportation corridor in the KNWR. Access along the Enstar pipeline may be substantially changed as a result of the construction activities. Historically used campsites may be defoliated, and traditional long-time users may be displaced by new users more tolerant of altered landscapes and meee Beg Bos me 5 r increased motorized use. The refuge may experience loss of control over maintaining 9V_ Refer to the USFWS Compatibility Determination in Appendix A OV: limited access opportunities along the Enstar pipeline north of the Mystery creek road. of the FEIS. The loss of contro} could result in significant management problems similar to those associated with oils and gas developments. (emphasis added) It is not clear whether the significant management problems referred to are those described in the first part of the paragraph or if there are others specifically related to oil and gas development. ‘0 help clarify this issue, we request the Final EIS provide some specific examples of the anagement problems. Also on page 3-143 the DEIS states, KNWR personnel have indicated that clearing of the right of way would, in most cases, 9W Refer to the USFWS Compatibility Determination in Appendix A ow result in an increase in snowmachine use along the right of way. Subsequently, the of the FEIS. refuge may close the area, which is currently open to snow machining. (emphasis added) does not provide relevant information related to closure procedures required by ANILCA 9X Although not currently proposed, closure of any area to the use of snow machines on the KNWR would be accomplished in accordance with applicable regulations. 9X = statement, while not necessarily inaccurate, is somewhat misleading fo the reader in that it DEIS Souther Intertie Project 8 December 5, 2001 implementing regulations 43 CFR 36 (11). An increase in snowmachine use does not lead to a closure except under specific criteria. We request the Final EIS clarify that a federal agency may close an area on a temporary or permanent basis to the use of snowmachines only upon a finding that such use would be detrimental to the resource values of the area and that any permanent closure would also require formal rulemaking with a minimum public comment period of 60 days and a public hearing held in the affected area. In addition, we have attached a comment letter submitted under a separate cover to the US Fish and Wildlife Service regarding the ANILCA Title XI procedures and the FWS compatibility process. Due to the circumstances with the U.S. mail in Washington D.C., I am sending you these comments by e-mail per your request with a signed hardcopy to follow. We appreciate the opportunity to comment on the DEIS. Please call or e-mail me if you have questions regarding these comments. Fes Sess Don Perrin Project Review Coordinator co: Daniel Bevington, KPBCMP Coordinator, KPB, Soldotna Thede Tobish, Municipality of Anchorage Stewart Seaberg, DFG/DHR, Anchorage Tim Rumfelt, DEC, Anchorage Karlee Gaskill, ACMP Coordinator, DNR, Anchorage Rod Combellick, DNR/GGS, Fairbanks ‘Stefanie Ludwig, DNR/SHPO, Anchorage ‘Suzanne Fisler, DNR/SP, Soldotna Brad Sworts, DOT/PF, Anchorage Glenda Landua, DFG/DHR, Soldoma Brian Anderson, USFWS Jack Hewitt, COB Dora Gropp, Chugach Electric STATE OF ALASKA GOVERNOR OFFICE OF THE GOVERNOR OFFICE OF MANAGEMENT AND BUDGET DIVISION OF GOVERNMENTAL COORDINATION 10A SOUTHCENTRAL KEGIONAL OFFICE, DF CENTRAL OFFICE a S50. 7 AVENUE, SUITE 1660 P.O. BON 110030 41L WEST 4 AVENI ANCIIORAGE, ALASKA 9501 JUNEAU, ALASKA 9981 1.0030 ANCHORAGE, ALASKA 99501-2147 PHT) 269-7400 PAN: (907) 20.3981 PAE (907) 465.3862 / FAX: (907) 465.3075 PHN (907) 271-4919 / PAX: (907) 272.3829 Devember 5, 2001 George Constantino US. Fish and Wildlife Service 101 E, Tudor Rd. Anchorage, Alaska 99503 Dear Mr, Constantino, The State of Alaska has reviewed the September 2001 Southern Intertie Project Draft Environmental finpact Statement (DEIS) with respect to the compatibility determination. The U.S. Department of Agriculture Rural Utilities Service (RUS), in cooperation with the U.S. Fish and Wildlife Service (FWS) and the U.S. Army Corp of Engineers, bas prepared the DEIS to satisfy the requirements of the National Environmental Policy Act (NEPA). ‘The DEIS is necessary, in part, because the Intertie Participants Group has filed for a right of way across the Kenai National Wildlife Refuge (9 construct a 138kV transmission line and associated facilities between the Soldotna Substation on the Kenai Peninsula and the International Substation in Anchorage. Two action alternatives are: examined in the DELS, one located within the boundatics of the refuge, the other located outside the refuge boundaries, CONTEXT The purpose of the DEIS is to identify and evaluate significant issues related to the proposed action. ‘The proposed action will require permits subject to review for consistency with the Alaska Coastal Management Program (ACMP). ‘The Division of Gaveramental Coordination (DGC) will coordinate a consistency teview upon receipt of a signed ACMP consistency certification statement and supporting information, and publication of a public notice. This will ‘occur after the completion of the NEPA process. Pre ACMP review comments will be submitted tw the RUS under a separate letter. DGC is also providing a coordinated review of the sight of way application provided under Title XU of the Alaska National Interest Lands Conservation Act (ANILCA) in addition to the compatibility determination required by the FWS. This letter identifies concerns and consolidated comments of State of Alaska agencies regarding the ANILCA Tule Xt application and the FWS compatibility determination for the appli¢ant’s proposal. ANILCA TITLE XL and REFUGE COMPATIBILITY ‘The DEIS appears to inadvertently misconstrue buth ANILCA Title XI Section 1104 and 43 CFR 36, Since the fatter implements the provisions of Title XI, our discussion focuses on the procedures specified in 43 CER 36.7. Specifically, page 1-35 of the DEIS states: The ANCA Title XI process also provides that applicable law shall apply with respect to the authorization and administration of transportation or uility systems across conservation waits, and includes a determination af compatibility with the unit's purposes as one af the criteria an agency ust consider when reviescing 1 right-of. way application, (cryphasis added) There ae Wo separate procedural routes for reviewing and approving a Title XI application, ‘The first involves 10A Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 10A Southern Intertie Projeet 2 December 5, 2001 those cases where the managing agency has an applicable law to issue a right of way permit and the area is outside the National Wildemess Preservation System. The second is used when an area involved is within designated Wilderness or the agency has no applicable law with respect to issuing a right of way permit, In the of the applicant's proposal, the route is outside designated Wilderness and the FWS has an ap) flaw, the National Wildlife Refuge System Administration Act, which contains the nec for the agency to grant a right of way of easement across a refuge and the route. This then triggers 43 CFR 36.7(a) that identifies 9 points the permitting agency shall consider when making its dec! none of which specifically consider compatibility, A determination that the right of way is compatible with the purposes of the refuge is required when the area involved is within designated Wilderness or the agency has no applicable law, but this is not the case with the applicant's proposed route. able y authority (Section 4(d)) not to say that a Title XI right of way application is not sabject to a compat ‘A 304(b) and the National Wildlife Refuge System Administration Ac jon 4(d) state that any casement granted under that section is subject to a compatibility determination. The point of this comment to clarify that in ase, the compatibility determination is required by ANILCA 304(b) and the FWS compatibility regulations (50 26, and 29), not by Title XL as implied in the above excerpt. determination. Both CFR Parts ‘The FWS Compatibility Policy, 603 FW 2.8 A., allows the Service to alter the compatibility process for applications for teansportation and utility systems. This is not mentioned in the refuge compatibility information provided in the DEIS. Articulating this policy, whether exercised or not, in the context of the Title XT right of way application would have allowed the reviewer a more complete understanding of the compatibility process in this instance. As such, the refuge manager may wish to provide some discussion of this policy when issuing the determination. We appreciate the opportunity to comment on this compatibility determination, Please contact me at (907) 269-7476 cordon. @ pov stite.dtk.us if you have questions concerning these comments. Sincerely, Don Perrin Project Review Coordinator wee Patrick Galvin, Director, Division of Governmental Coordination Frank Rue, Commissioner, Department of Fish and Game Pat Pourchot, Commissioner, Department of Natural Resources, Joseph Perkins. Commissioner, Department of Transportation and Publ Michele Brown, Commissioner, Department of Environmental Conservation Deborah Sedwick, Commissioner, Dept. of Community and Economic Development LIA y KNOWLES, GOVERNOR. STATE OF ALASKA SE I\fle iJ) IANS jt [e111 aarion avenue P.O. BOX 196900 DEPARTMENT OF TRANSPORTATION AND PUBLIC FACILITIES ANCHORAGE, ALASKA 99519-6900 free gso-oera CENTRAL REGION- PLANNING — / (907) 260-0820 (FAX 260-0621) [fA December 4, 2001 RE: Draft Environmental Impact Statement Southern Intertie Project Lawrence R. Wolfe Senior Environmental Protection Specialist USDA, Rural Utilities Service Engineering and Environmental Staff, Room 2240 1400 Independence Ave. SW, Stop 1571 Washington, DC 20250-1571 Dear Mr. Wolfe: | The Department of Transportation and Public Facilities (ADOT&PF) has reviewed the Draft Environmental Impact Statement (DEIS) for the Southern Intertie Project. The preferred alternative will impact the South Extension of the Coastal Trail in Anchorage. Project information is available from the project manager at 907/269-0544. The Tesoro alternative has potential to impact a planned extension of the North Kenai Spur Highway from MP 39. Project information is available from the Kenai Peninsula Borough Roads Director at 907/262-4427. The applicant will have to coordinate with the Department for permits once the exact location and impacts to ADOT&PF facilities have been determined. The Right of Way section can be contacted at 907/269-0700. Thank you for the opportunity to comment on the DEIS. Sincerely, fe LG Wilson! AICP Regional Planning Manager RYAh = 11A Project alternatives will avoid impacts to South Extension of the Coastal Trail by use of either horizontal directional drilling or underground cable. In addition, the lead and cooperating agencies along with the Applicant have held discussions and convened meetings among interested federal, state and local agencies in Anchorage and Kenai Peninsula Borough (March 26 and 27, 2002) to address specific mitigation recommendations associated with these areas. The types, locations and effectiveness of the measures are presented in Volume II of the FEIS. In addition, the Applicant will also continue to coordinate with ADOT & PF. See DEIS Section 4.6.2, Permits (pg. 4-27) for more information on ADOT permitting and construction requirements. 12A TONY KNOWLES, GOVERNOR STATE OF ALASKA [== DEPARTMENT OF FISH AND GAME PHONE RON Berea FAX: (907) 267-2464 Habitat and Restoration Division EMORANDUM TO: Don Perrin Project Review Coordinator Division of Governmental Coordination Office of Management and Budget FROM: Stewart SeabergST Ss Habitat Biologist Region II DATE: December 3, 2001 SUBJECT: Draft Environmental Impact Statement Comments Southem Intertie Tumagain Arm 45; SID No. AKOL10-11AA The Alaska Department of Fish and Game (ADF &G) has reviewed the Draft Environmental Impact Statement (DEIS) for the Southem Intertie project. The DEIS is for an electrical transmission line from the Kenai/Soldotna area to Anchorage. Two alternatives are being considered across the northern Kenai Peninsula: the Tesoro route along the existing Tesoro right- of-way from the Bernice Lake Substation to Point Possession; and the Enstar route (the Applicant’s proposed route) along the existing Enstar right-of-way from Soldotna to a location near Burnt Island in Chickaloon Bay. The Tesoro Route generally parallels the northwestem coast of the Kenai Peninsula and is located a short distance inland. The Enstar Route bisects the northeastern portion of the Kenai National Wildlife Refuge. From Point Possession and Bumt Island there are three proposed submarine alternatives that cross Turnagain Arm and come ashore in Anchorage. The ADF&G considers that the placement of the transmission line along the Enstar Route will have significantly more fish and wildlife impacts than the placement of the line along the Tesoro Route. The ADF&G believes that route segments A and C are the alternative route segments that will have the least impact to fish and wildlife resources. The ADF&G is also concerned that the DEIS does not adequately address potential impacts and permitting requirements for the submarine routes within the Anchorage Coastal Wildlife Refuge. 12A _ Refer to comment responses 9A through 9D — Alaska DGC letter (12/05/01). 12A cont. Mr. Don Perrin " we December 3, 2001 The development of the Enstar route will likely have detrimental impacts to brown bears. The Interagency Brown Bear Study Team (IBBST) has recommended against the Enstar route due primarily to habitat fragmentation and human access to the developed transmission line corridor. Brown bears require large expanses of unfragmented habitat and the Enstar corridor bisects the seasonal migratory routes of brown bears moving between mountain and lowland habitats. The development of the Enstar transmission line route would likely result in increased human access to the brown bear habitat which may increase the number of brown bears killed in defense of life or property. Waterbirds will also be impacted by the location of the transmission line in areas adjacent to waterfowl concentration areas, such as the Chickaloon Flats and the Anchorage Coastal Wildlife Refuge. The Enstar route will cross the eastem portion of Chickaloon Flats, which is heavily utilized by waterbirds as a spring and fall staging area as well as a nesting concentration area. Limiting construction activities in the Chickaloon Flats to the period from October 15 through April | will mitigate construction impacts, however; waterbirds will be susceptible to an increased frequency of collisions with transmission lines, guy wires, static lines and towers for the life of the project because these structures will be elevated above the surrounding terrain. The Enstar route has more anadromous fish streams within the corridor when compared with the Tesoro route. The ADF&G recommends that all stream crossings, regardless of route selection, be conducted on permanent bridges placed to accommodate construction traffic and all future traffic by maintenance vehicles or general motorized vehicle use by the public. The DEIS also states that snow or ice could be made on site to protect vegetation (page 3-41). The use of water from any fish-bearing stream would require authorization from the ADF&G. Winter flows on most waterways within both route corridors is minimal. It is unlikely that large amounts of water will be available for withdrawal and use for ice roads. Section 3.4.6 of the DEIS also discusses horizontal directional drilling (HDD) to avoid impacts to the bluff slopes, salt marshes and vegetated intertidal areas within the Anchorage Coastal Wildlife Refuge (ACWR). Figures B-22 through B-24 and Figure MV1B depict the approximate location of the HDD and trenching proposed. The shore-tail will be located within the boundaries of the ACWR and will require a Special Area Permit from the ADF&G. We recommend that the HDD be lengthened to place the shore-tail as far from shore as possible. In general, refuge habitat values decrease the further offshore from the vegetated tidelands, However, at low tidal stages the mud flats are utilized by shorebirds, including sandhill cranes. The shore-tail work should be planned to be conducted during the period from October 15 through April 1. We appreciate the opportunity to comment on this DEIS. Please call if you have any questions. cc: /T. Rumfelt, ADEC R. Thompson, ADNR C. Harmon, CEA L. Wolfe, USDA T. Tobish, MOA B. Anderson, FWS R. Sinnott, ADF&G J. Meehan, ADF&G A. Rappoport, FWS SPECIAL INTEREST GROUPS LASKA CENTER for the ENVIRONMENT 807 G Street, Suite 100 * Anchorage, Alaska 99501 (907) 274-3621 * fax: 274-8733 * email: ace@akcenter.org * www.akcenter.org December 5, 2001 Lawrence R. Wolfe Senior Environmental Specialist USDA - Rural Utilities Service 1400 Independence Ave. SW — Stop 1571 Washington, DC 20250-1571 ** SENT VIA FACSIMILE (202) 720-0820 and Email Lwolfe@rus.usda.gov** Re: Comments on the proposed Southern Intertie Project (DEIS) 13A 13B 13C Dear Mr. Wolfe: What follows are Alaska Center for the Environment's comments on the Draft Environmental Impact analysis (DEIS) for the proposed Southern Intertie. Alaska Center for the Environment (ACE) is the Alaska’s largest member-supported conservation organization, a non-profit, public interest group, with the majority of our members residing in the Anchorage Bowl. Since its establishment in 1971, Alaska Center for the Environment (ACE) has been dedicated to conserving Alaska’s intact ecosystems, fish and wildlife, while advocating the preservation of a unique quality of life. ACE works to ensure that citizen’s concerns for conservation, combined with sound science, are included in state, federal and municipal land management decisions. Our members depend on the conservation management of the Kenai National Wildlife Refuge to meet their wilderness recreation and subsistence needs, the natural beauty and health of the Anchorage Coastal Wildlife Refuge and Kincaid Park key indicators in measuring Anchorage’s quality of life. Summary Alaska Center for the Environment supports the No Action alternative for the proposed Southern Intertie project based on the fact that the DEIS fails to provide and evaluate the full spectrum of available, reasonable and feasible alternatives in its alternatives analysis. Apart from the No Action alternative, other alternatives are only mildly discussed, resulting in only two chief route alternatives for a single transmission line with a variety of proposed marine cable crossing alternatives and | Anchorage routes. The project costs must cover extensively more than the immediate construction and operating costs that will be borne by the project Applicant and their ratepayers. The DEIS fails to provide an economic cost-benefit analysis that thoroughly addresses long-term environmental costs, notably for loss of nationally and regionally significant wildlife, scenic values, eligible Wilderness areas in the Kenai | Navona Wildlife Refuge, and outdoor recreation opportunities. [The DEIS falls short of a detailed analysis on a subsistence determination [as required by NEPA under Section 810(a)]. The DEIS for the Southern Intertie Project does not adequately address subsistence impacts and fails to list loss of subsistence resources as among the issues of concern raised by the project. Since Section 810(a) does not contain a threshold level of impact at which a subsistence evaluation is required, the DEIS is arguably required to at least include a finding that the project will not have any effect on subsistence uses and needs to 13A_ For a discussion on the no action alternative see the General Response to Issue 1 (pgs. 1-3 to 1-4) and for a discussion on other alternatives see the General Response to Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS. 13B See the General Response to Issue 13 (pg. 1-8) in Chapter 1 and Section 2.2.7 Environmental Cost-Benefit Analysis Summary (pgs. 2-21 to 2-32) of the FEIS. 13C An analysis of subsistence is provided in Section 3.8 of the DEIS and as noted on pgs. 3-209 and 3-210 impacts to subsistence are not expected. Updated and corrected information on subsistence is provided in Section 2.3 of the FEIS (pg. 3-42). 13D Alaska Center for the Environment is decisively opposed to the “Enstar” route for 13D ___ | 4 proposed transmission line, identified by the Applicant and supporting agencies as the Preferred Route, Apart from the failing to meet the requirements for a full spectrum of alternatives, the proposed Enstar route is not an acceptable alternative. Purpose and Needs Statement This DEIS’s “purpose and needs” statement is overly narrow, resulting in a narrower range of alternatives that could meet the project purpose. The purpose and need statement, and its screening criteria, deems reconsideration to require the analysis of energy conservation, energy efficiencey, wind and tidal generation, and 13E fuel cells. We question the claims made in the DEIS that these do not meet the Applicant's desired screening criteria relative to the purpose and need statement [Table 2-1]. 13E The purpose and need statement is inadequate considering the unique context of the Project: in Alaska’s nationally significant Cook Inlet and Kenai National Wildlife Refuge. Energy conservation programs must also be adequately included in the Needs and 13F Objectives “efficiency” category, by the Applicant, to be granted federal or state LF approval. Both decentralized, renewable energy programs and conservation programs will help with the long-term power and energy needs of our region and nation, while lowering the security and environmental costs born by such centralized projects of the past. False Objective concerning Maintenance Cos One of the identified “objectives” of the proposed Project is to: “reduce 13G transmission line losses for power transfers and reduce maintenance costs”. We 13G feel this erroneously inaccurate since the maintenance costs of this project were not adequately evaluated. Marine cable crossing repairs will cost tens of millions of dollars for repair and maintenance, The lifespan of a cable averages 15 years or less. It is not clear who will pay for these very costly repairs, and what plans are [once the cables expire. Incompatibility with Purposes of the Kenai National Wildlife Refi As determined by the Alaska National Interest Lands Conservation Act, the Kenai National Wildlife Refuge (KNWR) was established “to conserve fish and wildlife populations and habitats in their natural diversity ... and to provide, in a manner The Enstar Route was identified as the Applicant’s proposal and the Tesoro Route was identified as the environmentally preferred alternative in the DEIS. The lead and cooperating agencies deferred their selection of a preferred alternative to the FEIS. Refer to FEIS Summary Section S.10 (pg. S-26) for agency preferences. For further information on alternatives analysis see the General Response to Issue 14 in Chapter | of the FEIS (pgs. 1-8 to 1-9). See the General Response to Issue | in Chapter | (pgs. 1-3 to 1-4) of the FEIS. The proposed project will utilize existing generation more efficiently, thus deferring the need for new generation. See DEIS Section 1.3.3, Economic Generation (pg. 1-23). See also the General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. 1-8 to 1-9) in Chapter 1 of the FEIS. With respect to the need for the Project regarding reduction of line losses for power transfers and maintenance costs, see DEIS pgs. |- 27 through 1-28. With regard to the maintenance costs for the Project, including a schedule for replacement of the submarine cable during the Project life, these costs are discussed and enumerated on pgs. 1-31 and 1-32 of the DEIS. Both maintenance costs and submarine cable replacement costs are included. The expected intervals of cable replacement expected are discussed on pg. 1-32 of the DEIS. The Project proponent would bear the costs for this work. Operation, Maintenance, and Abandonment of the submarine cables are discussed on pgs. 2-56 through 2-58 of the DEIS. See also FEIS Section 2.2.1 (pgs. 2-1 to 2-4) and Section 2.2.2 (pgs. 2-4 to 2-11) for additional information and costs for marine cable crossing repairs. 13H 131 13J compatible with these purposes, opportunities for fish and wildlife-oriented recreation.” [Section 303.4, ANILCA] The purpose does not say the KNWR was 13H established for transportation and utility corridors, oil and gas development or other infrastructure opportunities. The activities within the Refuge are to be compatible with the conservation of fish and wildlife populations. The proposed “Enstar” power line through the heart of the Refuge fails to meet the purpose of the Refuge. It is for this reason that the U.S. Fish and Wildlife Service (USFWS) made the decision to provide the State of Alaska and Kenai Borough with a transportation and utility corridor along its northwest boundary by modifying the Refuge in 1964. [Public Land Order 3400] Having provided this utility corridor, the “Tesoro Route” to preclude a transmission line through the Refuge, Alaska Center for the Environment was startled that the USFWS, as a collaborating agency in this DEIS, has: one, even allowed the “Enstar” route for serious consideration; and two, determined the route meets the compatibility for the purpose of the Refuge. 131 We find that the proposed Enstar route fails to meet the compatibility for which the KNWR was established for the following reasons: 1) As the DEIS acknowledges, the ENSTAR route will result in significant and cumulative environmental impacts of national significance. 2) Management of nationally significant wildlife is the Refuge’s primary purpose: [ Kenai Peninsula Brown Bear, ‘The Brown Bear is federally listed as an Endangered Species south of the Canadian border. ‘The isolated population of 13) brown bear, identified as the Kenai Peninsula Brown Bear, has been determined by the Alaska Department of Fish and Game as a “Species of Special Concem”. The habitat of this brown bear population has been exceedingly fragmented on the Peninsula, by new roads, timber harvesting, oil and gas development and a sprawl from communities in the region. The KNWR provides the primary habitat for Brown Bear, a species highly valued for its wildlife viewing, vital role in an intact ecosystem, and resource for sport and subsistence hunters. In order for this species to restore and maintain it’s population, further commercial and industrial development and infrastructure must be found inconsistent for the purpose of the Refuge to conserve this nationally significant wildlife species and habitat. Brown bears require large tracts of wilderness and secure travel corridors connecting them, especially to riparian habitats. The Chickaloon River watershed Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines (pgs. 2-18 to 2-19) of the FEIS for more information on brown bears. Refer also to the USFWS Compatibility Determination in Appendix A of the FEIS. 13J 13K 13L 13M 13N is an important feeding area to the Brown Bear. This habitat and corridor, the Project's preferred route, would lead to greater access to this region—leaving the bear and this fishery more vulnerable. The Chickaloon River basin is considered to be one of the best brown bear habitats in the entire Kenai Peninsula. [ The Kenai Refuge does not have the staff capacity to oversee the public access into areas that will be open because of the transmission line, especially in the remote region of the Chickaloon flats. The increase access as a result of this transmission line will inevitably harm the Brown Bear. We would like to know more from the USFWS and the Applicant on how they expect to do no harm to this critical Brown | Bear feeding area and habitat. The economic values of the Brown Bear to our state's tourism and visitor industry must be incorporated in a better economic cost-benefit analysis. The DEIS also fails to cither provide mitigation or compensate for short-term construction and long-term impacts to this utterly valuable species. Nee Moose The presence of the above ground transmission line would greatly affect the carrying capacity for moose at a low level of productivity for a significant part of the refuge, despite the fact that the KNWR was established to protect the Kenai's moose populations. Formerly “The Moose Range”, the northeast quadrant of the KNWR, which is bisected by the Enstar route, has a low density of winter moose (Figure MV-18). Having not been bumed in many years, the moose population in this area would likely increase the habitat to sustain stronger moose populations. [an The transmission line will, in effect, drastically impact local sport and subsistence hunting opportunities by not permitting prescribed bums and requiring controls on wildfires, necessary for natural habitat cycles. See “Appendix A” for recent news on declining moose population numbers in the Project study area. 13K 13L 13M 13N Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. Refer to FEIS Section 2.2.7, Environmental Cost-Benefit Analysis Summary (pgs. 2-21 to 2-32) for more information on the cost/benefit analysis, and the Mitigation Plan in FEIS Volume II. The DEIS acknowledges on pg. 3-69 and 3-70 that the proposed project could have adverse impacts on moose populations through impeded implementation of habitat improvement actions such as prescribed burning. See also USFWS Compatibility Determination in Appendix A of the FEIS. As noted in the DEIS on pg. 3-209, impacts to subsistence are not expected. Corrected and updated information on subsistence is provided in Section 2.3 (pg. 2-42) of the FEIS. 130 13 Subsistence Determination Required Section 810 of ANILCA directs any federal agency considering uses of public lands under its jurisdiction to: 2 hvu clot s nd needs, the availability of other lands for the purpose: eel to be achiey icv cd 1, and other alternativ es which would reduce or eliminate the use, occupancy, or disposition of public lands needed for subsistence purposes... The DEIS for the Southern Intertie Project does not address subsistence impacts and does not list subsistence as among the issues of concern raised by the project. Since Section 810(a) does not contain a threshold level of impact at which a subsistence evaluation is required, the DEIS is arguably required to at least include a finding that the project will not have any effect on subsistence uses and needs. While the DEIS recognizes the need to address subsistence, it inaccurately states that, "There appears to be no negative impact on populations of relevant species that would impair subsistence activities (page 3-209)." On the next page, the DEIS goes on to say that, "Moose hunting appears to be the most substantial subsistence use within the study area”, and admits that prohibiting prescribed burns would contribute to this decline is moose hunting habitat. Id. § 3120(a)(3). The agency's evaluation and findings must be included in any EIS prepared in connection with the project. 16 U.S.C. § 3120(b). We feel the evaluation of subsistence uses is not adequate and a thorough Ldetermination, including the impact on Beluga subsistence users, is required, Loss of Eligible Wilderness While the buried gasline does not effect the wilderness eligibility of this region of the Refuge, power line infrastructure would, according to the DEIS. Members of the Alaska Center for the Environment are strong advocates for ANILCA wilderness management of more regions of the Kenai Peninsula, both in the Refuge and on US Forest Service lands, as indicated in the recent Chugach Land Management revision process. Chickaloon, Moose River/Mystery Creek, Two Indians, Pipeline Lowland and Skilak Loop/Lake are the five non-roaded, wildland areas exist within the proposed ENSTAR Project area. The preferred alternative in the 1988 Final EIS for the Kenai Refuge Comprehensive-Conservation Plan (CCP) recommended wilderness designation for the northern portion of the Enstar Pipeline route because of the 130 Although the proposed project is likely to have adverse impacts on the 13P moose population of the KNWR through impeded implementation of habitat improvement actions such as prescribed burning, it is not anticipated that such impacts to moose population will negatively affect subsistence opportunities on the refuge as noted on pg. 3-209 of the DEIS. In addition, many subsistence harvests are taken outside of the study area (pg. 3-210). Impacts to beluga subsistence users was also discussed in the DEIS, but will not be significant. In fact, the DEIS states that NMFS has identified subsistence as the most likely cause of decline in beluga populations, and prohibits beluga harvests unless a cooperative agreement is granted by NMFS (pg. 3-113). Updated and corrected information on subsistence is also included in Section 2.3 of the FEIS (pg. 2-42). Comment noted. The DEIS acknowledges that the Enstar Route could potentially result in the modification of wilderness designation qualification between Big Indian Creek and Chickaloon Bay. See Section 3.6.3, Alternatives, Enstar to Chickaloon Bay — Route Option F, Environmental Consequences (pg. 3-143). Also see the USFWS Compatibility Determination in Appendix A of the FEIS. 13P 13Q 13R 13S and moose habitat in this northern region conflict with wilderness management of this region of the Refuge. route bisects. Beluga Whales of Cook Inlet Fisheries Service (NMFS) for Beluga concentrations. [See Ptp:/nmml.afs if istence resource. more detailed and scientific plan is required. taken lightly. Furthermore, the DEIS is inaccurate in assuming that any disturbance would be of a short-term nature. Conclusion valuable wildlife habitat this area encompasses—particularly the rich riparian, bear We are particularly concerned that during the revision of the KNWR land use management plan, beginning in 2002, that land areas along the Enstar route will no longer be eligible for wilderness eligibility because of the powerline, particularly the northern region encompassing the Chickaloon watershed. The utility would not only further fragment fish and wildlife habitat on the Peninsula, but also It is important to note that the proposed Project is included in the outlined activities and uses that the 1988 Kenai Refuge Comprehensive Conservation Plan (CCP) FEIS that were found incompatible with a minimal management area the Enstar [ Cook Inlet Beluga whales, a distinct, genetically separate population, were listed by the National Marine Fisheries Service as a depleted species in 2000. The Chickaloon Flats is an area noted in recent tagging surveys by National Marine -2001.hun and “Appendix B"|_ While the DEIS states that construction activities would not occur in Chickaloon Bay during calving and feeding periods, due to the depleted nature of this distinct population, ACE feels that the cable laying and all other construction and maintenance must not occur without direct consultation with NMFS and ‘Tribal Governments who have historically relied on Belugas as a We are not satisfied with the mere mention of mitigation to avoid the belugas; a The managers, NMFS, the Army Corps of Engineers and others need avoid all possible disturbance of this population during this important recovery period. The section on Mitigation (Appendix D) fails to make a resource preservation commitment. This regionally and nationally significant population must not be [ Considering the inevitable environmental costs of the project in the Kenai National Wildlife Refuge, ACE strongly opposes the Applicant's preferred ENSTAR route. Until a more thorough analysis of the full range of alternatives are studied and 13Q 13R 13S The DEIS acknowledges the designation of the Cook Inlet Beluga species as depleted. See DEIS Section 3.5.9, Marine Environment, Marine Mammal (pg. 3-111). The NMFS has been consulted regarding impacts to beluga whales, and is satisfied with the proposed mitigation. With mitigation, such as avoiding construction during the calving period, impacts to belugas are not expected to be significant. See DEIS Section 3.5.9, Marine Environment, Environmental Consequences and Mitigation, Marine Mammals (pg. 3-113). See also the Mitigation Plan in FEIS Volume II, which specifies avoiding construction during sensitive periods for sensitive animal species, and Chapter 2, Section 2.2.5, Update on Beluga Whales (pgs. 2-17 to 2-18) in the FEIS. RUS has determined that the DEIS has adequately addressed these issues, and a revised DEIS is not necessary. See the General Response to Issue 14 (pgs. 1-8 to 1-9) in FEIS Chapter | regarding alternatives analysis. See also the additional information on project costs provided in FEIS, Section 2.2.1 (pgs. 2-1 to 2-4) and Section 2.2.3 (pgs. 2-11 to 2-14), and FEIS Section 2.2.7, Environmental Cost-Benefit Analysis Summary (pgs. 2-21 to 2-32). 13S presented to the public, we urge the USDA to have the DEIS revised to meet the required range of alternatives and other previously mentioned determinations and selection criteria. Thank you for your careful consideration of these comments. Cordially, Michelle Wilson Program Coordinator Alaska Center for the Environment Ce: David Allen, Alaska Regional Director, USFWS Barbara Mahoney, Biologist, National Marine Fisheries Service Robin West, Kenai National Wildlife Refuge Manager Jack Hewitt, Project Manager, Army Corps of Engineers List of Individuals that E-mailed the Alaska Center for the Environment Form Letter to RUS on the Southern Intertie Project DEIS Sr. Environmental Protection Specialist Lawrence R. Wolfe 1400 Independence Ave. SW, Stop 1571 Washington, DC 202250-157 Dear Sr. Environmental Protection Specialist Lawrence R. Wolfe, Anchorage’s energy needs must not be met at the cost 14A Comment noted. of our Kenai National Wildlife Refuge. I am writing to oppose the preferred route ("Enstar Route") for Chugach Electric's state-subsidized utility line from Kenai to Anchorage. This route, identified in the Draft Environment Impact Statement (DEIS), would 14B _ Refer to the USFWS Compatibility Determination in Appendix A of the run through the very heart of the Kenai National Wildlife FEIS Refuge. . In 1964 the U.S. Fish and Wildlife Service modified 14A he Refuge boundary and granted the State of Alaska ’ corridor along the Cook Inlet coastline to meet utility ind transportation needs, This corridor, known as the "Tesoro Route" because of an existing gasline, was granted to meet the very needs of this project and would be far preferable to the Enstar Route. 14C Current oil and gas exploration were considered in the assessment of cumulative impacts. See DEIS Section 3.6.1, Land Jurisdiction and Management Plans, KNWR Comprehensive Management Plan, (pg. 3-122). See also Section 3.12.2, Cumulative Impact Process, Study Area — Including the KNWR (pg. 3-285) and Table 3-37, Cumulative Impact Analysis (3- The location and scope of this utility project is not 14B compatible with the purposes for which the Kenai National 292). wildlife Refuge was established: Cumulative Impacts. Oil and gas production already 14D Comment noted. Impacts to brown bears were acknowledged in the DEIS. 14C |eccurs on the Refuge (although we believe that it should See also FEIS Section 2.2.6, Update on Kenai Peninsula Brown Bear (pgs. never have been allowed). Further commercial/industrial development should not be permitted. 2-18 to 2-19). Kenai Peninsula Brown Bear. Identified by the State of Alaska as a "species of special concern,* this tenuous or declining population needs to be fully protected 14E from any unnecessary additional impacts. 7 Comment noted. See DEIS Section 3.5.3 Terrestrial — Wildlife, Brown Bears (pg. 3-68), and Predators (pg. 3-70). See also 3.6.3, Alternatives, Enstar to Chickaloon Bay — Route Option F, Environmental Consequences (pg. 3-143), and the Mitigation Plan in FEIS Volume II. Increased Human Access. The increased human access 14E chat would occur in the area where the intertie would oe routed under the preferred alternative could be yarmful to brown bear, wolf, and lynx. locum al Imo onl 1 14F Harm to Wildlife and Subsistence Resources. Routing the intertie through the Refuge would prevent managers from igniting prescribed fires there, significantly lowering the area‘s carrying capacity for moose. This would have an adverse impact on subsistence, sport hunting and wildlife viewing in Game Unit 15, directly affecting the subsistence communities of Ninilchik, Hope and Cooper Landing. The Kenai Refuge is a national treasure and a prized aaa 14F Comment noted. See response to comment 130 — Alaska Center for the Environment letter (12/05/01). See also, 3.6.1, Land Jurisdiction and Management Plans, Fire Management Plan (pg. 3-123), 3.5.3 Terrestrial — Wildlife, Moose (pg. 3-62 to 3-69), and 3.6.3, Alternatives, Enstar to Chickaloon Bay — Route Option F, Environmental Consequences (pg. 3- 143) in the DEIS. local subsistence and recreation area. Keep the intertie out of the Kenai National Wildlife Refuge. Other alternatives, 14G | and not just the Tesoro Route, need to be considered that meet the needs and purposes of the project. without harming our wildlands. Marine Crossings: T am not convinced the marine crossings will not impact the already declining populations of Sook Inlet beluga whales. Chickaloon Bay has been identified 14H as a sensitive habitat for belugas in Cook Inlet. To nitigate any possible harm, cable laying, seismic testing and maintence must not, under any circumstances, be allowed to occur during the months of May ~ September, when belugas are using the upper inlet. Energy conservation and efficiency, cogeneration, district 141 heating and cooling applications, and renewable energy resources, such as tidal energy, require far better analysis and consideration, Thank you for consideration of these comments, kristina Trotta James M nordlund 1239 Dickinson Dr p.o.b. 982 SRC RT 1110 Lakin, Kansas 67860 Coral Gables, Florida 33146 Kathryn Lorenz - 13 Kurt’s Court Whitesboro, New York 13492 “| Mike Williams 2952 Sunflower St Anchorage, Alaska 99508 Janice Foss Ken Li son 448-1 48th St. 5449 Shafter Ave. Oakland, California 94609 Oakland, California 94618 Tammy Hart 457B W. Elin Burbank, California 91506 Kathy Steberl — P.O. Box 2379 Homer, Alaska 99603.00 Emily Creely 907-274-9938 Anchorage, Alaska 99508 Mike McCat Frey 6 Flintlock Road | Flemington, New Jersey 08822 Daniel Behrens Z Z| | P.O, Box 478 Ottsville, Pennsylvania 18942 Tonya Newton 33310 stateline rd New Carlisle, Indiana 46552 Doug Kaser 8050 West Chester Road West Chester, Ohio 45069-3724 Marilyn Scarborough 17001 Aries Ct. Anchorage, Alaska 99516 14G 14H 141 See the General Response to Issue 14 in Chapter | (pgs. 1-8 to 1-9) of the FEIS. With mitigation, such as scheduling construction to avoid the calving period, impacts to belugas are not expected to be significant. See DEIS Section 3.5.9, Marine Environment, Environmental Consequences and Mitigation, Marine Mammals (pg. 3-113). See also Chapter 2, Section 2.2.5, Update on Beluga Whales (pgs. 2-17 to 2-18) in the FEIS. Energy efficiency, conservation, and load management programs are important tools that Alaska utilities are using, and will continue to use to manage the demand for and consumption of electricity. However, while valuable, these programs do not address any of the need categories of the Project (DEIS pgs. 2-3 to 2-4). Tidal energy production and cogeneration would be other methods of adding additional electric generating capacity to the system. However, the overall system currently has an excess of generating capacity over electrical load, and so additional generation sources are not needed (DEIS pgs. 2-4 to 2-5). District heating and cooling systems utilize a primary fuel such as gas, coal or oil to produce energy and provide for heating and cooling requirements over a local area, with the heat being transported through a pipeline system. These systems can be used to improve the efficiency of energy use in a local area where pipeline lengths can be kept short, and are sometimes used in densely populated areas. While a district heating and cooling system has the potential to increase energy efficiency in a localized area, it would not address the Project purpose and need, and is not a reasonable alternative to the Project. Duane Howe 1651 Tamarack St, Apt 1 Fairbanks, Alaska 99709 [ Josh Sage 510A Simonds Loop San Francisco, California 94129 Paul Borokhoy 420 River Rd. #BG Chatham, New Jersey 07928-1249 Lauren Collier Whitman College Walla Walla, Washington 99362 Autuim Kjer P.O. Box 50135 Bristolville, Ohio 44402 Jeté Frontz 310 Walhalla Rd Columbus, Ohio 43202 George Chianese 400 munsons hill ct. Stafford, Virginia 22554 Christy Rose P.O. Box 22594 Salt Lake City, Utah 84122 Mervin 0 Rife IV 5140 Northridge Rd #105 Sarasota, Florida 34238 Karen Marcey 6301 Bubbling Brook Anchorage, Alaska 99516 Carrie Rex 335 65th St NW Albuquerque, New Mexico 87105 stefanie moravitz 6600 north desert view drive tucson, Arizona 85743 Carrie Gray Wolfe HCO2 Box 7686-J Palmer, Alaska 99645 John Lynch 87-2900 Mamalahoa Hwy Captain Cook, Hawaii 96704-8706 Scott Wolfe HCO2 Box 7686-J Palmer, Alaska 99645 Jennifer Erwin 1430 20th Ave. East Tuscaloosa, Alabama 35404 Yesenia Nunez 1110 Lily Terrace Austin, Texas 7874) Owen Wozniak 2512 Edison Road Silverton, Oregon 97381 Ralph (Steve) Tarola & Regina Fiske P.O. Box 2074 Homer, Alaska 99603.00 Constance Anderson C.D.A. 2180 Newt Huff Way Sevierville, Tennessee 37862 Stephanie DeAngelo po Box 86 Talkeetna, Alaska 99676 Joanna Nichols 167 East State Street Apt #2 Baton Rouge, Louisiana 70802 Christopher White 17550 Burbank Blyd. Encino, California 91316 2631 darby circle anchorage, Alaska 99508 1106 2nd Street, PMB 332 Encinitas, California 92024 Susan Alter 204 Nth 195th Se. Shoreline, Washington 96133 Debra Chrissinger 2311 E 66th Ave 4B Anchorage, Alaska 99507 Berton Harrah 264 Mill Rd Marysville, Ohio 43040 / Christina Newell 2130 Park Ave #14 San Jose, California 95126 Raynit Basi-LaChapelle 2741 Seafarer Loop Anchorage, Alaska 99516 Monica Goulart 134 Auburn St. san rafael, California 94901 Amy Crawford 5500 E. 104th ave. Anchorage, Alaska 99516 Maryellen Oman 12951 Summer Circle Anchorage, Alaska 99516-2629 Debra Pohlman 1916 S SAlem Dr. Anchorage, Alaska 99508 “Scot tyder 2303 Homestead Drive Silver Spring, Maryland 20902 Kevin Egan 6612 Branch Hill Guinea Pike Loveland, Ohio 45140 Douglas Lottridge P.O. Box 92627 Anchorage, Alaska 99509-2627 mark lusch pobox 870634 wasilla, Alaska 99687 Lori Sgambati 1635 Kewalo Street Apartment 302 Honolulu, Hawaii 96822-3119 | Tony Kugler, Ph.D. 121 Corry St. Madison, Wisconsin 53704 Ben Kugler 121 Corry st. Madison, Wisconsin 53704 Michael Marting 3430 W 30th Ave Anchorage, Alaska 99517 Maggie Lakota-Ryan 580 Saratoga Drive Chicago Heights, Tllinois 60411 Jackie Costa 968 Hwy EE Winfield, Missouri 63389 Gordon Wetzel 6120 West Tree Dr Anchorage, Alaska 99507 Kent Williams 2087 Cliffside Dr. Anchorage, Alaska 99501 Edward Yarmak 5241 Taurus Circle Anchorage, Alaska 99516 Knute Horwitz 5249 N. Paulina Chicago, Illinois 60640 Alexandra Pharmakidis 99 Upton Avenue Providence, Rhode Island 02906 Tyler Forman 1212 Bast Minnezona Phoenix, Arizona 85014 spencer clubb 3 kings mews london, sw4 &ba United Kingdom beth porterfield 2631 Darby circle Anchorage, Alaska 99508 1 Kim Aho Thomas Hunt 6203 Green Tree Anchorage, Alaska 99507 Carmen Santasania 1410 Charles Street State College, Pennsylvania 16801 John Kesich 10 Linden Drive Highland Mills, New York 10930 2100 Patriot Circle Anchorage, Alaska 99515 17119 W Bernardo Dr #106 San Diego, California 92127 Willy Dunne P.O, Box 15043 Fritz Creek, Alaska 99603.00 Audrey Bowers 558 58th Street #D Oakland, California 94609 [Robin Colna 416 Durham Ct. Mantua, New Jersey 08051 John Mouw & Rika Mouw P.O. Box 212 Homer, Alaska 99603.00 Sufi Williams 4040 Summerlinn Dr. West Linn, Oregon 97068 Debra Jones 771A Broadway Ave Tryon, North Carolina 28782 Jane Banaszak 1308 F St #4 Anchorage, Alaska 99501 Adam Savett 1202 Dogwood Circle Blue Bell, Pennsylvania 19422-3400 Julie Ritter 921 Oakland Ann Arbor, Michigan 48104 ‘JoAnn and Richard Fireman 374 Laughing River Rd Mars Hill, North Carolina 28754 Carol Jensen 4800 &. 112th Avenue Anchorage, Alaska 99516 Carol Charat P.O. Box 1609 Homer, Alaska 99603.00 Mark Luttr Box 511 Seward, Alaska 99664 Jonathan Markowitz P.O. Box 656 Lahaska, Pennsylvania 18931 Sarah Mills Tucson, Arizona 85716 beth krisko 606 Brill Oxford, Ohio 45056 D. William Sinnett 2615 NE 359th Avenue Washougal, Washington 98671 Margaret Rydant — 335 Chureh St Northborough, Massachusetts 01532 Chris Granade 18335 McCrary Rd. Eagle River, Alaska 99577 ‘Sandra Mays” 423 Hamilton Street Lancaster, Pennsylvania 17602 Terri Doyle Gabriel Andres Thoumi 2011 3rd Ave S #334 Minneapolis Deborah Williams Minnesota 55404 Erika Sevetson 121 Corry St. Madison, Wisconsin 53704 Michelle Saltz megan vander leeuw Albright College PO Box 15234 CC Box 1506 Reading, Pennsylvania 19612 Gina Visci Homer, 2397 Waldron Drive 1142 G Street PO Box 2922 256 Tryon St Anchorage, Alaska 99507-1345 Anchorage, Alaska 99501 Seward, Alaska 99664 Honesdale, Pennsylvania 18431 gwen vilches —_ Geo. Donart ——— Betty Dean francisca van lith 622 NE Tillamook St 705 B West 20th PO Box428 440 san marin drive Ridgecrest Drive Asheville, North Carolina 28801 P.O, Box 974 Willow, Alaska 99688 4101 University Drive #732 Anchorage, Alaska 99508 1212 NE Brazee St. Portland, Oregon 97212 Portland, Oregon 97212 Anchorage, Alaska 99503 Sterling, Alaska 99672 Novato, California 94945 Nancy Hillstrand —"TMatthew McGuire - Michael Kacala Kathy Peel 7 P.O. Box 170 322 Redwood Lane 602 Littlecroft Rd. P.O. Box 3176 Alaska 99603 Cheshire, Connecticut 06410-2342 Upper Darby, Pennsylvania 19082 Homer, Alaska 99603.00 an ia James Carter Jason Geck Lisa DeVaney a a a. Mary Krane Derr 6103 South Woodlawn #1W Chicago, Illinois 60637 ‘Tom Krackeler 5824 Ocean View Drive Oakland, California 94618 dudith Hallberg 2 Oakdale Drive Apt. 222 Middletown, New Jersey 07748 Donovan Moretz 1215 Dougmar Dr. Santa Cruz, California 96062 Pbrian fireman 30 success st. apt. 1 Asheville, North Carolina 28806 Sharghi Rahmanian 11615 Lanesborough way Apt .606 knoxville, Tennessee 37922 Eric McLearon 1724 e grand river ave east lansing, Michigan 48823 Billy Stern 1324 Williamson st. #1 Madison, Wisconsin 53703 Nina Faust P.O. Box 2994 Homer, Alaska 99603 Shane Snipes 476 Sixth Avenue lst floor zl escee a New York 11215 Angela Winholrz 2631 S. Lowe Rd Blue Springs, Missouri 64015 Lou Bubala 1728 Columbia St. Eugene, Oregon 97403-1903 ‘Melissa Blackman 1507 Amberwood Circle Nashville, Tennessee 37221 PSill Strawder-Bubala $536 Winthrop Indianapolis, Indiana 46220 Bixler McClure 159 Baker St. Shell Beach, California 93449 Jane Olson 2025 Sage Lily Dr Sidney, Montana 59270 Richard DeBadts — 78 Commonwealth Avenue Buffalo, New York 14216 Kevin Laffey 2808 3rd Street Santa Monica, California 90405 Wendi Patrick 3390 Tanya Ave, NW Warren, Ohio 44485 Terry Cummings _ 6740 East 10th Avenue Anchorage, Alaska 99504 Rebecca Retzlaff 2037 W. Towa Chicago, Illinois 60622 Lisa maahs P.0,Box 91877 Anchorage, Alaska 99509 “Vielen & Colleen Carr P.O,.Box 217 Big Oak Flat, California 95305 Lisa Dietz 5323 Stoneridge Dr. Me Vernon, Indiana 47620 Jeremiah Spence 11206 Whiskey River Drive Austin, Texas 78748 | C.Ralston Allen 2817 Trenholm Road Columbia, South Carolina 29204 David Pray P.O, Box 111404 Anchorage, Alaska 99511 meggan waite po box 283 stinson beach, California 94970 Pamela Vincent 233 East 23rd Avenue Anchorage, Alaska 99503 Kenneth §. Warren 105 Evans Lane Oak Ridge, Tennessee 37830-4128 Marla McPherson PO Box 3585 Homer, Alaska 99603 Barbara Roth 112 Temple br las vegas, Nevada 89107 Marcia Kidd Box 412 Girdwood, Alaska 99587 ‘Leigh Meislahn 17 Mason Street Medford, Massachusetts 02155 Stasia Sprenger 914 West 26th Ave. #5 Anchorage, Alaska 99503 )Jack Conner 3638 Spotted Jack Loop Ss. Billings, Montana 59101 Abram Rutkowski 64351 Hickory Road Bremen, Indiana 46506 Megan ‘Ailen 1724 East Grand River Ave. # 8 Bast Lansing, Michigan 48823 SANDRA SIMS 3600 WAKETON ROAD #25 FLOWER MOUND, Texas 75028 Alan Seegert Box 203 Denali Park, Alaska 99755 Cheryl Rosenfeld University of Missouri 158 ASRC Columbia, Missouri 65211 mike stephen p.o.box40 st.joe, Arkansas 72675 Scott Thomas deborah Neerman 1015 iron mt. rd canton, Georgia 30115 Christy Swanson PoBox 1867 Dade City, Florida 33525 = aaah ; = Nancy Williams po box 170398 San Francisco, California 94117 16351 Nickleen Street Anchorage, Alaska 99516 David Cann 8778 Skyline Blvd. Oakland, California 94611 ‘| Cindy Hendel PO Box 670310 Chugiak, Alaska 99567 <i) AKPIR Alaska Public Interest Research Group P.O. Box 101093 | 507 E Street, Suite 213 | P: 907.278.3661 Anchorage, AK 99910 Anchorage, AK 99501 f: 907.278.9300 Written comments on Draft Environmental Impact Statement-Southern 15A See FEIS Sections 2.2.1, Project Costs and Benefits (pgs. 2-1 to 2-4) Intertie Project and Section 2.2.7, Environmental Cost-Benefit Analysis Summary Kenai Peninsula to Anchorage, Alaska, September 2001, November 26, (pg. 2-21). See also General Response to Issue 13 (pg. 1-8), Chapter 2001. 1 of the FEIS. Stephen Conn, Executive Director, Alaska Public Interest Research Group, submits the following comments: 15B Comment noted. See response to 15A above. 1. The Intertie is not economically feasible. Costs incumbent on construction ISA of the Intertie as related in the environmental impact statement do not include valuations of loss to the Wildlife Refuge by acknowledged . . . restrictions on burning and the impact of those restrictions on the moose 15C The proposed project would increase security of the transmission population and subsistence take of hunters. The new utility corridor will system, as stated in DEIS Section 1.3.1, Reliability (pg. 1-14), 15B open much of the refuge to human transport, both legal and illegal, and “Adding transmission lines to a system improves system reliability disrupt the habitat of the brown bear and other animal populations. Again, by providing multiple paths for the power to flow; thus, an outage of this cost was not allocated to the project. i i : i ot completely disrupt the system.” 2.Security concerns raised by an Intertie in the post-September 11" world a single component does not completely P' y' I5C will have to be met with as yet unadressed remedies whose cost is unknown. 3. Redundancy could be best performed by lower cost decentralized power devices such as fuel cells and microturbines rather than 15D _ See the General Response to Issues | (pgs. 1-3 and 1-4) and Issue 14 15D a second Intertie. Security costs could be lowered and disruption of the (pgs. 1-8 and 1-9) in Chapter | of the FEIS regarding the purpose and wildlife refuge would be lessened along with the costs incumbent on the need for the Project and alternatives considered. proposed Intertie, addressed and unaddressed. 4.Cost of long-term maintenance of the proposed route has not been factored SE a Ee a meaieeeeeee ie SR eign 15E Project maintenance costs were considered as part of the Project cost. . See DEIS Section 1.4.1, Construction and Life Cycle Costs (pg. 1- In sum, only by ignoring important ramifications of construction of the 31) and FEIS Section 2.2.1, Project Costs and Benefits (pgs. 2-1 to 2- Intertie, as proposed, can the authors of the EIS make the proposed route 4). The impact of maintenance on wildlife was primarily considered appear to be economically feasible. Once they are factored in, it becomes by factoring in the additional access and resulting disturbance from immediately apparent that substantial and additional public money will be spent to deal with inevitable consequences of construction and operation of the Intertie. the Project. 1SF Long-term development of the Kenai Peninsula and its power needs are ignored. The EIS assumes growth in Anchorage and an apparent absence of growth on the Peninsula. No evidence is provided for such a premise. This is a project whose time has passed, eclipsed by issues of cost, new technology and domestic security. We reject the proposed Intertie route and call for a more thorough analysis of costs of the proposed project with all elements factored into that equation. Stephen Conn Executive Director November 26, 2001 15F Studies summarized in the DEIS considered the long-term electrical load growth for the Anchorage, Kenai, and Fairbanks areas, as shown in Table 1-8, “Comparison of Peak Demand Forecasts for 2010” (pg. 1-21). See also DEIS Section 1.3, Purpose and Need for the Project (pg. 1-13). 16A National Headquarters 101 Foureenth Su Sone 1400 Washington, OC 20005 Telephone 202-682-9400 Fax 202.682-1331 wowdelenders org www kidsplanet ong, Preted on Regt Faget December 4, 2001 Lawrence R. Wolfe USDA Rural Utilities Service 1400 Independence Ave, SW, Stop 1571 Washington, D.C. 20250-1571 Robin West, Refuge Manager Kenai National Wildlife Refuge P.O. Box 2139 Soldotna, AK 99669 Dear Mr. Wolfe and Mr. West, Defenders of Wildlife submits the following comments on the Southem Intertie Project Draft Environmental Impact Statement (DEIS). Defenders of Wildlife is a national conservation organization with over 430,000 members nationwide, including Alaska. Defenders of Wildlife is dedicated to the to the protection of all native wild animals and plants in their natural communities. Defenders has been a long-time advocate for the Refuge System - convening a commission on the Refuge System resulting in the publication Putting Wildlife First: Recommendations for Reforming Our Troubled Refuge System, coordinating a workshop of scientists culminating in the publication Science Based Stewardship: Recommendations for implementing the National Wildlife Refuge System Improvement Act, lobbying for refuge funding as a leading member in the Cooperative Alliance for Refuge Enhancement (C.A.R.E.), and as a leader in the passage of the 1997 National Wildlife Refuge System Improvement Act (Improvement Act). We also have been actively involved with wildlife management issues on the Kenai peninsula. We are extremely concerned that the Enstar Route was chosen as the preferred alternative even though it is incompatible with the purposes of Kenai National Wildlife Refuge (KNWR), it would irreparably harm the fish, wildlife, plant, and recreational values of KNWR, and practical alternatives exist. The Alaska National Interest Lands Conservation Act (ANILCA) explicitly requires that for transportation and utility systems to established on or through conservation lands, including national wildlife refuges, it must be determined that: (1) such system would be compatible with the purposes for which the unit was established; and (2) there is no economically feasible and prudent alternative route for the system. (ANILCA §1105). The Enstar Route fails on both counts. 16A Refer to the response to comment 13D — Alaska Center for the Environment letter (12/05/01), and the USFWS Compatibility Determination in Appendix A of the FEIS. 16B Defenders of Wildlife Page 2 of 4 compatibility determination. The Enstar Route would require a compatibility determination and a special use permit to establish a right-of-way through KNWR, yet no such determination is made in the DEIS. The Enstar Route can not move forward without a compatibility determination, so it is clearly impossible to completely evaluate the project without this crucial documentation. 5 National wildlife refuges are closed to all uses unless explicitly opened through a c To fulfill the compatibility requirement, the Fish and Wildlife Service (FWS) KNWR manager must evaluate whether the proposed use will “materially interfere with or detract from the fulfillment of the National Wildlife Refuge System mission or the purpose(s) of’ KNWR (50 CFR §26.41(a)). The DEIS never lists the mission of the refuge system, nor the purposes of KNWR which are: The mission of the refuge system is: “.. to administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of the fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.” 16 USC §668dd. (National Wildlife Refuge Systern Administration Act) The purposes of KNWR are: “... () To conserve the fish and wildlife populations and habitats in their natural diversity including, but not limited to, moose, bears, mountain goats, Dall sheep, wolves and other furbearers, salmonoids and other fish, waterfowl and other migratory and nonmigratory birds; (ii) to fulfill the international treaty obligations of the United States with respect to fish and wildlife and their habitats; (iii) to ensure, to the maximum extent practicable and in a manner consistent with the purposes set forth in paragraph (1), water quality and necessary water quantity within the refuge; (iv) to provide in a manner consistent with subparagraphs (1) and (ii), opportunities for scientific research, interpretation, environmental education, and land management training; and (v) to provide in a manner consistent with these purposes, opportunities for fish and wildlife-oriented recreation." 94 Stat. 2391, dated Dec. 2, 1980. (Alaska National Interest Lands Conservation Act) “... as a refuge and breeding ground for moose ...” Executive Order 8979, dated Dec. 16, 1941, “.,. shall be administered by him [Secretary of the Interior] directly or in accordance with cooperative agreements ... and in accordance with such rules and regulations for the conservation, maintenance, and management of wildlife, resources thereof, and its habitat thereon, ...” 16 U.S.C. §664 (Fish and Wildlife Coordination Act) In addition, the FWS Compatibility Policy states that a “significant directive of the Refuge Administration Act is to ensure that we maintain the biological integrity, diversity, and environmental health of the National Wildlife Refuge System for present and future generations 16B Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 16B Defenders of Wildlife Page 3 of 4 of Americans... Uses that we reasonably may anticipate to conflict with pursuing this directive to maintain the (biological integrity, diversity, and environmental health] of System are contrary to fulfilling the National Wildlife Refuge System mission and are therefore not compatible. Fragmentation of the National Wildlife Refuge System's wildlife habitats is a direct threat to the integrity of the National Wildlife Refuge System, both today and in the decades ahead. Uses that we reasonably may anticipate to reduce the quality or quantity or fragment-habitats on a national wildlife refuge will not be compatible.’ (65 Fed. Reg. 62486, emphasis added). The FWS Compatibility Policy places the burden of proof on the proponent of a use that they pass the compatibility test; in fact, the DEIS provides multiple reasons why the preferred route should fail. The DEIS reveals there would be “long term and significant” cumulative impacts and “significant unavoidable adverse impacts” on “wildlife, vegetation, recreation, and visual resources within the KNWR” from the Enstar Route (DEIS, S-18, 3-314). The Enstar Route would have nationally significant, long term, irreversible, irretrievable, and cumulative impacts on moose, the very purpose the refuge was established in 1941 (DEIS, S-23). It is imperative to point out that the proposed use cannot be made compatible by offering compensatory mitigation, the proposed use must be compatible in its own right, which the Enstar Route clearly is not (50 CFR §26.41(b)). We are especially concemed about the impact the proposed Intertie will have on the already threatened Kenai brown bear population. The Kenai Brown bear has been declared a species of special concern by the state. The habitat of the brown bear has already been fragmented by other developments on the Kenai Peninsula. The Kenai Refuge currently has critical unroaded areas that are important to the survival of this species. The southern route will bisect the KNWR and fragment the habitat of the brown bear. Further fragmentation of their habitat by the Enstar Route could have serious impacts on the brown bears and lead to an endangered species listing. In addition, the fragmentation of unroaded areas by the construction of the intertie through the KNWR would reduce the eligibility of these areas for future wilderness designations in these areas. It would be reasonable for the refuge manager to deny the use without a compatibility determination. Refuge managers are entitled to deny uses without compatibility determinations if the proposed use conflicts “with the goals or objectives in an approved refuge management plan (e.g., comprehensive conservation plan, comprehensive management plan, master plan, or step-down management plan)” or “with other resource management objectives provided that the Refuge Manager specifies those objectives in denying the use.” (FWS Compatibility Policy, 65 Fed. Reg. 62489). The DEIS states the Enstar Route would disrupt KNWR’s moose/habitat management plan and fire management plans (DEIS, S-23) and that the project would require an amendment to the KNWR Comprehensive Conservation Plan, presumably because it conflicts | with that plan (DEIS, 4-13). Defenders of Wildlife Page 4 of 4 To protect the Kenai Peninsula brown bear, declared a species of special concern by the 16C 16c | State of Alaska, moose, wolves, bald eagles, and other fish and wildlife, wetlands, water quality, potential wilderness designations, and visual and recreational resources of the KNWR, the application for the Enstar Route, or any other route that passes through KNWR, simply must be denied. Sincerely, q Nook. i, ‘cam Mehl eck Noah Matson Michele Keck Refuge Program Manager Alaska Program Associate Comment noted. mes ‘Audubon ALASKA 408 G Stecst, Suite 217 17A 907-376-5069 udubon.org December 4, 2001 Lawrence R. Wolfe Senior Environmental Protection Specialist USDA, Rural Utilities Service Engineering and Environmental Staff, Room 2240 1400 Independence Ave. SW, Stop 1571 Washington, DC 20250-1571 Re: Comments on the Southern Intertie Project DEIS Dear Mr. Wolfe: On behalf of Audubon Alaska, we offer the following comments on the Draft Environmental Impact Statement for the Southern Intertie Project, Audubon Alaska is dedicated to the conservation of Alaska's natural ecosystems focusing on birds, other wildlife, and their habitats for the benefit and enjoyment of current and future generations. We are submitting this letter on behalf of Audubon Alaska and our 2,300 Alaska members and supporters, Audubon has a strong interest in the conservation and management of the Kenai National Wildlife Refuge. Many Audubon members have visited the refuge and a significant number of our Alaska members use the refuge tegulorly for hiking. birding, wildlife observation and photography, hunting, and fishing, Summary: udubon Alaska’s most significant concerns regarding the Southem Intertic Project are the project’s predicted environmental impacts, particularly associated with the Kenai National Wildlife Refuge (KNWR). We strongly object to the applicant's proposed Enstar Route to construct a 138 kV transmission line and associated facilities through the middle of the northem portion of the KNWR. We believe the proposed Enstar Route will further fragment the refuge and result in significant, long-term environmental impacts. Most of these impacts have been adequately identified and described in the DEIS. In our judgement, the proposed Enstar Route is not compatible with the purposes for which the KNWR was established and Audubon will urge the U.S, Fish and Wildlife Service (FWS) to find the proposed route incompatible with refuge purposes. There are other alternatives that provide cost-effective options for completing this electrical intertie and will not cause significant environmental impacts to the Kenai National Wildlife Refuge. Refuge Purposes and Compatibility: The KNWR was established to conserve fish and wildlife populations and habitats in their natural diversity. Major purposes of the KNWR, as set forth by Scction 303.4 of the Alaska National Interest Lands Conservation Act are: “to conserve fish and wildlife populations and habitats in their natural diversity including, but not limited to moose, 17A Comment noted. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. For information regarding alternatives, refer to the General Response to Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS. bear, mountain goats, Dall sheep, wolves and other furbearers, salmonoids and other fish, waterfowl and other migratory and nonmigratory birds...and to provide, in a manner compatible with these purposes, opportunities for fish and wildlife-oriented recreation.” Nowhere in these purposes do we find reference to providing transportation or utility 17B Comment noted. Refer to the USFWS Compatibility Determination in corridors. In fact, the northwestem boundary of the KNWR was modified in 1964 by i Public Land Order 3400, in part, to provide a future corridor for transportation and utility Appendix A of the FEIS. system development, and development in general on the Kenai Peninsula. 17B Compatible use of a national wildlife refuge is defined by regulation as: “a proposed or existing wildlife-dependent recreational use or any other use of a national wildlife refuge that, based on sound professional judgment, will not materially interfere with or detract from the fulfillment of the National Wildlife Refuge System mission or the purpose(s) of the national wildlife refuge.” (SOC.F.R. 25.12(a)). Because the Southern Intertie DEIS has determined that the proposed Enstar Route will result in significant and cumulative environmental impacts of national significance, this proposed route is clearly not compatible with the purposes for which the refuge was established. _Environmental Impacts: Brown bears: The Kenai Peninsula population of brown bears was listed by the Alaska Department of Fish and Game as a Species of Special Concem in 1998. The department took this action because the population is vulnerable to significant declines due to low numbers, restricted distribution, and sensitivity to environmental disturbance. The state also convened a brown bear stakeholder group charged with developing a conservation strategy for Kenai brown bears. The Kenai Peninsula Brown Bear Conservation Strategy 17C Comment noted. See FEIS Section 2.2.6, Update on Kenai Peninsula Brown (ADF&G 2000) identificd concems about utility corridors increasing access to important B d Wolveri 2-18 to 2-19 brown bear habitats, which may result in higher bear mortality duc to “defense of life or ears and Wolverines (pgs. 2-18 to 2-19). property” (DLP) kills. The conservation strategy recommended that: “Public land managers should plan and site new utilities to minimize or avoid impacts to important brown bear habitat, Route utilities in established utility corridors or along roadsides where possible.” Since the KNWR boundary was modified in 1964 explicitly for the 17¢ purpose of providing “a future corridor for transportation and utility system development,” it seems clear to us that there are better alternatives than building a major transmission utility corridor through the heart of the refuge. The Interagency Brown Bear Study Team (IBBST) has raised concems about the potential impacts of the Enstar Route on Kenai brown bears. In a 15 February 2000 letter to the refuge manager, the IBBST identified the following concems: The proposed Enstar Route has numerous potential threats to brown bears. This route penetrates over 30 miles of relatively remote and currently secure brown bear habitat on the refuge, and would intersect any east-west movement of brown bears traveling between lowland and mountainous areas. The Enstar Route will cross many streams that support large numbers of spawning salmon, which are the most important food for brown bears on the Kenai Peninsula. Any negative effect the Enstart Route may have on fish will result in subsequent negative impacts on brown bears. The Enstar Route will also increase opportunities for human access into brown bear habitat, which may greatly 17D increase the number of brown bears killed in defense-of-life-or property (DLP). Survival of the brown bear population on the Kenai Peninsula is susceptible to an increase in DLPs, hence the Enstar Route could have effects on the bear population far beyond habitat degredation. The Enstar Route would biscct the movements of at least six radio-collared brown bears that have been monitored by the IBBST from 1996-1999. In contrast, the Tesoro Route did not bisect any radio-collared bear movement during this time. Brown bears apparently do not make significant use of the coastal Tesoro Route, probably because of the higher human uses of this area compared to the Enstar Route. The Tesoro Route would cross four anadromous fish streams. In comparison the Enstar Route crosses seven anadromous salmon streams that provide feeding areas for brown bears. The DEIS also recognized the sensitivity of brown bears on the peninsula and has determined that there will be significant cumulative impacts. For example, the DEIS states (p. 3-295): “Additional cumulative impacts are anticipated as a result of the presence of increased access and potential for increased mortality through DLP. These effects are expected to be significant on the KNWR, and on the Kenai Peninsula.” In contrast to the Enstar Route, the DEIS does not identify significant impacts to brown bear from the Tesoro Route. Audubon Alaska has major concerns about the Enstar Route and its impacts on Kenai Peninsula brown bears. Maintaining a viable population of brown bears on the Kenai Peninsula will be a challenge for state and federal wildlife managers, even under the best of circumstances. It is not prudent to further exacerbate the risks to this population of concer by fragmenting the KNWR and increasing the opportunity for bear-human interactions that could lead to increased mortality pressures. Because the Kenai brown bear population is small and geographically isolated from mainland Alaska, it is at higher tisk of local extinction. Not only would the Enstar Route increase human-bear interactions, it would also increase the likelihood of additional incremental developments into the refuge in the future. A major goal of the Kenai Brown Bear Conservation Strategy was to apply proactive conservation measures to prevent the need for a federal endangered species listing. Such a listing would increase the cost of managing bears on the Kenai Peninsula. It is not reasonable or prudent to increase the risk of an |_Endangered Species Act listing by selecting the Enstar Route. Other terrestrial mammals: Audubon Alaska is concemed about the impacts of the Enstar Route on moose and wolves as a result of increased human interactions and disturbance and habitat change. For moose, in particular, the inability of the refuge to manage fire through “let-burn” policies and prescribed fire is a significant concern in maintaining productive habitat in early stages of forest succession. This would be | orsign with the refuge plan. The DEIS also acknowledges these concerns in terms of significant cumulative impacts to the KNWR from the Enstar Route. Beluga whales: The Chickaloon Flats is an important feeding area and a likely calving area of Cook Inlet beluga whales. Although the DEIS states that development activities 17D Comment noted. See DEIS Section, 3.6.1, Land Jurisdiction and Management Plans, Fire Management Plan (pg. 3-123), 3.5.3 Terrestrial — Wildlife, Moose (pg. 3-62 and 3-69), and 3.5.3 Terrestrial — Wildlife, Predators (pg. 3-58 and 3-70). See also 3.6.3, Alternatives, Enstar to Chickaloon Bay — Route Option F, Environmental Consequences (pg. 3- 143). Refer also to the USFWS Compatibility Determination in Appendix A of the FEIS. 17E 17F 17G 17H 171 17J 17K associated with the Enstar Route will not occur here during calving and feeding seasons, Audubon remains concerned that there may be overlap of construction activities or maintenance activities during seasons when beluga whales are using the area. Cook Inlet beluga whales are listed by the National Marine Fisheries Service as a depleted species. Managers must take extra care not to disturb or disrupt this small, isolated population of whales, particularly during their important recovery period. irds: The KNWR provides important habitat for over 130 species of birds. The northern portion of the refuge, through the Kenai Lowlands to the Chickaloon Flats, is a major waterfowl concentration area and includes an important breeding population of Trumpeter Swans. Trumpeter Swans are particularly sensitive to human disturbance. Audubon Alaska has concerns about the potential impacts of the Enstar Route on waterfowl populations, including Trumpeter Swans, and on Bald Eagle populations in the area. These concems are associated with increases in disturbance and the potential of collisions with power lines. Subsistence: Audubon would like to sce a further evaluation of the impacts of the Enstar Route on subsistence opportunities on the KNWR. Considering that this route would prohibit fire management and would likely result in a long-term decline in moose productivity, we assume there would be a commensurate decline in subsistence hunting opportunity on this part of the refuge. We are curious why a Section 810 Subsistence Lanalysis was not completed for this project. [Visual Impacts on Scenery and Recreation: The Enstar Route would leave a |_ianificant and visually obvious swath of cleared forest through the KNWR. This would ve long-term cumulative impacts on scenery and recreation on the refuge. Anchorage Coastal Wildlife Refuge: The Enstar Route would require burying a transmission line across the Anchorage Coastal Wildlife Refuge west of Potter Marsh. Audubon is concerned about the environmental impacts of this activity on the refuge. In contrast, the Tesoro Route would avoid any impacts to the refuge. __ Analysis of Alternatives: The DEIS identified significant differences between the Enstar Route and Tesoro Alternative. In comparison to the Tesoro Alternative, the Enstar Route would result in significant, long-term environmental impacts to the KNWR and many of its environmental resources. Although, in some cases, the DEIS suggests there may be some mitigation measures that would reduce those impacts, we believe the proposed mitigation is inadequate. We also feel that the range of alternatives was minimal and would like to have seen a better evaluation of additional alternatives beyond the proposed route, one |_alternative, and the no action alternative. Conclusions and Recommendations: [Audubon Alaska has reviewed the DEIS for the Southern Intertie Project and we strongly urge that the proposed Enstar Route be rejected because of its significant and cumulative environmental impacts. Although the range of alternatives was minimal, there are 17E VP 17G 17H 171 17J With mitigation, such as scheduling construction to avoid the calving period, impacts to belugas are not expected to be significant. See DEIS Section 3.5.9, Marine Environment, Environmental Consequences and Mitigation, Marine Mammals (pg. 3-113). See also Chapter 2, Section 2.2.5, Update on Beluga Whales (pgs. 2-17 to 2-18) of the FEIS. Comment noted. See DEIS Section 3.5.3, Terrestrial — Wildlife, Waterfowl (3-49) and Trumpeter Swans (3-52) and General Environmental Consequences and Mitigation for Wildlife, Birds (3-64). See also the Mitigation Plan in Volume II of the FEIS. Refer also to comment response IN - EPA letter (12/05/01). Section 3.8 of the DEIS contains the information that would be found ina Section 810 analysis, and as noted on pg. 3-209, impacts to subsistence are not expected to be significant. See also the response to comment 130 — Alaska Center for the Environment letter (12/05/01). Comment noted. See DEIS Section 3.9.1, Visual Resources Overview, Visual Assessment (pg. 3-216), Table 3-37, Cumulative Impact Analysis (pg. 3-299), and the Mitigation Plan in Volume II of the FEIS. Horizontal directional drilling on the ACWR would reduce impacts associated with intertidal areas to negligible levels. In addition, construction of project facilities would be consistent with the Anchorage Coastal Management Plan as noted on pgs. 3-129 — 3-130 of the DEIS. See also DEIS Section 3.4.6, Alternatives, Chickaloon Bay to Oceanview Park — Route Option H, Environmental Consequences and Mitigation (pg. 3-33), Appendix B, Construction Activities, Horizontal Directional Drill Submarine Cable Installation (pg. B-43). Additional information is also provided in the Mitigation Plan in FEIS Volume II and response to comments 9A and 9D — Alaska DGC letter (12/05/01). See the General Response to Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding adequacy of alternatives analysis. See also the Mitigation Plan in Volume II of the FEIS. acceptable alternatives to the proposed route. Developing the proposed route would hare a ; result in unacceptable environmental costs, Audubon strongly recommends that the FWS 17K Comment noted. See the USFWS Compatibility Determination in Appendix find the proposed route incompatible with refuge purposes. Based on the analysis in the A of the FEIS. DEIS and the refuge purposes, we believe there is no other logical finding. This is particularly obvious, since the refuge boundary was previously modified to accommodate a future utility corridor. When amortized over the life of the project, the additional construction cost of using the alternative route is likely insignificant when compared to the Enstar Route’s environmental costs and inadequacy of mitigation. 17K cont. Thank you for considering our comments, Sincerely, q 2 A Stanley E/Senner John W. Schoen, Ph.D. Executivé Director Senior Scientist 18A Sierra Club, Alaska Field Office 201 Barrow Street, Suite 101 Anchorage, Alaska 99501 December 5, 2001 Via electronic mail Mr. Laurence R. Wolfe USDA-Rural Utilities Service 1400 Independence Ave. SW-Stop 1571 Washington, D.C. 202-1571 Re: Draft Environmental Impact Statement, Southern Intertie Project Dear Mr. Wolfe: On behalf of the Sierra Club, Tum submitting comments on the Draft Environmental Impact Statement (DEIS), Southern Intertic Project. The Sierra Club is a national environmental organization of 700,000 members with chapters in every state. Our members are vitally interested in the protection of the public lands of Alaska, including the Kenai National Wildlife Refuge. Our members worked hard to enact the Alaska National Interest Lands Conservation Act of 1980, which, among many other important provisions, re-designated the former Kenai Moose Range as the Kenai National Wildlife Refuge and designated much of the Refuge as the Kenai Wilderness. Recommended alternative Of the altematives analyzed in the DEIS, the Sierra Club recommends adoption of the Tesoro Route- Options A and C, which avoids crossing the Kenai National Wildlife Refuge in favor of following an existing utility and transportation corridor along the western edge of the Kenai Peninsula, The DEIS concludes that the Tesoro Route is the environmentally preferred alternative, primarily because the route stays outside the refuge. 18A “he Enstar Route, the preferred alternative of the applicants, would cross the northern sortion of refuge. According to the DEIS, the route could be expected to have numerous «dverse impacts of national significance on refuge resources and values: Birds, including bald eagles, trumpeter swans, and general waterfowl; Vegetation and wetlands; Brown/grizzly bears, black bears, and moose; Predators, including wolf and lynx; Potential wilderness designation; and Visual/aesthetic values; ooooo90d Comment noted. The Tesoro Route has been selected as the agency preferred alternative as noted in the FEIS Summary, Section S.10 — Agency Preferences and Decision to be Made (pg. S-26). ‘The Tesoro route is found to have no nationally significant adverse impacts on the refuge resources and values listed above. It would have significant local impacts on visual/aesthetic values along the Cook Inlet coast portion of the route outside the refuge. Refuge compatibility determination he public should be given an opportunity to comment on a draft compatibility determination, The opportunity to comment on a DEIS is not an adequate substitute, as a DEIS does not contain the depth of analysis with respect to compatibility that a compatibility determination must contain, Without a draft compatibility analysis to evaluate, it is impossible for the public to focus its comments in a manner that is relevant and responsive to the issues, and the public is therefore deprived of the meaningful opportunity to comment that is required by the National Wildlife Refuge System Improvement Act of 1997, 18B Comment noted. Refer to the USFWS Compatibility Determination included in Appendix A of the FEIS. In the current case, the public is being denied the opportunity to review und comment on the draft compatibility determination for the southern Intertie Project until the final 18B environmental impuct statement or the subsequent record of decision is published. This denial is contrary to the Refuge Improvement Act of 1997. Title X 0) 5: Ci The Fish and Wildlife Service will not be able to approve the right-of- way across the Kenai Refuge for the applicant's proposal, because the agency will not be able to make and justify the findings required by Title XI of ANILCA., That title requires that the Service "consider, and make detailed findings supported by substantial evidence, with respect to- {A) the need for, and economic feasibility of, the transportation utility system; (B) alternative routes and modes of access, including a determination with respect to whether there is any economically feasible and prudent alternative to the routing of the system through or within a conservation system unit . . . ; (D) short- and long-term social, economic, and environmental impacts of national, State, or local significance, including impacts on fish and wildlife and their habitat, and on rural, traditional lifestyles; (F) any impacts that would affect the purposes for which the Federal unit or area concerned was established; (G) measures which should be instituted to avoid or minimize negative impacts; and (4) the short- and long-term public values which may be adversely affected by approval of the transportation or utility system versus the short- and long-term public benefits which may acerue from such 18C See the General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. 1-8 EepeLoy aie to 1-9) in Chapter 1 of the FEIS regarding the purpose and need for the 18C Because the need for the project has not been adequately Project and adequacy of alternatives analysis. The USFWS has provided a demonstrated, and because there are alternatives to the applicant's Compatibility Determination regarding the right-of-way application across proposal that would avoid impacts to the Kenai Refuge, the Service will the KNWR in Appendix A of the FEIS. not be able to supply substantial evidence to support findings in support of a decision to grant a right-of-way for the applicant‘s proposal. Thank you for this opportunity to submit our views. Sincerely, Jack Hession Senior Regional Representative cc: Mr. David Allen, Alaska Regional Director, U.S. Fish and Wildlife Service Mr. Robin West, Refuge Manager, Kenai National Wildlife Refuge 19A 19B a Original Message----- From: AWRTA - Sarah Leonard, Executive Director [mailto:sleonard@awrta.org) Sent: Wednesday, December 05, 2001 7:18 PM To: lwolfe@rus.usda.gov Cc: sthomas@awrta.org Subject: Southern Intertie comments - AWRTA RRR AE REAR AREER ERR EERE ERR RE EER ERROR ERE AREER RENEE This E-Mail and or attachments have been scanned for and found free of known viruses, EERE EER ARERR RETR K EIR EEE T EERE D EER EE To Whom It May Concern: lam writing on behalf of the Alaska Wilderness Recreation & Tourism Association (AWRTA) Board of Directors and membership to oppose the preferred intertie route (the “Enstar Route") across the Kenai National Wildlife Refuge (KNWR). AWRTA, a membership-based trade association represents 300 nature-based tourism businesses, partnering organizations and individuals throughout Alaska. We support the effort to upgrade and maintain electricity supplies throughout Alaska. However, we are strongly opposed to the applicant’s preferred route, the Enstar Route, across the KNWR. This route would have unacceptable impacts on the refuge, wildlife populations, habitat, and potentially, the sustainability of the Kenai Peninsula's nature-based tourism dependant businesses. There are reasonable alternatives to the Enstar Route that would accomplish the same objectives and would also preserve the integrity of the Kenai National Wildlife Retuge. For example, the Enstar route would cause unacceptable adverse impacts on the wildlife of the refuge. These impacts include loss of wildlife habitat and populations, wilderness qualities, and ability of KNWR to meet its legal mandates. A power line on the Enstar route would essentially stop habitat management for moose, bears, wolves, and lynx in the eastern third of the refuge. This effect would be due to a new obligation of fire management and efforts to put out every fire in the area in order to protect the southern intertie route as proposed. 19A 19B Comment noted. Impacts to wildlife are noted and discussed in the DEIS in Section 3.5.4 Alternatives Enstar to Chickaloon Bay — Route Option F (beginning on pg. 3-88). The DEIS also acknowledges that the Enstar Route could potentially conflict with management plans within the KNWR, see Section 3.6.3, Alternatives, Enstar to Chickaloon Bay — Route Option F, Environmental Consequences (pg. 3-143). 19C 19D 19E 19F 19G Periodic forest fires are important in the ecology of the Alaskan interior. Fires maintain the willow and aspen brush that are essential forage and cover for moose, lynx, and other wildlife; without fires, the forest loses these plants. The eastern half of KNWR burned in 1947 and is poor habitat for moose and lynx (as noted in the DEIS), whereas the southwestern refuge area, which burned in 1969, supports high densities of wildlife. KNWR currently allows natural fires to burn throughout the eastern part of the refuge, and it also does prescribed burning in a small area. [The Enstar route would impair the refuge's habitat management at a nationally significant level, as the DEIS acknowledges. The DEIS says that the Enstar route would only impact habitats in the powerline corridor itself, but this is a gross understatement. The DEIS says the line would interfere with prescribed burns, but it neglects the much larger impact of preventing natural {_fires from burning. The potential long-term and cumulative negative economic impacts of proposed routes must |_also be considered. AWRTA supports investigating an alternative route along the 150-foot wide power line corridor. Although a route along the power line corridor offers a higher initial cost; AWRTA argues that the long-term investment and benefits for tourism-based businesses and local economies within the Kenai area outweigh these short-term impacts. For example, the Kenai Peninsula economy is heavily dependent on the tourism and outdoor recreation industries, which rely on the health of wildlife populations and access to special areas. This includes hunting as an important recreational use of KNWR. Among the most desired species are moose and brown bear. Populations of both are below target levels and a brown bear season has not occurred since 1995. A 150-foot wide power line corridor would allow easier hunting access to the eastern part of the refuge, including seven anadromous fish streams where brown bears gather. Without the ability to improve moose habitat, itis possible that further hunting restrictions on moose may occur on the refuge. Also likely, are increases in loss of bears in defense of life and property, which is already rising on the northern Kenai Peninsula. If wildlife populations and habitat suffer as a result of restricted management practices on the refuge then it is likely that several tourism and outdoor recreation businesses will suffer, as well as outdoor recreation opportunities for Alaska residents. Several wildlife species of KNWR depend on wilderness. The central third has legal wilderness status, and the eastern third is wilderness in character (as the DEIS recognizes). Species that are vulnerable to disturbance would be pushed back from the area with increased access; these include trumpeter swans, wolves, and brown bears. Even after construction is completed, disturbance from increased human access would affect these species in the area. Recreation also would suffer; several lakes along the Enstar corridor are used for wilderness recreation where people go to experience the beauty and healing power of a natural place. {_These qualities would severely impacted by a powerline. Further, Chickaloon Flats is a state “Critical Wildlife Area." The Turnagain Arm population of beluga whales, which is considered a depleted species, calves and feeds on the Chickaloon Bay flats. Up to 25,000 waterfowl and shorebirds stage on the flats in spring. The DEIS does not analyze how a powerline could be buried in these flats during the applicant's preferred construction season without impacts on wildlife. It mentions avoiding the Beluga calving period, however that is only part of the sensitive period. Finally, the DEIS does not identify true values for wildlife and wilderness. The Enstar route is not the environmentally preferred route of this DEIS, yet the applicant prefers it on incomplete economic grounds alone. AWRTA urges the EIS include an accurate analysis of value for 19C It is acknowledged that the line would also affect suppression of natural fires, as well as prescribed burns (see DEIS pages 3-123 to 3-124). See also response to 19A (above). 19D Comment noted. See DEIS Summary and Section 3.12 for discussion on cumulative impacts. See also Section 2.6.2, Environmentally Preferred Alternative (pg. 2-59) for more information on the Tesoro Route. See also Sections 2.2.1 and 2.2.7 in the FEIS for more information on Project Costs and Benefits (pgs. 2-1 to 2-4) and on Environmental Cost-Benefit Analysis Summary (pgs 2-21 to 2-32). 19E Comment noted. See DEIS Section 3.7.2, Socioeconomic Consequences of the Proposed Action, Long-term Tourism and Recreation Impacts (pg. 3- 184). See also the General Response to Issue 13 (pg. 1-8) in Chapter 1 and Section 2.2.7, Environmental Cost-Benefit Analysis Summary (pgs 2-21 to 2-32) of the FEIS. 19F See response to comment 1G — EPA letter (12/05/01) regarding mitigation, and Chapter 2, Section 2.2.5, Update on Beluga Whales (pgs. 2-17 to 2-18) in the FEIS. 19G See Section 2.2.7, Environmental Cost-Benefit Analysis Summary (pgs. 2-21 to 2-32) of the FEIS. wildlife and wilderness. Several accepted economic models of analysis are available and could be compared with utility costs. 19H Comment noted. See DEIS Section 2.6, Alternative Route Comparison (pg. The wilderness character that exists over much of tha Kenai Peninsula provides unique 2-59). See also DEIS Section 1.4.1, Construction and Lifecycle Costs (pg. |- 19H _ | opportunities for all types of outdoor recreation enthusiasts to enjoy and appreciate the KNWR 31) and the General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. and other public lands on the Kenai Peninsula, Alternative routes, costs comparisons and long- : sae . . . term investments and impacts should be considered for a southern intertie route. 1-8 to 1-9) in Chapter | of the FEIS. Additional cost information regarding the alternatives may be found in Chapter 2 of the FEIS, Section 2.2.2, Cost AWRTA respectfully opposes the Enstar route and believes this proposed route would have and Technical Comparison Discussion of Route Options (pgs. 2-4 to 2-11). 191 | major long-lasting impacts on the KNWR, which is a valuable public resource for both businesses and residents. Thank you for considering these comments. 191 Comment noted. Sincerely, Sarah Leonard Executive Director The Alaska Wilderness Recreation & Tourism Association (AWRTA) The Alaska Institute for Sustainable Recreation & Tourism (AISRT) 2207 Spenard Road, Suite 201 Anchorage, AK 99503 907-258-3171 -'T * 907-258-3851 - F EMAIL - info@awrta.org http:/Awww.awrta.org Linking Business, Community and Conservation! 20A ay 4a Shs: ‘ ~ ane THE WILDERNESS SOCIETY Lawrence R. Wolfe USDA ~ Rural Utilities Service 1400 Independence Ave. SW - Stop 1571 Washington, DC 20250-1571 Lwolte@nus.usda.gow Sent via electronic and priority mail December 5, 2001 Re: Comments on the Southern Intertic Project Draft Environmental Impact Statement Dear Lawrence R. Wolfe Thank you very much for the opportunity to comment on the Souther Intertie Project Draft Environmental Impact Statement (DEIS). The Wildemess Society has a number of congems aout the proposed Southern Intertie and the DEIS and we welcome this opportunity to comment. Please accept the following as our comments. The Wildemess Society (TWS), founded in 1935, is a non-profit membership organization devoted to preserving wildemess and wildlife, protecting America’s prime forests, parks, rivers, deserts, and shorelines, and fostering an American land ethic, With 186,000 members nationwide, TWS has approximately 660 members in Alaska, many of whom use the Kenai National Wildlife Refuge and are concemed about the management of its natural resources and roadess arcas. TWS strongly opposes the proposed Southern Intertic, a 138 kilovolt transmission line, which wou'd follow the Enstar gas pipeline route and bifurcate the Kenai National Wildlife Refuge, in addition to impacting other pubic lands and waters. We oppose this project primanly for the environmental impacts it will cause, including further fragmenting the Kenai National Wildlife Refuge. We feel strongly that this project is incompatible with the purposes anid management intent of the Kenai Refuge. TWS also questions the timing and anced for the proposed project, and we have a number of concems regarding the DEIS outlined below. The DEIS Is insufficlent: TWS believes the DEIS is insufficient for a variety of reasons. These include: the range of alternatives, economic information, the scope of the purpose and need section, subsistence analysis and finally the analvsis of the impacts of the orovosed oroiect to ALASKA REGION 480 WEST 7TH AVENUE, ANCHORAGR, AK 99501 ‘TEL. (907) 272.9453 FAX (907) 272-1670 20A Comments noted. See responses below. 20B 20C 20D different user groups of national and state public lands in the project area. We outline these issucs in more detail below. p—Xange of Alternatives To begin, the DEIS does not sufficiently analyze a full range of alternatives. There are three alternatives analyzed in some detail in the DEIS. One is the no action alternative which is not fully fleshed out in the DEIS. The other two are both overhead power line alternatives. There is no detailed analysis of alternatives other than overhead power lines, so the alternatives analysis does not draw from the full spectrum of potential altematives, as NEPA requires. For example, we believe the existing power line, the Quartz Creek route, needs to be fully analyzed as a possible alternative. Instead, it is eliminated from detailed analysis in the DEIS, which is unacceptable for a document that is meant to analyze a full range of alternatives. We are not convinced that the DEIS has adequately justified its elimination of this and other alternatives. Additionally, the power generation from the Healy Clean Coal project is not considered in the DEIS, nor are any alternative energy sources. The latter are also eliminated from detailed analysis in the DEIS. Again, this is not acceptable for a document that is meant to analyze a full range of alternatives. Instead the DEIS analyzes two alternatives that are quite narrow in scope. -—Economic Issues Economic issues are dealt with insufficiently in the DEIS. There is no real cost benefit analysis of the proposed project in the DEIS. The DEIS does not take into account any of the costs associated with loss of habitat and impacts to wildlife, such as Mystery Creek and Chickaloon areas in the Kenai Refuge, in addition to others. Nor does it consider the cost of: impacting brown bear habitat and potentially threatening the long term viability of the Kenai Peninsula brown bear population; loss of fish and bird habitat; loss of biological diversity; and, finally, incompatibility overall. Thus we do not feel there is sufficient information in the DEIS to base any decisions on the economics of the proposed project. Purpose and Need [~TWS does not believe that the purpose and necd for the project has been adequately justified in the DEIS. To begin, we question the timing of the project, and are not convinced that it is, in fact, a necessary project at this time. We also believe that the DEIS does an insufficient job of documenting the deficiencies with the current power line system and need for this project. Thus we question whether the objectives of this proposed Intertie are reasonable. Among other reasons, the DEIS outlines, on page 1-13, that the project is needed in order to: . © Increase reliability of interconnected Railbelt electrical system from the Kenai Peninsula to Fairbanks, and reduce the requirement for load shedding during system disturbances 20B 20C 20D RUS has determined that the range and scope of alternatives have been adequately studied. See the General Response to Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding adequacy of alternatives analysis. The Healy Clean Coal Project was considered as part of the studies conducted for the DEIS. The Healy Clean Coal Project provides additional generation to the Railbelt grid and as explained under New Generation on pages 2-4 to 2-5 of the DEIS, the overall system currently has an excess of generating capacity over electrical load. As indicated in Table 2-1 (DEIS p. 2-2), new generation does not meet any of the seven alternative screening criteria. Consequently, the Healy Clean Coal Project is not a viable alternative to a second transmission line between Anchorage and the Kenai Peninsula. The Healy coal fired generation is shown as part of the Railbelt generation resources on Figure 1-3, page 1-5 and Figure 2-1, page 2-5 of the DEIS and was included in the electrical system studies for the Project (Power Engineers 1996, 1997). See the FEIS Chapter 1, Issue 13 (pg. 1-8) and Section 2.2.7, Environmental Cost-Benefit Analysis Summary (pgs. 2-21 to 2-32). See the General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding the purpose and need and adequacy of alternatives analysis statement. One of the purposes of the Project is to make the Kenai area generation more available to the utilities to the north. This is discussed in the DEIS in Sections 1.3.2, Power Transfer Capability (DEIS page 1-22) and 1.3.3, Economic Generation (DEIS pgs 1-23 to 1-24). With regard to consideration of the load growth on the Kenai and/or Anchorage or Fairbanks refer to response to comment 15F — Alaska Public Interest Research Group letter (11/26/01). 20D * Increase the power transfer capacity between the Kenai Peninsula and Anchorage area © Provide the capability to utilize the most economic generation mix available to reduce costs to consumers and to allow generation capacity in one area to support the load in the other area. The DEIS also outlines that the Quartz Creek line is limited and does not allow full use of the Kenai Peninsula generation. It states the following: The Quartz Creek transmission line is limited in electrical transfer capability and its ability to provide reliable back-up power during system outages. The line is subject to outages from ice, wind, and snow loading, and is routed across known and historically active avalanche areas. With the addition of the Bradley lake Hydroelectric Project in 1991, the limitations of the Quartz Creek transmission line have not allowed the increased generating capacity from the Bradley Lake Project to be used to full potential. (p. 1-2 DEIS) and The existing Quartz Creek transmission line is limited to transferring 70 MW of power for a secure transfer. To allow full use of the Kenai Peninsula generation, the intertie secure transfer capacity needs to be increased to 125 MW. (p. 1-8 DEIS) What the DEIS does not clarify is why this additional capacity transfer is actually needed in the Anchorage or Fairbanks area. Or, if it is needed, how else Anchorage and Fairbanks may be able to get this additional capacity other than by a new overhead power line. Nor does it discuss the future needs of the Kenai Peninsula as it experiences growth. It’s possible that the excess capacity may be needed on the Kenai Peninsula in the future in order to meet growth needs there. What the DEIS does state is that power would be available to consumers at lower costs if the project were put in place. For example, on page 1-23 of the DEIS it states the following: The present limitation on power transfers between the Kenai Peninsula and Anchorage area results in a more expensive mix of power being generated from the existing power plants to supply the load than if the Project were in service. However, TWS questions whether this reduction in costs to consumers outweighs the value of the loss of habitat and public lands the state and nation will experience as a result of this project. Again, we do not believe the DEIS justifies the purpose and need for this project. 20E 20F Subsistence The DEIS states that there would be only minimal impacts to subsistence uses as a result of the proposed project. The DEIS states specifically that: However, due to the overall low level of subsistence use in the area, no impacts, or only minimal impacts, on subsistence practices are anticipated from increased uses of hunting and fishing sports. (p. 3-209 DEIS) We believe this statement is over simplified, and that the DEIS does not take into consideration the full range of impacts to subsistence associated with this project. For example, the DEIS does identify that, “Moose hunting appears to be the most substantial subsistence use within the study area” (p. 3-210 DEIS). However, the subsistence section of the DEIS docs not mention, much less analyze, the impacts that the proposed project will ultimately have on moose habitat due to fire restrictions in and adjacent to the project area, Prescribed fires are a significant part of moose habitat management on the Kenai Peninsula. Having an overhead power line transecting the Kenai Refuge will significantly alter the U. S. Fish and Wildlife Service’s and Alaska Department of Fish and Game’s approach to moose habitat management. However, the long term effects of limiting or eliminating prescribed burns as a result of the project on moose populations and ultimately hunting is not discussed at all in the subsistence section. Further, the Summary to the DEIS indicates for the proposed route that: The cumulative effects on wildlife, vegetation, recreation, and visual resources within the KNWR along Route Option F are considered to be long term and significant. (p. S-18 DEIS) Even though, for example, the project has the potential to significantly impact moose habitat and ultimately the moose population, the DEIS suggests that impacts to subsistence will be minimal. The subsistence section states, for example: There appears to be no negative impact on populations of relevant species that would impair subsistence practices. (p. 3-209 DEIS) This statement seems to-contradict the above statement regarding long term significant impacts to wildlife as a result of the proposed project. Further, we question the validity of this finding, For these and other reasons we believe the subsistence analysis in the DEIS is inadequate. __Impacts to Different User Groups The DEIS does not analyze the impacts the proposed project will have on different user groups. For example, there is no analysis of impacts to hunters (other than subsistence hunters), trappers, sport fishers, hikers, cross country skiers, dog mushers, and boaters, and many other users of these public lands. This analysis is particularly important since, as the DEIS points out, the Kenai Refuge supports more recreational use than any other 20E 20F Refer to comment response 130 — Alaska Center for the Environment letter (12/05/01). Impacts on recreation and tourism were analyzed in the DEIS, and discussed in Section 3.7.2, Socioeconomic Consequences of the Proposed Action, and Long-term Tourism and Recreation Impacts (pg. 3-184). Recreational users are noted on pg. 3-131, and increase in law enforcement patrols as a result of increased access are described on pg. 3-144 of the DEIS. 20F cont. refuge in Alaska. Indeed, one of the purposes for establishing the refuge was, “ to provide . . . opportunities for fish and wildlife-oriented recreation.” (Sec. 303-4, ANILCA) The DEIS acknowledges that: The refuge may experience a loss of control over maintaining limited access opportunities along the Enstar pipeline north of Mystery Creek Road. This loss of control could result in significant management problems similar to those associated with oil and gas development. (p. 3-143 DEIS) The DEIS is deficient for not analyzing the impacts of the project and the potential loss of control regarding management of users as a result of the project on various user groups. Kenai Refuge Compatibility Issues In 1997, Congress enacted the National Wildlife Refuge System Improvement Act, a long-overdue “organic act” for the 93 million-acre Refuge System. With respect to national wildlife refuges in Alaska, the Refuge Improvement Act supplements the Alaska National Interest Lands Conservation Act. The Refuge Improvement Act spells out the System's mission, lays out requirements for planning national wildlife refuges, requires public review of decisions about what activities will be allowed on refuges, and details a series of mandates for the Secretary of the Interior to protect and provide for the Refuge System. In addition, the bill specifies that, while wildlife conservation is the highest priority of the refuges, wildlife-related recreation such as wildlife observation, fishing, hunting, and environmental education are appropriate uses that must take priority over non-wildlife uses of the refuges. Above all else, the Refuge Improvement Act requires that wildlife come first in the National Wildlife Refuge System. It does so by establishing that wildlife conservation is the singular mission of the Refuge System, by requiring the Service to maintain the system's biological integrity, diversity, and environmental health, and by mandating that the status and trends of fish, wildlife, and plants be monitored on each refuge. One of the most important provisions of the Refuge Improvement Act is the directive for the Secretary of the Interior to “maintain the biological integrity, diversity, and environmental health” of each refuge. To implement this directive, the Service should make the maintenance of biological integrity, diversity, and environmental health a foundation for refuge planning and management. The Kenai National Wildlife Refuge was established to conserve fish and wildlife populations and habitats in their natural diversity. Section 303.4 of the 1980 Alaska National Interest Lands Conservation Act (ANILCA) outlined the following as one of five purposes for the establishment of the Refuge: (i) to conserve fish and wildlife populations and habitats in their natural diversity including, but not limited to moose, bear, mountain goats, Dall sheep, wolves and other fur bearers, salmonids and other fish, waterfowl and other migratory and nonmigratory birds. , 20G 20H The National Wildlife Refuge System Administration Act (NWRSAA) authorizes the Secretary of the Interior to permit any use of a national wildlife refuge when the Secretary determines that the use is compatible with the purposes for which the refuge was established, The regulations define “compatible use” as: A proposed or existing wildlife-dependent recreational use or any other use of a national wildlife refuge that, based on sound professional judgement, will not materially interfere with or detract from the fulfillment of the National Wildlife Refuge System mission or the purpose(s) of the national wildlife refuge. As already outlined, the cumulative effects of the proposed project on wildlife, vegetation, recreation, and visual resources within the Kenai Refuge are projected to be long term and significant. Given that the proposed project will result in long term and significant impacts to wildlife, TWS believes that there is no possibility that this use is compatible with the purposes and primary management intent of the Kenai Refuge. In fact, the DEIS admits to the following: Based on the mandate and purpose establishing the refuge, predicted environmental impacts, proximity of highly sensitive wildlife species, and management concerns, the proposed Project would conflict with the KNWR Comprehensive Conservation Plan. (p. 3-143 DEIS) TWS agrees with the statement above, and we believe that this proposal is incompatible with the purposes of the Refuge. Wildlife conservation is the singular mission of the Refuge System, and, as outlined in the Refuge Improvement Act, wildlife must come first | above all other uses. rown Bears: Of particular concern to TWS is the Kenai Peninsula brown bear population. The Kenai Peninsula brown bear population is considered an isolated population and was declared a species of special concern by the state of Alaska in 1998. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat and resulted in an increase of bear mortality due to defense of life and property kills, among other types of mortality. The Kenai Refuge provides large tracts of unroaded lands that are critical to the long-term viability of this population. The DEIS clarifies that the proposed project, the Enstar route, would impact brown bear habitat, increase access and may disturb denning bears due to helicopter maintenance activities (p. 3-68, DEIS). For example, the DEIS states: An increase in inappropriate use of snowmobiles and unauthorized use of all- terrain vehicles likely would occur as a result of the Project (Johnston, personal communication, 1998). Increased human access resulting from the clearing of the right-of-way and improvement of existing roads likely will result in increases in humar/brown bear contact, potentially resulting in brown bear mortality and/or displacement of bears from traditional use areas. An increase in brown bear 20G 20H Comment noted. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See also FEIS, Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines (pgs. 2-18 to 2-19). 20H cont. 201 mortality, from either DLP deaths or poaching, could affect the population level of brown bears on the Kenai Peninsula (S. Farley, ADF&G, personal communication, 2001). P. 3-68 DEIS. A report focused specifically on the Kenai Peninsula Brown bear population, “A Management Strategy for Kenai Peninsula Brown Bears” (Jacobs 1989b), outlines recommendations for protection of this population. As the DEIS acknowledges, the report “specifically calls for retaining a large area of undeveloped land along the western slopes of the Kenai Mountains, including the Chickaloon drainage on the KNWR.” The Enstar route would only serve to further fragment the Kenai Refuge, which already has more roads and trails than any other refuge in Alaska, The proposed route would bisect large tracts of unroaded lands in the refuge, which could have significant impacts on the brown bear population in the refuge, and also on the overall viability of the brown bear population on the Kenai Peninsula, We do not feel allowing the Enstar route to be constructed is compatible with the purposes of the refuge, which must maintain species | diversity and manage for wildlife above all else. _ Other Wildlife Populations and Habitat: Further, we are concerned about the impacts of the project on forested and shrub areas and wetlands, and any other important habitat for wildlife. Additionally we are concemed about the impacts to moose, wolves, lynx, among other terrestrial mammals, and birds, including songbirds, waterfowl, shorebirds and birds of prey, among others. The IPG group outlines many of the projected impacts from the project in the DEIS. Lwith regard to birds, for example, the DEIS states: Clearing of mature forest habitats along the right-of-way could impact nesting and foraging habitat for several birds on the State of Alaska List of Species of Special Concer that require mature forest habitats. These species include the olive-sided flycatcher, gray-cheeked thrush, Townsend’s warbler, and blackpoll warbler. Conversely, clearing of mature forest habitats along the right-of-way could be beneficial to forest edge species and species that prefer open, grassy or shrub- dominated habitats. and Clearing of trees could reduce potential nest, roost, and perch sites for bald eagles and other raptors. , . Helicopters would be used for Project construction and annual maintenance patrol. Increased human access associated with the transmission line corridor and access roads could potentially result in increased disturbance and illegal harvesting of birds, Trumpeter swans and bald eagle would be especially vulnerable to human disturbance. Trumpeter swans could also be affected by disturbance related to construction or monitoring during the nesting season and by collision hazards. (p. 3-66 DEIS) 201 Comment noted. 203 20K 20L Given the potential long-term impacts to bald eagles, we question whether or not this project could be in compliance with the Bald Eagle Protection Act. Additionally, we do not believe allowing this type of habitat destruction and impact to wildlife on the refuge is compatible with the purposes of the refuge. We urge the U.S. Fish and Wildlife Service to find the proposed project, the Enstar route, incompatible with the purposes of the Kenai Refuge. Wilderness Eligibility: s stated above, the Refuge Improvement Act includes an important directive for the Secretary of the Interior to “maintain the biological integrity, diversity, and environmental health “ of each refuge. Designation of suitable areas as wilderness is one of the most effective measures that can be taken to mect this directive. Five roadless areas exist within the project study area, They are: Two Indians, Pipeline Lowland, Chickaloon, Moose River/Mystery Creek, and Skilak Loop/Lake. The preferred alternative in the 1988 Final EIS for the Kenai Refuge Comprehensive Conservation Plan (CCP) recommended wildemess designation for the northern portion of the Enstar Pipeline route because of the valuable wildlife habitat this area encompasses. This area is currently within a minimal management area. The CCP further outlined activities and uses that are incompatible with a minimal management area. The proposed project is one such incompatible use. Thus TWS strongly opposes the Enstar route, which would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge, precluding them from future wilderness designation. __Comparison of Routes: Enstar Route: TWS strongly opposes the proposed Enstar route primarily due to environmental impacts that would result from this route, including impacts to brown bear habitat and forested areas and wetlands, among other important wildlife habitat. For example, the Enstar route would have the greatest impact to brown bears and their habitat of the alternatives analyzed. Additionally, it would impact the highest number of forested acres of the alternatives analyzed -- approximately 604 acres of closed white spruce, needleleaf woodland, closed mixed forest, and black spruce forest would be cleared for right of way. We believe this route is incompatible with the purposes and management intent of the Kenai Refuge, and we urge the U.S. Fish and Wildlife Service to make such a finding. Further, we feel strongly that this route choice is unnecessary, even if power upgrades are truly found to be necessary, because there are other viable alternatives, which do not transect the Kenai Refuge. Tesoro Route: In 1964, the westerm shoreline of the refuge was transferred to the state of Alaska for the purpose of allowing a transportation and utility corridor route across refuge lands. This area totaled approximately 500 square miles. This corridor encompasses the Tesoro route proposed in the DEIS. The Tesoro route is also a viable alternative if such a power line structure is found to be truly necessary, because this corridor was created specifically for this type of use, among other development uses. Further, the Tesoro route would have 203 Comment noted. Refer to comment response 9Q — Alaska DGC letter (12/05/01). See also the USFWS Compatibility Determination in Appendix A of the FEIS. 20K Comment noted. As stated in the DEIS (pg. 3-143) — the Enstar Route would conflict with the KNWR comprehensive plan, and future wilderness designation. See the USFWS Compatibility Determination in Appendix A of the FEIS. 20L Comment noted. See response to comment IF - EPA letter (12/05/01). 20M fewer environmental impacts overall than the Enstar route, which the DEIS acknowledges in the Summary, when it highlights this route as the environmentally preferred alternative of the two action alternatives analyzed (p. S-19 DEIS). In summary, TWS questions the timing and purpose and need for this project. However, we believe that if the project needs to proceed, and power upgrades are found to be truly necessary for Anchorage and Fairbanks, there needs to be analysis of a full range of alternatives for this type of project. This would include fully analyzing the current power line route, the Quartz Creek route, other potential ways for Anchorage and Fairbanks to get power, and alternative energy sources, among other alternatives. Until a full range of alternatives is analyzed, TWS has no choice but to support the No Action alternative. Thank you for meaningfully incorporating these comments. Sincerely, - Yiet Wek ted tows Nicole Whittington-Evans Assistant Regional Director Cc: Dave Allen, Alaska Regional Director, USFWS Robin West, Kenai National Wildlife Refuge Manager 20M Comment noted. See the General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding Project purpose and need and alternatives analysis. The Quartz Creek Route was analyzed in detail, but does not meet the purpose and need for the Project (see also DEIS Section 2.2.2, Transmission Options, Quartz Creek Transmission Corridor, pgs. 2-8 to 2-19). 21A 21B 21C 21D List of Individuals that E-mailed the Wilderness Society Form Letter to RUS on the Southern Intertie Project DEIS December 3, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, I am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. [Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant.“ (p.S~18) The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine Lany potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of umroaded lands that are critical to the long term viability of this population. ‘o unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Sincerely, Thomas Hasek 28687 Windsor Drive PO Box 520 North Olmsted, OH 44070 Angel Fire, NM 87710 USA USA Lynn Eubank 21A 21B 21C 21D The DEIS acknowledges the 1964 modification of the KNWR boundary and establishment of a transportation corridor. The Tesoro Route is located within this corridor and has been selected as the agency preferred alternatives. See response to comment IF — EPA letter (12/05/01). See also DEIS Section 3.6.1, Land Jurisdiction and Management Plans, U.S. Fish and Wildlife Service, (pg. 3-121). Both the Tesoro Route and the Quartz Creek Route were evaluated as part of the DEIS. See DEIS Section 2.6.2, Environmentally Preferred Alternative (pg. 2-59) for more information on the Tesoro Route..See also Section 2.2.2, Transmission Options, Quartz Creek Transmission Corridor (pgs. 2-8 to 2-19). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. Comment noted. See DEIS Section 3.6.3, Alternatives, Enstar to Chickaloon Bay — Route Option F, Environmental Consequences (pg. 3-143) and Section 3.6.1, Land Jurisdiction and Management Plans, KNWR Comprehensive Management Plan (pg. 3-122). Refer also to the USFWS Compatibility Determination in Appendix A of the FEIS. Comment noted. Impacts to brown bears were acknowledged in the DEIS. See also FEIS, Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines (pgs. 2-18 to 2-19). Michael Lucid 161 S. 16th Place Pocatello, ID 83201 f | 1 ‘Cory Larsen 1633 Pine Ave Proctor, NN 55810 Ronald Gi rty- 1300 N. 21st Street apt. 310 Grand Junction, CO 81501 Kathryn Sibley 1865 Queens Rd. Concord, CA 94519 USA carolyn Stallard | 222 Hidden Valley Rd | Soquel, CA 95073 Nathan Martinez USA USA Watthew Robinson oe David Wick Sarah Diehl ~ 1 4042 41st Ave South 431 Spruce Ave fairbanks, AK 99775 Minneapolis, MN 55406 Pacific Grove, CA 93950 USA USA USA Karl Fenske Buck Tilton Jesse Krause Sandra Spicher Austin, TX 78759 USA LaVonne McCombie 1015 Fourth St. dson, WI 54016 ‘harlene Sherman 10 Purington Avenue Natick, MA 01760 USA 9417 Great Hills Trail #1016 21 Settlers Lane Westtield, NI 07090 USA Jennifer Clark 19721 33rd Drive SE Bothell, WA 98012 USA Jennifer Cavallaro 7105 Stonegate br. Benbrook, TX 76126 19 Pomeroy Road Andover, MA 01810 USA Frank & Josie Ackerman 1325 Henry St. Berkeley, CA 94709 USA PO Box 822 1307 Barry Ave, #7 P. O. Box 9 3110 NE 66th Ave. Apt. C Provo, UT B4603 Los Angeles, CA 90025 Pitkin, CO B124) Vancouver, WA 98661 USA USA USA ‘San ee Meghan Tirone ee Rebecca Backman _ Mick Lewis Oo 1921 N. Desert Palm Broken Arrow, OK 74012 USA 3919 A Olive St Bryan, TX 77801 USA Paul Garber 1401 Fairview St. Berkeley, CA 94702 “Lynne Jetfries 24792 Eaton Lane Laguna Niguel, CA 92677 John McCory 250 Edgewood Ave San Francisco, CA 94117 USA “Megan O'Connor 770 Van Ness Ave San Francisco, CA 94102 USA University of Wisconsin Milwaukee, WI 53204 Mountain View, CA 94042 USA USA USA USA ‘John i a ‘Daniel Weber — Erin Wells Pat LeBaron a 600 E. Greenfield Ave. PO Box 606 2368 Amaryllis Medford, OR 97504 USA Eric Dec 4787 Tantra Dr. Boulder, CO 80305 USA Kathleen Morse 196 Ampersand Av. Saranac Lake, NY 12983 USA Jim Gerlach 640 Alpine Rd Winston Salem, NC 27104 USA dylan e 1513 waller San Francisco, CA 94117 USA Dave Van Manen $929 apache Dr Beulah, CO 81023 USA ] Alison Luedecke James Showalter 120 Evelyn Way San Francisco, CA 94127 USA 12815 Chaparral Ridge Rd. San Diego, CA 92130 USA CAROLINE HOOPER 6638 EOGEWOOD DR Ni Albuquerque, N% 87107 USA James Hall 1428 Cromwell pr. Denton, TX 76209 USA “Sarah Towsley Steve Tauscheck 1302 1th st Anacortes, WA 98221 USA 5 Chatham Road Chelmsford, MA 01824 USA Cindy Dusine 1712 Borden San Mateo, CA 94403 USA David Bratton 1304 Lombard Street #8 San Francisco, CA 94109 USA Mary Cannon 1033 1/2 North 30th Street Billings, MT 59101 Christy Nickerson 475 New Castle St. New Wilmington, PA 16142 USA 1304 Lombard Street #8 San Francisco, CA 94109 USA Mark D. Nielsen 101 W. Olympic Place Suite 701 USA Seattle, WA 98119 Micha Casterl ~ Evan Albright Rhoads Ave 3335 Broad st. 15 Goleta, CA 93111 San Luis Obispo, CA 93401 USA USA steven tobin- 10 b cole st San Francisco, CA 94117 Adriana lopez 2123 fifth ave | Delano, CA 93215 USA i Cathy Halley 3999 Via Lucero, #B7 Santa Barbara, CA 93110 USA Lara Schmidt 15330 Steinbeck Lane USA Chris Specht Please send no post Los Angeles, CA 90049 USA Dinda Evans POB 178695 San Diego, CA 92177 USA Colorado Springs, CO 80921 [Tink Hydeman 18806 Vista Modjeska Rd. Portola Hills, CA 92679 USA Joan Breiding PO Box 170625 $an Francisco, USA CA 9ALL7 Kevin Toney 4313 Nelson DR Richmond, CA 94803 USA Sondra Sampson 440 Alameda de la Loma Novato, CA 94949 USA Evelyn W. on 216 Monarch Court Santa Rosa, CA 95401 USA Brent Larsen 2648 Torrey Pines Rd. La Jolla, CA 92037 USA DeAnna Woolston 1020 Rood Ave. Grand Junction, CO 81501 USA acy Pheneger 2424 Pennock Way Longmont, CO 80501 USA Marci Van Ausdal PO BOX 719 | MeCloud, CA 96057 USA Janet Foster 938 Geary Street San Francisco, CA 94109 USA Denise Gurtiza 258 Avenida Del Gado Oceanside, CA 92057 USA ee McKenzie 339 Industrial Pkwy 47 Hayward, CA 94544 USA Ginny Pendleton 2936 polk street, #11 San Francisco, CA 94109 USA Lawrence Loosmore 243 N. Day Powell, WY 82435 USA Kristin Stiff 439 Arroyo Road Santa Barbara, CA 93110 Cendrine Harker 220 12th Street, #21 Huntington Beach, CA 92: 648 121L Inlet Place Anchorage, AK 99501 833 Taylor St Apt 4 Monterey, CA 93940 fByvelyn Winston 216 Monarch Court Santa Rosa, CA 95401 USA USA USA Bridget Manley meee Alfred Papillon — 1269 North Vermont Avenue #40) PO Box 938 Los Angeles, CA 90029 West Glacier, NT 59936 USA USA ———— ——l | Jessica Nelson Merrill Cole, Ph.D, 706 Imperial Drive #323 Morris, MN 56267 Matthew Cohen 1101 Eagle Street #7 Anchorage, AK 99501 USA Susan Dzienius 10015 Paseo Montril San Diego, CA 92129 USA ~* Karin Lowden 794 Tonga Ce. Tom Langley P.O. Box 1607 10810 260th St Saint Cloud, MN 56301 USA bruce schottel 603 woodland hills Troy, IL 62294 USA 232 Myrtle Ave Ramsey, NJ 07446 USA john wardell 2199 hogan drive Santa Clara, CA 95054 USA San Jose, CA 95127 San Marcos, TX 78667 Costa Rica USA | Scott Diehl ~~ "Janet Foster —_] 809 Sweeny 938 Geary Street Burlington, IA 52601 San Francisco, CA 94109 USA USA Michelle Orofino ~~ Jane DiFava _ - 309 Vosseller Avenue PO Box 124 Bound Brook, NJ 08805 Adelaide, USA USA ‘Rob Dow “| Jason Ward ——T P.O. Box 187 2073 W Ash Maple Ln McCall, ID 83638 Elkhart, IN 46514 USA USA om Kilmer ~~ Christina hyde —_ —— 621 2nd Street p.o. box 486 Helena, MT 59601 Homer, AK 99603 USA USA Mark Young ~— ~ Peter Maier oe Sandra Heller 800 W. Cambridge Visalia, CA 93277 USA Ric and Ellen Fisher 1215 W. Hereford Dr. Jackson, WY 83001 USA Anita Calbert 212 E Second Street PO Box 1091 Whitehall, MT 59759 Barney McComas 2806 Sixth Avenue San Diego, CA 92103 USA Peter deLijser steve travis [Eric England Kat Mills 871 S. Havenwood Circle 259 market street 2412 Piedmont Ave #102 15372 Toya Ln. Orange, CA 92869 Carneys Point, NJ 08069 Berkeley, CA 94704 El Cajon, CA 92021 USA USA USA USA kaellyn moss ee Peter and Debbie Hackett, M.D.‘s Lisa Marshall Wesley Marshall 646 creston rd. # B 610 Sabeta Drive 15023 Rain Shadow Court 15023 Rain Shadow Court Berkeley, CA 94708 Ridgway, CO 81432 Houston, TX 77070 Houston, TX 77070 USA USA USA USA Carol Wiley Tracy Gilbert Adam Rakunas Sheila Zovar 15457 Eto Camino Road 1169 W. Banyon St. 1044 Lath street 2255 20th Street, 4B Victorville, CA 92394 Rialto, CA 92377 Santa Monica, CA 90403 Santa Monica, CA 90405 USA USA USA USA | Joseph Orr Brenden Raymond Monica Cady Marcia Kolb 13235 Trentwood PO Box 84666 P.O. BOX 29 6225 Manoa Street San Antonio, TX 78231 Fairbanks, AK 99708 Port Yates, ND 58538 Oakland, CA 94618 USA USA USA USA Deonne Horton ~ _ Barbara Magnuson Susan C. Peters pat hatton 14782 Coutolenc Rd 1467 Red Feather Dr. 52 Meadow Avenue 408 Simcoe street Magalia, CA 95954 P.O. Box 322 San Rafael, CA 94901 newmarket, L3Y 2M3 USA Cotopaxi, CO 81223 USA Canada Jane Olson Alice Neuhauser Raymond Grace Todd Warnke 2025 Sage Lily Dr 1466 11th Street 775 Euclid Avenue 2215 S. Buckley Rd., #102 Sidney, MT 59270 Manhattan Beach, CA 90266 Long Beach, CA 90804 Aurora, CO 80013 USA USA USA USA Mark Bender jack young doyce Mitchell Elaine Schlinger 502 S$ Almon St. po box 713 1526 Brazil Lane 3459 Skycrest Drive Moscow, ID 83843 Winters, CA 95694 Santa Cruz, CA 95062 Oroville, CA 95965 USA USA USA USA [gayle speck Phil Young Michael Krassnosky Rob Seltzer 20 Howells Rd. 1168 Cervantes Way 4119 Lost Creek Court 9595 Wilshire Blvd., Suite 1020 Belmont, MA 02478 Pacifica, CA 94044 Fort Collins, CO 80526 Beverly Hills, CA 90212 USA USA USA USA Carol Wiley 7 Michael Blankenship Vera Brown “~)Jonathan Gibbs 19457 Eto Camino Road 1730N Edgemont st. 6 Barcelona Circle PO Box 40 Victorville, CA 92394 Los Angeles, CA 90027 Redwood City, CA 94065 Redwood Valley, CA 95470 USA USA USA USA Thomas R. Conroy - oT Jacqueline Lasahn Gregory P. Kutsko | Holly Dyer 1466 Lith Street 6475 Benvenue Ave 426 East E St #3 834 Robinwood Manhattan Beach, CA 90266 Oakland, CA 94618 Moscow, ID 83843 Troy, M1 48083 USA USA USA | USA Matthew Peak Kristen Eddy Linda Winn Don Eichelberger 10386 Amistad Court 59 Sacramento St., #8 3715 S$. Browns Lake Dr. 632 Guerrero St. Cupertino, CA 95014 Cambridge, MA 02138 Apt. 105 San Francisco, CA 94110 USA USA Burlington, WI 53105 USA jack young Jeff Golden Robert Muilenburg Joshua Thompson po box 713 2110 Table Rock Rd. Schelluinsevliet 57 PO Box 50651 Winters, CA 95694 Boise, ID 83712 Gorinchem, 4203 NC Casper, WY 82605 USA USA Netherlands USA Sandra Thompson 616 Vernon Oaks Drive Roseville, CA 95678 Ronald Marks 991 Edenbury Ln San Jose, CA 95136 Elizabeth Kitson 8801 Jason Ct North Richland Hills, TX 76180 Sharon Morris 23693 Glenbrook Lane Hayward, CA 94541 USA USA USA USA Sloan Matt Amy Brzeczek Lisa Marshall Michael Weintraub 1804 Embarcadero Road 10140 Mountair Avenue 15023 Rain Shadow Court 359G Cannon Green Dr. Suite 201 Apt. 102 Houston, TX 77070 Goleta, CA 93117 Palo Alto, CA 94303 Tujunga, CA 91042 USA USA Robin Gordon 17231 rolando Ave Castro Valley, CA 94546 USA Shari Bence 52 Irving Street Apartment B2 Cambridge 1119 Stanyan St San Francisco, CA 94117 USA kathleen gonnoud 6433 nancy st Los Angeles, CA 90045 USA Jason Gardner 545 43rd Street Oakland, CA 94609 USA Sharon Mullane 4084 Redwood Ave. #4 Los Angeles, CA 90066 USA Lisa Poser 30710 350th Street Redwood Falls, MN 56283 USA Peter Dillon 713 County RD 83 Boulder, CO 80302 USA Carol Walsh 209-A Hidden Valley Rd. Watsonville, CA 95076 USA Jessica Jones 0615 SW Palatine Hill Road MSC 1070 Portland, OR 97219 USA Letitia Todd 1635 Gough St., #501 San Francisco, CA 94109 USA Kitty Dagnall 7880 Castlewood Way Mobile, AL 36619 USA Lisa Poser 30710 350th Street Redwood Falls, MN 56283 USA Janine Taulman 150 Winona Drive Carmel, IN 46032 USA julie gengo P.O. Box 217 Cardiff, CA 92007 USA Cedar Brown 234 Divisadero St San Francisco, CA 94117 USA David Lamners | PO Box 771 Inverness, CA 94937 Karen Coussens 8559 Homestead Rd. Benzonia, MI 49616 Janet L. Senneker 12125 Shaftsburg Rd. Perry, MI 48872 Jason Trout 401 Sibley st Apt. 814 | Lawrence Lucas 42823 Lilley Pointe Dr Canton, MI 48187 USA USA USA USA Saint Paul, MN 55101 Maya Moiseyov —— R Gehring = Kevin Jackson Travis darrell 2302 COlumbia Street 4818 186th Ave. 67 Noe St. 370 Chestnut Avenune Palo Alto, CA 94306 Bloomer, WI 54724 San Prancisco, CA 94114 #10 USA USA USA Carlsbad, CA 92008 pamela taylor 202 Lauren Ave. Pacifica, CA 94044 USA John Wojdak 42 Town Farm Road Brookfield, MA 01506 USA | Dennis Alien 2761 S. Swallowtail Lane Boise, ID 83706 USA Judith Smith 1208 N. 6th St. Enid, OK 73701 USA Dave Scherman 41 McLeod Lane Topsfield, MA 01983 USA Andrew Becker 44 Brittin St Madison, NJ 07940 USA Donald Ryan American Embassy Unit 2711, Box 8 APO, AA 34021 Dave Piasecki 205 Johnson Ave. Los Gatos, CA 95030 USA Richard Schuh 1346 Legs Lane Sonoma, CA 95476 USA | Miranda Steele 6100 E Rancier Ave #280 Killeen, TX 76543 USA mary little PO Box 304 Boone, NC 28607 USA Clyde Everton 5720 Becliffe Ct. Boise, TD 83704 USA Frank Aaron 19251 Preston Rd. #902 Dallas, TX 75252 June MacArthur 2029 Albany Dr. Santa Rosa, CA 95401 USA David Rhodes 1795 El Monte Rd. Crescent City, CA 95531 USA [Jim nuBois 75 West St Northampton, MA 01060 SA judy desreuisseau 2 myrtle street Gill, MA 01376 USA Jean Durbin 3417 Halfway Avenue McKinleyville, CA 95919 USA KC Curry 7202 W Sun Lane San Angelo, TX 76901 USA Nancy Lashly P.O. Box 1049 Murrieta, CA 92564 USA Davin Peterson 1088 N Street Arcata, CA 95521 USA David J. Ledermann 6675 Meadowlake Rd. Bloomfield Hills, MI 48301 USA Kevin J. Schieb 134 Steiner Hall Stevens Point, WI 54481 USA 8 james hamilton 3805 winslow Fort Worth, TX 76109 USA 8880 Bay Drive Gainesville, GA 30506 USA Priscilla Khweis 410 Willis Street Cambridge, MD 21613 USA Tracy Thurber PO Box 279 Arizona City, AZ 85223 USA Lauren Hotchkiss 98 Vernon Street, Apt. Oakland, CA 94610 USA Robert: Krone 4507 W. Pioneer Dr., #915 Irving, TX 75061 Louis. mersten 2319 Imperial Dr Saint Cloud, MN 56301 USA Carol Bryce 640 W. 16th Se. San Pedro, CA 90731 USA Miriam Bennett 5675 Telegraph Ave. apt, B Oakland, CA 94609 Gina Owens 110 Church Street Scandinavia, Wi 54977 USA “|Erie Bourgeois 888 Mass. Ave. 614-A Cambridge, MA 02139 USA Daniela Miro Quesada 11527 Echo Wood Houston, TX 77024 USA fain Stewart 277 Crescent St. Apt. 4 Northampton, MA 01060 Matthew Schweitzer 555 EB, Haseltine St. Richland Center, WI 53581 USA L, 0D. Mitchell Box 902317 Palmdale, CA 935390 USA Kathy Rakestraw Claire Perricelli 2046 West Park Ave. Napa, CA 94558 USA Phil and Susie Kaplan 553 Paradise Park Santa Cruz, CA 95060 USA Victor Vuyas 1244 Broadway San Francisco, CA 94109 USA Amy Steiner 1244 Broadway San Francisco, CA 94109 USA Michael Green AJ Magic Mtn. Rd. Cazadero, CA 95421 USA Kathryn Posten 250 Mountain View Rd. Rexford, MT 59930 USA Paul Bickmore 101 Bast Twenty-first Street M809 Austin, TX 78705 USA Carol Williams 515 South Loader Dr. Pleasant Grove, UT 84062 USA Horace Mann 17900 Ocean Drive #4) Fort Bragg, CA 95437 USA Kelly MacLeod Box 1619 Gambier, OH 43022 USA scott williams 5828 Winnetka Woodland Hills, CA 91367 USA Cindy Parker 4845 Ogram Road Santa Barbara, CA 93105 USA Howard Greene ‘724 County Road 12A Ridgway, CO 81432 USA Keith Fischer 1017 Yargerville rd Ida, MI 48140 USA lance drill 780 post st. san francisco, CA 94109 USA Jennifer Erwin 1430 20th AVe. East Tuscaloosa, AL 35404 USA Dorna Khazeni 859 3/4 La Fayette Pk Pi Los Angeles, CA 90026 USA Timothy Johnston 3094 Lake Drive, Apt. F7 Marina, CA 93933 USA Estey Theriault P.O, Box 1014 Joshua Tree, CA 92252 USA Philip and Jennifer Floyd 459-745 Lakeview Drive Janesville, CA 96114 USA June MacArthur 2029 Albany Dr. Santa Rosa, CA 95401 USA Michael Filip 311 8. Upas St. Escondido, CA 92025 USA Mack Bray 450 Trap Club Road Jackson, WY 83001 USA Claudia Barbieri R. Roquete Pinto 60/104 Rio de Janeiro, 22291210 Brazil david mi 717 foch blvd Williston Park, SY 11596 USA 1450 N. Gardner St. Los Angeles, CA 90046 michael religa 1027 crawford st Green Bay, WI 54304 Laurie Schlueb 130 W. Kent "9 Missoula, MT 59801 Kar] M Wiessmann 9 Ridge Road - Lake Wallkill Sussex, NJ 07461 USA USA USA USA Elizabeth Brobst = Maryam Abdullah Joann Bar - ~ | jennifer pierc 467 Park Ave. 6204 Gloria Dr. #215 PO Box 65 2017 south faris avenue Lock Haven, PA 17745 Sacramento, CA 95831 Johannesburg, CA 93528 Sioux Falls, SD 57105 USA USA USA USA Ruth Ross ——— Dave Chappell David Livingston Dave Lacey 121 Country Club Rd. Cheshire, Cr 06410 USA Ruth Benson 247 Potter Avenue Staten Island, NY 10314 USA 7276 Callison Rd Penryn, CA 95663 USA Indra Zuno 11817 Texas Ave. #2 Los Angeles, CA 90025 USA | Los Angeles, Heather Gnewu 83 West Lane Ridgefield, CT 06877 USA Diane Henrick 27 Woodbury Road Billerica, MA 01821 USA William Klassen POB 34 Broadalbin, NY 12025 USA Gerald Orcholski 2400 Brigden Rd, Pasadena, CA 91104 USA Chiyo Mauldin Peter Sandoval 2781 Ocean Ave Brooklyn, N¥ 11229 USA aptde Gregory Esteve 3655 North Scenic Highway Lake Wales, FL 33853 USA 1802 Sotgrande #205 Hurst, TX 76053 USA Sarah Emmerson 14612 Golders Green Lane Westminster, CA 92683 USA Judy th 6704 Ready Rd. South Rockwood, MI 48179 USA Ruediger Maar P.O. Box 5403 de Pere, WI 54115 USA “Matthew Quellas 4143 Perlita Avenue #A CA 90039 USA Michelle Palladine 777: &. Tahquitz Canyon Way Suite 200 Palm Springs, CA 92262 ‘Michael Galbraith 8422 Rickie Westland, MI 48185 USA Jeff Hansen 3866 Ravenswood Dr. Yorba Linda, CA 92886 USA Margie Haley 7149 Hillgreen Dallas, TX 75214 USA Nicole Wood 99 Oxford St. Arlington, MA 02474 USA P.O. Box 147 943 Sharon Ln; Felton, CA 95018 Ben Lomond, CA 95005 ann William Kent 130 Emma Lane Menlo Park, CA 94025 William Barmore P. O. Box 17 Wilson, WY 83014 USA Joel Jensen 3595 Hayden Place #3 Boulder, CO 80301 USA 38045 - 10th St. E 446 Palmdale, CA 93550 USA Sharon Hatfi P.O. Box 630133 Rockville, UT 84763 USA amy bradley 11904 arlee ave. Norwalk, CA 90650 USA Joe Pisciotto 858 Richmond Way Nekoosa, WI 54457 USA Paul Teepen Solbacka Gard Eskilstuna, USA William Sly P.O. Box 6659 Rast Brunswick, NJ 08816 USA PO Box 81765 Fairbanks, AK 99708 USA rosa henry 2025 diamond street apt. 5 2025 diamond street apt. 5 san diego, CA 92109 Michelle Little 23141 Hill Rd Silverhill, AL 36576 USA Shelley Rothwell 771 Clubhouse Drive Ypsilanti, MI 48197 USA ‘Kristen Holland 7110 San Mateo Dr, #328 Dallas, TX 75223 Humboldt Rd 12 Green Bay, WI 54311 USA Elaine Fischer 94 Cherry Hill Rd. Branford, Ct 06405 USA | Olga Michel — 3125 SW 96 Avenue Miami, FL 33165 USA Jan MacLaughlin 4326 Newton Street The Colony, TX 75056 USA Donald Frantz P. O. box 429 Franktown, CO 80116 USA ‘Warren Brubacher Jessica Simms Denny Johnson 1431 County Road 9 [Greg Willmarth 1827 Illinois St 2 Regal Rd 2101 Belmont Dr. Toronto, M6H 204 Anchorage, AK 99517 Garvin, MN 56132 Vallejo, CA 94590 Canada USA USA USA “Tamra Katieta Nicholas Christianson — Beverly Gaye Scofield ingrid good Rt. 1 box 1456 Willamette University PO Box 5522 3017 Dohr St. Roosevelt, UT 84066 900 State St. Box#G103 Santa Maria, CA 93456 Berkeley, CA 94702 USA Salem, OR 97301 USA USA Robert Rubin Peter Galbraith E- Lore Matz Galen Davis 5207 Avenida Del Sol 3534 Porter St. NW 6707 W Lincoln Ave 257 Collins St. Las Cruces, NM 88011 Washington, DC 20016 West Allis, WI 53219 San Francisco, CA 94118 USA USA USA USA Lesley Ura: 7 alex gagnon Becky Izen Leroy Porter 3502 Times Square 2602 Main st. 18900 Killimore Ct. P. 0. Box 905 Harlingen, TX 78552 Santa Monica, CA 90405 Northridge, CA 91326 Columbia Palls, MT 59912 USA USA USA USA gary benmour 1448 @1 camino real #3 Dorothy Bachand 318 Bryan Drive barbara geenen 5003 e oklahoma st Cindy Talerico 30370 Castleford Ct. Burlingame, CA 94010 Alamo, CA 94507 Tulsa, OK 74115 Farmington Hills, MI 48331 USA USA USA USA Laurene Brady Michael Wolf Susan Fischer | Gaby Gollub P.O.Box 31 2380 Van Buren ct 144 Colovista Dr 4500 Connecticut Ave. NW Fairview, NJ 07022 Reno, NV 89503 Bastrop, TX 78602 Apt. 509 USA USA USA Washington, DC 20008 Sabine Werk Judith Embry Jean Nesta-Berry Joyel Spoden 7 . — 7655 S. Cambria Circle 51 Blackstone Road R.D. 2 3975 Shenstone Dr. 2103 Mineral Point. Ave. Salt Lake City, UT 84121 North Adams, MA 01247 Eugene, OR 97404 Janesville, WI 53545 USA USA USA USA lL Hamblen ricia J. Jennings Josh Laughbaum Jerry Wilson 20 Lake Dr 49 Florence St. 5610 Morgan Rd 5323 Stanhope, NJ 07874 Winchester, MA 01890 New Albany, OH 43054 Brightwood Road USA USA USA Bethel Park, PA 15102 JULIE MOHR Holly Eaton Elaine Sonnie matra m. 376 vista baya 8 Delta Cr 633 McHenry Ave river wood Newport Beach, CA 92660 North Brunswick, NJ 08902 Woodstock, IL 60098 Toronto, m8y 4el USA USA USA Canada Julia Frazer Anna Saxon-Tatlor Nanette Oggiono ~~ | Richard Salmon 7. 1208 N. Olive Dr. Apt. 110 B/5, 62 Wattle Street 3 Sadler Rad 1331 Bellevus Street Lot #G West Hollywood, CA 90069 LYNEHAM Upton, MA 01568 Green Bay, WI 54302 USA CANBERRA, USA USA Roger Jahnke 243 Pebble Beach Thomas Colburn 2060 Ellis St. Goleta, CA 93117 Golden, CO 80401 USA USA Susan White —— Jim Steitz 2736 LOS PADILLAS $.¥. Albuquerque, NM 87105 USA 1255 E 1000 N #202 Logan, UT 84321 Charles Siegel 2140 Shattuck Ave., suite 2111 Beverly Byrum 47 Caddy Road Berkeley, CA 94704 Rotonda West, FL 33947 USA USA Rev.Michael W. Kennedy ~ | Adele McVeigh - —— 29 Fern Dr. 18210 Jamestown Cir. Little Egg Harbor Twp, NJ 08087 USA Northville, MI 48167 USA [sandra paris 8625 mourning dove Stephanie Selznick 53 Lind Street USA Running Springs, CA 92382 Missoula, MP 59808 Quincy, MA 02169 USA usA la Mospan Rebecca Donicht PO Box 2035 Rt. 3, Box 340-D Hinckley, MN 55037 USA Cary) Buckstein Patrice Lyke rah Dubin-Vaughn | 483 Pine Needles br. del Mar, CA 92014 USA Esther Fillner | 25 Commercial Street | Portola, CA 96122 | USA Mike Miller 14 Forest: Drive New Milford, CT 06776 USA rlos Gabezud P.O. Box 430509 Bart Kowalski 2536 Anakapa Dr #106 Costa Mesa, CA 92626 USA yogavati cook 108 petaluma way Petaluma, CA 94954 USA RICHARD O CONNOR 706 LINCOLN AVENUE Palmyra, NJ 08065 USA ———— a Kathryn Sawyer 6848 Ridgewood Dr. Oakland, CA 94611 USA henry Ingersoll 2043 Via Ladeta La Jolla, CA 92037 Kerry Weller $069 Vincent Trail Shelby Twp, MI 48316 USA fred kleindenst — 6157 fern lane Paradise, CA 95969 Joel Malkerson 15480 Lindholm Dr Hayward, WI 54843 USA Elizabeth Wasmuth 243 Avenue E Bayonne, NJ 07002 rodney burke 9714 forest lane 17050 E. Ford Dr. #105 1109 Egan Street Aurora, CO 80017 Denton, TX 76201 USA USA USA joseph viens Benjamin Marsh po box 2391 5221 Hammersley Road Newport Beach, CA 92659 Madison, WI 53711 USA USA USA ‘Anne Grady ~~ Garon Byl il 6 Drury Lane 817 Sylvan Dr. Natick, MA 01760 Fort Worth, TX 76120 USA USA USA Willie M. Defee ~~ | tina Tong - —_ f H.C.6 Box 823 726 n cherry branch Hemphill, TX 75948 Mustang, OK 73064 apt 5803 USA USA Dallas, TX 75243 Kate Poulter 9555 Dogwood Circle Eden Prairie, MN 55347 USA Denise Hughes 1802 E, Maple Street Ellen Goerler 768 Springfield Avenue Unit B-6 Summit, NJ 07901 J omen Alan Deane 1600 Broadway Apt #5 Glendale, CA 91205 USA paul boone 1936 belmont crt Santa Rosa, CA 95404 USA Tina Johns 1102 W Joppa Road Mary Stadler 19308 Bothell Way NE Apt 306 Bothell, WA 98011 Robert Dixon 147 Masachusetts Ave Arlington, MA 02474 USA Caldwell, ID 83605 USA Sylvia Slayton 3140 Layton Fort Worth, TX 76117 USA Robert vonGiebel 96 Millbrook Rd Washington, NJ 07882 usa Teresa Wong 408 Rosemont Blvd. San Gabriel, CA 91775 USA barry medow 8200 sheridan #709 westminster, CO 80003 USA carolyn taormina 700 enos lane Mary Stadler 19308 Bothell Way NE Nancy Davis 3428 Hanks Street Sacramento, CA 95827 USA Denise Khore: 479 Patton Street Somerset, PA 15501 USA Ben Duhem 405 El Camino Real #623 Menlo Park, CA 94025 USA San Ysidro, CA 92143 Baltimore, MD 21204 Corralitos, CA 95076 Apt 306 USA USA USA Bothell, WA 98011 Diane Gonzales | Sharon Prewett — 1 Shelly Clapp [ terry lee _ SSS PO Box 535 P. O. Box 660 701 &, Travis Blvd. # 17 pobox 20711 Calimesa, CA 92320 Flint, TX 75762 Fairfield, CA 94533 Qakland, CA 94620 USA USA USA USA Ray Duhem 405 El Camino Real #623 Menlo Park, CA 94025 USA Lori Bartann 1161 Willow Road #5 Menlo Park, CA 94025 USA Jerry Fell 900 Coleman Ave Menlo Park, CA 94025 USA Jamie Fell 900 Coleman Ave Menlo Park, CA 94025 Pranklin Spicer 920 E. Colorado Pasadena, CA 91106 USA john craig 11 222 east buffalo Rawlins, WY 82301 USA Madeline Fell 900 Coleman Ave Menlo Park, CA 94025 USA Mike Jastremski 240 East Kent Street Missoula, MT 59801 USA Sandra Hendricks 2727 De Anza Rd #B15 San Diego, CA 92109 USA Anna Shamble 744 Cornell Dr. Santa Clara, CA 95051 USA Brandon Fell | 900 Coleman Ave | Menlo Park, CA 94025 | usa Barb Piers 161 Durazno Way Portola Valley, CA 94028 USA Tricia Piers 161 Durazno Way Portola Valley, CA 94028 USA Ben Hoh] 4 Virginia lane Atherton, CA 94027 USA 4 Virginia lane Atherton, CA 94027 USA Jen Fell 900 Coleman Ave Menlo Park, CA 94025 USA Carolyn Piers 161 Durazno Way Portola Valley, CA 94028 USA Greg Piers 161 Durazno Way Portola Valley, CA 94028 USA Josh Hohl 4 Virginia lane Atherton, CA 94027 USA | Dave toni 4 Virginia lane Atherton, CA 94027 USA Ben Robbins 675 Hobart ave. Menlo Park, CA 94025 USA Peli Lee 730-F Columbia Santa Fe, NM 87505 USA Chuck Robbins 675 Hobart ave. Menlo Park, CA 94025 USA Pat Robbins 675 Hobart ave. Menlo Park, CA 94025 USA Tiffinay Robbins 675 Hobart ave. Menlo Park, CA 94025 USA Mark Skaggs 8619 W Smithville Rd. Mapleton, IL 61547 USA Tannis Hugill 2424Tenth Street Berkeley, CA 94710 USA Jackie Meyer 157 St Hwy 35 #34 River Falls, WI 54022 USA Sheila Stoftels 6626 Chantilly Place Colorado Springs, CO 80922 USA salvatore zappala 58 Woodstown Rd. #522 Mullica Hill, NJ 08062 USA Denys Kelly 304 Kings Highway Cape May Court House, NJ 08210 USA Laurence Stratton 1671 Century Cir #224 Woodbury, MN 55125 Dusty Miller 24385 W. 7ist St. Shawnee Mission, KS 66227 USA Lisha Doucet $135 Kingfisher Dr Houston, TX 77035 USA Carle Brown 444 Middle St Portsmouth, NH 03801 USA Theresa Kulas 62 Arthur Ave NE Grand Rapids, MI 49503 USA Robert Zinn 12 Winding Way Mullica Hill, NJ 08062 USA Steve Plutt 38830 County Road 77 Lake George, CO #0827 USA Darla Barnshaw 123 W. Sylvan ave. Morton, PA 19070 USA Amanda Smith 59 William St. Red Bank, NJ 07701 USA Colleen Whittaker 78 Wentworth Street South Hamilton, ON 00000 Paul Black 2031 Kerr Gulch Road Evergreen, CO 80439 USA Annette Lozier 495 Holley Mill Road Eclectic, AL 36024 USA marcia langley 472 cutler ave Mentone, AL 35984 USA carlos hardy 1144 fourth st Santa Rosa, CA 95404 USA Gabriel Chavez 6 boothbay Cir. Madison, WI 53717 USA Jennifer Ball P.O. Box 1076 Lakeside, CA 92040 USA Michael Fieleke 92 Walworth Street Roslindale, MA 02131 USA 143 S. 500 #. Logan, UT 84321 USA Barbara Morgan 5510 Broadway SE Albuquerque, NM 87105 xed 2328 haugen st. Cody, WY 82414 USA cookie moran 3330 Esperanza Dr. Concord, CA 94519 USA Shirley Puga 139 N. Vulcan Ave Encinitas, CA 92024 USA Robert Mizar $494 Gates Rd. Santa Rosa, CA 95404 USA olga troxel 2328 haugen st. Cody, WY 82414 USA thoa nguyen 6528 Wilbur Ave #208 Reseda, CA 91335 USA Carissa Jenkins 3256 Foothill Ave. Corona, CA 92882 USA Lani J. Adams 38627 Pond Ave. Palmdale, CA 93550 USA steve frye pob 172 Jefferson, WI 53549 USA Adrian F. Van Dellen 48 Campers Cove Rd. Woodville, TX 75979 USA Kevin Goodwin 3254 Ashford St. Apt. W San Diego, CA 92111 USA Dpt Lang, Lit, Comm Augusta State Univ Augusta, GE 30904 John F. Bowe 250 Florence Rd. Florence, MA 01062 USA Mary Alicia Sours 410 Washington Avenue Wheeling, WV 26003 Michael Blankenship 1730N Edgemont st. Los Angeles, CA 90027 USA Judy Schriebman 3 Poco Paso St. San Rafael, CA 94903 USA Robert Galbraith 317 Camino de las Flores Encinitas, CA 92024 USA kenny hogg 27 birch avenue scone, Perth, ph26le scotland Diana Sieradski 1334 Micheltorena Los Angeles, CA 90026 USA judy distasio 208 lexington street East Boston, MA 02128 USA Jim Lang 476 Casino Drive Farmingdale, NJ 07727 USA |Louls C. Harris, Jr. 1002 Abington kd. Cherry Hill, NJ 08034 USA Frederic Griest 6944 FB. Villanova Pl. Denver, CO 80224 USA USA Shiree Duncan Bryan Gieszl 136 w 500 S 477 S Hudson Ave Logan, UT 84321 Pasadena, CA 91101 USA USA Philip H. Coe ~ | Cees Beijer — 200 Twin Mountain Road, Oudlaan 70 » B-5 Naaldwijk, 2672 BP Wimberley, TX 78676 Netherlands [Michael Duncan Paul Magnuson 4885 Sunnybrook Ave. pob 758 Buena Park, CA 90621 Newtown, CT 06470 USA USA Mike Gauthier 1642 9th St Manhattan Beach, CA 90266 USA Maria Sara Sayago 9001 Rock Creek Rd. Placerville, CA 95667 USA | kathy goodwin 1707 Giles Street Austin, TX 78722 USA Karsten Schulz 9001 Rock Creek Rd. Placerville, CA 95667 USA Joshua Howe 1085 1/2 Grand Avenue Saint Paul, MN 55105 USA Lawrence Adrian 907 Boston Road Groton, MA 01450 Abbey Gaterud 0615 SW Palatine Hill Rd MSC 773 Portland, OR 97219 Robert Kurz 23256 Arelo Court Laguna Niguel, CA 92677 USA michael bavers po box 113 Soldotna, AK 99669 USA Mary Bodde 3343 Brookshear Circle Auburn Hills, MI 48326 USA Anica Williams 1415 C Compton Rd San Francisco, CA 94129 USA Mike Bradshaw 633 Baden Ave. Apt. B South San Francisco, CA 94080 Ottawa, KS 66067 Lisa Lessa 989 Coronado Drive Glendale, CA 91206 USA “Dayalan Srinivasan 60 Greenough St; #5 Brookline, MA 02445 USA USA USA | David Brunner Oliver Nickels 1601 8S. Hickory 4250 Cedar Heights Dr. Apt. F2 Colorado Springs, CO 80904 USA Trebor Gibson 6333 Mt. Ada Rd., #161 San Diego, CA 92111 USA Mary Collins 11181 W. Powers Place Littleton, CO 80127 USA Ricardo Neves Rua Bardo do Rio Branco , 20-30 Mirassol, 15,130-000 Brazil Ryan Conrad 615 N Towa St Gunnison, CO 81230 USA Mitchell Maness 2800 Knight Street #1 Dallas, TX 75219 USA Ana Karinna Etcheverry Dr. Carlos Marfa de Pena 4950 Montevideo, 11900 Uruguay Elvira Floran-Hernier 4500 19th Street Boulder, CO 80304 USA Betty Jean Herner 9087 Prospect Road Strongsville, OH 44149 USA Julie Olexa 1517 E. Garfield St. ‘Tkara johnson 3440 korovin bay circle Laramie, WY 82070 Anchorage, AK 99515 USA USA Eleanor Osgood ~~Tpavid Porter 4224 Lincoln Ave 10 Culver City, CA 90232 USA Tanya Shersno! 177 North Pleasant St., Apt. 15 Awherst, MA 01002 USA Steve Tudisco 2022 Traceway Drive, Apt 206 Fitchburg, WI 53713 USA Glacier Peak Ln. Chico, CA 95973 David Cann 8778 Skyline Blvd. Oakland, CA 94611 USA Roberta Kennedy 2208 Gateway Oaks #393 Donna Pfaff 6510 Gloria Avenue Van Nuys, CA 91406 USA “| Mary Sanborn 12119 Wilsey Way Sacramento, CA 95833 Poway, CA 92064 USA USA heather moench Paul Duffy 653 e 300 s #8 P.O, Box 83366 Salt Lake City, UT 84102 Fairbanks, AK 99708 USA USA William Wolverton Nancy Guttenberg M.A. Box 393 3155 Armourdale Ave. Escalante, UT 84726 Long Beach, CA 90808 USA us Mills Tandy 3509 Lafayette Ave Austin, TX 78722 USA Tatjana Terauds 264 W Mariposa Dr Moore 14280 SW Stallion Drive Beaverton, OR 97008 USA John Kolarik 151 Bergwall way Vallejo, CA 94591 USA Rachel Enright 419 N. Pinckney St, Madison, WI 53703 USA Apt. 204 San Antonio, TX 78212 USA Catherine M. Fidalgo 107 Whitlow St. New Bedford, MA 02740 USA Elizabeth Molholt 1513 Princeton Street Apt. I Santa Monica, CA 90404 iam §| 5616 Arroyo Rd. Austin, TX 78734 USA Sandy Childs 1825 N. Edgemont Street #7 Los Angeles, CA 90027 USA James Kavanaugh 319 12th Street Petaluma, CA 94952 USA Rick Formanek 9040 Far Away Place Fort Jones, CA 96032 USA Jesseca Davis 1222 Stafford Rd. Glassboro, NJ 08028 Jesseca Davis 1222 Stafford Rd. Glassboro, NJ 08028 USA Debira Branscombe 2344 Knollwood Drive Cameron Park, CA USA 51 Sushine Lane Katy Eagan Mind Body Consciousness Web Ring Laurie Jiobu 3022 Windsor Avenue Santa Barbara, CA 93105 1607 Silver S.E. Los Angeles, CA 90039 USA Albuquerque, NM 87106 USA richard tenney | Richard Riggs — PAnn M.B. — 308 @ bozeman 143 Cedar Grove Rd 10515 Deneane Road Bozeman, MP 59715 Somerville, NJ 08876 Silver Spring, MD 20903 USA USA USA Janita Baker 10650 Little Quail Lane Santa Margarita, CA 93453 USA Thomas & Janet Bender 86 Cherry Tree Farin Road New Monmouth, NJ 07748 USA Cru 1077 Vista Madera Lane El Cajon, CA 92019 USA Debira Branscombe 2344 Knollwood Drive Cameron Park, CA USA 46817 Bradley St. Fremont, CA 94539 USA Michael McFarland 8612 N. Cedar Ave. Fresno, CA 93720 USA Sandra Pena P.O. Box 5030 Camp Verde, TX 78010 USA NATHALIE BROWN! 1000 N US HIGHWAY 1 Jupiter, FL 33477 USA | Lynda James PO Box 628 Bailey, CO 80421 USA Brenda Ayer #260 2166) Brookhurst St., Huntington Beach, CA 92646 | Rhiannon Chandler 2915 Arnold Palmer Dr. Billings, MT 59106 USA GENE REIMER 600 ENTERPRISE BLVD Rockport, TX 78382 USA Thomas Brustman 2013 Devita Ct Walnut Creek, CA 94595 USA Michael Barnes 3305 Shasta Drive San Mateo, CA 94403 USA peter weiner p.o. box 11281 Burbank, CA 91510 USA Foriba Bebnam 1606 Speyer Lane USA John Sherman P.O. Box 1187 Wilson, WY 83014 USA adam hannuksela 7838 w. holt ct. USA Minneapolis, MN 55: USA 409 Redondo Beach, CA 90278 Boise, ID 83704 USA Walter Johnson a Melissa Swanda #30 Maverick 1172 Utah SE 3900 N Woodlawn Huron, SP 57350 Wichita, KS 67220 USA PAustin Ring an Wade Stoddard 404 E, Washington Ave, &3 3220 Maple Ave. #458 Madison, WI 53703 Dallas, TX 75201 USA Jean Melom ~~ "'Susan C. Peters 3755 Pleasant Av. S 52 Meadow Avenue San Rafael, CA 94901 USA Jonathan Evans 2641 Regent Berkeley, CA 94704 3794 Poplar Drive Clarkston, GA 3002 USA Moses Sedler PO Box 1124 Fairfax, CA 94978 1 Roberta Papazoglow 1332 Leavenworth Street San Francisco, CA 94109 USA Dick Cameron 116 New Montgomery Suite 500 San Francisco, CA 94105 “Sarah Thomas 1455 Arnold Dr. #4 Martinez, CA 94553 Pamela Cappelli 6 Rue des Pensées, Lagny sur Marne, Prance Apt. 77400 LT/A USA USA Paul Belz a |Christa Bijkerk PO Box 11507 Kamille 44 Oakland, CA 94611 Culemborg, 4102 HW USA Netherlands Thomas Amaroli 917 Cole Street San Francisco, CA 94117 USA Julie Hart 11801 Washington Northglenn, CO 80233 USA Andrea Christy 9815 Geneva Avenue Montclair, CA 91763 USA mike griffith 951 cornell ave Albany, CA 94706 USA Paul Luehrmann PMB #294 223 N. Guadalupe Street Santa Fe, NM 87501 Heather Tindall 918 Afton Road San Marino, CA 91108 USA Stephen ‘| Marian Lopez Gail Atkins 1758 Odell Holly Springs, MS 38635 USA karen barnes 3943 high street Oakland, CA 94619 USA Anne 1 907 Huntington st. Huntington Beach, CA 92648 USA 824 Tola Street Montebello, CA 90640 USA Jennifer Wickert 514 Courtside St Sw, R205 Olympia, WA 98502 USA Nichole Long P. O. Box 252045 Montgomery, AL 36125 6123 Inway Drive Northampton Subdivision Spring, TX 77389 Gail Atkins USA 6 Pinebrook Drive 1758 Odell Easthampton, MA 01027 Holly Springs, MS 38635 USA USA |ieit tye ~~ —"T Elisabeth Storm valervn. 9 Rietbergstraat 161 Moss, ZUTPHEN The Netherlands, 7201 GG jon Hone 5675 Andros place apt 1 San Diego, CA 92115 usa Mary Luc 6123 Inway Drive Northampton Subdivision Spring, TX 77389 Rene Colucci 12 Ridgeview Road Hopewell Junction, NY 12533 USA Julia Gillam 2686 South Ct Palo Alto, CA 94306 USA | Beverly Hadkikhani 6041 Fountain Pk Ln #10 Woodland Hills, CA 91367 US: Brooke Samuelson 24 Birch Street Old Saybrook, CT 06475 USA Timothy J. Chip 640 N. Sandy Ln. USA Christina Blue 1624 Old McDade Rd Gregg Rosenbery 6322 Sunhollow Lane Marty Rergotfen Southern Appalachian Biodiversity Proj USA Matthew Kauffmann 7416 Bryant Ave So MN 55423 Richtield, SA Cynthia Fleming 187 Argilla Rd Ipswich, MA 01938 USA Gabriel Andres Thoumi 2011 3rd Ave S #334 Minneapolis, MN 55404 USA Andrew Ragatz 10 Purington Avenue Natick, MA 01760 USA | stephen harding 3014 arrowhead dr. USA | Cathy Romanowski 1113 M Street, NW #1 Washington, DC 20005 USA Norma Feinberg 286 Broad Ave Leonia, NJ 07605 Elkhorn, WI 53121 Elgin, TX 78621 Haslett, MI 48840 POB 3141 USA USA Asheville, NC 26802 Harold Radtke D Mechura ~ Debbie Carr ~ Ron Torretta w227 N2905 Duplainville 50 Main Ave #2 5806 78th Street P. 0. Box 1525 Waukesha, WI 53186 Ocean Grove, NJ 07756 Lubbock, TX 79424 Canon City, CO 81215 USA Edward Levieux 1010 Plant Lady Lane Dripping Springs, TX 78620 USA USA USA | Mary Sier Stephen Fagen ~ Jacalyn LaPierre PO Rox 1443 19 Thetford 94 Bayo Vista Ave. 102 Manhattan, KS 66505 Sugar Land, TX 77479 Oakland, CA 94611 USA USA USA John Vann - ‘Tammy LaRue —— ~~) John ‘Fiynan ~ — “ 9044 N. Prairie Rd. 2621 Gretta St. NE 22 Werf Drive Springport, IN 47386 Albuquerque, NM 87112 Redding, CT 06896 usa USA USA steve johnson Paul Comtois ‘David Wick —— 8095 e crystal dr Anaheim, CA 92807 USA Adam Schwartz 2528 18th Ave Temple, TX 76502 Forest Grove, OR 97116 USA USA (Julia Benedetti Corinne Lambdin s—SsS | 8657 Via Mallorca #101 15 CR 198 | La Jolla, CA 92037 Oxford, MS 38655 LUsA usa James Justen Meredith Beckham ~ 5945 Larkwood Court #3A 1503 John Kalamazoo, Mi 49048 Winfield, KS 67156 USA USA renee mezo ee" Kellie Rugg _ 13433 buxton ave 231 Sth. Santa Rosa St. Poway, CA 92064 Ventura, CA, CA 93001 USA USA Ken Straley Dennis Davie 873 N 1100 E POB 651 Price, UT 84501 USA Mary McCormac ° ba0L 1121 Albion St. Denver, CO 80220 USA Capitola, CA 95010 USA Scot Libants 1222 Parkview Lansing, MI 48912 USA 18 Pine Knoll Dr Ludlow, MA 01056 USA Richard Landau 768 Springfield Avenue Unit B-6 Summit, NJ 07901 Sheryl Allen 1430 Highway 72 Golden, CO 80403 USA Hugh Hitchcock 3011 Colonial Drive Sugar Land, TX 77479 USA Shirleen Mills 12612 Sunglow Farmers Branch, USA John Ringoen 578 Arkansas Mountain Road Boulder, CO 80302 USA Chris Gartiand 1619 S. Emerson St. Denver, CO 80210 TX 75234 USA _ Margaret Corley 700 Commonwealth Ave. 4042 41st Ave South Minneapolis, MN 55406 USA Joan Sieywald 762 Kasserine Pass Mobile, AL 36609° USA “Kelly Roth 142 Willowleaf Drive Littleton, CO 80127 USA Stacey Hicks 82 Manchester Ave Keyport, NJ 07735 USA Jeanne Evanchuk 100 Parsons Pond Drive Franklin Lakes, NJ 07417 USA Boston, MA 02215 USA Thomas Rottler 31160 Broken Talon Trail Oak Creek, CO 80467 USA Anne Wang 25 Bedford Ave 8102 Norwalk, CT USA Bob Paxson 06850 9351 Crowell Dr Elk Grove, CA 95624 USA Kelly Erwin 12324 Moorpark St. Studio City USA Michael Gordon — + CA 91604 3632 East 2nd Street #10 Long Beach, USA CA 90803 Myke Farricker 14 Valley View Rd Wayland, MA USA susan koop 01778 4033 pine bluft Waterford, MI 48328 [ Robert Park 172 W. Maude Ave. Sunnyvale, CA 94085 USA Will Fry 4 Baggins End #4 Davis, CA 95616 USA ‘| Michael Iza 1617 Castillo St. #3 Santa Barbara, CA 93101 USA Colleen Vachuska 440 North Street West Bend, WI 53090 USA Fran Jutzi 2100 W. Palmyra Ave, Orange, CA 92868 USA Lae eeeroreersnremtirni Joan & Richard Waak 755 Languid Lane Simi Valley, CA 93065 Kaisa Ireland 11400 Paseo del Oso NE Albuquerque, NM 87111 USA Holly Brunkal 1116 Arbutus Chico, CA 95926 USA trudi goodman 1221 cambridge street 708 Eleanor MacLellan 185 Commonwealth Ave. Chestnut Hill, MA 02467 Cambridge, MA 02139 USA Matt Fitzpatrick kathy kuyper 1404 Granite Court po box 218 Missoula, MT 59801 USA Tom Burns 136 Topo Street Anaheim, CA 92804 USA Michelle Waters P.O, Box 7430 Santa Cruz, CA 95061 USA Jennifer Buck 412A Scripps Drive Davis, CA 95616 USA USA USA Jessie Lee — apo Dana Stibor _ 1 926 £. 40th St. 4307 10737 La Grange Avenue #8 Austin, TX 78751 Los Angeles, CA 90025 USA USA “Suzanne Lefebvre ‘| Janet Foster 12 Endicott Road 938 Geary Arlington, MA 02476 San Francisco, CA 94109 USA USA E BETH OTTO 2074 HOWARD ROAD Petoskey, MI 49770 USA Michelle LeBeau 105 E. Peach St Apt. A Bozeman, MT USA Sayel Cortes 59715 Av. circunvalacién Ote # 143-8 Cd. Granja, 333 Harvard Apartment 2 Cambridge, MA 02139 guadalajara, mney Street 45010 Valerie Soza 761 W. Bonita Avenue Claremont, CA 91711 USA Jennifer Maas: 1331 1/2 E. Dayton St. Madison, WI 53703 USA Sherri Pickel 834 Magnolia Ave Ontario, CA 91762 USA Carl Clark 604 34 Ave NE Great Falls, MT 59404 USA Samantha Rosenthal 3714 Drake Street Houston, TX 77005 USA Clifton, Co 81520 USA Jacqueline Turner 10410 Pineville Cupertino, CA 95014 USA ‘| Michael McFarland 8612 N. Cedar Ave. Fresno, CA 93720 USA Timothy Sharp 1422 Waverly, Missoula, MT 59802 USA “Mike Shriberg 123 N. State #3 Ann Arbor, MI 48104 USA Avenue Robert Betz Charles Plum 737 Pacific Ave. Beachwood, NJ 08722 USA Charles Ferris 6233 Pine Street Pollock Pines, CA 95726 USA 12100 Trinkle Rd Dexter, MI 48130 USA Ryan Crowley 104 South First Avenue Highland park, NJ 08904 USA Diane Grinde 1041 Madison St. Anoka, MN 55303 USA Lisa Tubman 15 Thomas St Kingston, MA 02364 USA } Billie Bresnahan 1163 Olive Street #7 Chico, CA 95928 USA Jim Summers 8901 Chisholm Lane Austin, TX 78748 USA Marilyn L. Monroe 13780 N. Saint Vrain Dr. Lyons, CO 80540 USA Anita Aerts 17635 Henderson San Antonio, TX USA Pass #723 78232 Anna Norville 486 S. Oakland Ave., 43 Pasadena, CA 91101 USA Leslie Pierpont 103 Los Hornos Rd Lamy, NM 87540 USA Jennifer Gregory 720 Rockingham Ave Alma, MI 48801 USA Edgar Plum 1600 Grand Avenue Saint Paul, MN 55105 USA Laura Sciurba 932 Lyfoord Dr. San Dimas, CA 91773 usA Brandy Hodges 1206 Main St. Morro Bay, CA 93442 USA Marci Segal 7655 $. Cambria Circle Salt Lake City, UT 84121 USA Rebecca Bodnar 416 Gth Ave Sw Ronan, MT $9864 USA Mary Braunger 4801 Hermsmeier Lane Madison, WI 53714 USA Jim Lunsford 1788 La Force Rd. Alpine, CA 91901 USA Dawn Piper 22 Winfield San Francisco, CA 94110 USA Daria Inbar 2222 maroneal #135 Houston, TX 77030 USA =] Keith Nichlols N6807 Cty. Rd. N Beldenville, Wt 54003 USA Keith Nichlols N6807 Cty. Rd. N Beldenville, WI 54003 USA Robert Marsing 7466 So, 1000 &. apt. 3b Midvale, UT 84047 fossa Darryl Partner PO Box 600113 Paragonah, UT 84760 Cheryl Costigan Joel Gray P.O. Box 490 691 Country Club Athol, ID 83801 Stansbury Park, UT 84074 USA USA Edward vanEckert Michael Garvin PO Box 1220 710 Spring St. Fort Lee, NJ 07024 Sausalito, CA 94965 USA USA [Quentin Fischer 94 Cherry Hill Rd. Brantord, CT 06405 USA / Sean Rogers 180 Water St Leominster, MA 01453 USA USA William Borigan — Lisa Loel I PO Box 89 1911 MLK Jr. Way, Chester, CA 96020 Berkeley, CA 94704 USA USA Samantha Suvak 115 1/2 N, Knoblock Apt. A Stillwater, OK 74075 Sarah Sansom 169 Southwind Drive Apartment 3 Wallingford, CT 06492 USA Ken Goldsmith 172 Commonwealth Ave., Apt.7 Boston, MA 02116 USA Todd Engleman 1954 Olde Buggy Drive Neenah, WI 54956 Geoff Shester 441 W. Sth Ave Suite 500 Anchorage, AK 99501 Amanda Hardesty 10238 § Turkey Creek Rd Morrison, CO 80465 USA Molly Bailey 606 Tantra Drive Boulder, CO 80305 USA Jeanne Christensen 558 Clarkson Denver, CO 80218 USA Mike Jerant 377 So. Bernardo Ave. Sunnyvale, CA 94086 USA Nicola Hill 911 West Campus Lane Goleta, CA 93117 USA Vincent Turano 191 Brentwood Circle North Andover, MA 01845 USA Angela Lewis 3907 Blue Mound Drive Cedar Rapids, IA 52402 USA Jay Paul 11425 178th st Artesia, CA 90701 USA Frances Teders 180 Waring Way Merritt Island, FL 32952 USA [Kenneth Goodrow, MS, LPC, NCC, CcMHC 22 Alamosa Avenue Alamosa, CO 81101 USA Erin Altemus 431 S 2nd Ave W Missoula, MT 59801 USA w. hollemanplein 99 eindhoven, 5616jx netherlands ‘Tim Palmer-Fettig 11100 Mountain Top Circle Leander, TX 78645 USA Kyla Rice 606 Desnoyer Ave Saint Paul, MN 55104 USA Matt Law 1165 Crescent Dr. San Jose, CA 95125 USA ‘Pheresa McLaughlin 1019 Lakeland Dr. Lewisville, TX 75067 USA Robin Lynn-Jacobs 3834 Crescent Drive Santa Barbara, CA 93110 USA Susan Brown and Must) 288 Whitmore #128 Oakland, CA 94611 USA Sarah DeSousa 351 Whispering Oaks Spring Branch, TX 78070 USA Kyle Joly 7322 Huntsmen Anchorage, AK 99518 USA USA Thomas Metcalf 411 Amherst SE Albuquerque, NM 87106 USA Gwen Carter Route 1 Box 251 Lapwai, ID 83540 USA Scott Dercks 4102 6th St NE Columbia Heights, USA MN 5542 1 USA ‘Thelma Benard “Rath Stoner Muzzin Susan Lefler “| dettrey Koppensteiner 13058 Richview Drive 1390 Flores Dr. 8701 Bear Creek Drive 314 Amoth Ct. #1R Pacifica, CA 94044 Austin, TX 78737 Madison, WI 53704 USA USA USA Bonnie Benard Peter Seidman Cyndy Turnage Joan Dacey 7 1238 Josephine Street 1238 Josephine Street Barry Avenue POB 353 Berkeley, CA 94703 Berkeley, CA 94703 Los Angeles, CA 90066 Mokelumne Hill, CA 95245 USA usa USA Sarah Thomas “TGarel Sebastian SS Christine Hayes “| Prudy Gillette — 101 Rivoli Street San Prancisco, CA 9411 USA Judy Fehrlage 140 172 Melrose Avenue Monrovia, CA 91016 USA Renée Kirkpatrick 1018 San Jacinto Dr. Irving, TX 75063 USA Andrea Learmon 509 No Midvale Blvd #3 Madison, WI 53705 USA Virginia Cross 1322 Summit Creek 7 1527 P.O. Box 2415 Running Springs, CA 92382 USA 1534 Fairwood Way Upland, CA 91786 USA 144 Boston Post Rd Old Lyme, CT 06371 USA David Marston, IIT 3139 E, 4th Street National City, CA 91950 USA Alan Mishell 2476 S. Beaver Creek Rd Golden, CO 80403 USA ampbe. 540 detroit st Ann Arbor, MI 48104 USA Sandy Roggenkamp 13099 River Lane sw i Megan Bomba 5371 Kalein br Culver City, CA 90230 USA Kenneth Wallace 3209 via Solana Escondido, CA 92029 USA casey pera 400 paloma ave Pacifica, CA 94044 USA Don & Linda Bentley — 301 W. Windsor Ave. Patricia Lambert 344 Westwood Ct. Coppell, TX 75019 USA Sherry Knoppers 3450 Nine Mile Nw Sparta, MI 49345 USA William D. Christ 7974 West Highway 61 PO Box 34 Schroeder, MN 55613 Joel Podgorski 3315 Chisholm Trail | Jamaica Plain, USA San Antonio, TX 78258 Pillager, MN 56473 Phoenix, AZ 85003 #303E USA USA USA co 80301 Sean Damitz Raymond Cachia Laura Watchman - @ Barbutti - 357 BLVD 1711 Washington St. 420 Independence Ave. SE 1159 Nimitz Lane Logan, UT 84321 San Francisco, CA 94109 Washington, DC 20003 Foster City, CA 94404 USA USA usa USA Gail Wilcox Patrick Huber “Paula Odabaai ———$—— === inten none cee 13030 Wi. North Avenue 721 B. llth st. 423 Cedar Ave 22030 Ybarra Road Brookfield, WI 53005 Davis, CA 95616 Highland Park, NJ 08904 Woodland Hills, CA 91364 USA USA USA USA Michael Heald Gail Herath-Veiby Steven Friedman rachel roffman 4135 1/2 Hyer 16 Nipmuck Drive i Ridge Ave 22 Iffley Road Dallas, TX 75205 Westborough, MA 01581 San Rafael, CA 94901 MA 02130 USA USA USA Sandra L. Rasche Post Office Box 116 Ruth, CA 95526 USA Rhonda Saenz 3308 N. Broadmoor Blvd. San Bernardino, CA 92404 USA | Peter Zadis 115-64 220 Street Jamaica, NY 11411 USA Emerson Kindy 3729 Sadler dr. Sanford, MI 48657 USA [REBECCA DREWES | 720 9TH AVE S.E. Rochester, MN 55904 USA Richard Frazier 522 Alamo Trail Grapevine, TX 76051 Rifkind Michael Joan Roney JANET BARBER, PH.D. 5899 Empire 304 EB, 83rd St., #4D 85 GLEN AVE 43 Santa Cruz, CA 95060 New York, NY 10028 Oakland, CA 94611 USA USA USA HARRISON P BERTRAM Tammy LaRue beth smith —_ 1090 W GROTON CT Schaumburg, IL 60193 2621 Gretta St. NE Albuquerque, NM 87112 108 Lincoln Bangor, MT 49013 USA USA USA USA Kate Crowley ~| Dianne Miller-Boyle Carlo Popolizio Janet Ostrowski 3295 Walters Rd 514 NW 43 1600 Atlantic Ave.. Apt. 11 P.O. Box 223 Willow River, MN 55795 Oklahoma City, OK 73118 Longport, NJ 08403 Suttons Bay, MI 49682 USA USA USA USA Maureen Keating 14 Cumberland Street #1 San Francisco, CA 94110 USA Cynthia Bau P.O, Box 1322 Oakhurst, CA 93644 USA Susan Fallander 1987 S. Harlan Ct. Lakewood, CO 80227 USA Christopher Malley 835 Orman Dr Boulder, CO 80303 USA Maria Therese 6831 N Tripp Ave Lincolnwood, IL 60712 USA ennifer Eck 1719 S. 10th St. W. Missoula, MT 59801 USA Priscilla Atwood 1802 Kipling Street Houston, TX 77098 USA Olivia Posner 221 Piesta Street Santa Fe, NM 87501 USA Venessa Komocar 26109 McBean Pkwy #54 Valencia, CA 91355 Mary Zimmerman 2565 Portola Avenue #18 Santa Cruz, CA 95062 Mark Jones 5708-B Taylor Draper Cove Austin, TX 78759 William Brown 15 royal street s.w. apt 4 370 Chestnut Avenune #10 Carlsbad, CA 92008 christine romero 2621 Gretta Albuquerque, NM 87112 USA 1218 Toomes Avenue Corning, CA 96021 USA Karen Strand 7802 Shasta Ave. Highland, CA 92346 USA 307 N. lst Avenue Valders, WI 54245 USA tracy johnson 3830 elijah court #434 San Diego, CA 92130 USA 522 Judah Street San Francisco, CA 94122 USA Ilana McAllister 3152 Charlemagne Ave Long Beach, CA 90808 USA USA USA USA Leesburg, VA 20175 Phyllis Montague | Peter Xebic pete farino ‘Cesare Mitrano SSS 2166 Caminito del Barco 134 Main 1625 grasscreek dr 748 Shannock Rd del Mar, CA 92014 S.F., CA 94118 San Dimas, CA 91773 Wakefield, RI 02879 USA USA USA USA ‘Ramon Meijer —_ john mcclure <icaiais| David Osteraas Elizabeth Santos a Torenstraat 14 po box 144 POB 1178 8228 Station Village Ln Utrecht, 3732 DX Deming, NM 88031 Gualala, CA 95445 1511 The Netherlands USA USA San Diego, CA 92108 Travis Jarrell — - [barry Bailey | Mark Euclide a Nina Vukic oo Lisa Clarke 623 N 1570 W Pleasant Grove, UT 84062 USA Vicki Butters 24 Fulton Street Woburn, MA 01801 USA Theodore Hopkins 5501 Turkeyfoot Ln. Manhattan, KS 66503 USA Madeline Yamate 90 Arlington Ave. Kensington, CA 94707 USA Sharon Smith 870 Casitas Court San Luis Obispo, CA 93405 USA Scott Olsen 8512 B 24th Pl Tulsa, OK 74129 USA Richard Smith 27200 145th st New Auburn, WI 54757 USA George Stone 4812 West Wells Street, Apt. 4 Milwaukee, WI 53208 USA Dale Rudolph - paula krell hance Melinda Milam Martha Johnson 9350 Hillery Dr. 7724 shingle creek drive 350 S. Fuller Ave, #10-H 4404 Water Oak Ct #11205 Brooklyn Park, MN 55443 Los Angeles, CA 90036 Concord, CA 94521 San Diego, CA 92126 USA USA USA Christa Berger es ‘Jennifer Hodgens Thane Harpole Diana Dexter 8504 Roseland Ct. 2192 Blossom Lane 1171 Boylston St. #6 6309 W 101lst Place Oak Park, MI 48237 La Verne, CA 91750 Boston, MA 02215 Overland Park, KS 66212 USA USA USA USA Clodagh Byrne Jeff Stewart Melissa Varelas Tom Merrill Sandymount: 4660 Arizona St. 84 Arbaugh 31300 hwy 82 #5 Dublin, San Diego, CA 92116 Weed, CA 96094 Aspen, CO 81611 USA USA USA sl illough Jason Sexton Nancy Mayo Stacy Pandey 8105 Breeze Way 7535 Bannock Tr. 4390 Route 12 1216 Dexford Dr. Lago Vista, TX 78645 Yucca Valley, CA 92284 New Hartford, NY 13413 Austin, TX 78753 USA USA USA Jean Forsythe ~"Tkent Ki tlough nate locks sharon abercrombie 4787 Mt. Frissell br. G11 fF 45th 12 tribes ave. 2020 Damuth St. #1 San Diego. CA 92117 Austin, TX 78751 las vegan, NM 87701 Oakland, CA 94602 USA USA USA USA Jonathan Nadler Victoria Allen Jacqueline Walburn SS ong mei —_ 811 Marco Place 1703 Prince St. 12801 Wild Goose St Bedok Venice, CA 90291 Conway, AR 72032 Garden Grove, CA 92845 Singapore, USA USA USA [Wendy NeGlothiin Jesse Bearheart SS ro mei ~~ Mary Monk — ee 11541 NW STEWART ROAD 8387 Beatty Road Bedok 12500 Hibner Union Star, MO 64494 Cook, MN 55723 Singapore, 4601 Nartland, Mt 48353 usa USA Singapore USA Doug Barnes. SSS Bryan Wyberg SS DD Stokes Jay lL. Rey 728 Bedford Court 12854 Raven Street Nw P.O. Box 272 1409 Salome Woodstock, GA 30188 Coon Rapids, MN 55448 Big Bear City, CA 92314 Wichita, KS 67216 USA usa Usa | Sheryl Archul - ~ ~ “kai Aili TV racy Hawes —— P.O. Box 1404 428 millcreek lane 638 Adamsville Road Buena Vista, CO 81211 Borup, MN 56519 Trinidad, CA 95570 Westport, MA 02790 USA USA USA USA Peter Zadis Bert Arnett Lisa Johnson Lena Ray a | 115-64 220 Street 14245 Albain Rd. 1449 Sixth Street 188 Laurel Circle ‘ Jamaica, NY 11411 Petersburg, MI 49270 Alameda, CA 94501 P.O, Box 157 j USA USA USA Gurley, AL 35748 Craig Kelso Craig Kelso Richard = Julia Rios == SOCS~<“S~Ss~—s—sSSSS 101 Kiler Canyon Rd. 101 Kiler Canyon Rd. 179 EB. 20230 Union St Paso Robles, CA 93446 Paso Robles, CA 93446 Bridgeton, NJ 08302 Wildomar, CA 92595 USA USA USA USA Connie Fletcher Jackie Rogers Morgan Alber ee Juliann Rule — n256 river drive 2322 South whitney p.o. box 14 35002 115th Avenue Menominee, MI 49858 Rocklin, CA 95677 Gardner, CO 81040 Avon, MN 56310 USA USA USA USA sean frank RR 4 box 245 Austin, MN 55912 USA Traci Torres 180 Summit Ave summit, NJ 07901 USA Veronic 802 Spencer Avenue Santa Rosa, CA 95404 USA ‘Barbara Murphy Bonnie Grand P.O. Box 311 Forestville, CA 95436 USA Ruth Feldman 22 Gary Way Alamo, CA 94507 USA I-Wen Wei 4150 Mystic View Court Hayward, CA 94542 USA DeWitt Henderson Theresa Kellgreen 990 Scenic Way Ben Loond, CA 95005 USA Julie Raymond-Yakoubian PO Box 84666 Fairbanks, AK 99708 USA Logan, UT 84321 USA Norma Tassler 11820 SW 80th St./*318 Miami, FL 33183 USA Susan Trivisonno 2810 Oak Estates Ct San Jose, CA 95135 USA Laguna Beach, USA Gwen Demitria | somerset 1726 Foster Dr. | Calgary, Arlington, TX 76012 | Canada USA ‘Morgan Rogers Carol Snow — 716 Canyon Rd PO Box 43 CA 92652 24901 Largo Dr Laguna Hills, USA Korey Simeone CA 92653 1200 Hollow Creek Dr. #201 Austin, TX 78704 Brenden Raymond-Yakoubian PO Box 84666 Fairbanks, AK 99708 USA John Warner 223 East Mountain Dr. Santa Barbara, CA 93108 USA cristina amarillas Marie/Blake/Emilie Bufford 2030 Fir Street Concord, CA 94519 USA Joan Breiding PO Box 170625 San Francisco, CA 94117 USA Mark Turbin 833 Norwich Avenue Pittsburgh, PA 15226 USA Michael Seeber 529 15th st. Eureka, CA 95501 USA po box 8387 7820 Durham Way Monterey, CA 93943 Boulder, CO 80301 USA USA Pamela Roudebush Tara Dell 1007-B W. Denver Ave. Gunnsion, CO 81231 USA Chloe Stull-Lane 727 Polaris Way Livermore, CA 94550 USA USA 1334 W. Wright Cr. Boise, ID 83705 USA “Bobbie Johnson 1237 Pennsylvania Ave Canon City, CO 61212 USA Wendy Murphy 3563 Sacramento Street San Francisco, CA 94118 USA Stephanie West 2417-K Elden Avenue Costa Mesa, CA 92627 USA USA ) Annette Nello A. Biasetti 15820 Kinga Creek Road Leith walk Boulder Creek, CA 95006 Edinburgh - Scotland, EH6 5 UK [Ray Mullenax a Jeri pollock 10438 las lunitas Tujunga, CA 91042 311 assembly ave Santa Cruz, CA 95062 USA Steve Bauhs 3402 Fawn Trail Austin, TX 78746 USA Jeanette King 4205 Colgate Way Livermore, CA 94550 USA Daniel Villaume 36 Berenda Way Portola Valley, CA 94028 USA Lori Charkey 162 Westwood Avenue Westwood, NJ 07675 USA Sean Houle 2680 EB. Highland Ave. #1328 Highland, CA 92346 USA James Ferrigno 118 MIramar Ave. San Francisco, CA 94112 Jennifer Clanahan 539 Baker St. Longmont, CO 80501 USA yest! Natton,/ hy y “ig £ S ie % P.O. Box 1449 Soldotna, Alaska 99669-1449 (907) 262-7021 9 262-3 Alaska fax (907) 262-3599 December 4, 2001 Lawrence R. Wolfe, Senior Environmental Protection Specialist USDA, Rural Utilities Service Engineering and Environmental Staff, Room 2240 1400 Independence Ave. SW, Stop 157} Washington, DC 20250-1571 Subject: DEIS for the Southern Intertie Project, Alaska Dear Sir: The Friends of Kenai National Wildlife Refuge are strongly opposed to the proposed Enstar Route for the Southern Intertic transmission line, due to the many adverse impacts [listed in the DEIS, We also recognize that in addition to substantial incremental 22A problems, major, unidentified cumulative impacts will result. Non-assessment of cumulative impacts is a serious deficiency in the DEIS. The viability of the Refuge is potentially threatened We support selection of the Tesoro Route, which follows the utility corridor set aside to avoid negative impacts to the Refuge. The Souther Intertic project is a government- subsidized commercial venture, providing for the marketing of sunk power-generating capacity. The relatively minor additional cost of the Tesoro Route simply represents the real cost of doing business in a sensitive area. [t would be improper for federal government to subsidize the destruction of this priceless National Wildlife Refuge. 22B The Kenai NWR is recognized to be a unique, world-class Refuge. It is already a matter 2c of great concern that this Refuge continually faces development impacts from a number of diverse interests. By comparison, the gross impacts of the Enstar Route are devastating. The Enstar Route is not compatible with the goals of the Kenai National Wildlife Refuge. This proposal is a great insult to a national treasure, and as such |_represents unacceptable public policy. Sincerely, Robert L. Baldwin President cc: Manager, Kenai NWR 22A 22B 22C Cumulative impacts were addressed in DEIS Section 3.12, Cumulative Impacts Analysis (beginning pg. 3-280), and in the DEIS Summary, Table S-2, pg. S-16. Comment noted. The Tesoro Route has been selected as the agency preferred alternative. See response to comment IF — EPA letter (12/05/01). Comment noted. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 23A 23B --+--Original Message----- From: The Fish Site [matlto:tkwhip@gci.net] Sent: Friday, December 14, 2001 3:04 AM To: Iwolfe@rus.usda.gov Subject: Southern Intertie Project FI III TOI III III ICICI TIO II This E-Mail and or attachments have been scanned for and found free of known viruses. FEO TOIT IOI IOI IT Lawrence R. Wolfe USDA - Rural Utilities Service 1400 Independence Avenue, S.W - Stop 1571 Washington, D.C, 20250-1571 Phone: (202) 720-5093 Fax: (202) 720-0820 Dear Mr. Wolfe: Woe cannot support an above-ground transmission line for the Tesoro (Option A) Route. The proposed Tesoro Route to Point Possession is through all private land. The above-ground | transmission line wouldd ecimate the property value. When Tesoro originally installed theirp ipeline in 1976, there were no private property owners to deal with. M embers of the NDESA owning bluff property on the proposed transmission line are not willing to grant access (Option A), therefore, the more logical route would to be Option F, Naptown to Burnt Island. ‘Sincerely, Ted Whip Northern District Eastside Setnetters Association 23A 23B Comment noted. See DEIS Section 3.7.2, Socioeconomic Consequences of the Proposed Action, Facility Impacts on Property Values (pg. 3-176). Comment noted. The Tesoro Route is located in the KPB planned transportation and utility corridor. Right-of-way permits and authorizations will be obtained as outlined in DEIS Section 2.5.2, Right-of-Way Acquisition Process (pg. 2-51). 24A 24B 24C 24D 24E Pt. Possession, Inc. 1321 Oxford Drive Anchorage, Alaska 99503 (907) 279-2702 (907) 276-8112 November 12, 2001 Mr. Lawrence R. Wolfe Senior Environmental Protection Specialist Engineering and Environmental Staff USDA Rural Utilities Services, Stop 1571 1400 Independence Avenue, SW Washington, DC 20250-1571 Dear Mr. Wolfe: Pt. Possession, Inc. (PPI) hereby submits comments on the DEIS for the Southern Intertie Project. PPI is a Native corporation under the Alaska Native Claims Settlement Act (ANCSA) which owns 4,217.17 acres at the northernmost point of Point Possession on the Kenai Peninsula. Additionally, the Point Possession Village is located on a 110-acre allotment directly west of the PPI Corporation lands. The proposed “Tesoro” Intertie route alternative will pass adjacent to the 110-acre traditional village site allotment which is the location of several setnet/personal use cabins and is used throughout the year and extensively in the summer scason for traditional activities, including setnet fishing, The “Tesoro” route also cuts through the northwest portion of the PPI Corporation lands. The purpose of this letter is to again state PPI's and the members of the Point Possession Village, the strong opposition to the possible use of the Tesoro Pipeline route for the | Southern Intertie. Use of this route would greatly impact our use of the traditional Point Possession Village site by: impacting the aesthetic setting, causing visual and noise access the property on the beach or nearby lakes, The route would also adversely impact our efforts to sell or use our Native Corporation Group lands (4,217.17 acres) for wilderness recreation development. The installation of the tall towers and wires would: damage the wilderness nature of our land and reduce its commercial value. In addition, it would greatly reduce the usability of the attractive areas of Pt. Possession, (especially at the northern most point); and make it more dangerous to accessing the beach, and possibly the future airstrip near the point and lakes on the property by plane. pl I appreciate your consideration of PPI's comments and urge your rejection of the Tesoro route alternative. If you have any questions, please contact me at (907) 276-8112. Sincerely, Pt. Possession, Inc. Nowench: Klenow Norman A. Kallander President Ce: file EES and making it more difficult, if not more dangerous, to land planes used to’ 24A 24B 24C 24D 24E Comment noted. Refer to the General Response to Issue 9 (pg. 1-7) in Chapter | of the FEIS. Links T8 and T9 would be underground cable. See DEIS Section 3.6.3, Alternatives, Bernice Lake to Pt. Possession — Route Option A (pg. 3-135). See also Appendix B, “Access to Area” Table, (pg. B-29). Comment noted. See DEIS Section 3.7.2, Socioeconomic Consequences of the Proposed Action, Facility Impacts on Property Values (pg. 3-176). See response to comments 24A and 24B (above). Comment noted. \ Bigroaicar IVERSITY rac CALIFORNIA AND Paciric Orrice proteaing endangered species and uild places trough scone, ehuation, policy and enivormmental law VIA FACSIMILE and US MAIL December 25, 2001 Mr. Lawrence R. Wolfe USDA - Rural Utilities Service 1400 Independence Ave. SW — Stop 1571 Washington, DC 20250-1571 Facsimile: (202) 720-0820 Lwolfe@rus.usda.gov Mr. Robin West, Refuge Manager Kenai National Wildlife Refuge P.O. Box 2139, Soldotna, AK 99669 Facsimile: (907) 262-3599 in_ we fws.gov Mr. Jack Hewitt U.S. Army Corps of Engincers Regulatory Branch (1145 b) Post Office Box 898 Anchorage, Alaska 99506-0898 Facsimile: (907) 753-5567 Re: Comments on the Proposed Southem Intertie Project on the Kenai Peninsula Gentlemen: This letter is submitted on behalf of the Center for Biological Diversity (“CBD") regarding the Proposed Southern Intertie Project on the Kenai Peninsula. We appreciate the comment period being held open to receive our comments. The CBD is a non-profit environmental organization dedicated to the protection of native specics and their habitats in the Western Hemisphere through science, policy, and environmental law. The CBD has over 6000 members throughout the western United States, including in the Kenai Peninsula and Anchorage areas that will be directly affected by the proposed project. Tucson * Phoenix * Silver City * San Diego * Berkeley * Shaw Island Kassie R. Siegel, Staff Attorney PO Box493, Idyllwild, CA 92549 TEL: (909) 659-6053 x. 302 * FAX: (909) 659-2484 Email: ksiegel@ biologicaldiversity.org * wowbobgrakivestyorg 25A 25B Our comments below are focused on the biological impacts of the proposed Southem Intertie project, and in particular on the impacts to species such as the Kenai brown bear, Kenai population of the wolverine, and the Cook Inlet population of the Beluga whale. In general, the CBD supports the no-project alternative and believes that no compelling purpose and need has been established for this project. In addition, if the project is to move forward, significant additional analysis must be completed to comply with the mandates of the National Environmental Policy Act, Clean Water Act, and other applicable laws. Il. THE AGENCIES HAVE FAILED TO COMPLY WITH THE NATIONAL ENVIRONMENTAL POLICY ACT A. The Legal Requirements of the National Environmental Policy Act. Section 101 of NEPA declares a broad national commitment to protecting and promoting environmental quality. Robertson v, Methow Valley Citizens Council, 490 U.S. 332, 348 (1989), citing 83 Stat. 852, 42 U.S.C. § 4331. "The sweeping policy goals announced in § 101 of NEPA are . - tealized through a set of ‘action-forcing’ procedures that require that agencies take a “hard look’ at environmental consequences.” Id, at 350, citing Kleppe v. Sierra Club, 427 U.S. 390, 410 n.21 (1976). NEPA's main “action-torcing” procedure comes in the form an environmental impact statement ("EIS"), a detailed statement on environmental impacts that must be prepared before an agency undertakes any "major Federal action{] significantly affecting the quality of the human environment." NEPA § 102(2)(C), 42 U.S.C. § 4332(2)(C). Thus, NEPA “ensures that the agency, in reaching its decision, will have available, and will carefully consider, detailed information concerning significant environmental impacts.” Robertson v. Methow Valley Citizens Council, 490 U.S, 332, 349 (1989). See also Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, 435 U.S. 519, 553 (1978) ("NEPA places upon an agency the obligation to consider every significant aspect of the environmental impact of a proposed action"). "These procedural provisions of NEPA ‘are designed to see that all federal agencies do in fact exercise the substantive discretion given them. These provisions are not highly flexible. Indeed, they establish a strict standard of compliance.” Sierra Club y. Watkins, 808 F. Supp. 852, 859 (D.D.C. 1991), quoting Calvert Cliffs! Coordinating Comm. Inc. v, United States Atomic Energy Comm'n, 449 F.2d 1109, 1112 (D.C. Cir. 1971). Thus, substantive environmental protection is presumed to flow from NEPA's procedural safeguards. As such, strict compliance with NEPA's mandates is vital to ensuring the quality of our environment. The Council on Environmental Quality ("CEQ") has promulgated’ regulations implementing NEPA that are binding on all federal agencies. 40 C.F.R. § 1500.3; Robertson v. Methow Valley Citizens Council, 490 U.S. at 354. B. The REIS Fails to Adequately Evaluate the Purpose and Need for the Souther Intertie Project The DEIS fails to demonstrate a need for the Souther Intertie project. While the DEIS contains a section on the topic of purpose and need, there simply is no evidence that the project is needed. Rather, it appears that the primary benefit of the project, will be, at best, to lower the cost of supplying electricity to consumers in the area. (DEIS p. 1-23.) Even if one accepts the fact that this savings would be passed on to consumers, it is a scanty benefit indeed for the massive environmental consequences that this project will have for the species and the wild places of the Kenai Peninsula. Page 2 25A 25B Comment noted. The DEIS was prepared in compliance with the Council on Environmental Quality Regulations implementing NEPA, USFWS, USACE, and RUS NEPA implementing regulations, and in accordance with a Memorandum of Understanding developed among the agencies. RUS believes that the purpose and need has been confirmed and that the range of alternatives has been adequately studied. See the General Response to Issue | (pgs 1-3 to 1-4) and Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS. 25C 25D A elated issue is that the project’s cost-cffectiveness is not adequately analyzed. Rather, the public is asked to accept, at face value, the Applicant's contention that the proposed project is the only cost-effective and feasible option. While we have no trouble accepting the proposition that above ground transmission lines built across de-facto wildemess areas for the shortest point-to-point distance is the cheapest option for the Applicant, this does little to assess the costs and benefits to the public of this significant project. C. — TheDEIS a ihe Serna While the DEIS is voluminous, it fails to adequately describe the project and the impacts the project will have to the species and biological resources of the project area. The DEIS’s treatment is particularly deficient with respect to a number of species including the Kenai brown bear, Kenai Peninsula population of the wolverine, the beluga whale, and migratory birds, as discussed below. The project’s impacts on the Kenai brown bear were not adequately analyzed. While the DEIS acknowledges that the impacts from habitat fragmentation, additional human interaction, and increased mortality will be significant, the DEIS fails to explore the ramifications of these impacts. The Kenai brown bear clearly qualifies as a listable entity under the federal Endangered Species Act (“ESA”). The term “species” is defined broadly under the ESA to include “any subspecies of fish or wildlife or plants and any distinct population segment of any species of vertebrate fish or wildlife which interbreeds when mature.” 16 U.S.C. § 1532 (16). It is clear that the Kenai brown bear qualifies for disting as a “distinct population segment” under 16 U.S.C. § 1532 (16). In the “Policy Regarding the Recognition of Distinct Vertebrate Population Segments under the Endangered Species Act,” the FWS defined “distinct population segment” for purposes of listing under the ESA. (61 Fed. Reg: 4721). Under the policy, three elements are to be considered sequentially in determining the status of a potential DPS: (1) the discreteness of the population relative to the rest of the species; (2). the. significance of the population segment to the species; and (3) the populations segment’s conservation status in relation to the Act’s standards for listing. (Id,) The Kenai brown bear clearly meets each of these criteria. A population will be considered discrete if it satisfies one of the following criteria: (1) it is markedly separated from other populations of: the same taxon as -a consequence of physical, physiological, ecolugical, or behavioral factors, (2) it is delimited by intemational governmental boundaries within which differences in control of exploitation, management of habitat, conservation status, or regulutory mechanisms exist that ace significant in light of section 4(a)(1)(D) of the Act. ({d,.) As the DEIS admits, the Kenai brown bear is a geographically and genetically isolated entity, and clearly satisfies the criteria for a discrete population. Turning to the second factor, the consideration of significance includes, but is not limited to, the following factors: (1) persistence of the discrete population segment in an ecological sctting unusual or unique for the taxon, (2) evidence that the loss of the discrete population segment would result in a significant gap in the range of the taxon, (3) evidence that the discrete populations segment differs markedly from other populations of the species in its genetic characteristics. Clearly the Kenai brown bear is significant under these criteria. The Kenai peninsula is a unique ccological setting | for this species, and loss of the Kenai peninsula population would lead to a significant gap in the specics’ Tange. Page 3 : 25C 25D The cost effectiveness of the Project has been studied and the value of the benefits that would accrue from the Project have been described in the Decision Focus 1989 studies and 1998 update study. These studies are summarized and compared to the costs in the DEIS on pages 1-29 through 1-32. See also Section 2.2.1, Project Costs and Benefits (pgs. 2-1 to 2-4) and Section 2.2.7, Environmental Cost-Benefit Analysis Summary (pgs. 2-21 to 2-32) in Chapter 2 of the FEIS. Comment noted, impacts to brown bears were acknowledged in the DEIS. See also FEIS, Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines (pgs. 2-18 to 2-19). 25D cont. 25E 25F 25G mall The final criterion for classifying a DPS is the conservation status of the species. With the exception of the Anchorage area, the Kenai Peninsula is the most densely populated and heavily recreated area of Alaska. The Kenai brown bear suffers heavy mortality from hunting and from other human interactions, and the DEIS acknowledges that the current level of mortality is unsustainable. (DEIS, p. 3-60.) The high degree of endangerment of the Kenai brown bear establishes the importance of listing it as a distinct population segment. The impacts from the Southern Intertie project, and especially from the proposed Enstar Route, are precisely the type of impacts that will continue to drive the Kenai brown bear to extinction, and make listing under the federal ESA inevitable. This fact is demonstrated by the admission of the DEIS that cither route would directly conflict with existing management recommendations for the species. (DEIS, p. 3-68.) Therefore, the impacts on the Kenai brown bear from the proposed Southern Intertie project are entirely unacceptable. In addition, we disagree with some of the statements in the DEIS regarding this species. In particular, the general implication that large areas have lost all value as brown bear habitat duc to displacement is not substantiated, While this is certainly truc in some areas, in others the species may persist in areas with some degree of human use. Therefore, this statement should not be used as a means of dismissing the impacts of the project as insignificant in areas that already expericnce human use without substantiating the presence or absence of the species. The discussion of the Kenai population of the wolverine and the effects of the proposed Southem Intertie project on this species was also inadequate. The Kenai population of the wolverine is a geographically and genetically isolated population and meets all the criteria for a DPS under the federal ESA. In fact, some treatments! consider the Kenai population to be a separate subspecies. Discussion of the impact of the Souther Intertie project on the wolverine was almost entirely lacking. The CBD believes that further fragmentation of its habitat, such as would be caused by the Southem Intertie project, would be unsustainable and would pat the Kenai population of the wolverine, like the Kenai brown bear, on a trajectory for listing under the federal ESA. E Similarly, the discussion of impacts to the Cook Inlet population of the Beluga whale was also inadequate, While we appreciate the inclusion of Figure MV-17 showing Beluga whale concentrations in Cook Inlet, the text of the EIR gives short shrift to this imperiled species. Fhe CBD and other groups have petitioned to have the Cook Inlet population of the Beluga whale listed under the federal ESA, and the National Marine Fisheries Services’ denial of this petition is currently on appeal before the Ninth Circuit. The DEIS must be revised to contain a comprehensive discussion of the potential impacts to this species. The discussion of impacts to birds from the proposed project was also insufficient to meet the mandates of NEPA. In particular, we disagree with the statement that “It is impossible to estimate the numbers of waterfowl, raptors, and other birds that are likely to collide with transmission line structures over any period of time because collision rates depend on site-specific settings and conditions.” (DEIS, p. 3-64.) This statement is belied by the ensuing discussion of different levels of bird mortality from transmission lines in different areas of the country. The DEIS should be revised to include an estimate of bird mortality, by species, for the alternatives analyzed. "Hall, E.R. 1981. The mammals of N. America. John Wiley and Sons, New York. Page 4 25E 25F 25G Comment noted. The wolverine was not selected as an evaluation species for this evaluation because it was assumed that potential impacts to brown bears would be applicable to the wolverine. However, a discussion of potential impacts to wolverine has been included in Chapter 2 of the FEIS, Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines (pgs. 2-19 to 2-20). See Chapter 2, Section 2.2.5, Update on Beluga Whales (pgs. 2- 17 to 2-18) of the FEIS. See also response to comment 13R — Alaska Center for the Environment letter (12/05/01). The DEIS takes into account the site specific settings and conditions associated with potential areas of conflict and has factored those into the impact assessment as generally described on pgs. 3-65 through 3-67, and for each of the alternatives in Section 3.5.4 of the DEIS. See also response to comments 1N — EPA letter (12/05/01) in the FEIS. 25H D. The DEIS Fails to Properly Consider Cumulative I NEPA and the CEQ regulations require the discussion of cumulative impacts in an EIS. 40 C.F.R. § 1508.7; Thompson _y. Peterson, 753 F.2d 754-758 (9"" Cir. 1985); LaFlamme v. Federal Energy Regulatory Comm'n, 852 F.2d 398, 402 (9" Cir. 1988) (individual project cannot be considered in isolation without considering the net impact that all projects in an area may have on the environment). The regulations define a “cumulative impact” as: The impact on the environment which results from the incremental impact of the action when added to past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. 40 C.F.R. § 1508.7, The Ninth Circuit has held that 40 C.F.R. § 1508.7 requires an agency to “consider cumulative impacts of the proposed actions which supplement or aggravate the impacts of past, present, and reasonably foreseeable actions. Oregon Natural Resources Council v. Marsh, 832 F.2d 1489, 1497-98 9" Cir. 1987), rev’d on other grounds, 109 S.Ct. 1851 (1989). The Fifth Cizcuit, in a well-cited opinion, set a five-prong standard for what Qonstitates a “meaningful cumulative effects study.” Fritiofson v. Alexander, 772 F.2d 1225, 1245 (5" Cir. 1985); see_also City of Carmel-By-The-Sea_v. U.S. Dept, Of Transp,, 95 F3d 892, 902 (9 Cir. 1996) (adopting the Fritiofson standard). The standard requires the EIS to identify: 1) the area in which effects of the proposed project will be felt; 2) the impacts that are expected in the area from the proposed project; 3) other actions — past, proposed, and reasonably foreseeable — that have had or are expected to have impacts in the same area; 4) the impacts or expected impacts from these other actions; and 5) the overall impact that can be expected if the individual i impacts are allowed to accumulate. City of Carmel-By-The-Sea, 95 F.3d at 902. The standard requires that “probable impacts be identified and considered.” Fritiofson, 772 F.2d at 1245 n15. In this instance, while the DEIS is voluminous, the discussion of cumulative impacts is brief and cursory, and does not meet the standard set forth by NEPA, the CEQ regulations, and applicable caselaw. The cumulative impacts section should:be revised to contain a detailed discussion of the cumulative impacts to all species and resources in the planning area. We suggest particular emphasis be given to cumulative impacts affecting the Kenai brown bear, Kenai population of the wolverine, migratory birds, and the Beluga whale. Without a meaningful cumulative impacts analysis, it is impossible to assess the overall impacts of the project on the environment. For example, we disagree with the DEIS’s conclusion that regional impacts to wetlands will be insignificant. (DEIS, p. 3-41.) However, without a meaningful discussion of cumulative impacts, the record contains little factual information regarding this issue. This shortcoming must be corrected. For further information regarding cumulative impacts, please see Council on Environmental Quality, 1997, Considering cumulative effects under the National Environmental Policy Act. E. The DEIS Fails to Consider a Reasonable Range of Altematives to Proposed Enstar Route Page S 25H Cumulative impacts are presented in DEIS Section 3.12 (beginning on pg. 3-280), including a resource and species- specific cumulative impacts analysis in Table 3-37 (beginning on pg. 3-292). These cumulative effects are summarized in Table S-2. Further information on brown bears and wolverines is presented in the FEIS Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines (pgs. 2-18 to 2-20). See also response to comment 25E (above). 251 25J The analysis of alternatives should be the heart of the EIS. Yet the DEIS fails to analyze a reasonable range of alternatives. In particular, there is insufficient justification or reasoning for dismissing problem-solving options that do not involve the construction of a new transmission line and substations. In addition, there is insufficient justification for dismissing options such as the Quartz Creck corridor that would traverse more developed areas. These options should have been discussed at a comparable level of analysis to the proposed Enstar and the Tesoro Routes. IL. ‘The Proposed is Not in Compliance with Section 404 of the Clean Water Act or the 404(b)(1) Guidelines A. ec SI Because of the shortcomings discussed above and further issues discussed below, it is clear that the Army Corps must complete additional analysis to determine the significance of the project's impacts on the environment, and to comply with the public interest determination requirements and with the EPA 404(h)(1) Guidelines. The proper level of analysis is for the Army Corps to prepare an EIS on the issuance of this permit. The NEPA requires that an EIS be prepared for all “major Federal actions significantly affecting the quality of the human environment." 42 U.S.C.A. § 4332(2)(C). Whether there may be a significant effect on the environment requires consideration of two broad factors: "context and intensity." See 40 C.F.R. § 1508.27; 42 U.S.C. § 4332(2)(C). These factors are discussed in tum below. It is indisputable that the issuance of a 404 permit for this project mandates the preparation of an EIS when viewed both in the context of the de-facto wilderness areas of the Kenai peninsula, and in the national context. Here, the project implicates a large part of an area {hat has enormous value for many sensitive and imperiled species of wildlife., Many of these species, in particular the Kenai brown bear, will be greatly impacted and imperiled by, further development and fragmentation of the habitat. The loss of wetlands, riparian vegetation, and biological resources is enormously significant when viewed both in the context of the Kenai Peninsula and in the national context., ‘The factors the Corps must consider in determining the intensity of the action are set forth at 40 C.F.R. § 1508.27. These include the degree to which the proposed action affects public health or safety, unique characteristics of the geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas, the degree to which the effects on the quality of the human environment are likely to be highly controversial, the degree to which the possible effects on the human environment are highly uncertain, whether the action is related to other actions with individually insignificant but cumulatively significant impacts, the degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act,. and other factors. Furthermore, the Corps must consider the effects of the permit over the entire project area, because it is clear that the project could not occur but for the issuance of a 404 permit by the Comps. 33 C.F.R. § 325, Appendix B 7(b)(2). Based on the information contained in the DEIS and public comments received, the environmental impact of this project can only be considered extremely intense in light of the above factors. This project will have substantial impacts waters of the U.S., and has been the subject of considerable controversy, as evidenced by the receipt of over 700 comments from members of the — Page 6 251 25J See the General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. 1-8 to 1-9) in Chapter 1 of the FEIS regarding purpose and need and adequacy of alternatives analysis for the Project. The USACE has acted as a cooperating agency in the preparation of the DEIS and has utilized the results from the DEIS to prepare a Draft Section 404(b)(1) Evaluation, included in Appendix B of the FEIS. As indicated in response to comments 1A and 1F — EPA letter (12/05/01), the USACE has determined that the Tesoro Route is the least damaging practicable alternative. See also Section S.10 of the FEIS (pg. S- 26) for agency route preferences. 25K public so far.” Because of these factors, as well as others discussed throughout these comments, it is clear that an EIS must be prepared. B. Ther. 4 Project is Not in Compli ith the 40406)(1) Guideli Further environmental review is clearly necessary to comply with the 404(b)(1) Guidelines. As a threshold matter, the level of environmental review of direct, indirect, and cumulative impacts to wetlands and biological resources contained in the DEIS is grossly insufficient to satisfy these requirements. For the most part, the DIES contains insufficient analysis of the indirect and cumulative impacts of this project, which are extremely significant. The indirect effects of this project will be enormous. For example, increased human intrusion into the area opened by the corridor right-of-way will have a profound impact on species such as the Kenai brown bear and Kenai population of the wolverine. This impact is particularly troublesome because the project study area is absolutely critical for the long term survival of these species. Indirect effects such as this must be identified, avoided, minimized, and mitigated to the maximum extent practicable. This process has not been completed, as the mitigation proposed by the DEIS is vaguc and incomplete at best. Some of the mitigation measures suggested are quite simply not mitigation. For example, “not “Increased access could be minimized by not improving existing roads,” (DEIS p. 3-68) is certainly a wise management decision, but it can hardly be considered as mitigation for the transmission corridor itself. In addition, it has not been demonstrated that the project is the Least Environmentally Damaging Practicable Alternative (“LEDPA”) as required by 40 C.F.R. § 230.10{a), nor has it been demonstrated that the project will not contribute to: the violation of any Alaska state water quality standard, or violate any toxic cffluent standard under 33 C.F.R. § 1317. It also has not been demonstrated that the project will not cause significant degradation to waters of the U.S. as required by 40 C.F.R. § 230.10{c). The specific and extensive factual findings required to make these determinations have not been made as required by 40 C.F.R. § 230.11. While the CBD acknowledges that the proper time to make these findings is after all environmental review procedures have been completed, even the limited information currently available on the project shows that the current Preferred Alternative will ultimately be unable to meet these substantive legal and biological requirements, for a number of reasons, as discussed below. 1. The Proposed Project is Not the Least Environmentally Damaging Practicable Alternative Neither the PN nor the DIES demonstrate that the proposed project is the LEDPA as required by the 404(b)(1) Guidelines. This statement holds true in a gencral sense, for the transmission of any electrical transmission line and facilities in the area, and in the more specific sense for the proposed Enstar Route. Because the project is not water dependent, off-site altematives are presumed to he available. Yet altematives that would not include filling waters of the U.S., such as energy conservation programs, were not analyzed in detail. as Environmental Impacts have not been Avoided, Minimized, and Mitigated to the Maximum Extent Practicable * Mr, Larry Wolfe, personal communication. Page 7 25K See response to 25J (above). Mitigation has been considered throughout the EIS process, including corridor selection, facility siting studies, concept design, and the identification of standard and specific mitigation measures. A Mitigation Plan for the Project is provided in Volume II of the FEIS. 25K cont. 25L 25M 25N Chapter 3 of the DEIS reveals that environmental impacts have not been avoided, minimized and mitigated to the maximum extent practicable. Very little true mitigation is proposed for the Project overall. The Public Notice states the following: As a result of early project planning, the applicant has incorporated into the proposed project the following mitigation efforts to reduce impacts to the aquatic environment: use of existing access roads, use of tracked and low ground pressure vehicles, temporary steel matting on compressible soils, scheduling of work during winter months when ground is frozen, suspending the transmission line beneath existing bridges, directional boring under streams and intertidal areas, or spanning, wetlands and rivers with minimum tower setbacks. (DEIS, Appendix F.) At best, these measures speak to minimizing impacts. As discussed above, the DEIS did not demonstrate that impacts have been avoided to the maximum extent practicable, and the impacts have certainly not been mitigated to the maximum extent practicable. As discussed above, the proposed project will have significant adverse impacts to species such as the Kenai brown bear, Kenai population of the wolverine, Beluga whale, and many different bird species. Neither the DEIS nor the Public Notice appear to propose any meaningful mitigation for these species whatsoever. If the project were to go forward, the Army Corps must meet, at a minimum, the statutory and regulatory standards of Section 404 of the Clean Water Act and the 404(b)(I) Guidelines. These standards have not been met. As stated above, general statements such as “not improving existing roads would lessen impacts,” are not acceptable mitigation measures. Cc. The Proposed Project is Not in the Public Interest In order to issue the permit, the Army Corps must make a finding pursuant 33 C.F.R. § 320.4 that the issuance of a permit for this project is in the public interest. Even if issuance of the permit for the project as currently proposed were otherwise lawful, which it is not, it is clear that the issuance of a permit for the project is mot in the public interest. As discussed above, the Applicant proposes to construct a monumentally environmentally damaging electrical transmission corridor through some of the most biologically areas of the Kenai peninsula, for what appears to be nothing more than an increase in power generation and transmission for the Applicant, and perhaps minor energy savings for the consumer. Such an action is poor planning, poor policy, and is not in the public interest. Our public agencies should not approve the proposed project. IL, The Proposed Enstar Route Conflicts with the National Wildlife Refuge System Improvement Act The explicit purpose of the National Wildlife Refuge System is conservation of wildlife and biological resources. As the DEIS admits, the proposed project is in direct conflict with the Management objectives of the Kenai National Wildlife Refuge. Therefore, not only would the implementation of the Enstar Route be poor planning and management, it would also be unlawful. IV. Conclusion For all the reasons discussed above, the CBD encourages adoption of the no-project alternative. If the no-project alternative is not selected, then additional analysis must be conducted consistent with these comments in order to bring the project into conformance with all applicable laws. Page 8 25L 25M 25N Comment noted. Refer to Draft Section 404(b)(1) Evaluation in FEIS Appendix B. Refer also to the General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding purpose and need for the Project and alternatives. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See the General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. 1-8 to 1-9) in Chapter 1 of the FEIS regarding purpose and need and analysis of alternatives for the Project. Thank you very much for the opportunity to comment. Please add the Center for Biological Diversity to the mailing lists to receive all information about this project: CBD, P.O. Box 493, Idyllwild, CA 92549, Sincerely, dint yl Kassie R. Siegel Staff Attomey Center for Biological Diversity ~~ 260A Anchorage Audubon Society, Inc. P.O. Box 101161 * Anchorage, Alaska 99510 © (907) 278-3007 December 4, 2001 Lawrence R. Wolfe Senior Environmental Protection Specialist USDA, Rural Utilities Service Engineering and Environment Staff 14000 Independence Ave. SW Stop 1571 Washington, DC 20250-1571 Dear Mr, Wolfe: Following are comments by the Anchorage Audubon Society regarding the Southern Intertie Project Draft Environmental Impact Statement (DEIS). These comments are organized by; 1) Criteria for Review, 2) Wildlife Related Inadequacies and Inaccuracics, 3) Other Inadequacies and Inaccuracies, and 4) Conclusions. 1. Criteria for Review The Anchorage Audubon Socicty has about 1,200 members who live in the Anchorage Bowl, the Mat-Su Valley, or the Kenai Peninsula. Most of our members are also ratepayers with one of the utilities who comprise the Applicant for the Southern Intertic Project. Our members would benefit from having more reliable electricity, the principal purpose for the proposed project. On the other hand, most of our members would be negatively affected by any project that impacts wildlife or our opportunity to benefit from the presence of wildlife, including both consumptive and nonconsumptive uses as well as nomuses (c.g., existence value). The bottom line for Anchorage Audubon is whether or not the benefits from the Southern Intertie are worth the wildlife and outdoor recreation losses (i.¢., external costs) that could be imposed on us by the project. While we cannot speak for the general public, we believe that the vast majority of southcentral Alaska residents also place high importance on the presence of wildlife and opportunities for outdoor recreation and how these attributes might be impacted by the Southern Intertie. We base this on our knowledge of a number of surveys. For example, several years ago, the Alaska Department of Fish and Game asked residents throughout the state if “Wildlife adds a great deal to my enjoyment of living in Alaska.” Of those who reside in Southcentral, 80.7% strongly agreed and 15.7% moderately agreed, totaling ANCHORAGE AUDUBON SOCIETY IS A CHAPHER OF THE NATIONAL AUDUBON SOCIETY B rwcpoes race 26A Comments noted. 20B 26C 96.5% agreement. When asked if, “I think more concern should be given to protecting the land and water where wildlife live,” 47.7% of these same respondents strongly agreed and 29.8% moderately agreed, for a total of 77.5% agreement (McCollum and Miller 1994). Also, as part of its Forest Plan Revision for the Chugach National Forest, the U.S. Forest Service recently surveyed nearby communities to determine the values that local residents attribute to the Forest. The survey includes many statistics indicating strong support for the protection of wildlife and opportunities for outdoor recreation. Referring to these studies, the DEIS for the Forest Plan Revision states, “A significant portion of the public is interested in how the Forest is managed and is especially interested in managing for amenity values rather than commodity values” (USDA Forest Service 2000). These surveys clearly indicate that wildlife and outdoor recreation are important values to not only Audubon members, but most residents of southcentral Alaska. Given this importance, it is imperative that the DEIS for the Southern Intertie include not only an “adequate” and “accurate” description of the direct and cumulative impacts on wildlife and outdoor recreation by the project, but a decision-making process that incorporates a quantitative assessment of these impacts (i.¢., costs) to respective user groups. To be technically correct, the benefit/cost analysis needs to internalize these costs within the overall cost of the project. Given the importance and value of the regional and nationally important resources that will be impacted by the project, it should be apparent that the actual project costs includes significantly more than just the direct construction and | operating costs that will be borne by the project Applicant. While the principal concern of Anchorage Audubon is the impact that the proposed project might have on wildlife, we are also interested in knowing whether adequate consideration is being given to the full range of alternatives, or mix thereof, that could meet the purpose and need statement. We are particularly interested in seeing that; ¢ load forecasts are tempered by aggressive energy conservation efforts that are sponsored by Applicant utilities, * renewable energy resources are used where feasible in order to reduce the environmental impacts associated with the use of fossil fuels, and ¢ distributed energy systems are used where feasible to reduce dependence on centralized systems that are more vulnerable to widespread power outages and security risks, In essence, we are interested in energy-efficient alternatives that will lead us into the new millennium, with respect to energy supply and demand, rather than alternatives that are vestiges of the past. Combining our interest in reducing environmental impacts and increasing energy efficiency, the decision-making framework that we think is needed for selecting the optimal alternative should be based on the least-cost planning concept, which is described below (Hanson and Kidwell 1991). 26B 26C Cumulative impacts are discussed in DEIS Section 3.12 (beginning on pg. 3-280). See also response to 25H — Center for Biological Diversity letter (12/05/01). Regarding costs, see Issue 13 (pg. 1-8) in the FEIS and Section 2.2.7, Environmental Cost- Benefit Analysis Summary (pgs. 2-21 to 2-32) in Chapter 2 of the FEIS. While section 2621(d)(7) of the Energy Policy Act does require “each electric utility” to employ “integrated resource planning,” that section does not apply to the RUS or to this Project. Section 2621 and the standards it sets out apply only to State regulatory authorities that have adopted the standards. The Regulatory Commission of Alaska considered the standards set out in Section 2621 and after all appropriate procedures declined to adopt them. Consequently, this Project is not subject to any of Section 2621, including the “integrated resource planning” standards. It should be noted that the DEIS has given appropriate consideration to unquantified environmental amenities and values along with economic and technical considerations in full compliance with NEPA. See also the General Response to Issue | (pgs. 1-3 to 1-4), Issue 13 (pg. 1-8), and Issue 14 (pgs. 1-8 to 1-9) in Chapter 1 of the FEIS for further information regarding purpose and need for the Project, cost-benefit analysis, and alternative analysis. 26C cont. 26D 26E Least-cost planning encompasses both the use of alternative supply sources (that is, supply-side options), and modifications in the use of energy (that is, demand- side options)...., Demand-side options are technologically based or behaviorally based programs that modify the amount or time of energy use. Demand-side options for electricity and other energy forms include attic or water heater insulation; high-efficiency motors, lights, ballasts, and furnaces; timers on water heaters; direct-load control equipment; time-of-use pricing; interruptible service; and business work hours and manufacturing shifts. A central goal of least-cost planning is to provide energy services at minimum cost using demand and supply options. Minimizing the cost of energy services (such as heating, lighting, and mechanical drive in manufacturing processes) extends beyond achieving the lowest cost for power supply; meeting energy requirements efficiently requires attention to economic, environmental, and social effects. Least-cost planning provides one means for addressing the market failures arising from environmental externalities. An integral element of least-cost planning is assessment of the environmental consequences of the various demand-side and supply-side options. With least-cost planning, environmental concerns can be treated more directly and flexibly than in traditional planning, where such concerns are handled simply as a constraint.” It should be noted that least-cost planning is consistent with the federal Energy Policy Act of 1992 which states that, “Each electric utility shall employ integrated resource planning,” a concept that is essentially the same as least-cost planning. Since the RUS is a federal agency, your review and decision on this project must be consistent with the requirements of the Energy Policy Act. L 2. Wildlife Related Inadequacies and Inaccuracies In our review of the Southern Intertie Project DEIS, we find that the document has a number of significant and fatal inadequacies and inaccuracies. Wildlife Values - At first, the DEIS appears to give a comprehensive and candid report on the impacts that either alternative for the Southern Intertie might have on wildlife populations and habitat. But closer review reveals that these impacts are merely listed and then essentially ignored in the project design/selection process. The most serious inadequacy of the DEIS, from our perspective, is that neither the benefit/cost analysis nor the socio-economic impact analysis makes any attempt to account for the loss of wildlife or outdoor recreation values. Having some familiarity with what these values are because of other studies, we doubt that either version of the Southern Intertie would be economically feasible if the loss of these values were internalized within the project. Brown Bears - According to wildlife valuation studies, brown bears are Alaska’s most highly valued species of wildlife to both hunters and wildlife viewers (McCollum and 26D See the FEIS, Chapter 1, Issue 8 (pg. 1-8) and Chapter 2, Section 2.2.7, Environmental Cost-Benefit Analysis Summary (pgs. 2-21 to 2-32). 26E cont. 26F 20G Miller 1994), Although the DEIS acknowledges that the Kenai Peninsula population of brown bears has been declared a “species of special concern” by the state and that the Enstar route will have “Significant cumulative impacts within the KNWR” (Table 3-37), no adequate measures have been proposed to either mitigate or compensate for long-term impacts to this valuable species. The DEIS does mention that access to the intertie right- of-way will be restricted, which could help reduce Defense of Life or Property instances, but most land managers recognize that these restrictions are often violated, particularly by the type of individuals whose behavior is more likely to lead to conflicts with bears. Since brown bears tend to utilize the entire landscape in those areas where they occur, adequate mitigation would have to protect as much productive and unprotected landscape as that which will be impacted by the Southern Intertie. To repeat, mitigation for brown bear impact has to be at the landscape level. Although there are few opportunities to provide this sort of mitigation, it might be possible and it behooves the Applicant to investigate the possibilities. If landscape mitigation is not possible, it would have to be demonstrated that the benefits derived from the Southern Intertie are more substantial than the benefits of sustaining Kenai brown bears at current population levels. It should be noted that there is an accepted economic method for this type of analysis. This method, called Safe Minimum Standard (SMS), provides a framework for measuring tradeoffs between such things as brown bear values and intertie benefits, as well as other issues imbedded in this DEIS. Attached to this letter is a copy of a paper from the journal of Ecological Economics that describes the SMS approach. Applying this methodology would require a survey that measures the public’s perception of opportunity costs at stake between competing values. Without such a survey, the RUS has no substantive basis for favoring the benefits from the Southern Intertie over the value of brown bears. In essence, lack of having this information amounts to a fatal flaw of the DEIS. [— Moose — The DEIS candidly acknowledges that construction of the Enstar route for the Southern Intertie will have irreversible and irretrievable impacts on moose populations throughout the life of the project (Table 3-39). Currently, most of the northeast quadrant of the KNWR, which is bisected by the Enstar route, has a low density of winter moose (Figure MV-18). However, this area has not had a burn in a long time. Either a prescribed burn or not controlling a wildfire could significantly improve winter moose habitat. This in turn is likely to result in moose population densities similar to that which exists in the area just to the west pf the right-of-way, which burned in 1969 and now has a super high or high density of winter moose. But, as the DEIS acknowledges, for sake of security, the presence of the Southern Intertie would preclude a prescribed burn and require that fire control be implemented in the event of wildfire. In essence, the Southern Intertie would dictate habitat management for not only its right-of-way through the KNWR, but this quadrant of the refuge. This would hold the carrying capacity for moose at a low level of productivity for a significant portion of the refuge, despite the fact that the KNWR was established to protect the Kenai’s moose populations, Maintaining this condition will significantly impact both local sport and subsistence hunting opportunities. A major inadequacy of the DEIS is that it does not address the impact or opportunity 26E 26F 26G Comment noted. Impacts to brown bears were acknowledged in the DEIS. See Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines (pgs. 2-18 to 2-19) of the FEIS and the Mitigation Plan, Volume II of the FEIS. See also response to comment 26D (above). See Section 2.2.7, Environmental Cost-Benefit Analysis Summary (pgs. 2-21 to 2-32) in Chapter 2 of the FEIS. See response to comment 130 — Alaska Center for the Environment letter (12/05/01). 26H 261 26) costs that the project will have on moose habitat and populations and subsequent use by L_ predators, hunters or wildlife viewers. The impact of the intertie on moose habitat could be largely mitigated by having the intertie go underground through the KNWR. In fact, this is suggested in the DEIS (page 3-184) but then dismissed because it would require a contingent valuation survey that “included a question asking how much the respondents would be willing to pay to have the facility out of sight, [and] the conclusion could only be regarded as indicative of a general sentiment.” It seems to us that any information indicative of general sentiment is important and should be included in the DEIS. In fact, the justification for the whole project seems to be based on no more than general sentiment that reliable power is a good thing. Considering the overall cost of the project, the expense of a contingent valuation survey would be a drop in the bucket and well worth the information it provides. One further point is that it would be more technically correct to have a contingent valuation survey ask “how much are you wiling to accept” rather than, “how much are you willing to pay.” It is the Applicant who is proposing to restrict use of public resources and to obtain benefit from these restrictions. The public is not trying to protect a resource that is L_ on privately owned land, in which case a “willing to pay” question would be appropriate. Beluga Whales ~ The DEIS recognizes that the beluga whale is on the state’s species of special concern list as well as the NMFS depletion list and that the submarine cable for either the Enstar or the Tesoro routes transects beluga whale concentration areas in Chickaloon Bay, including calving areas. The DEIS acknowledges that construction or repair of the submarine cable could disturb beluga whales, particularly during calving. Although the DEIS states that impacts on calving could be avoided by scheduling construction at a different time of the year, the section on Mitigation (Appendix D) fails to make any such commitment. This is an inadequate response to a species whose loss of population in Cook Inlet has been controversial. The pubic has no assurance that this issue will be adequately dealt with before the final EIS. Also, the DEIS is inaccurate in assuming that any disturbance would be of a short-term nature. Beluga whales have slow reproductive rates and few young, making their long-term population dynamics more vulnerable to short-term disturbances. Subsistence — While the DEIS recognizes the need to address subsistence, it inaccurately states that, “There appears to be no negative impact on populations of relevant species that would impair subsistence activities (page 3-209).” On the next page, the DEIS goes on to say that, “Moose hunting appears to be the most substantial subsistence use within the study area.” Considering that the population of moose in the northeastern quadrant of the KNWR would be kept at a low level of abundance because of the presence of the intertie, if the Enstar route is built, it seems more than apparent that the activities of some subsistence users will be impacted. Furthermore, having reduced moose populations in the area of the intertie and subsequent loss of hunting opportunity puts greater hunting pressures on other areas. A significant inadequacy of the DEIS relative to subsistence is the lack of discussion about the possible effects that disturbance of beluga whales might have on subsistence 26H Comment noted. See FEIS Section 2.2.7, Environmental Cost- Benefit Analysis Summary (pgs. 2-21 to 2-32) regarding cost/benefit analysis. See also Chapter 2 of the FEIS, Section 2.2.3 Underground Construction Costs (pgs. 2-11 to 2-14) for additional information. 261 See response to comment 13R — Alaska Center for the Environment letter (12/05/01). 26] See response to comment 130 — Alaska Center for the Environment letter (12/05/01). 26) cont. 26K 26L users. The DEIS overlooks that a subsistence user does not necessarily have to live in any of the communities close to the project, which is the case with beluga whale subsistence hunters. It should be more than apparent that the Southern Intertie could restrict opportunities for subsistence use. Therefore, the DEIS needs to comply with Section 810 of ANILCA. Carrying out the procedures of Section 810 could significantly alter not only the material in the DEIS, but the entire public review process. The F& WS (particularly for moose) and NMFS (particularly for beluga whales) should have complied with Section 810 requirements before the DEIS was issued. It will be a breach of the EIS process for the RUS to proceed to a Final EIS without first giving the public an opportunity to see how ompliance with Section 810 changes matters. Northern Flying Squirrel — Although this is not a significant inadequacy of the DEIS, it should be mentioned that the list of terrestrial mammals (Table 3-7) does not include the northern-flying squirrel, Being a nocturnal species, its presence in an area often goes unnoticed. The wide right-of-way that would need to be cleared to accommodate the Southern Intertie could present a difficult barrier to flying squirrels. Crossing wide open areas exposes squirrels to predators, such as owls. 3. Other Inadequacies and Inaccuracies Purpose and Need The purpose and need statement lists general benefits that nobody can disagree with, regardless of support for or against the project. What is missing, however, are any objectives that provide guidance for handling impacts and opportunity costs on public interests other than electrical supply. In this respect, the purpose and need statement is inadequate. In essence, the Applicant has taken a minimalist approach to addressing, impacts on other resources, deferring to the RUS, the U.S. Fish & Wildlife Service, and the U.S. Army Corps of Engineers the responsibility for defining how resources, such as wildlife populations and habitat, should be protected. Hopefully, these agencies will have the resources to fill this vacuum. The analysis of project benefits is key to the economic justification for the project. Despite the importance of this material, the DEIS provides a grossly inadequate summary of project benefits. The DEIS itself does not contain enough information to indicate whether or not these calculations are biased, asymmetric, or involve double-counting. Most of the substantive reference materials are in other relatively obscure reports that are not included with the document or the CD. (It would have been relatively easy to include some of the key documents in the CD). It appears to us that this is a violation of 40 C.F.R. 1502.21 which states: "Agencies shall incorporate material into an environmental impact statement by reference when the effect will be to cut down on bulk without impeding agency and public review of the action. The incorporated material shall be | cited in the statement and its content briefly described. No material may be incorporated 20K 26L There has not been a confirmed incident of the northern flying squirrel on the Kenai Peninsula (Bailey, pers. Comm.., KNWR). See the General Response to Issue | (pgs. 1-3 to 1-4), Issue 13 (pg. 1-8), and Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding alternative analysis, cost/benefit analysis, project benefits, and purpose and need for the Project. With regard to the availability of the supporting studies, including the studies that analyzed and calculated the benefits for the Project, it was explained at Project public meetings that because of the bulk of the Project background studies and reports, including the studies that analyzed and calculated the benefits for the Project, these reports would be available to be reviewed upon request made to Chugach or RUS. These reports are voluminous, as shown in the References section of the DEIS, and briefly described in the DEIS. These studies were made reasonably available to interested parties. No requests for reference documents were made during the DEIS review period. The Project benefits were evaluated in detailed studies conducted by Decision Focus in 1989 and 1998. These studies are summarized in DEIS Section 1.4, Project Benefits and Costs (pg. 1-29). Additional information on project benefits has been provided in Chapter 2 of the FEIS, Section 2.2.1 (pgs. 2-1 to 2-4). 26M by reference unless it is reasonably available for inspection by potentially interested persons within the time allowed for comment.” Given the complexity involved in calculating these benefits, and the need for appropriate databases and models, virtually no reviewer of the DEIS will have the means to perform an independent analysis. This puts the burden on the RUS to provide an independent and objective review of the Applicant’s project benefits. However, the DEIS material on benefits is virtually the same as material presented more than two years ago in an Environmental Evaluation report done by consultants for the Applicant. Consequently, it appears that the RUS has accepted this information with little if any critical review. There is reason to be suspicious of the benefit calculations, For instance, the DEIS lists $20.9 million in capacity sharing benefits for either the Enstar or Tesoro route of the Southern Intertie, because of the “amount of capacity avoided or deferred.” This is nearly 15% of total project benefits. However, all sub regions of the Railbelt already have significant excess capacity, so it is not clear what capacity construction will be avoided or deferred. Furthermore, if power is being transferred from a more distant power plant, there will be additional line losses. The data on this benefit is not detailed enough to determine if the benefit calculations were adjusted to include added line losses. The benefit/cost analysis at the end of this section includes just costs directly related to the construction, operation and maintenance of the intertie over its 40 year project life. The Enstar route has a b/c of 1.44 and the Tesoro route is 1.25, which provides little margin for error if the benefit calculations are indeed inflated. For example, eliminating just the capacity sharing benefit would put the feasibility of the Tesoro route on the brink of being uneconomic. The so-called “adjusted benefit/cost ratio” in Table 1-12, which subtracts from the project costs the $46.8 million grant from the state, adds further reason for suspicion. This is an unorthodox approach that is apparently trying to stretch matters to present a more rosy analysis. Project costs are project costs regardless of who pays for them. Eliminating subsidies from the calculation is improper. While this improper maneuver is readily apparent, it raises questions regarding the possibility that other improper maneuvers are buried in data not included in the DEIS. It should be apparent that economic feasibility of the Southern Intertie, based on just the benefits and costs directly related to the project, may be questionable. RUS, being the lead agency, needs to rectify these flaws by providing an independent and objective analysis of Southern Intertie benefits. The most egregious example of problems with the benefit/cost analysis is that it leaves out the cost of any lost opportunities that the project will impose on the use of other resources, particularly wildlife and outdoor recreation. As stated earlier, we consider recognition of these costs crucial to project justification. In our view, leaving these costs “ out of the analysis is a fatal flaw to the adequacy and accuracy of the DEIS. [ Alternatives 26M RUS did conduct an independent review of the purpose and need and the alternatives considered for the Project and found that the need and alternatives sections as written in the DEIS adequately describe and justify the need for the Project. The benefit/cost ration for the Project has not been obscured in any way. Table 1-12 on pg. 1-31 of the DEIS lists the benefit/cost rations for the Project with and without the $46.8 million dollar state grant. The Project benefits were specifically evaluated in detailed studies conducted by DFI in 1989 and 1998 (see 26K above). See also FEIS Chapter 2, Section 2.2.1, Project Costs and Benefits (pgs. 2-1 to 2-4) for more information on project benefits and costs and Section 2.2.7, Environmental Cost- Benefit Analysis Summary (pgs. 2-21 to 2-32) for a discussion on the cost/benefit analysis. 20N 20N The concept of the Southern Intertie has been debated for years and millions of dollars have been spent by state and federal agencies as well as Railbelt utilities on studies of the 4E’s (energy use, engineering concepts, economic benefits and costs, and environmental impacts) that apply to this project. These studies have looked at a wide range of alternatives, The critical issue with the DEIS is not whether this information is mentioned, inferring some degree of authority, but whether it has been objectively used to develop a balanced array of alternatives (as described by the Energy Policy Act) that can contribute, either individually or as a mix, to the purpose and need statement. The DEIS mentions several key alternatives, but then dismisses all but one, an intertie that is divided into two alternatives based on route selection. Table 2-1 states that demand side management (DSM), energy efficiency/conservation, wind generation, and fuel cells do not meet any of seven screening criteria that relate to the purpose and need statement, We seriously question these assertions. Although the DEIS acknowledges that DSM and energy conservation are important to Railbelt utilities and that they have initiated some programs, it dismisses these alternative because of the small portion of load that would be affected by these technologies. This is indicative of the commitment that Railbelt utilities have given DSM and energy conservation over the years; small. If DSM and energy conservation are relegated to being only showcase alternatives, then it is a self-fulfilling prophecy that their contribution will be small What the DEIS needs to demonstrate is the potential for DSM and energy conservation based on current technology. This is typically done via an end-use analysis that compares how much of the various end-uses can be met with certain DSM or energy conservation technologies. It should be noted that in the past, there have been end-use studies of the Railbelt load, but it does not appear that these studies were seriously considered in the project planning process. Consequently, the alternatives presented in the DEIS are not only inadequate, but slant the decision-making to supply-side options. Chugach Electric deserves credit for participating in the installation of a one MW fuel cell plant. However, the DEIS discussion on fuel cells not only ignores this experience, but inaccurately describe the total benefits of this alternative. For instance, the DEIS states that fuel cells costs about $3,000/kW and compares this to combustion turbines which costs between $450-600/kW. The obvious implication is that fuel cells are much more expensive, But, as Chugach Electric well knows, there is more to consider. Both fuel cells and combustion turbines use natural gas, but fuel cells are more efficient, thereby reducing fuel costs, an important component of project life cycle costs. Also, having a fuel cell on site allows that site to use the waste heat for space heating, adding to net energy (not just electrical energy) benefits. In addition, fuel cells can provide more reliable power than power that is transmitted from some energy source hundreds of stormy miles away, such as Bradley Lake Hydro. Despite all these benefits, the DEIS writes off meaningful consideration of fuel cells “because additional gencration is not needed.” See the General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding the Project benefits, purpose and need for the Project, and alternatives considered. Table 1-2 in the DEIS (page 1-10) lists the 14 separate studies conducted to confirm the purpose and need for the Project. The titles of these 14 studies are listed on page R-1 of the DEIS (References Section). As listed in the References Section, study number 2 is the “Railbelt Intertie Reconnaissance Study,” Alaska Power Authority, 1989, Eleven Volumes and Addendum. Volume 3 of this study is “Analysis of Electrical End Use Efficiency Programs for the Alaskan Railbelt.” End use programs were studied and considered as part of the Project process. DSM and Energy Conservation, and New Generation including distributed generation, wind generation, and fuel cells are reviewed and the reasons for their elimination as alternatives to the Project proposal are discussed in the DEIS (pages 2-3 to 2-7). Currently, fuel cells are in fact more expensive on a per kW basis than combustion turbines, but regardless, new generation will not fulfill the purpose and need for the Project. While fuel cells are undergoing research and development and will likely be lower in cost in the future, the use of fuel cells for this Project will not address the specific purpose and need for the Project. See also DEIS Section 2.1, Overview of Alternatives and Screening Process (page 2-1) for a summary of the alternatives screened. Table 2-1, Alternative Screening Summary (DEIS page 2-2), summarizes the alternatives considered but eliminated and whether each alternative meets the Project purpose and need screening criteria in each of the seven areas. Each alternative considered is denoted as to whether it would meet, partially meet, or would not meet the screening criteria. The Healy Clean Coal Project does not meet “all the criteria listed in the purpose and need statement” of the DEIS. The Healy Clean Coal Project provides additional generation to the Railbelt grid and as explained under new generation on pages 2-4 and 2-5 of the DEIS, the overall system currently has an excess of generating capacity over electrical load. As summarized in Table 2-1, new generation does not meet any of the seven alternative screening criteria. Consequently, the Healy Coal Fired Generating is shown as part of the Railbelt generation resources on Figure 1-3, page 1-5 and Figure 2-1, page 2-5 of the DEIS and was included in the electrical system studies for the Project (Power Engineers 1996, 1997). 26N cont. 260 26P 26Q We think that the brief discussion by the DEIS on fuel cells illustrates the type of bias that runs through much of planning process used for the DEIS, but tends to be obscured by lack of detail or references to obscure reports. It is apparent that the DEIS states only what it think needs to be said to comply with NEPA and other legal requirements. There is no evidence, particularly in the discussion on alternatives, that the Applicant intended to provide an explicit and accurate account of the strengths and weaknesses of each viable alternative. In essence, the alternative discussion by the DEIS is woefully inadequate. What we think needs to be presented in the DEIS is an alternative based on an end-use analysis which matches various end-uses with the appropriate technology taken from a mix of DSM, energy conservation, fuel cells, and wind generation. The objective of this alternative is to present a diverse approach that uses the most reliable and cost-effective technology for each type of electrical use. We think that this alternative would not only have merit, but is the direction that will prevail for energy development well within the life of the project. One viable alternative that is not even mentioned in the DEIS is the Healy Clean Coal Project. Although this project has been completed but is not operational, we think these problems will be resolved long before the Southern Intertie could come online. The advantage pf the Healy Clean Coal Project is that an intertie to the Anchorage load center already exists. It seems to us that the Healy Clean Coal Power meets all the criteria listed in the purpose and need statement. If the cost of power from this source is more expensive than Bradley Lake Hydro or any of the other sources used to derive the benefit analysis, it would have to be demonstrated that this marginal difference would amount to more than the life cycle costs of the Southern Intertie. The DEIS is fatally flawed unless it includes the Healy Clean Coal Project as a viable alternative. Conclusion Our review of the DEIS for the Southern Intertie reveals that it does not adequately or accurately address the opportunity costs that would be imposed by the project on other important values, particularly wildlife; including one species of special concern (brown bear) and the one species that is depleted (beluga whale). Ignoring the impact on these species indicates that stronger levels of protection may be needed to get the point across. [ Also, the DEIS does not give adequate or accurate consideration to all alternatives that could meet the purpose and need statement. The benefit analysis of the two route alternatives (Enstar and Tesoro) leaves much to be desired in terms of explaining how these benefits are derived. Another critical factor is whether the Enstar Route, which is preferred by the Applicant, is compatible with the purpose of the Kenai National Wildlife Refuge (KNWR). The DEIS clearly demonstrates it is not. In fact, the presence of the intertie would seriously limit management of a significant portion of the refuge, to the detriment of wildlife. 26N The benefits from the Project were analyzed and calculated in detail by cont. Decision Focus (DFI) in their 1989 studies (Decision Focus, June 1989 & December 1989). In 1998, DFI reviewed and updated the key data items underlying the benefit values from the previous studies and calculated new updated benefit values (Decision Focus, 1998, “Update Study”). The Healy generating units were considered in the DFI Update Study. As a result of this review, updated benefit values were calculated and are included in the DEIS and are summarized in Table 1-11, Net Present Worth of Benefits for the Project. A summary of the DFI study is given in the associated text (DEIS pages 1-29 through 1-31). Additionally, throughout Section 1.3, Purpose and Need for the Project, each area of need is discussed (DEIS pages 1-13 through 1-29) and added detail regarding the DFI studies and the benefits from the Project are described as they relate to that area of need. See Chapter 2, Section 2.2.1 (pgs. 2-1 to 2-4) of the FEIS for more information on project benefits and costs. 260 See response to comments 26E and 26] (above). 26P See the General Response to Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding adequacy of alternatives analysis. See also response to 26M (above) regarding project benefits. 26Q The Tesoro Route has been selected as the agency preferred alternative as noted in response to comment 1F - EPA letter (12/05/01) and as presented in Section S.10 (pg. S-26) of the FEIS. Refer also to the USFWS Compatibility Determination in Appendix A of the FEIS. 26Q cont. 26R 26S The Applicant gives no compelling reason why the Enstar route should take precedence over the long-established purpose for the KNWR. The only apparent reason is that life cycle costs for the Enstar route are slightly less than the Tesoro route. It is puzzling to us |_why the Applicant is so insistent on the cheapest alternative when public (i.e., state) grants for the project more than make up for any premium that is needed to reduce impacts on public resources. In addition, no information is presented to demonstrate that the Applicants ratepayers are willing to accept losses to their use of wildlife and outdoor recreation opportunities in order to save a few dollars. We contend that the Southern Intertie DEIS can not, in its present state, be used to definitively decide which alternative is optimal. Therefore, we recommend that the DEIS be sent back to the Applicant stating that it’s numerous inadequacies and inaccuracies need to be corrected before a defensible choice can be made. Meanwhile, any further decision on the Southern Intertie should be deferred. Sincerely, George Matz, President of the Anchorage Audubon Society 26R 26S See DEIS Section 3.7.3, Rate Impacts from the Project (pg. 3- 189). See also Section 3.7.2, Socioeconomic Consequences of the Proposed Action, Long-term Tourism and Recreation Impacts (pg. 3-184). Comment noted. References Hanson, Mark and Kidwell, Stephen. 1991, Electric utility least-cost planning: Making {t Work Within a Multiattribute Decision-Making Framework. Journal of the American Planning Association, Winter, Vol. 57 Issue 1. McCollum, D.W. and Miller, SuzAnne. 1994a, Alaska Voters, Alaska Hunters, ad Alaska Nonresident Hunters: Their Characteristics and Attitudes ‘owards Wildlife, ADF&G. Anchorage. U.S. Forest Service, 2000. Draft Environmental Impact Statement: Chugach National Forest Land Management Plan Revision. Anchorage, AK. 27A >) CRISTEA erase kaiaa Lok ea ee ee ‘O/ 1010 Wisconsin Av NW, Suite 200, Washington, D.C, 20007 202.333.9075 * Facsimile 202.333.9077 * hitp://www.refugenet.org, s- National Wildlife Refuge Association October 26, 2001 Mr. Lawrence R. Wolfe USDA-Rural Utilities Service 1400 Independence Ave. SW-Stop 1571 Washington, DC 20250-1571 Dear Mr. Wolfe: This letter comments on the compatibility of the Southern Intertie Project (SIP) crossing the Kenai National Wildlife Refuge (KNWR). I am the Alaska Representative of the National Wildlife Refuge Association (NWRA) and have been an Alaska resident for 27A over 25 years, more than 20 years on the Kenai Peninsula. The NWRA is the only national membership organization dedicated solely to protecting and perpetuating the National Wildlife Refuge System (NWRS). Our mission is to protect, enhance and expand the National Wildlife Refuge System, lands set aside by the American people to protect our country’s diverse wildlife heritage. First, the crossing of the KNWR should have never been considered for this project. In 1964, Public Land Order 3400 withdrew lands along the west boundary of the refuge. The Kenai Peninsula Borough has identified these withdrawn lands as a transportation corridor in their planning efforts (SIP DEIS, p. S-15). I find the proposal by Intertie Participants Group to put a 38-mile long 138kV transmission line across a National Wildlife Refuge, when this alternate route is available and identified in borough planning processes, to be short-sighted and cavalier, Under present regulations, the Refuge Manager will not initiate or permit a new use of a national wildlife refuge or expand, renew, or extend an existing use of a national wildlife refuge unless the Refuge Manager has determined that the use is compatible. A compatible use is one that does not materially interfere with or detract ftom the fulfillment of the National Wildlife Refuge System mission or the purposes of the refuge in question. The mission of the National Wildlife Refuge System is to: “administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of the Sish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans." Comments noted. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 27A cont. The purposes of the KNWR are: "To conserve the fish and wildlife populations and habitats in their natural diversity including, but not limited to, moose, bears, mountain goats, Dall sheep, wolves and other furbearers, salmonoids and other fish, waterfowl and other migratory and nonmigratory birds; (ii) to fulfill the international treaty obligations of the United States with respect to fish and wildlife and their habitats; (iii) to ensure, to the maximum extent practicable and in a manner consistent with the purposes set forth in paragraph (i), water quality and necessary water quantity within the refuge; (iv) to provide in a manner consistent with subparagraphs (i) and (ii), opportunities for scientific research, interpretation, environmental education, and land management training; and (v) to provide in a manner consistent with these purposes, opportunities for fish and wildlife-oriented recreation." After reviewing the Draft Environmental Impact Statement, I offer the following comments on the compatibility of the applicant's alternative. The applicant's proposal (Enstar Route) through the refuge will materially interfere with the mission of the NWRS and the purposes of the KNWR. The project would require removal of 530 acres of upland vegetation, interfering with the system mission of conserving "...plants...and habitats..." and the refuge purpose of conserving "...habitats in their natural diversity... These impacts are listed as irreversible and irretrievable in the SIPS DEIS. Changes in the KNWR fire plan (habitat management) required by the presence of the highline will affect habitat and habitat planning also. Collisions between birds and the towers in Chickaloon Bay, near lakes, and at stream crossings are also listed as irreversible and irretrievable in the SIPS DEIS. Construction and possibly the presence of the highline could affect two eagle nests within 1/4 mile of the route. There will be temporary displacement of moose, black bears, brown bears, wolves, and other predators during construction. Black bears den within the area. The presence of the new access will result in increased harvest of most species. These nationally significant impacts interfere with system mission and refuge purposes to "... conserve the fish and wildlife populations and habitats in their natural diversity including, but not limited to, moose, bears, mountain goats, Dall sheep, wolves and other furbearers, salmonoids and other fish, waterfowl and other migratory and nonmigratory birds...". In addition, it will materially interfere with the purpose "... to provide in a manner consistent with these purposes, opportunities for fish and wildlife-oriented recreation...". The visual impacts of towers, transformers, conductors, and access roads will forever change the character of that portion of the KNWR. Changes to recreational management plans and wilderness designations will interfere with the type of wildlife/wildlands recreation that many people seek on refuges. In summary, the construction activities and permanent presence of the Souther Intertie Project across the KNWR will materially interfere with and detract from the mission of (es NWRS and the purposes of the KNWR, making it a non-compatible use. Please put me on your mailing list for this issue. My address is: John L. Martin, Alaska Representative National Wildlife Refuge Association P.O. Box 3283 Homer, AK 99603 (907) 235-6348, (907) 299-1443 (cell) imartin@alaska.net Thank you for this opportunity to comment. Sincerely, Jee by Pfam John L. Martin Alaska Representative cc: Evan Hirsche, President NWRA Robin West, Refuge Manager KNWR Todd Logan, Chief of Refuges Alaska Region WILDERNESS SOCIETY FORM LETTERS (Personalized) 28A 28B 28C 28D To: Mr. Wolfe : Bon't support hypocrisy This E-Mail and or attachments have been scanned for and found free of known viruses. Seen eeeen semen December 2, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., Si -- Stop 1571 Washington, D.C. 20250-1571 Dear Hr. Wolfe, t am weiting in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. By intruding into this area we are being hypscritical of the word “refuge*. Encroaching onto protected habitat to once again degrade and destroy the area that is the safety net of these animals in unacceptable and inhumana, The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. Thia corridor along with an existing powerline corridor etween Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge, The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habit. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are ponsidered to be long term and significant." (p.S-18) The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unreaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. : Kenai Peninsula brown bear population is considered an isolated Sincerely. Cathy Kropp Po Box 252 Mantorville, MN 55955 USA 28A 28B 28C 28D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 29A 29B ‘his E-Mail and or attachments have been scanned tor and found free of known viruses. -Original Message--~~- From: Daniel Cooke [mailto:bbrdcooke@earth}ink.net} Sent: Monday, December 03, 2001 1:39 AM To: Mr. Wolte Subject: Oppose Enstar route on Kenai Refuge This B-Mail and or attachments have been scanned for and found free ef known viruses, December 2, 2001 Mr. Lawrence Wolfe USDA Rural Utilities Service 1400 Independence Ave., Sw -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, Hopefully you will take the time to consider this situation carefully. I am writing in opposition te the proposed Enstar rouve for the Southern Intercie on the Kenai National Wildlife Refuge. But first let me point ouc: The rate of extinction of species in the highest now in at least 65 million years. The last time it was this high it is presumed that an asteroid or comet destroyed moat life on earth. This time humankind (sic) is the destroyer. Now you face a choice. At this most auspicious time in the history of this planet, you have an opportunity. The opportunity to maintain a very significant piece of the mosaic of life on this earth. Do you have children? Hope for great grandchildren? How fast have you seen the natural world altered in your lifetime. Is there trnly no consequence to ripping access into the heart of a wilderness? The Kenai Refuge provided a corridor for transportation and utility needs by wignificantly altering its western boundary in (964. This corridor along with an existing powerline corridor setween Anchorage and the Kenai Peninsula provide viable and legitimate ‘iternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. snacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purpoyeys of the 29A 29B See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 29B cont. 29C 29D xefuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DELS states that "the cumulative effects on wildlife, vegetation, recreation, and visual resources ... are nsidered to be long term and significant." (p.S-18) The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the FWS mandate to protect wildlife on the refuge. It's time to awaken. It’s time to protect. We can no longer afford to destroy. Sincerely, Daniel Cooke 172 Obert Drive San Jose, CA 95136 USA 29C 29D See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 30A 30B 30C 30D From: Kathleen & Richard Huneke (mailto: lakeuidelady@hotmaii.con) Sent: Monday, December 03, 2001 11:37 AM To: Mr, Wolfe Subject; Uppose Enatar rouve on Kenai Refuge lor attachment@ have been seanned for of known viruses. 3. 2001 ence Wolte Rural Utilities service lependence Ave., SW -- Stop 1571 ton, D.C. 20250-1572 Dear Mr. wolfe, Lam writing in opposition to the preponed Enutar route for the Southern Intertie on the Kenai National Wildlife Refuge. why do we designate areas "Wildlife Refuges when their priority can be changed by proposals which will invade their terri tory?? ESPECIALLY when there are two other viable alternative utility corridors already exit, including one provided by the Kenai Refuge when It significantly alrering its western boundary in 1964. the project in not compatible with the purposes of the Refuge, because it would impact wildlife habitat and create new access to these remote areas, Which I’m sure will be utilized by Off Foad Vehicle enthusiasts and others, undermining the original intent of the land. The *Enstar* route would cut across valuable, unroaded lands in the Kenas National Wildlife Refuge, undermining any potential for wilderness deuignation in these areas. - this project would unnecesaarily impact the Kenai Peninsula brown bear, declared a species of special concern by the state Gf Alaska. The unreaded lands of the Refuge are erittcal to the Long term viability of the bear. 30A 30B 30C 30D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 30E 30F 30G 30H The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge, The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant." (p.S-18) The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Sincerely, Kathleen & Richard Huneke 16985 Rio Maria Road Lakeside, CA 92040 USA 30E 30F 30G 30H See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 31A 31B 31C 31D -----Original Message Eric Horstman [mailto:vonhorst@qu.pro.ec] Sent: Sunday, December 02, 2001 11:08 PM To: Mr. Wolfe Subject: Oppose Enstar route on Kenai Refuge AREER Eee eR eA AEE AORN EEA E REE A GEREN EEE SEDER REET ERA AE EEE This E-Mail and or attachments have been scanned for and found free of known viruses. Raa deeere nee Peeeeeee ee ereeees Sere eeewerreene December 2, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, 1 am writing in opposition to the proposed Enstar route for the Southern Inrertie on the Kenai National wildlife Refuge. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access tu these remote areas, further degrading brown bear habitat. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are nsidered to be long term and significant.* (p.S-18) The Enstar route would cut, across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for tuture wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. { work as a reserve director of the Cerro Blanco Protected Forest on the outskirts of the city of Guayaquil, Ecuador and I know first hand the effects that roads and other developments can have on the integrity of natural areas, especially in regards to increased human access to these same areas. Please help set the example far developing country park systems, don't let this development go through in the Kenai! Sincerely, Eric Horstman 210 Paulsen Street Weaverville, CA 96093 USA 31A 31B 31C 31D See response to 21 A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 32A 32B 32C 32D -----Original Message- --- From: Ashlin Tucker (mailt Sent: Wednesday, December 05 To: Mr. Wolfe Subject; Oppose Enstar route on Kenai Refuge shl in82eyahoo.com) 2001 12:24 pM This £-Mail and or attachments have been scanned for and found free of known viruses. December 5, 2001 Mr. Lawrence Wolte USDA -- Rural Utilities Service 1400 Independence Ave., St Stop 1573 Washington, D.C. 20250-1571 Dear Mr. Wolfe, I am writing in opposition to the proposed Enstar route tor the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to binect the northern portion oft the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote arean, further degrading brown bear habitat. Even the DEIS states that "the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are sidered to be long term and significant.* (p.S-18) The Enstar route would cut across valuable, unreaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides f 32A 32B 32C 32D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). wrge tracts of unroaded lands that are critical to the long term iability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Let us protect threatened species before they become endangered, which is much like a patient on life support; little chance of overall survival. It is key to protect wildlife and habitat BEFORE they are on life support, ensuring their survival for future generations. Please PLEASE consider existing power line corridors and ALL alternatives before permentantly jepardising the health of vital wildlife populations. Sincerely, Ashlin H. Tucker P.O. Box #18 Silverthorne, CO 80498 1014 Straight Creek DR. Dillon, Co 80493 Sincerely, Ashlin Tucker P.O. Box 18 1014 Straight Creek Dr. Dillon, Co 80493 Silverthorne, CO 80498 USA 33A 33B 33C 33D w+--- Original Message---~--~ From: Tony DeFalco [mailto:tonydefalco@yahoo. com) Sent: Monday, December 03, 2001 8:29 PM To: Mr, Wolfe Subject: Oppose Enstar route on Kenai Refuge This E-Mail and or attachments have been scanned for and found tree of known viruses. SOONER eRe eee eee eee eben eee a STONE PAE E HESS O ERE H EEE nba December 3, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, I have worked extensively on powerline issues in the Lake Superior basin. These lines have numerous known and unknown impacts to people and wildlife. Before approving any plan, please consult with the folks at Save Our Unique Lands in Wisconsin - they have tons of helpful information on these impacts, The community response there opposing the line was tremendous. Please avail yourselves af these resources before making any decisions. Thanks. 1 am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. he Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. ggeegl Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge, The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DETS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant." (p.8-18) The Enstar route would cut across valuable, unroaded lands in ue Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability ef this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the SFWS mandate to protect wildlife on the refuge. Sincerely, Tony DeFalco 1706 Orchard Street Ann Arbor, MI 48103 USA 33A 33B 33C 33D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 34A 34B 34C 34D 34E sone Original Message-- --- From: Daniel James [mailto:adguy55@hotmail.com) Sent: Monday, December 03, 2001 3:37 PM To: Mr jolfe Subject: Oppose Enstar route on Kenai Refuge tee eeeee tees This E-Mail and or attachments have been scanned for and found free of known viruses. o sedans PROT R EERE NEE E ARENDT AEA E EER AREA EA EERE AR ER REE TEER ORE December 3, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, If the attacks of September 11 did nothing else they should force a re-evaluation of public resources which can easily be put at risk, To continue the 20th century ideal of highly centralized power grids and power plants seems irresponsible. To destroy one of the great wildlife refuges in the world for this otherwise short-sighted project displays how far you would destroy vast beauty for personal business interests. I am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. tility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these via P Kenai Refuge provided a corridor for transportation and uw ie routes and further encroach on the Refuge is unacceptable. of the Kenai Refuge is not compatible with the purposes of the Refuge, The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear abitat. Even the DEIS states that *the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are onsidered to be long term and significant." (p.S-18) EE the Southern Intertie to bisect the northern portion 9 h c The Enstar route would cut across valuable, unroaded lands in 1 ne Kenai National Wildlife Ketuge, Those unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas, the Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Sincerely, Daniel James 1855 S. Pearl St., #10 Denver, CO 80210 usA 34A 34B 34C 34D 34E The proposed project would increase security of the transmission system, as stated in Section 1.3.1, Reliability (pg. 1-14), “Adding transmission lines to a system improves system reliability by providing multiple paths for the power to flow; thus, an outage of a single component does non completely disrupt the system.” See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 35A 35B 3c 35D -----Original Message----- From: Amanda Cluck {mailto:mandycluck60@hotmail.com) Sent: Monday, December 03, 2001 1:41 PM To: Mr. Wolfe Subject: Oppose Enstar route on Kenai Refuge seaeaee This E-Mail and or attachments have been scanned for and found free of known vicuses. BARRERA AREA E EERE REAPER ERE REE EERE ED RRR e REE EER RTE H TORRE REDE THERE A EERO OD teteee December 3, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, 1 am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. I am a student studying wildlife ecology and understand the importance of large areas of untouched land to the ecology of an area. Also being a logical person, I understand the importance of providing power in less civilized areas of the nation. But please think about the long term affects that will result from adding this power line. The nation is fast losing large areas of land that are essential to maintain ecological processes that are necessary to all forms of life. Please allow this portion of the country to remain as it is. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that *the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant." (p.S-18) fhe Enstar roure would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Sincerely, Amanda Cluck 1229 N. Knoxville Tulsa, OK 74115 USA 35A 35B 35C 35D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 360A 36B 36C 36D --Original Message----- From: Monika Willisegger [mailto:nonika.willisegger@ch. ibm.com) Sent: Monday, December 03, 2001 2:56 aK To: Mr. Wolfe Subject: Keep the Kenai Refuge as valuable as possible This E-Mail and or attachments have been scanned for and found free of known viruses. Poeeee eee eee eee SESS OO eS SC e rere errr eerie errr rier errr series December 2, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, We cannot turn the wheel back, but we can keep what we have saved up to now and one of these saved spots ia the ai National Wildlife Refuge. 1 oppose the proposed Enstar route for the Southern Intertie in the Kenai National Wildlife Refuge. The new route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation {n these areas. Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and turther encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge, The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that ‘the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant.* (p.8-18) The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Sincerely, Monika Willisegger Ziricherstrasse 28 Uitikon, 8142 Switzerland 36A 36B 36C 36D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 37A 37B 37C 37D -----Original Message-~--- From: kristin Hjelle [mailto:crags@wic.net) Sent: Sunday, December 02, 2001 8:27 PM To: Mr. Wolfe Subject: Oppose Enstar route on Kenai Refuge PENNE ERROR E EERE AREER ARE E EE H AERO E ERE E ERE E REET A AO EEE ED This E-Mail and or attachments have been scanned for and found free of known viruses. beeen nneeerenerane December 2, 2001 Mr. Lawrence Wolfe USDA -~ Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, Please record my opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. Tt is time to stop encroaching on and destroying our wildlands. The Kenai Refuge has already provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor, and also an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project, To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge, The Enatar route would impact wildlife habirat and create new access to these remote areas, further degrading brown bear habitat. ven the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant." (p.S-18) the Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. ‘he Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern vy the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Vecsers 32 Sincerely, kristin Hjelle 2030 Poplar br. Grand Junction, CO 81505 USA 37A 37B 37C 37D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 38A 38B 38C 38D Seon Original Message----- From: burnis e (gene) tuck (mailto: burnisetuck9yahoo.com) Sent: Sunday, December 02, 2001 12:02 PM to: Mr. Wolfe Subject: Strongly oppose Enatar route on Kenai Refuge RENNER neta eee eee eee TEETH EEE O TEES MEME HEARNE EERE EEE EEE This E-Mail and or attachments have been scanned for and found free of known viruses. Seeeeeeneeeeeee December 2, 2001 Mr. wrence Wolfe USDA -~ Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, I’m over 62 years old and have been a life-long advocate for wilderness and wildlife, having grown up in Oklahoma and lived most of my life in the Northwest and West, near several National Parks and Seashores. I‘m always alert to threats to our great natural, national resources, and it seems like Alaska is bearing a lot of the brunt of these incursions in recent years, according to the news. Therefore, I am writing to express opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corvidor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor tween Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, turther degrading brown bear habitat. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be Long term and signiticant.* (p.S-18) he Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a specien of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula hay encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population, To unnecessarily impact this population is unacceptable and would be nationally significant, due to the ISFWS mandate to protect wildlife on the refuge. I know there is always going to be tension between commercial development and protection and.preservation, but I don’t have to remind you what your most important mandate is, by law-~PROTECTION! Sincerely, burnis e (gene) tuck 8852 n chance ave Fresno, CA 93720 USA 38A 38B 38C 38D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 39A 39B 39C 39D ronment Original Message----~ From: Christopher Lish [(mailto:lishchris@yahoo. com] Sent; Saturday, December 01, 2001 10:55 PM To: lwolfe@rus.usda.gov; robin_west@fwa.gov Ce: George W. Bush; Gale Norton; Ann Venneman Subject: please oppose Enstar route on Kenai Refuge RAR ANON eRe Ree ART ree eO OREN ETA EE AOA ERRE TARE ROORE HEE EAES This E-Mail and or attachments have been scanned for and found free of known viruses. Peeeeee Ceres es eey Dear Mr. Wolfe and Mr. West, 1 am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. ‘The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that ‘the cumulative effects on wildlife, vegetation, recreation, and visual resources...are considered to be long term and significant." (p.S-18) The Enstar route would cut across valuable unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population in considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai xefuge provides large tracts of unroaded lands that are critica] to the long-term viability of this population. To unnecessarily impact this population is unacceptable and would have vast, national repercussions, due to the USFWS mandate to protect wildlife on the refuge, Allowing these Enstar route would violate this mandate and set a terrible precedence, Thank you for taking my views into consideration. 1 look forward to your response. Sincerely, Christopher Lish PO Box 113 Olema, CA 94950 lishchris@yahoo.com 39A 39B 39C 39D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 40A 40B Original Message----- From: Garold Faber (mailto: joygarfaber@ecarth] ink-net] Sent aturday, December 01, 2001 8:18 PM To: Mr. Wolfe Subject: Exclude Enstar route Not Kenai Refuge This £-Mail and or attachments have been scanned for and found free of known viruses. December 1, 2001 Mr. Lawrence volte USDA -- Rural Utilities service 1400 independence Ave., SW -- Stop 1571 ashington, D.C. 20250-1571 Dear Mr. Wolfe, I am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. It is bad coaching to allow football players to drink alcohol before a gaze. It is also bad stewardship to allow encroachment of our wilderness areas by allowing roads to divide them. I am a fourth generation Californian. Needlesa to say my family has witnessed the rapid urbanization of this beautiful area and the exploitation for protit of its resources. I urge you to uphold the stewardship role of your offices and protect this priceless Kanai National wildlife Refuge from the request of the Southern Intertie as it reflects a narrow vision rather than a broad vision of our common good - a vision that includes a committment to our grandchildren and our great great grandchildren, that they may inherit the full resources of this earth that has been given to us to value not to exploit for short term selfish interests. The Kenai Kefuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this proj To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear 1 40A 40B See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 40B cont. 40C 40D vutat. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources .. . are Lconsidered to be long term and significant." (p.S-18) The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. [ The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the LUSFWS mandate to protect wildlife on the refuge. Sincerely, Garold Faber 20011 tomlee Avenue Torrance, CA 90503 USA 40C 40D See response to comment 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 41A 41B 41C 41D -Original Message----- From: Lance McCardle (mailto: lancemccardle@hotmail.com]} Sent: Saturday, December 01, 2001 2:06 PM To: Mr. Wolfe Subject: Oppose Enstar PRR E Rn rR R ANAM RAHA EAR EREDAR REHEAT EE OORT SEER EEO H EES This E-Mail and or attachments have been scanned for and found free of known viruses. RRR ener R REE EEO Ree REE REE EE REAR EEE AEA EAE EERE MEER EM December 1, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, I am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Bush administration is clearly trying to push their anti enviromental agenda at the cost to wildlife and Alaskan peoplec¥s life style. Do the people really need this or are you eating out of the hands of our selfish admidistration? The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project, To forego using either of these viable routes and turther encroach on the Refuge is unacceptable, Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuye is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant.* (p.S-18) The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Sincerely, Lance McCardle 86-A Miller Ave Mill Valley, CA 94941 USA 41A 41B 41C 41D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 42A ~- >> Original Mennage---~- om: VEOMPKINSN@AG].com [iat l Lo: VOMPRINSN@a0l .com) Sent: Saturday, December 01, 2001 2:15 Pu To: Iwolfo@rus.usda.gov Ce: robin_westdtw».gov Subject: Fwd: Fw: ACTION: Kenai Refuge power line; Bitterroot salvage E-Mail and er attachments have been scanned for found freu of known viruses. this is to imform you that we are very concerned about the alaska wilderness and are against any invasion on the unreaded backlands ~ be it utility or oil drilling norma & h. victor tompkins 42A Comment noted. ----- Original Message ---~- : *WwildAlert* <wilderness-alert@alert.wilderness.org> <marhof@ainop.com> Friday, November 30, 2001 5:40 PM Subject: ACTION: Kenai Refuge power line; Bitterroot salvage sale * WILD ALERT * Friday, November 30, 2001 Reena e ene ee neon eeuneansanaae A eee eee n ene eee ene Dear WildAlert Subscriber, Regional issues are topping the news today. Your comments are needed for BOTH items: 1. KENAI NAT‘L WILDLIFE REFUGE: power line proposal would bisect critical habitat. 2. BITTERROOT NATIONAL FOREST: Administration trying to eliminate public participation from largest salvage logging sale ever. RARER Eee e Ee A AERO nae e eens nese newn ee erneeeehasarenns i, POWER LINE THREATENS KENAI REFUGE AND BROWN BEAR HABITAT Alaska’s Kenai National Wildlife Refuge is threatened by 4 proposal to build high-voltage power lines through defacto wilderness from the Kenai Peninsula to Anchorage. ‘The Refuge is known for its world class salmon fishing, brown bear, moose and lynx habitat, and outstanding wilderness recreation opportunities. Your comments on a Draft Environmental Impact Statement are needed by December 5 to help protect this outstanding refuge: http: //waw.wilderness.org/takeaction/?step=2&item=880 the transmission line would cut through the Refuge for more than 38 miles in a 50-toot-wide corridor, scarring the landscape, requiring helicopter use for maintenance, and opening access to these wild, unroaded lands. But two alternative corridors for utility lines *alveady exist.* TAKE ACTION Send your comments to both the US Fish & Wildlife Service and the US Forest Service by December 5th: http: //www.wilderness.org/takeact.ion/2step=2&item=880 Or tell the agencies directly: VVVYVVY¥VYV¥VYVVV¥V¥ VV VV 42B _ See response to 21A — Wilderness Society form letter 42B [7,22 viable alternative utility corridors already exist, including (12/03/01) one provided by the Kenai Refuge when it significantly altering its : western boundary in 1964. 42C - The project is not compatible with the purposes of the Refuge, 42C Refer to the USFWS Compatibility Determination in Appendix because it would impact wildlife habitat and create new access to A of the FEIS these remote areas. oO le 3 “~- The "Enstar* route would cut across valuable, unroaded lands in the ” s 42D | Kenai National Wildlife Refuge, undermining any potential for 42D See response to 21C — Wilderness Society form letter wilderness designation in these areas. (12/03/01) 42E - This project would unnecessarily impact the Kenai Peninsula brown 42E See response to 21D — Wilderness Society form letter bear, declared a species of special concern by the state of Alaska. The unroaded lands of the Refuge are critical to the long term (12/03/01), Ioviability of the bear. Please send your comments to BOTH: Lawrence R. Wolfe, USDA Rural Utilities Service 1400 Independence Ave, SW, Stop 1571 Washington, D.C. 20250-1571 EMAIL: lwolfe@rus.usda.gov AND ‘ Robin West, Refuge Manager Kenai National Wildlife Refuge P,Q. Box 2139, Soldotna, AK 99669 EMAIL: robin_west@fws.gov fax: (907) 262-3599 pene een eeeenenee 2. BITTERROOT: ADMINISTRATION TRYING TO SLAM THE DOOR ON PUBLIC PARTICIPATION The Chief of the Forest Service is working behind the scenes with the Bush Administration to eliminate the public appeals process on the largest timber sale pending in the country -- a proposed 181 million board feet salvage logging timber sale on the Bitterroot National Forest in western Montana. Please contact Forest Service Chief Dale Bosworth and tell him to follow the law and retain the appeals process for the Bitterroot and all other national forest projects: http: //www.wilderness.org/takeact ion/?step=2kitem=883 Ree e eee e eee * BACKGROUND In November 2001, Chief Bosworth asked Mark Rey, the under-secretary of Agriculture who oversees the Forest Service, to co-sign the decision on the Bitterroot. If Rey signs the decision, it would eliminate the opportunity for the 2,500 people and organizations who commented on the timber sale to file any appeals. This salvage logging sale would be the largest in Forest Service history, and allows for more timber to be pulled from the Bitterroot than was taken off the Forest in the last 15 years combined. ‘*But having Rey sign the decision would also set a terrible precedent, potentially allowing the Forest Service to avoid appeals of controversial decisions *anywhere* on our country’s National Forests.** VY VUV VV VV TAKE ACTION Please write Chief Bosworth by December 9 from http: //wew.wilderness.org/takeaction/?step=2h4item=843 and ask him to: Withdraw his request that Agriculture Under~Secretary Mark Rey sign the Record of Decision on the Bitterroot Burn Area Recovery Plan. Not circumvent the Forest Service appeals process. Send your comments to: Forest Service Chief Dale Bosworth c/o Forest Service Northern Region Public and Governmental Relations P.O. Box 7669, Missoula, MT 59807 EMAIL: eme@£s.fed.us FAX: 202-205-8517 see For a full list of Action Items, visit http: //wew.wilderness.org/whatcan/takeaction. htm eee eereeeeey seeeeneee bee PERERA eee A ALLA R eae eee e eae EA AEN EEE P RES Eee Rese eeeee Ene An archive of past WildAlerts can he found at http: //www.wilderness.org/wildalert/wildalerts. htm 2 VVVVVV Ye cadena ERROR RRA RAE R e To make a gift online to The Wilderness Society, click here https://secure-net .com/tws/join.asp seenee Pere cere rer APRA RRR Ree wildAlert is an email action alert system brought to you by The Wilderness Society to keep you apprised of threats to our wildlands in the field and in Washington. wWwildAlert messages include updates along with clear, concise actions you can take to protect America’s last wild places. You are welcome to forward WildAlerts to all those interested in saving America’s wildlands. BRA RRR EERE TERRE REAR ERE FEEDBACK: If you need to get in contact with the owner of the list, {if you have trouble unsubscribing, or have questions about the list itself) send email to <action@tws.org>. TO SUBSCRIBE: If you have been forwarded this message and would like to subscribe to the list, visit http: //www.wilderness.org/forms/subscribe.htm or send a message to wildalert@tws.org with ‘SUBSCRIBE’ in the subject line. V¥VVYVVY VV VV TO UNSUBSCRIBE: Send an email to wilderness-alert@alert .wilderness,org from marhof@ainop,com with the word "remove" in the subject line. vv Or visit the TWS unsubscribe page at: http: //www.wilderness.org/unsubscribe.asp?emai]=marhof@ainop.com Founded in 1935, The Wilderness Society works to protect America‘s wilderness and to develop a nation-wide network of wild lands through public education, scientific analysis and advocacy. Our goal is to ensure that future generations will enjoy the clean air and water, wildlife, beauty and opportunities for recreation and renewal that pristine forests, rivers, deserts and mountains provide. To take action on behalf of wildlands today, visit our website at http: //www.wilderness.org VVVV¥VV¥ VV 43A 43B 43C ~----Original Message-~---~ From: Laurel Stephen Gove and Stuart Higgins [mailtothigginn@idcomm. com} Sent: Saturday, December 01, 2001 2:38 PM ‘vo: Mr. Wolfe Subject: Higgins Family Opposes Enstar route on Kenai Refuge This E-Mail and or attachments have been scanned for and found free of known viruses. ae aaaene December 1, 2001 My. Lawrence Wolfe USDA ~- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1871 Washington, D.C, 20250-1571 Dear Mr. Wolfe, I am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. de live adjacent the Roosevelt N.F. and The Indian Peaks Wilderness area. When living near such wild and beautiful expanses adjacent to a large metropolitan area, we understand what a huge impact new roads and improvements via power lines can have on out wildlife. ease do not build new roads or power line improvements on essential wildlife habitat for threatened species such as, brown bears and lynx, as well as other species that could be affected by these anthoughtful, unessential human need improvements. Especially since: rhe Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create aew access to these remote areas, further degrading brown bear nabitat. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant." (p.s-18) The Enstar route would cut across valuable, unroaded lands in 1 43A 43B 43C Comment noted. See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 43D 43E .e Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Sincerely, Laurel Stephen Gove and Stuart Higgins higgins@idcomm.com 188 Diane ave Rollinsville, CO 80403 Sincerely, Laurel Stephen Gove and Stuart Higgins 188 Diane Ave. Golden, CO 80403 USA 43D 43E See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 44A 44B 44c 44D Original Message From: David Morgan {(mailto:davidmorgan29@hotmail .com) ent: Saturday, December 01, 2001 2:51 PM lwolfe@rus.usda.gov Subjec Kenai NWR Ata teen e eee ee Ree ee eee eee PeeeTeeeTe Terre? This E-Mail and or attachments have been scanned for and found free of known viruses. Lawrence R. Wolfe, USDA Rural Utilities Service 1400 Independence Ave, SW, Stop 1571 Washington, D.C. 20250-1571 Robin West, Refuge Manager Kenai National Wildlife Refuge P.O. Box 2139, Soldotna, AK 99669 Please note, regarding the power line proposal: Two viable alternative utility corridors already exist, including one provided by the Kenai Refuge when it significantly altering its western boundary in 1964. The project is not compatible with the purposes of the Refuge, because it would impact wildlife habitat and create new access to these remote areas. The “Enstar" route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge, undermining any potential for wilderness designation in these areas. This project would unnecessarily impact the Kenai Peninsula brown bear, declared a species of special concern by the state of Alaska. The unroaded lands of the Refuge are critical to the long term viability of the bear. Thanks. David Morgan 826 N Hall St Grangeville, ID 83530 44A 44B 44C 44D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). ----Original Mossage~-- From: Paul Black (mailto: pblack@ner Sent: Sunday, December 02, 2001 8 To: Mr. Wolfe Subject: Oppose Enstar route on Kenai Refuge PUNneAndco. com) 7M This E-Mail and or attachments have been scanned for and found free of known viruses. December 2, 2003 Mr. Lawrence Wolfe USDA Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C, 20250-1571 Dear Mr. Wolfe, I am tiring of continuing to write comments and letters related to the dismal environmental record of this Administration. However. if we all completely tire of doing so then we are not serving our future generations. Man has without doubt been the single greatest cause among 411 animals of environmental change, usually for the wor Although we clearly have a need and desire to continue our race econimcally, politically and socially, it seems that rethinking our use of resources and the environment will be necessary for us to be able to sustain what we have started. vThe sooner we do that the better we can help prepare for the well being of our distant future generations, The U.S. was once the environmental leader of the developed World, but that ie changing due in large part to the actions of this Administration. Some how we need to find a way of measuring the potential benefit to mankind of actions that we take for economic gain so that a complete perspective on the cost-benefits can be obtained. Tt seems that this Administration Looks only at the short term, when a long term vision and analysis is needed. In saying this I recognize that people do not all share the same views, and it's a strength that we don’t. From my perspective, however, IT find that on the face of it, the proposed actions described below for the Kenai appear to be short-sighted, in line with many of this Administration's policies and proposals that affect the environment. The remainder of this message was prepared by the Wilderness 1 45A 45B 45C 45D society. Sincerely, Paul Black I am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown hear habitat. Even the DEIS states that "the cumulative effects on wildlife, vegetation, recreation, and visual resources ... are considered to be long term and significant." (p.S-18) The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Sincerely, Paul Black 2031 Kerr Gulch Road Evergreen, CO 80439 USA 45A 45B 45C 45D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 46A 46B 46C 40D +---- Original Message----- From: Carolyn J. Bishop [mailto:cbishopma@earthlink.net} Sent: Sunday, December 02, 2001 10:15 AM To: Mr. Wolfe Subject: Please preserve the Kenai Refuge Aneune Pee eeee sare) BERRA RARER ERR RE ERER REM ER ERNIE This E-Mail and or attachments have been scanned for and found free of known viruses. eb eetenes wae wheeeee A eetenee December 2, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, We are writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The planned route for the power lines cuts right through the Kenae Refuge. Since there already exists an alternative along the western boundary, this route is unneccessary. The destruction to the refuge from this project would be devastating and totally against the principles of a refuge. lowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that "the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant." (p.S-18) ‘he Enstar route would cut across valuable, unroaded Lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine y potential for wilderness designation in these areas. Protection to Brown bear habitat is vital and would be totally compromised by this project. Please reconsider this route and avoid destruction of the refuge. Sincerely, Carolyn J. Bishop 7 Orchard Street Belmont, MA 02478 USA 460A 46B 46C 46D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 47A 47B 47C 47D 47E <a Original Message-~~-- From: Timothy McGovern [imailto:tmcg99@yahoo.com} Sent: Sunday, December 02, 2001 11:30 PM to: Mr. Wolfe Subject: #1 goal should be to protect wildlife, vegetation, etc. POEvES ST STSTSSSTSOOOUSUSULOCUCOCOOeSTSOSeT SSS Eeerereerere terete! This E-Mail and or attachments have been scanned for and found free of known viruses. PROP e Rete tee a ee eee Rene eee eee ee NR ERAT EEEEN ESE EOE ARH E ACESS December 2, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 washington, D.C. 20250-1571 Dear Mr. Wolfe, As a former resident of Cooper Landing, Alaska, I am writing an opposition to the propesed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. Naving spent countless summer and winter days recreating in and around the Refuge, I feel that I have a real sense of it’s uniqueness. Any further threats to this pristine environment could have a devastating mpact on it’s wildlife, vegetation, and natural splendor. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964, This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. llowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that ‘the cumulative effects on sildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant.* (p.$-18) i J The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlite Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. e Kenai Peninsula brown bear population ia considered an isolated opulation and has been declared a species of special concern oy the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population {s unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. I Fa Sincerely, Timothy McGovern P. QO. Box 1192 Mancos, CO 81328 USA 47A 47B 47C 47D 47E Comments noted. See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 48A 48B 48C 48D Original Message From: ryan carlson fmailto:rycarlson9@hotmail.com) Sent: Monday, December 03, 2001 12:34 pM To: lwolfe@rus.usda.qov Subject: kenai refuge Serer ere re ee ere ere es oe This E-Mail and or attacht ts have been scanned tor and found free of known viruses. eee ee eSE USE SECS OSeCe CC SeSeCeO Sere cee Terese eee Serer ere reer ees Mr. Wolfe, I am writing to you concerning the power line that has been proposed to [Be built through the Kenai National Wildlife Refuge. Please recognize that two viable alternative utility corridors already exist, including the one rovided by the refuge when the western border was altered back in 1964. This project is not compatible with the purposes of the refuge, because it ould impact wildlife habitat and create new access to these remote areas. Yhe “Enstar" route would cut across valuable, roadless areas in the refuge, undermining any potential for wilderness designation in the defacto area. this project would unnecessarily impact the Kenai Peninsula brown bear, declared a species of special concern by the state of Alaska. The roadless lands ot the refuge are critical to the long term viability of the bear. So many impacts are taking effect on most of our nations wild lands, and we shouldn’t impact the areas that have already been protected. It’s imperative that these actions be reduced if we intend to retain any of our wild lands for the future. Thank you. Ryan Carlson your FREE download of MSN Explorer at http://explorer.man,com/intL.asp 48A 48B 48C 48D See response to 21A — Wilderness Society form letter (12/03/01. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01. See response to 21D — Wilderness Society form letter (12/03/01). 49A 49B 49C 49D Original Message----- Fro Susan Brown and Mustafa Top [mailto:siouxzenbee@hotmail.com) Sent: Monday, December 03, 2001 2:18 PM v Mr. Wolfe Subject: Cutting Across the Kenai Refuge PREECE EE ER ERED EERE RNS ER ED EH ERNE ER EAR E RRA E ERAGE This E-Mail and or attachments have been scanned for and found free of known viruses. ere e ee eee reece ere! eee eeeeeerery Danwnenene Anan enene December 3, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -~ Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, I am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. This is completely immoral and unacceptable. The profit of a few should never outweigh the good of preserving this precious resource which belongs to the American People. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that "the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are Leonsidered to be long term and significant.* (p.S-18) The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are cligible for future wilderness designation, and this project would undermine Lany potential for wilderness designation in these areas. 2 Kenai Peninsula brown bear population is considered an isolated vopulation and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term ; viability of this population, To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. "Sincerely, Susan Brown and Mustafa Top 288 Whitmore #128 Oakland, CA 94611 USA 49A 49B 49C 49D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 50A 50B S0C 50D Original Mensage----- From: Cora Mae Sutterlin [mailto Sent: Monday, December 03, 2001 5: Yo: lwolfe@rus.usda.gov Subject: Re: Kenai Refuge power line Sr ps1E juno. com) 9 PM This E-Mail and or attachments have been scanned for and found free of known viruses. To Lawrence R. Wolfe. USDA Rural Utilities Service Re: the proposed Kenai Refuge power line; Two viable alternative utility corridors already exist, including one provided by the Kenai Refuge when it significantly altered its western undary in 1964. The project is not compatible with the purposes of the Refuge, because at would impact wildlife habitat and create new access to these remote areas. The "Enstar" route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge, undermining any potential for wilderness designation in these areas. This project would unnecessarily impact the Kenai Peninsula brown bear. declared a species of special concern by the state of Alaska. ‘The unroaded lands of the Refuge are crit 1 to the long term viability of the bear. cerely, Cora Sutterlin 9 Pebble Brook Lane Belgrade, Mt 59714 SOA 50B 50C 50D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). SIA 51B SIC 51D Original Message: From: Monika Walker [mailto:Monika.Walker@sci.monash.edu.au]} Sent: Monday, December 03, 2001 5:54 PM To: Iwolfe@rus.usda.gov; robin_west@fws.gov Subject: POWER LINE THREATENS KENAI REFUGE ANDB ROWN BEAR HABITAT SRR ERE R REE REET EEE MERRIE This E-Mail and or attachments have been scanned for and found free of knownv iruses. REE R REET EE EER AREER ERE EERE EEE EERE END POWER LINE THREATENS KENAI REFUGE AND BROWN BEAR HABITAT Alaska's Kenai National Wildlife Refuge is threatened by a proposal to build high-voltage power! ines through defacto wilderness from the Kenai Peninsula to Anchorage. The Refuge is known for its world class salmon fishing, brown bear, moose and lynx habitat, and outstanding wilderness recreation opportunities. ‘The transmission line would cut through the Refuge for more than 38 miles in a 50-foot-wide corridor, scarring the landscape, requiring helicopter use for maintenance, and opening access to these wild, unroaded lands. But twou lernative corridors for utility lines *already exist.* - Two viable alternative utility corridors already exist, including one provided by the Kenai Refuge when it significantly altering its yestern boundary in 1964. - The project is not compatible with the purposes of the Refuge,< BR>because it would impact wildlife habitat and create new access to se remote aureus. - The “Enstar” route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge, undermining any potential for wilderness designation in these areas. - This project would unnecessarily impact the Kenai Peninsula brown bear, declared a species of special concern by the state of Alaska. The unroaded lands of the Refuge are critical to the long term viability of the bear. Monika Walker telephone 99055767 External Relations Officer/Curator fax 99054903 School of Geosciences (Department of Earth Sciences) mwalker@mail.carth.monash.edu.au Monash University Melbourne, Victoria 3800 SIA SIB SIC S1D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). Original Message - From: Trudy 5S Gillette [mailtortrfg?juno.com) Sent: Monday, December 03, 2001 8:48 PM To: lwolfe@rus. usda.gov Subject: Power line Proposal ~ Kenai National Refuge This E-Mail and or attachments have been scanned fa: and found free of known viruses. Dear Mr. wolfe, twill keep this mevsage very brief. Please take the following into consideration whon making decisionn regarding the building of power lines in the Kenai Refuge National Reserve. he transmission Line would cut through the Refuge for more than 38 miles in a 50-foot-wide corridor, scarring the landscape, requiring helicopter use for maintenance, and opening access to these wild, unroaded lands. But two alternative corridors for utility Lines ‘already exist. wo viable alternative utility corridors already exist, ineluding © provided by the Kenai Refuge when it significantly altered its tern boundary in 1964, © project is not compatible with the purposes of the Refuge, ecaune it would impact wildlife habitat and create new access to hese remote areas. 52 The “Enatar* route would cut across valuable, unroaded landa in the tenai National wildlife Refuge, undermining any potential for Widerness desi nation in these areas, t tf our responsibility as caretakern of thie planet to preserve ite wildlife and natural beauty, whenever possible, We have alternatives to a plan that would have a major impact on a wilderness area. Please consider these options. Sincerely, Trudy F. Gillette 52A 52B 52C See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). 53A 53B -Original Message- From: Deborah Longman -Marien (mailto:dlongmanmarien@yahoo. Sent: Tuesday, December 04, 2001 11:18 AM To: Mr. Wolfe Subject: Oppose Enstar route on Kenai Refuge This E-Mail and oc attachments have been scanned for and found free of known viruses. December 4, 2001 Mr. Lawrence Wolfe USDA Rural Utilities service 1400 Independence ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, t am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corridor tor transportation and utility needa by significantly altering {ts western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge {#8 unacceptable. T as a birdwatcher, when I travel L want to know that there is wilderness there around me being protected. 1 care that the habitat is being protected for future generations. I don’t like spending my tourist dollars in states that don‘t care to protect what they have. T have net been hearing very good things coming out of Alaska lately. Tt does not make me want to travel to Alaska anytime goon to spend my money, unless people up there clean up their act about their environment instead of corporations like oil companies and power companies run amok. 1 respectfully ask that people in Alaska and Washington start thinking about the future instead of immediate greed. Please consider that I vote and invest according to what care I see is being taken with environment. Companies and agencies that do damage to the enviroment go on my boycott List. 53A 53B See response to 21A — Wilderness Society form letter (12/03/01). Comment noted. 33€ 53D 53E Allowing the Southern Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that "the cumulative effects on wildlife, vegetation, recreation, and visual resources .,. . are sonsidered to be long term and significant." (p.S-18) the Kenai National Wildlife Refuge. These unroaded areas are eligible ES Enstar route would cut across valuable, unroaded lands in for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Thank you for considering the opinions of an American who would like as much as Alaska preserved as possible for the people, not greedy corporations, Sincerely, Deborah Longman-Marien 9 Collins Street Newburyport, MA 01950 USA 53C 53D 53E Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). S4A 54B 54C 54D -Original Message-~--- From: Flying Popcorn Ranch (mailto: birdfrog@blackfoot .net) ‘SPM Sent: Tuesday, December 04, 2001 12: To: ‘lwolfe@rus.usda.gov' Ce: trobin_west@fiws.gov’ Subject: Kenai Refuge power Line errr Terres sate wennnae paw ennee This E-Mail and or attachments have been scanned for and tound free of known viruses. eee ee ree eee Peer ere ee errr rr creer rere rete terrier rere Teer) Dear Folks, I am writing to ask you to reconsider the route taken by the proposed Qwerline for the following reasons: Two viable alternative utility corridors already exist, including one provided by the Kenai Refuge when it significantly altered its western boundary in 1964. - The project is not compatible with the purposes of the Refuge, because it would impact wildlife habitat and create new access to these remote areas. National Wildlife Refuge, undermining any potential for wilderness - The “Enstar" route would cut across valuable, unroaded lands in the Kenai signation in these areas. ~ This project would unnecessarily impact the Kenai Peninsula brown bear, declared a species of special concern by the state of Alaska. The unroaded lands of the Refuge are critical to the long term viability of the bear. Thank-you for your thoughtful consideration. Sincerely, Brian Parks Hwy 83 south Swan Lake, MT $9911 406-754-2461 birdfrog@blackfoot .net S4A 54B 54C 54D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). SSA 55B 55C -----| Original Message----~- From: Heidi Blankenship (mailto:heidi_b55@hotmail.com) Sent: Tuesday, December 04, 2001 12:59 PM To: Mr. Wolfe Subject: Opposition to the powerline on Kenai Refuge TERENCE REA e eRe REAR AERATOR EERE O NESE RE EEE RRO A ERA EEE This E-Mail and or attachments have been scanned for and found free of known viruses. PPR eRe R ARORA ARPA O AREER TEETH REDE E AGHA H EEE EATER TREO EES December 4, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, T am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The already existing transportation corridor (along the western boundary) and the powerline corridor between Anchorage and the Kenai Peninsula is a more legititmate alternative for this project. The Enstar proposal is not compatible with the purposes of the Refuge as it would further encroach on valuable wildlife habitat and give more access to remote areas sporting some of the more pristine wilderness we have left in the U.S. Certainly, as the DEIS states, "the cumulative effects on wildlife, vegetation, recreation, and visual resources...are considered long term and significant" and should therefore be completely unacceptable. ie refuge should remain just that...a place where brown bears can live and roam free in large tracts of landscape that are unscathed by cross cuts of roads for a ridiculous powerline. These lands are critical to their survival. Please use already existing routes for the Enstar line. Please stand up to companies who threaten to impact the habitat of our wildlife in wildlands that have been set aside for the protection of our wildlife. I guess I'm just asking you to do your job. Please. Keep the Kenai a refuge for bears rather than a haven for powerlines. ‘Thank you. Sincerely, Heidi Blankenship 112 1/2 South Avenue East Missoula, MT 59801 USA S55A 55B 55C See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. Comment noted. 56A SOB ~++»-Original Message---~- From: Terry B (mailto: terry@apex2000.net) Sent: Tuesday, December 04, 2001 11:52 PM Lawrence R. Wolfe Subject: Kenai National Wildlife Refuge This E-Mail and or attachments have been scanned for and found free of known viruses. ertece cece ce cece eres e Tee eee eee SCC eS eCe CeCe ect Cee Seer eS SS Ter SCS Dear Mr. Wolfe: I urge you to not allow a electric utility transmission lines to be built in a new 50 foot wide, 38 mile long corridor through the KNWR. I almost visited the refuge two years ago, after an earlier trip to SE Alaska, and still hope to see some of tha abundant wildlife and wilderness habitat in the KNWR. I do not believe high power transmission Lines are compatible with the intent and purpose of the refuge, and would cut open remote de facto wilderness areas to further vehicular and other intrusion, degrading wildlife and habitat, and preventing possible wilderness designation for this area. Two alternate utility corridors already exist, and the "Enstar" route should not be allowed to damage KNWR. Sincerely, Terry R. Burns, M.D, 4009 Fox Hollow CT Midland, TX 79707 56A S6B Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See also response to 21C — Wilderness Society form letter (12/03/01). See response to 21A — Wilderness Society form letter (12/03/01). STA 57B S7C Original Message-~ From: Lorraine Streckfus [mailto:streckfuslé@peiays.net) Sent: Wednesday, December 0%, 2001 11:44 AM To: robin_wesvéfws.gov Ce: lwolfe@rus.usda.gov Subject: Deny proposed Enstar route for the Southern Intervie This #-Mail and or attachments have been scanned for and found free of known viruses. Mr. Robin West, Refuge Manager Kenal National Wildlife Refuge and Lawrence R, Wolfe usDA Rural Utilities: Service Mr. West and Mr. Wolfe: I would like to submit for your consideration my opinion on the proposed route for the Southern Intertie through the Kenai National Wildlife Refuge known an the Enstar route. I understand that thia transmission line would cut a $0-foot-wide corridor for 38 miles through the Refuge. The scarring and impacts of helicopter maintenance that would be required are completely unacceptable. I suggest that the electric associations consider one of two existing alternatives--the corridor tor transportation and utility needs along the utern boundary of the Refuge and an existing power line corridor. I believe the Bastar route would impact wildlife habitat and create new access to these remote arean, turther degrading brown bear habitat and ving deleterious effects on the brown bear which has been declared a species of special concern by the state of Alaska, ft would also cut across valuable, unroaded iands in the Kenai National Wildlife Refuge, undermining any potential for wilderness designation in these areas. vhank you for your time and consideration of my comments. Lorraine Streckfus 1908 N. Cascade Ave. 46 Colorado Springs, CO 80907-6769 atreckfuslOpe isys net STA 57B 57C See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). S8A 58B 58C Original Hesnage-~--- ne Strecktup (wailtoratreckfu rdnesday, December 05, 2001 6:19 PM lwolfe@rus.usda.gov robin wenté twit .gov Subject: Daniel Brendle comments: Deny proposed Enstar route for the Southerntntertic l@peiny: This E-Mail and or attachments have been scanned for and found free of known viruses. Lawrence R. Wolfe UsDA Rural Utilities Service r. Robin West. Refuge Manager Kenai National wildlife Refuge Mr. Wolfe and Mr. West: T would like ta sutmit my comments in opposition to the proposed route for o Southern Intertie through the Kenai National Wildlife Refuge known as e "Enstar rou cause installation of this transmission line would te a 50-foot-wide corridor for 38 miley through the Refuge and it would preclude future wilderness designation for this portion of the refuge, the Corridors that have been previously designated should be used. These corridors are the one accommodated by the adjustment of the western boundary of the refuge that was done in 1964 and the other in the exiating power Line corridor between Anchorage and the Kenai Peninaula. th The Enstar coute would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat and having deleterious effects on the brown bear which has been declared a species of wpecial concern by the state of Alaska. Thank you for consider ng my comme Daniel Brendale 816 North Weber Street, Apt. 1 Colorado Springs. CO 80903 (719) 632-7353 S8A 58B 58C See response to 21C — Wilderness Society form letter (12/03/01). See response to 21A — Wilderness Society form letter (12/03/01). See response to 21C and 21D — Wilderness Society form letter (12/03/01). S9A 59B 59C 59D -++--Original Message----- From: lisa oakes (mallto:loakes@san.tr,com) Sent; Sunday, December 09, 2001 2:08 PM To: robin_west@fws.gov; Iwolfe@rus.usda.gov Subject: Opposition to Proposed Kenai Refuge Powerlines ETE RE RRR ERE EERE EERE TERRE REE EERE ER ERE E REE EERE This E-Mail and or attachments have been scanned for and found free of known viruses. Pere eee Se TCP CCST eC Se eee eee ee eee T eit eee ee rire eee eee ete tee Docernbor 9, 2001 Mr, Robie Wast Rotuge Manager Konal National Widhte Refuge P.0. Box 2139 Soldotna, AK 99669 Me, Lawrence Wolfe USDA -- Rural Uvties Service 1400 independence Ave., SW ~ Stop 1571 Washington, 0.C. 20250-1571 Dear Mr. Wolle and Me, West, 1am writing In opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corridor fort ransportation and utility needs by significantly altering its westem boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the vai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertie to bisect the northern portion of the Kenal Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildiife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that "the cumulative effects on wildlife, etation, recreation, and visual resources .. . are considered to be long term and significant." (p.S-18) The Enstar route would cut across valuable, unroaded lands In the Kenai National Wildlife Refuge, These unroaded areas are eligible for future wildarness designation, and this project would underrnine any potential for wilderness designation in these areas. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern by the state of Alaska. Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Retuge provides large tracts of unroaded lands that are critical fo the long term viability of this population. To unnecessarily impact this population is unacceptable and would be nationally significant, due to the USFWS mandate to protect wildlife on the refuge. Sincerely, James D, Oakes 12844 Oaktield Way Poway, CA 92064 S9A 59B 59C 59D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). INDIVIDUALS 60A seen Original Message----- From: meljo (mailto:meljo@gci.net] Sent: Tuesday, November 13, 2001 11:59 AM To: Wolfe, Larry -RUS Ce: cliff@akcenter.org Subject: Southern Intertie This E-Mail and or attachments have been scanned for and tound free of known viruses. Sir, We are writing this letter to express our concern over the proposed Intertio between the Kenai and Anchorage. We understand the proferred route tor the project runs through the Kenai National Wildlife Refuge and also crosses Cook Inlet. Both of these factors send us warning signals. We have got to preserve the Wildlife Reluge with a minamal amount of man madod isruptions. Our State has got to protect the resourses we have which are our wildlife for all uses. What makes thi: ite what it is is slowly being eaten away by one project and another. We understand there are other routs availabe, especially the Quartz Creek route, that will have much less impact ‘on thei nviorment. Please protect our State and the Kenai Retuge for all people to benifit rom for now and future generations. Make the utility use the Quartz Creek route, which we don't understand why it isn't the preferedr oute anyway. Met and Joanne Ackerman 60A Comment noted. The Quartz Creek Route does not meet the purpose and need for the Project. See DEIS Section 2.2.2, Transmission Options, Quartz Creek Transmission Corridor (pg. 2-8 to 2-19). 61A 6lB 61C Original Message~ ~~~ From: Stockton, Blaine -RUS Sent: Tuesday, November 13, 2001 8:04 AM Yo: Wolfe, Larry -RUS; Moerman, Rose -RUS; Price, Sally -RUS; Jenkins, Brian ~RUS Subject: FW: Kenai Peninsula Electric Intertie ~ Alaska FYI, Blaine -Origina! Message From: Carol Jensen [inailto:cjensen®pobox.alaska.net] Sent: Sunday, November 11, 2001 7:28 PM To: butockto@rus.usda.gov Subject: Kenai Peninsula Electric Intertie - Alaska This E-Mail and or attachments have been scanned for and found free of known viruses. Stockton: Please pass my comments to the proper authorities on this matter (it you are not the correct person to contact). There is a Sr. Environmental Protection Specialist, Lawrence Wolfe who should also receive these comments, but I don’t know what agency he is with. I strongly oppose the Enstar route which would cut through the fragile ecosystem of the Kenai Wildlife Refuge. The activity associated with the clearing and construction of this line, the on-going maintenance and its very presence would have a very negative impact on wildlife that is already stressed in that area due to development, hunting, trapping, fishing and other “recreational” human activities. the increased acco! this route would allow humans would further negatively impact ldlite. The bear population would be particularly disturbed by the further fragmentation chis route would cause, The E1S describes the route’s potential effect on wildlife ‘to be long term and significant". The bear population is already plummeting in this area, and needs full protection. This alone should be enough to kill the route, especially when there are other routes available (the *Tesoro* te, amony others). The utility companies are going for the cheapest route, without regard Lo the preferences of most Alaskans, which is to protect our wildlife and wildlite habit 1 61A 61B 61C The DEIS acknowledges that the proposed project could result in increased access and conflicts with wildlife and management plans (see DEIS pg. 3-143). Impacts to brown bears are acknowledged in the DEIS. See FEIS Section 2.2.6 (pgs. 2-18 to 2-19) for more information on Kenai Peninsula brown bears. Comment noted. Please see DEIS Section 3.7.3, Rate Impacts from the Project (pg. 3-189). 61C cont. 61D eneapest route will not bring the cheapest rates to the utility customers. Our electric company has been getting hefty rate increases with more to come for the past few years, especially this year. They are not interested in “cheap electricity" for the consumer. They are only interested in ways to cut their own costs and make their profits, salaries and perks larger. Energy conservation, efficiency, and alternative sources are but a few of the suggested alternatives to building this route that will have such a long term negative impact on our dwindling wildlife. I urge you and all the agencies involved to deny the Enstar route and research alternatives that do not impact the wildlife and their already diminishing habitat. Thank you. Carol Jensen 4800 East 112th Avenue Anchorage, AK 99516 61D These other alternatives do not meet the purpose and need for the Project, as explained in DEIS Section 2.2.1, Alternatives to a Transmission Option (pg. 2-1). See also the General Response to Issue 1 (pgs. 1-3 to 1-4) and Issue 14 (pgs 1-8 to 1-9) in Chapter 1 of the FEIS regarding adequacy of alternatives analysis. : 62A 63A --Original Message From: Frank Norris {mailto:ctnorrindalaska net) Sent: Wednesday, November 14, 2001 2:23 AM To: iwolfe@rus.usda.gov Subject: Southern Intertie Project - Comment. This K-Mail and or attachments have been scanned for and found {ree of known viruses. bbe eee ee ner ereneeeees Dear Mr. Wolfe, I'm writing to protest the Chugach Electric’s preferred utility line between Kenai and Anchorage. This line, ax you know, would go through the Kenai Nacional Wildlife Refuge, a world-renowned refuge that was established way back in 1941 to protect moose and other nationally-significant wildlife. T am not opposed to this line per se, but it seems absolutely unnecessary to route this line through this untramneled refuge when it would be just as logical to have the intertie follow an existing utility-development corridor -- i.e., along the Cook Inlet coastline, where a Tesoro gas Line currently exists. 1 urge you to reconsider the Utility's preferred route, Instead, the proposed intertie right-of-way should be either moved over to the coast or scrapped altogether, Sincerely, Frank Norris Anchorage -----Original Message----- From: michael. funke@cexp.com [mailco:michael. funke@cexp.com) Sent: Monday, November 19, 2001 6:16 PM To: lwolfe@rus.usda.gov Subject: Southern Intertie PREPARE RENAN EEE E EERE ORO OEP OO RETR TERE EMEEES SOOO EEO HERES This E-Mail and or attachments have anned for and found free of known viruses. Poe PPee OO OVeCe Serre rere reer r iter rete e rere rer eer errr rere er etre ress Sr. Environmental Protection Specialist Lawrence R. Wolfe 1400 Independence Ave. SW, Stop 1571 Washington, DC 202250-157 Dear Sr. Environmental Protection Specialist Lawrence R. Wolfe, i have been hearing about Chugach Electric’ run an electrical intertie to the Kenai Pe 1 think the proposed Enstar Route is a bad idea. The impact to the Kenai NWR and the wildlife on the Kenai Peninsula I believe would be too great. 1 guide trips in this part of the Kenai, and this type of development would impact the wildlife and scenery that my business depends on. thanks for considering ty comments. PLeas try to find an alternative to the Enstar Route. Sincerely, Michael Funke 8660 Barney Circle Anchorage, Alaska 99507 62A Comment noted. See FEIS Summary Section S.10, Agency Preferences and Decisions to be Made. See also response to comment IF — EPA letter (12/05/01). 63A Comment noted. Impacts to tourism and recreation are addressed on pg. 3-184 and 3-185 of the DEIS. See also the General Response to Issue 4 (pg. 1-5) in the FEIS. Theodore N. Bailey 30915 Hakala Drive Soldotna, AK 99669 907-262-5129 November 27, 2001 Lawrence R. Wolfe Senior Environmental Protection Specialist SDA, Rural Utilities Service Engincering and Environmental Staff, Room 2240 1400 Independence Ave, SW, Stop 1571 Washington, DC 20250-1571 Lawrence R. Wolfe: Enclosed are my comments on the Draft Environmental linpact Statement for the Southern Intertie Project in south central Alaska. My comments are pertinent to the Kenai Peninsula portion of the proposal and are based on my professional experience employed as a supervisory fish and wildlife biologist on the Kenai Nauonal Wildlife Refuge for the past 24 years (1977-2001) before retiring this past June, These comments therefore are my personal comments. First. there are several sections within the DEIS that should be updated or revised to reflect new, changing. or erroneous information or conditions since completion of the original draft: 64A 1) Table 3.3 - Page 3-36: As shown in the first row of information in the table, marten (misspelled “mastin”), are extremely uncommon to rare in the project study area, Because marten are known to occur only ina limited portion of the refuge, they should be removed from the table lest readers of the document gain the impression that marten are common on the Kenai National Wildlife Refuge or on the northwestern portion of the Kenai Peninsula. 2) Table 3.3 - Page 3-36: Nomenclature for shrews. The Arctie shrew does not occur on the Kenai Peninsula. The pigmy shrew and common shrew do. Shrew names have changed recently and their correct common and scientific names should be reflected in the text and tables for accuracy and credibility. 3) Page 3-57, Table 3-7, Small Mammals: Collared pikas and Arcti¢ ground squirrels should be removed trom the sentence and table because they are not known to occur within the project study area on the Kenai Peninsula, the Kenai National Wildlife Refuge, and possibly the Kenai Peninsula. 4) Page 3-59, Canada Lynx: The lynx is no longer a candidate species but was off a threatened species in the contiguous United States by the U.S. Fish and Wildlife March 24, 2000. 5) Page 3-59, Canada Lynx: Qualify the statement about a depressed lynx population on the KNWR to say depressed in the 19808. Closure of the lynx seasons from the mid- 1980's to the mid-1990's on the Kenai Peninsula presumably allowed the lynx population to recover to atl but cyclic levels by the mid- 1990's, ) F 3-61 to 3-62, Brown Bears: Additional and new information obtained on brown bears on the Kenai Peninsula was summarized by the [BBST in 1999 and 2000 and included in a report by a governor appointed task force of recommendations to conserve brown bears on the Kenai Peninsula, ‘This new and additional information on brown bears should be updated and included in the DEIS text. 7) Pages 3-65 to 3-68, Birds: This section should emphasize that power lines constructed along the proposed Enstar Route pose « greater threat (than the Tesoro Route) to trumpeter swans because they are the largest-bodied bird using the project area, Large bodied birds are more 64B 64C ly declared Service on 64D 64E 64F 64G 64A 64B 64C 64D 64E 64F 64G Noted and corrected in FEIS Chapter 2, Section 2.3 (pg. 2-35). Noted and corrected in FEIS Chapter 2, Section 2.3 (pg. 2-35). Noted and corrected in FEIS Chapter 2, Section 2.3 (pg. 2-35). Noted and corrected in FEIS Chapter 2, Section 2.3 (pg 2-35). Noted and corrected in FEIS Chapter 2, Section 2.3 (pg. 2-35). Refer to FEIS, Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines (pgs. 2-18 to 2-19). Noted and corrected in FEIS Chapter 2, Section 2.3 (pg. 2-35). 64G 64H 641 64) 64K 64L 64M susceptible than small birds to power line collisions. Power lines along the proposed Enstar Route are a greater threat to trumpeter swans because of the documented trumpeter swan staging areas at the lower Moose River and Watson Lake and their known migratory route that passes through the Chickaloon Flats. 8) Pages 3-68 tw 3-70, Brown Bears: This section should reflect the recommendations of a governor appointed task force which are contained in a recent report outlining recommended strategies to conserve brown bears on the Kenai Peninsula 9) Page 3-71: Add that hunting and trapping also appear to be the main cause of mortality among adult lynx on the KNWR (Bailey et al. 1986) and that trapping along the edge of a cleared power line right-of-way might increase trapping mortality as lynx move along the edge. {tis questionable that the clearing of the power line right-of-way would have any short-term or long-term benefits to snowshoe hares «ind therefore lynx. This is because hares are reluctant to colonize areas with little protective cover from predators - protective cover that would be absent after clearing then periodically removed to protect the power lines. In faster-tree- growing-areas of the southern boreal forest (Quebec), hares avoided clear-cut areas (=similar to power line right-of-ways) for at least 10 years (Bellefeuille et al. 2000, Potvin et al. 1999), It was also concluded that it may take 30 years for hares to increase to peak densities in that environment (Ferron ct al, 1998), That observation is supported by similar observations on the Kenai P ula. It took over 20 years for snowshoe hares to reach substantial population levels in the extensive 1969 burn on the refuge. Habitat structure is highly important to hares and a minimum lateral cover of 70% is recommended for suitable hare habitat (Litvaitis et al. 1985) - a value unlikely to be found in a power line right-of-way. And itis likely that the power line right-of-way would be cleared at least once, if not twice or more, in 20 years thus periodically removing any protective cover for hares. 10) Page 3-74, Canada lynx: Stated benefits to snowshoe hares are probably inappropriate. See above comments. 1) Page 3-89, Trumpeter swan: Should emphasize a potential power line along this route to haye more impacts on (rumpeter swans than the Tesoro Route because of a known |__ area (Watson Lake) and migration route (Chickaloon Flats) near the proposed power line, 12) Page 3-90 to 3-91, Canada lyn: ection and others on lynx habitat fails to portray the dynamics of boreal forest ecosystems. Although much of the current lynx habitat along the proposed Enstar Route is currently low quality lynx habitat, that could be changed overnight if a large wildlife was allowed to burn through the area of if prescribed burns were used in the same areas to reset forest succession. Neither of these two options is likely if a power line is constructed along Enstar Route because any and all fires would have to be extinguished to protect the power line. In other words, if a power line is built through the proposed Enstar Route area on the refuge, that action seals the fate of the forest in that region for the next 50+ There would be little chance for modification of the forest using fire and of the forest retur ning to an earlier successional stage and higher-quality habitat for hares, moose and other wildlife. 13) Page 3-89 to 3-92: A species nat discussed in the DIES text is the wolverine. For unknown reasons, wolverines are extremely scarce in the lowlands of the northwestern Kenai Peninsula including the northwestern, lowland portion of the Kenai National Wildlife Refuge. If the Enstar Route is selected, dispersing or exploratory-moving and potentially colonizing wolverine moving west from mountainous habitat to the east would have to cross the power line right-of-way to colonize the lowlands. Many of the wolverines trapped on the northern ikely ng, refuge in the past have been caught along the Enstar gas pipeline access road. Increased trapping pressure (related to improved access and increased wolverine track visibility) along, the power line right-of-way could further increase mortality of wolverines and thereby further reduce the survival rate of potential lowland-colonizing wolverines. 14) Pa paragraph: The numbers cited for some anadromous fish returns into the Chickaloon River appear high and in error, especially for king salmon and Dolly Varden. Correct the data and cite up-to-date references. 64H 641 643 64K 64L 64M 64N See response to comment 64F (above). Noted and corrected in FEIS Chapter 2, Section 2.3 (pgs. 2-35 to 2-36). See response to comment 641 (above). Noted and corrected in FEIS, Chapter 2, Section 2.3 (pg. 2-35). The DEIS acknowledges that the proposed project would conflict with fire management plans (pg. 3-143). Comment noted. Information on wolverines has been added to FEIS Chapter 2, Section 2.2.6, Update on Kenai Peninsula Brown Bear (pgs. 2-19 to 2-20). Noted and corrected in FEIS Chapter 2, Section 2.3 (pg. 2-36). 15) Pages 3-105 to 3-112; Although one can extract the environmental implications from various portions of the text and tables, it should be emphasized to the readers that the proposed Tesoro 640 Route crosses only 4 anadromous fish streams (in developed habitat), only one of which is. known to support significant numbers of salmon (Swanson River). In contrast, the proposed Enstar Route crosses 8 anadromous fish streams (in undeveloped habitat) of which at least four (Mystery Creek, Chickaloon River, Big Indian Creek and Little Indian Creek) support significant numbers of salmon AND are the known prime feeding areas of brown bears on the northern Kenai National Wildlife Refuge and northwestern Kenai Peninsula. Second, it is evident from the DEIS, especially in the Cumulative Impact Analysis Section 3.12 and Tables. 3-37 and 3-38, that the most environmentally damaging alternative route is the Enstar Route across the Kenai National Wildlife Refuge. This is specifically spelled out on page 3-320, which states "Significant unavoidable adverse impacts are expected for biology, land use and recreation, and visual resources on the KNWR. Biological impacts on the KNWR would be considered both regionally and nationally significant.” Construction of a power line along the Tesoro Route would be less damaging to the environment and should be the final selected route for these reasons: 1) The Tesoro Route is the least environmentally damaging route. According to Table 3-37, only 64P five resources would be impacted (one significantly) by the Tesoro Route compared to nine (four significantly) for the Enstar Route. ir Route would significantly jeopardize the purposes for which the Kenai National Wildlife Refuge was established and would therefore be incompatible with the purposes of the refuge. 2) Over 30 years ago (1964) and in anticipation of future development on the Kenai Peninsula, the northwestern boundary of the Kenai National Wildlife Refuge was withdrawn from the 64Q coast to allow for future utility and transportation corridors, ‘This region is now outside the boundary of the refuge and includes the proposed Tesoro Route. The final selected route should therefore be the Tesoro Route in order to fulfil ane of the intended purposes of the refuge boundary adjustment. 3) The land along the proposed Tesoro Route has already been partially developed (borough and 64R private land, cabins, roads, pipelines) and will continue to be developed in the future, regardless of the route selected for the Southern Intertie. It is therefore rational and prudent to confine as many future development-related activities to this area as possible instead of spreading future development into relatively pristine and undisturbed habitats critical to many species of fish and wildlife on the Kenai National Wildlife Refuge and Kenai Peninsula (the Enstar Route). 4) Misa relatively simple exercise to calculate the monetary costs and benefits of the power line route alternatives. It is much more difficult and complex to ealculate the economic and other 64S values of current and future fisheries and wildlife resources, recreational opportunities, scenic values, etc. and to contrast those values to the costs and benefits of the power line. And despite the statement that the life of the proposed project is only $0 years, itis highly unlikely that the power line would be dismantled after $0 years. [tis more realistic that the power line will remain forever and would eventually be upgraded. The cost of the project in lost resource values would therefore extend well beyond the stated 50-year period. Finally, not all values important to humans can be expressed monetarily and it is these non-monetary resource, scenic and wildland values that will become more important to Alaskans and others in the future, ‘Thank you for the opportunity fo comment on this Draft Environmental Impact Statement. In addition to this e-mail, you will also receive a hard copy of this letter postmarked before December 5. Sincerely, Theodore N. Bailey. Ph.D. Fish and Wildlife Biologist (Retired) 640 64P 64Q 64R 64S Comment noted. Comment noted. See FEIS Summary Section S.10, Agency Preferences and Decisions to be Made (pg. S-26), and response to comment IF — EPA letters (12/05/01). See response to 21A — Wilderness Society form letter (12/03/01). Comment noted. Existing and future land use along the Tesoro Route is described on pgs. 3-135 and 3-136 of the DEIS, and was considered in the assessment. See FEIS Chapter 2, Section 2.2.7, Environmental Cost-Benefit Analysis Summary (pgs. 2-21 to 2-32) for additional information on cost/benefit analysis. Bellefeuille, S. de, L. Belanger, J. Huot and A. Cimon, 2001. Clear-cutting and regeneration in Quebec boreal balsam fir forest: effects on snowshoe hare. Canadian Journal of Forest Research 31 (1): 41-51 Ferron, J., F. Potvin, and C, Dussault. 1998. Short-term effects of logging on snowshoe hares in the boreal forest. Canadian Journal of Forest Research 28 (9): 1335-1343. Litvaitis, J.A., J.A. Sherburne, and J.A. Bissonette. 1985. Influence of understory characteristics on snowshoe hare habitat use and density. Journal of Wildlife Management 49: 866-873. Potvin, F. R. Courtois and L.. Belanger. 1999, Short-term response of wildlife to clear-cutting in Quebec boreal forest: multiscale effects and management implications. Canadian Journal of Forest Research 29 (7): 1120-1127 65A 65B ‘Subject: FW: High voltage power lines in Kenai FREER EE EHR ERNE EE ERE RHR EE ERR ERERA EERE This E-Mail and or attachments have been scanned for and found free of known viruses. AREER R EERE EEE TERRA EE EERE HEED DEERE EEE EEE -----Original Message: From: Joey Lee [mailto:8j!13@qlink.queensu.ca} Sent: Saturday, December 01, 2001 2:39 PM To: robin_west@fws.gov; lwolfe@rus.usda.gov Subject: High voltage power lines in Kenai eee ee eee eee eee ee eee eee eee ee ee eee ee eee eee eee ee ee ees This E-Mail and or attachments have been scanned for and found free of known viruses. RRR RRR eR EE ERR RRR RH ERO R ERE EERE EE Tam writing this letter to voice my concerns about the proposal to build high-voltage power lines through the wildemess area from the Kenai Peninsula to Anchorage. The project is absolutely incompatible with the purposes of theKenai Refuge. A high ve ¢ power line project will impact wildlife habitat and create new access to these remote ai Furthermore, | am astounded that this project is even being considered, given that two viable alternative utility corridors already exist, including oncp rovided by the Kenai Refuge in 1964. The “Enstar” route would cut across valuable, unroaded lands in theKenai National Wildlife Refuge. undermining any potential forwildemess designation in these areas. Please stop this project. Joey Lee 65A 65B Comment noted. See USFWS Compatibility Determination in Appendix A of the FEIS. Also refer to DEIS Chapter 2 Section 2.2, Alternatives Studied and Eliminated from Detailed Study, and Section 2.3, Alternatives Studied in Detail. The DEIS acknowledges that the Enstar Route would conflict with management plans and could prohibit future wilderness designation (pg. 3-143). See also response to 21A — Wilderness Society form letter (12/03/01). 66A 66B 66C 66D -Original Message----- From: Don Hagey [mailto:d.hagey@att.net] Sent: Friday, November 30, 2001 5:39 PM To: Mr. Wolfe Subject: I Support Enstar route on Kenai Refuge eeenee abeee wane PoeUETESESUSESOSOSSSSSSI OST. This E-Mail and or attachments have been scanned for and found free of known viruses, ORR senaee weeeenee weneee November 30, 200! Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C, 20250-1571 Dear Mr. Wolfe, 1 am writing in support of the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Retuge is acceptable. Allowing the Southern Intertie to bisect the northern portion ot the Kenai Refuge is compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas, further degrading brown bear habitat. Even the DEIS states that "the cumulative effects on wildlife, vegetation, recreation, and visual resources . . . are considered to be long term and significant." (p.S-18) This is more than acceptable. The Enstar route would cut across valuable, unroaded lands in the Kenai National Wildlife Refuge. These unroaded areas are eligible for future wilderness designation, and this project would undermine any potential for wilderness designation in these areas. This refuge needs roads cut into it so disabled people like me can scess their beauty. The Kenai Peninsula brown bear population is considered an isolated population and has been declared a species of special concern , the state of Alaska, Development elsewhere on the Kenai Peninsula has encroached on brown bear habitat, and the Kenai Refuge provides large tracts of unroaded lands that are critical to the long term viability of this population. ‘The amount of traffic that would use the roads is negligable, let‘s do it! Sincerely, Don Hagey 3518 235th St E Spanaway, WA 98387 USA 66A 66B 66C 66D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). Original Message--~--~ From: Karl Frederick [mailto:kwf{@mindspring.com) Sent: Friday, November 30, 2001 6:24 PM T Mr. Wolfe Subject: Oppose Enstar route on Kenai Refuge error eee eee eee eee eee eee reer reer ere reer ieee ee eee reer eee re eres This E-Mail and or attachments have been scanned for and found free of known viruses. SERRE EERE EAE RR RE ERE ERE EE REREAD ARASH ERE E RHA ARE November 30, 2001 Mr. Lawrence Wolfe USDA Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, I am opposed to the proposed Enstar route for the Southern Intertie 67A = the Kenai National Wildlife Refuge. 67A Comment noted. Please reconsider your path of action. Sincerely. Karl Frederick 9001 Bennett Valley Rd Glen Ellen, CA 95442 USA -----Original Message Ron Sutherland (mailto: rwautherland@students.wise.edu) Sent: Friday, November 30, 2001 7:03 PM To: Mr. Wolfe Subject: Don‘t route powerline through NWR! SR ene eee eRe Eee EEA TERRA READ HERE REE REE E This E-Mail and or attachments have been scanned for and found free of known viruses. Whee eee eee ee Ue eee See e eee cere e eee e Sree eee rere eer re rr errr rs. November 30, 2001 Mc. Lawrence Wolte USDA -- Rural utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, 1 hope to visit Alaska‘s National Wildlife Refuges some day, and trust that in the meantime you will take every action possible to keep them from being overrun with powerlines and logging roads. Specifically, T am writing in opposition to the proposed Enstar 68A Comment noted. See response to comment 21A — Wilderness route for the Southern Intertie on the Kenai National Wildlife Society form letter (12/03/01). G8A | xeruge. By al) accounts, there are perfectly feasible routes in already existing corridors in the area- why must you ruin the aesthetics and natural value of yet another park in favor of ugly rastructure? 68B | wave you considered the alternative of curtailing growth in 68B Comment noted. electricity use? 2000 scientists agree that global warming is going to cause huge problems, and yet every local government always insists on the unavoidability of growing demand for energy. Thanks for your wise decisions. Sincerely, Ron Sutherland 207 Eagle Heights Apt G Madison, WI 53705 USA 69A 69B 70A Original Message- --- : EBERSOCATS@cs.com [mailto: EBERSOCATS@cs . corn) : Friday, November 30, 2001 7:05 PM To: lwolfe@rus.usda.gov Ce: robin_west@fws.goyv Subject: Kenai National Wildlite Reserve This E-Mail and or attachments have been scanned for and found free of known viruses, PERRET eRe Rae eee ERED EA aR EE wenenane TRE REE ERNE MRA E ARERR ADEE EEE A ERED Dear Mr. Wolfe, Please take whatever steps are necessary to prevent any building of power lines in the Reserve area, as this would be counter productive to the UY pose of the reserve. It would also threaten the preservation of the Kenai peninisula brown bear that has been declared of special concern by the laskan government. Thank you for your efforts in this matter, Sincerely yours, Deborah Ebersold 1041 N. Gardner St. Los Angeles, CA 90046 --~--Original Message-~-~--~- From: Beth Brobst [mailto:ebrobst@cub.kcnet.orq]) Sent: Saturday, December 01, 2001 5:53 PM ‘To: lwolfe@rus.usda.gov Subject: power line alternative placement PeeeeeURESeTUSUESSSOSOSOOOOSOOSSOOOSOOSOSSSSSCSOCOOCOOCIOSSST SSE This &-Mail and or attachments have been scanned for and found free of known viruses. PRR e renee Reenter REPEAT E PERSE HSE EEA RE REE DHE ER EEN E HAO RE 1 understand that there are two alternative placement options for the power lines that are presently being planned to go across the Kenai wilderness area. Please remember that every time an area is cut through, “edges* are created where indigenous animals will no longer live, because other more common plants and animals fill in. PLEASE RECONSIDER placement of these power lines to be more considerate of the environment. Elizabeth S. Brobst, Lock Haven, PA. I have great concern for all of our wilderness areas, which are constantly being more and wore fragmented. Please do the right thing for our shrinking wilderness! 69A 69B 70A Comment noted. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. Comment noted. See FEIS Chapter 2, Section 2.2.6 regarding additional information on impacts to brown bears (pgs. 2-18 to 2- 19). The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment IF — EPA letter (12/05/01). See also the response to 21A - Wilderness Society form letter (12/03/01) and Section S.10 (pg. S-26) in the FEIS. TIA ~-Original Message-~ From: maegan williams [mailto:maeganwilliams@hotmail.com) Sent: Saturday, December 01, 2001 3:31 PM To: Mr. Wolfe Subject: NO to Power Line Proposal on Kenai Refuge This E-Mail and or attachments have been scanned for and found free of known viruses. RRR RE ERE ERR EEE EAE E REET E REE EERE EE December 1, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, Please pay special attention to the many U.S. citizens in oppostition to the power line proposal for the Southern Intertie on the Kenai National Wildlife Refuge. Please use your positions of power winely. Sincerely, maegan williams 86A Miller Ave Mill valley, CA 94941 USA TIA Comment noted. -----Original Message~---- From: Stew & Mimi McMillen [mailto:grizzly@ktc.com) Sent: Saturday, December 01, 2001 4:06 PM To: Iwolfe@rus.usda.gov Ce: robin west@fws.gov Subject: Bitterroot FRR RR RA KOO TITRA RII TOI TOI H HR tk This E-Mail and or attachments have been scanned for and found free of known viruses. REE RRR RR ERR ERE RR AER EERE EER REDE REE R ERE Dear Mr. Wolfe & Ms. West, Since two alternative corridors for utility lines exist, | question why you want to cut a 50’ 72A — The Tesoro Route has been identified as the agency preferred wide corridor through 38 plus miles of the Kenal Nat'l Wildlife Refuge (a wilderness alternative. Refer to response to comment IF — EPA letter gem), scarring the landscape and opening up access to these wild, unroaded lands. (12/05/01) and Section S.10 (pg. S-26) in the FEIS. See also the Roads are the single greatest threat to wildlife. response to 21A - Wilderness Society form letter (12/03/01). T2A PLEASE do NOT build the high voltage power lines through this sensitive area, ESPECIALLY when two alternative corridors exist. Thanks you for hearing me out. Mimi McMillen, 1621 Indian Creek Loop, Kerrville, Tx. 78028 T3A ankee Pry ARRAN RAR R ERE This E-Mail and or attachments have been scanned for and found free of known viruses. Ae whee ae Rene eenee --«--Original Message~-~«---~- From: Nina Wouk [mailto:nwouk@ix.netcom.com) Sent: Sunday, December 02, 2001 12:21 AM To: Mr. Wolfe Subject: Oppose Enstar route on Kenai Refuge AAA EER REAR This E-Mail and or attachments have been scanned for and found free of known viruses. Ananth heen ee Athenee ennee AMR e ene e eee eee eee eee eee thane nee wanes December 1, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C, 20250-1571 Dear Mr. Wolfe, I am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The primary purpose of a wildlife refuge is protect wildlife, not to transmit energy. The power line would be dangerous to least one species. Therefore it has to go somewhere else. Period. Sincerely, Nina Wouk 1259 El Camino Real #215 Menlo Park, CA 94025 USA 3A Comment noted. --~--Original Message-- --- From: John J Bartolini [mailto:jebart2@juno.com] Sent: Sunday, December 02, 2001 1:36 AM To: lwolfe@rus.usda.gov Ce: robin_west@fws.gov; emc@fs.fed.us Subject: Proposed Kenai Nat'l Wildlife refuge powerline road and Bitterroot National Forest logging sale. oeeeeeeUROUSUSEOCeEOUSOSOSeOOOSSOOOOOOOOSOOSO SSIS TO e Teese) This E-Mail and or attachments have been scanned for and found free of known viruses. CARER REAR RARER REAR E ERAT REET E EERE EEE R HERERO E HESS As one who has had the good fortune to make several visits to this area T4A Comment noted. and landed a 52 1b salman, I am apposed to any unessary encroachment into this national wildlife refuge. I want to be assured that my grand children will be able to enjoy the area as much as we have. T4A I would now like to address the proposed logging sale in the Bitterroot National Forest - surely the public should be allowed to voice their oppinions and be heard in this most important undertaking. Thank You, John Bartolini - 1830 Sunningdale #20L, Seal Beach, Ca. 90740 - jebart2@juno.com 15A 75B From: Sent: Sunday, December 02 vo: Mr. Wolfe abject; No Power Lines through Kenai Refuge Original Message-- Ted Kennel [mailto:tedkenneléyahoo.com) 2001 1:23 pM SR eee eee eee a eae baw eae This E-Mail and or attachments have been scanned for and found free of known viruses. we eeenee De 2001 DOr Mr. Lawrence Wolfe USDA Rural utilities Service 1460 Independence Ave.. SW Stop 1571 Washington, D.C. 20250-1571 Dear Mr. wolfe, I have just heard of the proposal to build a power line through the Kenai National Wildlite Refuge over the Enstar route, and i find it to be a truly revolting idea. Building a power Line through the Refuge completely subverts the purpose for which it was created. The Refuge is there to provide habitat for animals such as moose and brown bears who need large areas of contiguous wild lands in which to survive. Building the Enstar route right through currently roadless areas will fragment the wilderness and bring wildlife into more frequent and detrimental contact with civilization. In addition, two alternate routes for the power line already exist. One of which was created in 1964 when the Refuge ceded @ significant porti of it jow many more times must the Refuge be violated for this purpose? Please reject the destructive Enstar route through this invaluable portion of our nation’s natural heritage. Please take the mission of protecting our nation’s wildlife and their habitats seriously. Sincerely, Yed Kennel 395 Richmond Dr., Apt#i2 Millbrae, CA 94030 usa wentern border to the state of Alaska. 715A 75B Comments noted. The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment IF — EPA letter (12/05/01) and Section S.10 (pg. S-26) in the FEIS. See also the response to 21A - Wilderness Society form letter (12/03/01). 760A --Original Message----- From: LeAnne Chism (mailto: Leannechismdmsn com] Sent: Sunday, December 02, 2001 4:29 PM To: Mr. Wolfe Subject: The Enstar Suggestion is unwarrented disruption with significant, long-term deqredation. teens stares . steer This E-Mail and or attachments have been scanned for and found free of known viruses. thee seeeene seeee Decembor 2, 2001 Mr. Lawrence Wolte USDA ~~ Rural Utilities Service 1400 Independence Ave., Si -- Stop 1571 Wavhington, D.C. 20250-1571 Near Mr. Wolfe, There mst be limits, there are already acceptable alternatives to bivecting this Kenai Refuge. A corridor for powerlines already exist. What is Enstar’s purpose in degrading the brown bear habitat? What good reason exists when a route has already been negotiated in 1964? Will continue co ignore impact statements ? When does science and research to protect the environmental sensitive land deserve consideration? when there is no opposition to prevent it? ts that the basis for action? There needs to be some very clear boundary setting if the few remaining wilderness areas are to be protected, Later is wonderful but now is present tense. If this was a hundred and fifty years ago, there might be some legitimate argument. However. when accomaodations have already been made and more and more is being asked for IN SPITE OF NEGATIVE IMPACT STATEMENTS, it is very clear who has lost the straight line in their heads. Beaucrats who will be long dead after the damage is done. But the bears and vegetation and beauty will not vie for the silent camera but will become another “sad commentary” of what could have been { another myth of the days of yore) if men of integrity could see farther than their own retirement plans. when do you say no? The pressure will never cease to take short cuts, ignore solid research and give in to corporate pressure. If inch by inch is a cinch, why not set the whole damn Refuge out on the auction block and get it over standing up? Sincerely, LeAnne Chism 3227 Bonnie Lane Stockton, CA 95204 USA 76A Comments noted. 77 Original Message----- From: Eldon Hiebert [mailto:eah12345@aol.com] Sent: Sunday, December 02, 2001 11:23 AM ‘To: Mr. Wolfe Subject: Oppose Enstar route on Kenai Refuge BRE RRR ERR EEE EEE EERE RRA REDE A EERE EERE This E-Mail and or attachments have been scanned for and found free of known viruses. BREEN EERE R REAR ERE EERE REAR EERE REE REE EEE December 2, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, We should be doing everything we can to preserve what remains of natural America. There is too little left to condider economic gain as a reason for disturbing our last natural places. Sincerely, Eldon Hiebert 241 List Avenue Pasadena, MD 21122 USA 77 Comment noted. 78A 78B ~---- Original Message----- From: David Marlin [mailto:davidmar} in@mediaone.net} Sent: Sunday, December 02, 2001 6:32 PM To: Mr. Wolte Subject: Please Prevent the Enstar route on Kenai Refuge BARR eR ee Aha ee ERR EAHA EEE H AED Ha HAE EERE HEE ear eae This E-Mail and or attachments have been scanned for and found free of known viruses. ARR Ree Reem en Re R REAR A H ARH EE RAPE ERA ERE ER EEE HH RAE E Rb EE EERE December 2, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr, Wolfe, I am writing to ask you to oppose the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. I have visited the refuge, and I believe it is one of the most precious places on earth. It is one of the few areas of it’s size which allows such a diverse and fascinating group of wildlife to exhist in their natural habitat. There are so few places like that left on earth. Human expansion has resulted in the extinction of a number of animals, and certainly a number of open spaces as wonderful as Kenai. Please, for the state of Alaska, for Americans, and for the world, respect it as the precious place it is. Let it be. (And besides, there are two viable alternatives - including the corridor cut from Kenai in 1964). Sincerely, David Marlin 89 Amherst Rd. South Hadley, MA 01075 USA T8A 78B Comment noted. The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment IF — EPA letter (12/05/01). See also the response to 21A - Wilderness Society form letter (12/03/01) and Section S.10 (pg. 2-26) in the FEIS. --Original Message~---- From: Robert Dolan [mailto:rdolan@cast.org) Sent: Monday, December 03, 2001 7:33 AM To: Mr. Wolfe Subject: Protect Kenai penninsula from Enstar encroachment BERRA REAR Eee EER ERE AR RARER REE REED This E-Mail and or attachments have been scanned for and found free of known viruses. ARMA R hea eee EER ER Aaa December 3, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, I oppose the Enstar route for the Southern Intertie being considered 79A — The Tesoro Route has been identified as the agency preferred for the Kenai National Wildlife Refuge. There are alternative ‘ = 79a | Solutions that will allow us to avoid the negative impact these alternative. Refer to response to comment IF — EPA (12/05/01). lines would have on the wilderness of the penninsula, impact that See also the response to 21A - Wilderness Society form letter surely will be a catalyst for further encroachment over the years (12/03/01) to come. Sincerely, Robert Dolan 89 Green St. Marblehead, MA 01945 USA -- 80A errr e ee eee rere re sy ARORA R RRR ERE R HAO E REAR This E-Mail and or attachments have been scanned for and found free of known viruses. AN RRR RARER REO ROTA ERE EERO HEROD EH EERE EEE E AEE -Original Message From: Karen Gray [mailto:kgray@colorado.cirrus.com] Sent: Monday, December 03, 2001 1:02 PM To: Mr. Wolfe Subject: Reconsider alternatives to the Enstar route on Kenai Refuge This E-Mail and or attachments have been scanned for and found free of known viruses. CREO e RENEE MEAS AERO EAE RAHA BRR E NENA ARAMA MARAE EAE OER HAAR ENERO ERED RE REE RE EEE December 3, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1 Washington, D. 20250-1571 Dear Mr. Wolfe, I am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. Please reconsider alternatives to the Enstar route which would less drastically impact the landscape and the wildlife unique to this dramatic refuge. The Kenai Refuge provided a corridor for transportation and ability needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these viable routes and further encroach on the Refuge is unacceptable. Again, please give serious consideration to viable alternatives to the Enstar route. Thank you. Sincerely, karen Gray 4187 Spy Glass Lane Longmont, CO 80503 usA 80A Comment noted. See response to 21A — Wilderness Society form letter (12/03/01). 81A 82A --~-Original Message ~ From: Karen.Case@blueshieldca.com [mailto:Karen.Case@blueshieldca.com) Sent: Monday, December 03, 2001 7:02 PM To: lwolfeGrus.usda.gov Subject: power lines in Alaska ARR e Eee Ee eee EERE EARNER RHEE RARE RARER EAA EERE EOD This E-Mail and or attachments have been scanned for and found free of known viruses. REO Ree M ROR OH ERE ERE EMME ERED RARER RE EE EERE EERE EEE EES To Whom This May Concern: Please do not allow the building of highvoltage power lines through wilderness from the Kenai Peninsula to Anchorage. The Refuge is known for its world class salmon fishing, brown bear, moose and lynx habitat, and outstanding wilderness recreation opportunities. There is so little land ft and there are other routes which can be used. ‘Thank you Karen Case --Original Message---~--~ Fro adnor@mail.cybermesa.com [mailto:adnor@mail.cybermesa.com) Sent: Monday, December 03, 2001 10:06 PM Yo: lwolfe@rus.usda.gov Subject: (No subject) HANNE ERR ERA R EER DEAR TEE T ENTREE ERENT EERE EERE EE ED This E-Mail and or attachments have been scanned for and found free of known viruses. ARERR ERE ERT ERROR RE EERE E RET EEE TERRE RE AEER EERE EEE EEE I am apposed to the power line . I appreciate your regard to public oppion Ronda Kay Santa Fe New Mexico 81A 82 Comment noted. Comment noted. 83A 84A 85A From: angie sanchez [mailto:angies1@attbi.com] Sent: Monday, December 03, 2001 10:29 PM To: Iwolfe@rus.usda.gov Cc: robin_west@fws.gov Subject: CSIC IO IOI IIOI OI Ot This E-Mail and or attachments have been scanned for and found free of known viruses. FR RISO ROTOR OR RRR SORORITIES IO RR Please help Alaska be one of the very few places on carth where nature stays, Look at Alaska as a futare "Cash cow", ----- Original Message----- From: mike link [mailto:link@audubon-center.org) Sent: Monday, December 03, 2001 10:45 PM To: lwolfe@rus.usda.gov Subject: Arctic Utility corridor NEARER EERE REE E EEE HERE E ERATE EDT EEE HERRERA DEERE EES ERED This E-Mail and or attachments have been scanned for and found free of known viruses. AAR Renee eRe eee eee Re eae eens ARR eRe Ree Please reconsider the decision to put a powerline in the Kenai refuge. THis is much more than an issue of aesthetics. There are volumes of published works about the death of birds in relation to powerlines and towers. To put them in the same place that is intended to welcome wildlife is a terrible descision. -----Original Message----- From: Richard D Strong [mailto:voiceofthesoil@juno.com) Sent: Sunday, December 02, 2001 1 0 PM To: lwolfe@rus.usda.gov; robin-west@fws.gov Cc: voiceofthesoil@juno.com Subject: Objection to Kenai power line. ERENCE REHEAT NER E AERA AERA HAAR EMRE R ERA R ER EERE REED ‘This E-Mail and or attachments have been scanned for and found free of known viruses. HEAT R AER R eRe EOP aE E RHE EEHEE REED REEH DERE H DEER EERE R DEES Dear Lawrence Wolfe and Robin West, A 38 mile power line through an unroaded wilderness area makes no sense when there are alternaive routes available. In essense, to open up an area such as this is irreversible. I urge you to reconsider this proposed route. Sincerely, Richard Strong, 8 La Madronal, Orinda, CA 94563. 83A 84A 85A Comment noted. The Tesoro Route has been identified as the agency preferred alternative (see response to comment IF - EPA letter (12/05/01)). Also refer to comment 9A — Alaska DGC (12/05/01), and Chapter 2, Section 2.2.8 (pgs. 2-32 to 2-34) of the FEIS regarding potential for bird strikes. The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment 1F — EPA letter (12/05/01), and General Response to Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS. - Original Message---~-~- From: Vincent J. Lucid, Ph.D. (mailto:vlucid@tweny.rr.com] Sent: Tuesday, December 04, 2001 9:01 AM vo: Mr. Wolfe Subject: Kenai Enstar Route -- professional opinion ane Ata ennnne eee eee eee e ee oer ereerrrery This E-Mail and or attachments have been scanned for and found free of known viruses. AAR RRR ARR R RRA A RRR December 4, 2001 Mr. Lawrence Wolfe USDA -- Rural Utilities Service 1400 Independence Ave., SW -- Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Wolfe, I have a Ph.D. in Wildife Biology and 25 years as an environmental consultant. TI was the environmental studies director for a $4 86A | million study in south-central Alaska. So I speak with some authority. I oppose to the proposed Enstar route for the Southern Intertie 86A The Tesoro Route has been identified as the agency preferred on the Kenai National Wildlife Refuge. Please reject it. alternative. Refer to response to comment 1F —~EPA letter (12/05/01). Sincerely, Vincent J. Lucid, Ph.D. 388 County Route 10 Pennellville, NY 13132 USA 87A 87B ++++-Original Message----- From: chris renee [mailto:chris_renee@hotmail.com) Sent: Tuesday, December 04, 2001 3:50 PM To: Iwolfe@rus.usda.gov Subject: Kenai National Wildlife Refuge RRR EEE EER EERE EERE EERE EEREER ERA ERE REE EERE REED This E-Mail and or attachments have been scanned for and found free of known viruses. FREER EE ER REE RR EE EER REDE EER EIR TREE PRE EERE MAHER EH 1am opposed to the building of high voltage power lines through the Kenai Refuge. Not only awe there 2 other viable utility corridors already in existence making this project superfluous and a waste but I sce no reason to cause substantial impacts on the wildlife afffected by the proposed project particularly the genetically isolated population of Kenai Peninsula brown bears. In addition this development will cause greater access to the refuge and render it unable to be designated as a wilderness area. How much development do we need? Can't we leave something for the animals and the natural world we SHARE 1 IE PLANET with-- Cruz, Ca Chris Renee, $ lownload of MSN Explorer at hutp://explorer.msn.com Get your FR! 87A 87B The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment IF — EPA (12/05/01) and 21A — Wilderness Society form letter (12/03/01). Refer to Section 2.2.6, Update on Kenai Peninsula Brown Bears and Wolverines (pgs. 2-18 to 2-19) of the FEIS. The DEIS acknowledges that the Enstar Route would conflict with management plans and could prohibit future wilderness designation (pg. 3-143). Refer also to the USFWS Compatibility Determination in Appendix A of the FEIS. -Original Message~--~~~ Fro dheeney@shopamericamarket.inggroup.com {mailto:dheeney@shopamericamarket inggroup.com) Sent: Wednesday, December 05, 2001 12:20 PM To: lwolfe@rus.usda.gov Ce: robin_west@fws.gov Subject: Kenai Refuge power line errr eee eee eee eee e eee cece e Teer errr reves e ress rere rere ries) This E-Mail and or attachments have been scanned for and found free of known viruses. BAAR T eee R EERE ROLE REAR E AERA DREHER ER ERE TO POWER LINE THREAT OF KENAI REFUGE >Alaska‘s Kenai National Wildlife Refuge is threatened by a proposal to >build high-voltage power lines through defacto wilderness from the 88A Comment noted. >Kenai Peninsula to Anchorage. Please consider my comments on a Draft >Environmental Impact Statement and protect this outstanding refuge use eady existing lines. Thank you! Truly, Donna Heeney 532 Hinman Ave. Apt G Evanston, IL 60202 Comments to both the US Fish & Wildlife Service and the US >Forest Service by December Sth: ohrtp: //www.wilderness.org/takeact ion/?step=2&item=880 > 88A >Received: from BOB ([(64.242.124.66]) by ccmail.itd.nps.gov with SMTP > (IMA Internet Exchange 3.13) id 00F53202; Fri, 30 Nov 2001 17:45:55 -0500 eMessage-ID: <1023040. 1007160432796 . JavaMail . IWAM_D1NL8B01@B0B> >Date: Fri, 30 Nov 2001 14:47:12 -0800 (PST) >From; WildAlert <wilderness-alert@alert .wilderness.org> >To: judith johnson@nps.gov >Subject: ACTION: Bitterroot salvage sale; Kenai Refuge power line >Mime-Version: 1.0 Content-Type: text/plain »Content~-Transfer-Encoding: 7bit > December 3, 2001 37 Ternan Avenue East Greenbush, NY 12061 Mr. Lawrence R. Wolfe Sr. Environmental Protection Specialist USDA, Rural Utilities Service Engineering and Environmental Staff, Room 2240 1400 Independence Ave. SW, Stop 1571 Washington, DC 202250-1571 RE: Proposed Southern Intertie Dear Mr. Wolfe, Thank you for allowing me to comment on this plan. | am writing to express my opposition to the proposed route. The preferred route by the utility company goes through the heart of the Kenai National Wildlife Refuge (KNWR), despite the fact that the USFWS povided a transportation and utility corridor to meet these needs in 1964 along the Cook Inlet coastline (where a Tesoro gasline presently runs). According to ANILCA (Title XI), the preferred route for the project must be found “compatible with the purposes tor which the Unit [KNWR] was tablished." Increased human access poses a serious threat to Kenai Peninsula brown bear populations. Chugach Electric's preferred route would cross Game Unit 15 and not permit prescribed burning. 89A 89B The Kenai National Wildlife Retuge belongs to all Americans. It should be kept as wild and 89C undeveloped as possible. It is the wilderness character of Alaska’s public lands which makes Alaska unique. That's what makes me a frequent visitor to Alaska, Alaska’s development need not take the same course as was taken In the “lower 48.” Please utiliize the Cook Inlet coastline route instead of the proposed route. Thank you for your time and attention. Sincerely on Fr h_ David Pisaneschi Ce: Senator Clinton Senator Schumer Congressman McNulty 89A 89B 89C See response to 21A — Wilderness Society form letter (12/03/01). See response to comment 87B — Individuals. The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment IF — EPA letter (12/05/01). Original Message-~--~- From: Hylocichla@aol.com (mailto:Hylocichla@aol.com| Sent: Wednesday, December 05, 2001 1:58 PM To: lwolfe@rus.usda.gov Subject: Intertie Alaska This Mail and or attachments have been scanned for and found free of known viruses. REAR Renee eee een eens December Sth, 2001 Lawrence Wolfe Mr. Wolfe, 90A Having followed the Southern Intertie project, with a background in Kenai Peninsula history and ecology, I would recommend against building out the Mystery Creek Route. 1 believe the wilderness values of the Chickaloon area, and the lands between the Dave Spencer Wilderness and the Resurrection Pass have an increasingly high value as backcountry wildland, which would be compromised by building this route. i realize the complications of a Possession crossing, but believe that if the line is to be built, it should go out the stairstepped Refuge withdrawal along the coast. 90B A deep bow to all of you in D.C. with this winters turmoil. thank you David Rhode Box 796 Cooper landing, Alaska 99972 90A 90B Comment noted. The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment 1F — EPA letter (12/05/01). ---Original Message From: CARL HOLMGREN [(mailto:CARL.HOLMGREN@worldnet .att .net] Sent: Wednesday, December 05, 2001 1:03 PM To: Lawrence R. Wolfe, USDA Rural Util. Serv. Subject: Kenai Refuge power lines PRN T REET ARERR A EERE RETR DERE REE ATER EER R EAR EERE ERROR EER EE This E-Mail and or attachments have been scanned for and found free of known viruses. RRR e RENDER eh Rae ARERR ER REMOE EAE R ERE ERS paren Dear Sir, I find it unconscionable that a proposal to further degrade wilderness status of the Kenai National Wildlife Refuge is being considered, when two alternative corridors already exist. Clear-cutting a new 38 mile swath, 50 feet wide through virgin forest just for convenience is sheer madness, resulting in a negative impact upon wildlife habitat. Blessings, Carl SIA OIA The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment 1F — EPA letter (12/05/01) and 21A — Wilderness Society form letter (12/03/01). 92A 92B 92C December 4, 2001 Lawrence R. Wolfe Senior Environmental Protection Specialist USDA, Rural Utilities Service Engineering and Environmental Staff, Room 2240 1400 Independence Ave. SW. Stop 1571 Washington, DC 20250-1171 RE: Southern Intertie Project DEIS Dear Mr. Wolfe, The best solution at this time for the Southern Intertie Project is the NO-ACTION ALTERNATIVE. This project was ill conceived from the start and its necessity is based on flawed reasoning and weak proof. The Draft EIS process should be stopped at Lthis point and further proof of necessity should be provided. If in fact this project could be found necessary, only the TESORO ROUTE ALTERNATIVE should be considered VIABLE. This route corridor was removed from what is now the Kenai National Wildlife Refuge and set aside as a utility corridor between Anchorage and the Kenai Peninsula. This corridor should be used for the purpose it was set aside for and further environmental damage to the Kenai National Wildlife Refuge should not be considered under any circumstance. The Draft EIS clearly shows that the short and long term environmental impacts from the Enstar Route are far greater then that of the Tesoro Route. The cost and expediency of the Enstar Route do not and should not override the damage that |.would be caused to the fish, wildlife and habitat of the Refuge. Because of all the significant impacts found, the ENSTAR ROUTE ALTERNATIVE should be REMOVED from FURTHER CONSIDERATION and found NOT COMPATIBLE with the mission and purpose of the Kenai National Wildlife Refuge. The Enstar Route as proposed by the applicant would have a significant detrimental impact on brown bears, a specie of special concern and possibly our national symbol, bald eagles. Upland and other habitat would be permanently destroyed with a significant impact on moose and other large mammals, bears and predators, waterfowl and other birds, and the recreational opportunity of all Americans. These significant impacts are not compatible with the stated purpose of the Kenai National Wildlife Refuge "to conserve wildlife populations and habitats in their natural diversity". Since DS SLAMS Bill Stockwell P.O. Box 721 Cooper Landing, AK 99572-0721 92A 92B 92C See General Response to Issue | in Chapter | (pgs. 1-3 to 1-4) of the FEIS regarding purpose and need for the Project. The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment 1F — EPA (12/05/01). See also the response to 21A - Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. Lawrence R. Wolfe USDA, Rural Utilities Service Engineering & Environmental Staff 1400 Independence Ave, SW Room 2240, Mail Stop 1571 Washington, D.C, 20250-1571 Fax (202) 720-0820 E-mail: lwolfe@rus.usda. gov Gentlemen, Here are my written comments on the Draft Environmental [mpact Statement for the Southern Intertie Project and the public meeting in Soldotna, Alaska where [ testified on November 14, 2001 Td like to thank you for allowing me the opportunity to comment on this plan. T understand that mail is not being delivered to your office because of the anthrax scare. My response will be faxed to your office in order to meet the December 5, 2001 deadline. for comments. My comments wil] be candid. I hope my response doesn’t ruffle too many feathers in the U.S. Fish and Wildlife Service (FWS). What are my qualifications to comment on this plan, From 1984 to early 1987 I was the fishery project leader for the Kenai Fishery Resources Office of the FWS. During that period our primary responsibility was to provide fishery assistance to the Kenai National Wildlife Refuge (NWR). ; A substantial portion of this preferred intertie route passes through the watershed of the Chickaloon River, During the summers of 1984 and 1985 my staff and I conducted the first and only overall fishery investigation of the Chickaloon River basin. In 1984 this watershed provided spawning habitat to over 115,000 salmon of four different species. Not only did we discover a significant fishery resource we also discovered the presence of a substantial brown bear population. That summer we encountered an average of one brown bear a day during our field study. The U.S, Forest Service had a brown bear study team working on the adjacent Chugach National Forest that year. We were seeing more brown bears than the Brown Bear Study Team. In 1984 there were over 450,000 pounds of potential bear food in the form of salmon in the Chickaloon River and its tributaries, Because of this food source the Chickaloon River basin provides the best brown bear habitat on the Kenai Peninsula north of the Sterling Highway. Efforts to radio tag brown bears along the Chickaloon River have been hampered by dense Tiparian vegetation making it difficult to spot bears from the air. If a bear is spotted and darted, there are few places to land to attach a radio collar. For these reasons these bears are not as well represented as they should be in studies by the Interagency Brown Bear Study Team. Both the Big and the Little Indian Creeks support salmon runs. Neither stream has been investigated so the extent of those nuns remains unknown. Bear signs are common along both streams in the summer suggesting a substantial amount of salmon and bear use. The FWS has known that this intertie proposal was coming down the tumpike for at least five years. Here we are, five years later and the FWS knows little about these anadromus streams on the Kenai National Wildlife Refuge (Kenai NWR) that could be impacted by this intertie. 93A [nis fishery biologist Dave Faurot wrote a 70 page report on our Chickaloon River fishery 93B 93€ 93D 93E investigation. This report has not been quoted and is not listed as a referenge in this EIS Every one of the salmon numbers for the Chickaloon River on pages 3-109 and 3-1 10 of this EIS is incorrect. Where did the number of Dolly Varden reported on page 3-110 come from? Was this number taken from a study or is this a figment of some fishery biologists imagination? It’s t to me that the Anchorage Regional Office of the FWS did not request a teview of this draft EIS by their own Kenai Fishery Resources Office. Two years ago the FWS had this same problem with the draft EIS on the Wolf Lake Natural Gas Field. I was the only fishery biologist to give that EIS a critical review. There were notable data gaps in the fishery information base. Frankly U had a field day with that EIS. My free analysis of that EIS was not appreciated and my suggestions for additional studies, with one exception, totally ignored. The FWS still doesn’t know any more today about the watershed most likely to be impacted by a hazardous materials spill from that gas field than they did two years ago; The 100,000 chinook salmon this EIS has returning to the Chickaloon River is so far off the mark as to be ridiculous. That’s more chinook salmon than return to the world famous Kenai River. Two years ago I did the Services fisheries work for them. This time they will have to do the work themselves, The FWS will have to find Dave Faurot’s Chickaloon River report, read it, make the needed corrections to this EIS ° Another point I'd like to make is that the Kenai NWR is being nickled and dimed to death by projects such as the proposed Enstar route for this electric intertie. On this national wildlife refuge habitat has been lost to hydroelectric projects, residential development, highways, gravel its, natural gas fields, oil fields, oil and gas pipelines and native land selections. There have been oil spills, produced water spills, a 40,000 gallon zylene spill and there is PCB contamination. There are unmarked barrels buried on the Swanson River Oil Field. No one knows what they contain. There are above normal numbers of deformed frogs in parts of the refuge. The cause of these deformities is under investigation. To some of us who follow refuge developments it appears that it should be renamed the Kenai National Sacrifice Area. Tn 1985 a Comprehensive Conservation Plan and Environmental lmpact Statement was prepared for the Kenai NWR. This plan had a substantial amount of public and interagency review. Permitted activities on the refuge were identified for five different categories of land. These land categories varied from paved parking lofs to wilderness status, Wilderness, of course, received Toost protection. There were two other land use categories called minimal management and traditional management where the plan stated, on page 92, that public utilities would not be yermuitted. The preferred alternative route in this EIS crosses land that has been classified as ninimal management where this type of development is incompatible with refuge purposes. 93A 93B 93C 93D 93E The subject report for the Chickaloon River fishery investigation did not receive peer review and was not published. See Chapter 2 — Section 2.3 (beginning on pg. 2-34) for corrected information on the Chickaloon River fishery. Noted and corrected in FEIS Chapter 2, Section 2.3 (beginning on pg. 2-34). Noted and corrected in FEIS Chapter 2, Section 2.3 (beginning on pg. 2-34). Comment noted. Comment noted. See DEIS Chapter 3, pg. 3-143 regarding compatibility with management plans. Refer also to the USFWS Compatibility Determination in Appendix A of the FEIS. 93F 93G 93H 931 This 1985 mangement plan has not been replaced. It therefore seems reasonable to expect that it is still a valid and meaningful plan to govern responsible management of these public trust Jands. I would like to pose a question to the Regional Director. .If there exists an EIS for the entire refuge that states that an activity will not be permitted will it be overttined by this EIS that is only applicable to a slice of this refuge? 1 was dismayed to read in this plan that a favorable compatibility determination by the FWS cannot be subject to review. On the other hand if the Refuge Manager and the Regional Director disapprove of the preferred utility route across the refuge that decision is subject to review and can be overturned by the President. If this statement is correct, it appears that development projects get a running start over protection of refuge habitats, If the FWS disapproves of the Enstar route for this intertie the anti environmentalists at the Interior Department or the White House will no doubt allow it to proceed. This is a classic lose-lose situation for the Refuge Manager and the Regional Director. If the Regional Director disapproves he will no doubt be promptly reassigned to a staff position in the Washington Office of the FWS and the project will go forward anyway. After the Enstar Natural Gas Pipeline was laid down in the early 1960's, Kenai NWR gave up & utlity corridor along the coast. This was to allow for the future development of additional utilities between Anchorage and the Kenai Peninsula. The Tesoro pipcline follows this route. This electric intertie should also follow that route. The utilities have over $46 million dollars of the public's money to build this intertie. Purely business decisions should not be the only consideration. On a national wildlife refuge what is good for wildlife should come first, not last. According to this plan the existing intertie can only carry 70 MV. At peak power Bradley Lake can produce more power than the existing line can carry. It was brought to my attention at the Soldotna meeting that because of insufficient water storage capacity, Bradley Lake normally operates at about 30 MV. If this is the case the existing intertie can carry the normal power production from Bradley Lake to Chugach Electric Association’s facilities in Anchorage. The existing intertie has worked well for many years. I question the need for another intertic, especially one that will negatively affect bears, birds and fish on the Kenaj NWR as described in L_this EIS. Chugach Electric Association operates a hydro facility at Cooper and Kenai Lakes, This facility is being investigated as the source of PCB’s in lake trout in Kenai Lake. The utilities handling of PCB’s prior to 1987 Jeft a great deal to be desired. Is this the utility company we want to be directing the construction and operation of power line across the refuge with $46 million of the public’s money? . a At each end of the submerged portion of an underwater cable there will be a transition facility. This facility is needed to maintain pressure on liquid in the cable. Reportedly these facilities will be remotely operated. No doubt maintenance will be required periodically. Access over the dirt tract along the Enstar pipeline, if this route is selcted, will be difficult most of the year. The only efficient way to reach a transition facility near Chickaloon Bay will be by helicopter. We L_then can add helicopter landings to the long list of nickle and diming activities on the Kenai 93F 93G 93H 931 See response to 21A — Wilderness Society form letter (12/03/01). See also response to comment 1F — EPA (12/05/01) regarding the agency preferred alternative (Tesoro Route). See DEIS Section 1.2.1, How the Existing System is Operated (DEIS page 1-8), and Section 1.3.3, Economic Generation (DEIS page 1-23), for an explanation of how increased utilization of the Bradley Lake generation would be possible with the Project in service and the benefits that would accrue. The Project would allow increased coordination of the hydroelectric generation at Bradley Lake with the thermal generation in the Anchorage and north areas, which would result in lowering the overall cost of producing electricity. The average output of the Bradley Lake Project is 45 to 50 MW year around. The peak output is currently L1O8MW and the design of the power plant is such that an additional SOMW of generation could be added in the future. As described in the DEIS, utilization of the existing generation plants in the most efficient and cost effective manner would at times require transferring the peak output power of the Bradley Lake Project north to the Anchorage area, in lieu of operating more expensive thermal units. To accomplish this, additional transmission capacity is needed between the Kenai Peninsula and Anchorage. Comment noted. Helicopter maintenance is suggested to mitigate impacts associated with overland access. See DEIS Section 2.5.3 Construction Access (pg. 2-52). See also the Mitigation Plan in FEIS Volume II. 93J NWR. T’ve been involved in this project in one capacity or another since we had the first public meeting several years ago. When this project seemed to be creeping along it was suggested that Dora ropp, Project Intertie Leader, was slowing this project down waiting for the 2000 election which she hoped would put a Republican in the White House. From the first meeting it was apparent than Ms. Gropp was an extremely capable and competent manager. [ have to take my hat off to her. By waiting until this year she has put the FWS in a no win situation. If the Regional Director disapproves of the preferred option he will be overruled. If the Regional Director approves the preferred option he will probably lose what little clout he has Jeft with groups working for responsible management of Alaska’s National Wildlife Refuges. If this is how our system works today I wonder why we’re bothering with this cumbersome EIS system. Let’s just write the developers a blank check and tell them to do whatever they please, with our money, on Alaska’s National Wildlife Refuges. That’s essentially what's being done in this case. In case U haven't stated my concerns clearly enough, I am adamantly opposed to the preferred Enstar route for this proposed intertie. I hope the critters and their habitats come first in this and in any future decision on the Kenai NWR. Jack Dean & “fr Retired fishery biologist P.O. Box 428 Sterling, Alaska 99672 (907) 262- 9769 songbird@alaska.net November 17, 200] 93J Comments noted. 94A Wolfe, Larry -RUS . . a . Sc From: Thane Harpole [thane75@nwinetwork.com) Sent: Wednesday, December 05, 2001 11:59 PM To: twolfe@rus.usda.gov, robin_west@fws.gov Subjact: Proposed Enstar powerline corridor FOI OI III GOI III III III III II III III IN NI IIIS I TOI III IOI IO: This E-Mail and or attachments have been scanned for and found free of known viruses. BINA IIIS IOI IIIS IIIS IIR III IIIT I SIDS H He 29H The Kenai National Wildlife Refuge needs and deserves our protection. Cutting a new powerline corridor thraugh this pristine wilderness Is not consistent with the responsibilities of the Fish& amp; Wildlife Service or the Forest Service. The corridor set up In 1984 to handle this type of dovalopment is the clear altemative to the Enstarp roposal, and should be the only choice, Protect the Kenai NWR, don'td estroy tt. Sinceraly, Thane Harpole P.O. Box 1401 White Marsh VA 23183 94A Comment noted. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. John AGEL LOS Bir fof Fv43slat F SEee3 ZL Buc Cn ee GE Ae lhe LS44d Sere LAS Tres Se CE Washing fer, Ac oo anal iobame Ate MCS, fo cx Se cL pao /n < a esol Sirel ¢ oss ih oe Z = cue, LU aL. Cfo eerese . an ewdeh tre? of reo a2 ~ yy. 95B Gren we. négere ret) Apel (0 conspreffr av Fonte “722 ge or Of: geal CI oe! pa esiag Be ez ane’ A oe as re Ser evel Le wc // Jo “he 2 — ee zey poallacs he73 u Te. *~ LOT eL POLS: er osc | SF vn 7 sbacsiaans Leo, oF yoower~ ; . eZ er BACeECSS eve, TE OOD pew PT LAC (G7 fes= Agee ceva slo os 2 : LAr’ ae -. ay beer Xe, te Lew dr = al yhee, pubf Lv er FO 7 feed (ett en fee she < Cmefo ale — Sort of 0 Alan tae Tie ce5e, Sy ores ony Eee — Aha Lewar WWR, Por’, 2—, 95A 95B 95C Comment noted. Comment noted. The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment 1F — EPA letter (12/05/01) and 21A — Wilderness Society form letter (12/03/01). Impacts to brown bears are acknowledged in the DEIS. See also FEIS Section 2.2.6, Update on Kenai Peninsula Brown Bear (pgs. 2-18 to 2-19) and the USFWS Compatibility Determination in Appendix A of the FEIS. 96A Original Message Frot Golden (mailto:Golden@Quixnet.net} Sent: Friday, December 21, 2001 3:55 AM To: lwolfe@rus.usda.gov Subject: Alaska Intertie Project EERE EEE EERE EERE ER ERE EERE EERE EERE ERE This E-Mail and or attachments have been scanned for and found free of known viruses. FROST IOI IO IIIT IO IRR Re ies and Gentlemen, Please note my strong support of the southern Intertie Project, involving the construction of a high voltage transmission line between <enai and Anchorage. Mitigation of visual impacts should be included at reasonable costs. iel J. Golden 96A Comment noted. Mitigation of visual impacts is discussed in the DEIS beginning on pg. 3-238. Additional information on mitigation is provided in the Mitigation Plan in Volume II of the FEIS. Cornment Sheet for the Southern Intertie Project Draft Environmental Impact Statement Name__M 7 PM: Keown Submit to the an agency ‘/ ‘ resentative at this pul Representing Self, fanuily + Ftionds = or mail by December 5, 2001 : Address: 1 DAO Valagian Street oe ch Yasha 9950 Lawrence R. Wolf -Aichornge., ts f: & USDA, Rural Utilities Service Engineering & Environmental Staff ape 1400 Independence Ave. SW Phone#:__ 707 -A77-W7¥ Room 2240, Mall Stop 1571 Washington, D.C. 20250-1571 Far#o Fax (202) 720-0820 mali ‘ @ ma d Com E-mail: |wolfe@rus.usda. Comments [ setts brief - OTA Comment noted. STA Not Aten p} Ta Jorsp ape hom Auyowe Wo oO dees tet have. Maw, J Rieke ju This io; ¢ tt Rete, rafasal peed aytee OE ere. Fine obofe. Plepse, feo Cretelly cousifler our objection, Thad you. 978 | {amvwtiting this to strongly object to granting a permit forthe Soythern Intertic Project through the Kenai National Wildlife Refuge (KNWR). The projééf Clearly has other alternative routes, including a utility corridor to the west of the reflige and the highway route which already has |_cxisting powerlines, The reasons for my objections are many. First, the KNWR is a pristine and unspoiled place, The existing Enstar gas line has been in place for over 30 years and much of the vegetation has overgrown the existing 50" right of way, This has been a blessing to the wildlife 97C in the area and to the visual and scenic value of this portion of the KNWR. A new powerline with a 200 foot clearing straight through the KNWR would not only be a visual disturbance, but would endanger existing populations of Moose, Brown Bear, Wolf, Caribou, and other - mammals. In addition, substantial impacts could negatively affect large numbers of waterfowl | which concentrate in the Chickaloon Flats arca of the KNWR in the spring, summer and fall. The draft of the Environmental Impact Statement for this project itself states that there is no clear mitigation for this issuc and does not even suggest an understanding of the potential problems. 97D | 11995, the Alaska State Legislature in House Bill 58, designated the Chickaloon Flats Critical Habitat Arca, as.a crucial waterfowl staging arca. It is clear to me that a 75” high powerline running along the Enstar right of way has a significant chance of collisions with migrating waterfowl I base this on over 25 years of observations watching waterfowl migrate not only from the north, but also from the west and southwest heading north to Chickaloon Flats along the Kenai Mountains, Even to bury the cable in the tidal flats creates habitat problems for waterfowl in all seasons except winter. It is also clear to me that as many as seven salmon spawning streams would be affected by this project. In summary, J am strongly against granting a permit for the Southern Intertic Project through the KNWR. Michael P, McKeown ie LIP Will —— Wrefol Vee “ 6 . also opposed to granting a permit for the Southerg lntertie Project through the Kenaj National Wildlife Refuge bee LL ; the / . lows Novato, gLt A “dan Mme ti/2t fet (tied if Q ohert oak Ng von, Harold Os7erud 97B 97C 97D Comment noted. The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment 1F— EPA letter (12/05/01). See also the response to 21A - Wilderness Society form letter (12/03/01), and the USFWS Compatibility Determination in Appendix A of the FEIS. Comment noted. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. Comment noted. See response to comments IN — EPA letter (12/05/01) and 91 — Alaska DGC (12/05/01) regarding impacts to waterfowl and tidal flats. See also comments 5B — NMFS (12/12/01) and 9B — Alaska DGC (12/05/01) regarding anadromous fish streams. I am writing this to strongly object to granting a permit for the Southern Intertie Project through the Kenai National Wildlife Refuge (KNWR). The project clearly has other alternative routes, including a utility corridor to the west of the refuge and the highway route which already has existing powerlines. ‘The reasons for my objections are many. First, the KNWR is a pristine and unspoiled place. The existing Enstar gas line has been in place for over 30 years and much of the vegetation has overgrawn the existing 50° right of way. This has been a blessing to the wildlife in the area and to the visual and scenic value of this portion of the KNWR. A new powerline with s 200 foot clearing straight through the KNWR would not only be a visual disturbance, but would endanger existing populations of Moose, Brown Bear, Wolf, Caribou, and other mammals, In addition, substantial impacts could negatively affect large numbers of waterfowl! which concentrate in the Chickaloon Flats area of the KNWR in the spring, summer and fall. The draft of the Environmental Impact Statement for this project itself states that there {s no clear mitigation for this issue and does not even suggest an understanding of the potential problems. In 1995, the Alaska State Legislature in House Bill 58, designated the Chickaloon Flats Critical Habitat Area, as a crucial waterfowl staging area. It is clear to me that a 75’ high powerline running along the Enstar right of way has a significant chance of collisions with migrating waterfowl. I base this on over 25 years of observations watching waterfowl migrate not only from the north, but also from the west and southwest heading north to Chickaloon Flats along the Kenai Mountains. Even to bury the cable in the tidal flats creates habitat problems for waterfowl! in all seasons except winter. It is also clear to me that as many as seven salmon spawning streams would be affécted by this project. In summary, I am strongly against granting a permit for the Southern Intertie Project through the KNWR. Michael P. McKeown ?: Md! Jr Lam also opposed to granting a permit for the Southern Intertie Project through the Kenai National Wildlife Refuge Loaune A. IN¢Keown Par A. mYpeow) It [Bc — Wiktiam E, BRETT ithe E, CYEFF TY. Lino w y I CuteT D CRaekeR (YA Rie, Digel a VY 0- NOTE: Petition sheet has same comments as comment letter 97. The petitions were considered as one letter with 12 signees. 98A LANG CONSULTING 2117 Belair Dr. Anchorage, Ak. 99517 Tel/fax (907) 274-7448 Lawrence R. Wolfe Nov.12, 2001 Senior Environmental Protection Specialist USDA, Rural Utilities Service Engineering and Environmental Staff, Room 2240 1400 Independence Ave SW, Stop 1571 Washington, DC 20250-1571 Dear Mr, Wolfe, Ihave reviewed the DEIS for the Southem Intertie Project and fully support a power line on the Enstar route as shown on Fig. S-4 and following route option 4 along the Alaska railroad to the International Substation. As for the Turnagain Arm crossing, 1 should like to offer a crossing concept which was proposed by the U.S. Army Corps of Engineers, Alaska District, while I was employed by them as their electrical design section chief (see encl.) The causeway concept still has merit for future consideration when Alaska should build the Susitna Hydroelectric project and the Kenai/ Soldotna area is opened for expansion. For now, we need to get the Intertie Project developed, to assure 2 reliable alternate power line to this area, T have included extracts from relevant documents to support my position . Sincerely, 4 / Aetna ie Enclosures 98A Comment noted. 999A 99B Wolfe, Larry -RUS From: Steve and Nancy Beardsley [sn-beards@gci.net} Sent: Friday, December 14, 2001 7:33 PM To: lwolte@rus.usda.gov Subject: inter tie FIO Rik On inns This E-Mail and or attachments have been scanned for and found free of known viruses. FR II I III III III II III IOI IOI TOI OI III III tte at | am against the route through the Refuge Area for numerous reasons. | am also against the use of the ilroad right of way through Oceanview Subdivision as this would be a eyesore at my residence and might cause potential erosion at the bluff area. steve beardsley 13201 reet anchorage ak 99515 99A 99B Comment noted. Potential visual impacts for this route are discussed on pg. 3-259. Mitigation measures, including those listed in DEIS Table 3-2, pg. 3-15, will be used to minimize soil erosion and directional drilling will be used in this area. See the Mitigation Plan in Volume II of the FEIS. 100A 100B 100C 100D December 1, 2001 Mr. Lawrence Wolfe USDA, Rural Utilities Service 1400 Independence Ave. SW, Stop 1571 Washington, D.C. 20250-1571 Dear Mr. Walfe, |.am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these routes and further encroach on the Refuge is unacceptable. Allowing the Southern Intertle to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources... are to ke considered Jong term and L significant.” The Enstar route would cut across unroaded lands in the Kenal National Wildlife Refuge. These areas are eligible for future wildemess designation and | this project would undermine any potential for wilderness designation. The USFWS mandate Is to protect wildlife on the Refuge. -This project would pose additional threats to the Kenai Peninsula brown:bear, which:-has - been declared a species of special concern by the state due to the vast amount of development elsewhere on the Kenai. Since the Kenai Refuge provides the habitat that Is critical to the long term viability of the brown bear, the Enstar route should be avoided. Sincerely, Ell B llsw Mitchell.B. Cline ‘P,O.Box 945 Gitdwood, AK 99587 100A 100B 100C 100D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 101A 101B 101C 101D December 3, 2001 Mr. Lawrence Wolfe USDA, Rural Utilities Service 1400 Independence Ave. SW, Stop 1571 Washington, D.C. 20250-1671 Dear Mr. Wolfe, | am writing in opposition to the proposed Enstar route for the Southern Intertie on the Kenai National Wildlife Refuge. The Kenai Refuge provided a corridor for transportation and utility needs by significantly altering its western boundary in 1964. This corridor along with an existing powerline corridor between Anchorage and the Kenai Peninsula provide viable and legitimate alternatives for this project. To forego using either of these Lroutes and further encroach on the Refuge is unacceptable. Allowing the Souther Intertie to bisect the northern portion of the Kenai Refuge is not compatible with the purposes of the Refuge. The Enstar route would impact wildlife habitat and create new access to these remote areas. Even the DEIS states that “the cumulative effects on wildlife, vegetation, recreation, and visual resources... are to be considered long term and L significant.” The Enstar route would cut across unroaded lands in the Kenai National Wildlife Refuge, These areas are eligible for future wilderness designation and this project wauld undermine any potential for wilderness designation. The USFWS mandate is to protect wildlife on the Refuge. This project would pose additional threats to the Kenai Peninsula brown bear, which has been declared a species of special concern by the state due to the vast amount of development elsewhere on the Kenai. Since the Kenai Refuge provides the habitat that Is critical to the long term viability of the brown bear, the Enstar route should be avoided. Sincerely, fore. (sec e Cline. £.0 Box 389 Girdwood, AK. 99587 101A 101B 101C 101D See response to 21A — Wilderness Society form letter (12/03/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to 21C — Wilderness Society form letter (12/03/01). See response to 21D — Wilderness Society form letter (12/03/01). 1.3.3 RESPONSES TO VERBAL COMMENTS 1.3.3 Responses to Verbal Comments This section provides responses to the 12 individuals who provided verbal testimony at the formal federal public hearings conducted in Anchorage, Alaska, and Soldotna, Alaska (no verbal comments were received at the District of Columbia hearings). Table 1-3 is organized by comment source (individual/affiliation), showing who provided verbal comments on the DEIS at the hearings, and general topics of comment (by issue number). TABLE 1-3 GUIDE TO AGENCIES, ORGANIZATIONS, AND INDIVIDUALS WHO PROVIDED VERBAL COMMENTS ON DEIS Comment Issues Commented Number* Name/Affiliation On District of Columbia, October 30, 2001 None Anchorage, Alaska, November 13, 2001 102 Mike McKeown 4,7, 8, 14 103 Jack Hession, Sierra Club 2, 4, 5,7, 8, 14 104 Shawn Wendling 1 105 Steve Conn, Executive Director, Alaska Public Interest Research 1,5, 8, 13, 14 Group 106 Bill Nagengast 1 107 Vivian Mendenhall, National Audubon Society — Alaska Office and | 2, 4,5, 8, 13, 14 Anchorage Chapter 108 Steve Stanford 1, 13, 14 109 Michelle Wilson, Alaska Center for the Environment 1,5, 8, 14 110 Gregory Michael Errico 1 lll Marcie Errico 2,4,8 Soldotna, Alaska, November 14, 2001 112 Dr. Douglas Stark 8, 13 113 Jack Dean 5, 8, 13, 14 *Verbal comment number follows the written comment number in beginning sequence. The following are the transcripts from the hearings in Anchorage and Soldotna, Alaska including responses to specific verbal comments received on the DEIS. Similar to the written comments, each individual’s set of comments are assigned a unique number. For each speaker, each comment, or issue is bracketed and assigned a letter code. Responses to those comments are assigned the same letter code, and are provided on the transcript next to the corresponding comment. Where appropriate, responses to selected comments have been referenced ahead to the supplemental information provided in Chapter 2; or to Volume II, Mitigation Plan; Appendix A, USFWS Compatibility Determination; or Appendix B, USACE Draft Section 404(b)(1) Evaluation. Southern Intertie Project Chapter 1 — Public Comments and Responses Final EIS 1-13 July 2002 . ow 20 a a 13 “ 1s «6 ar 1s as 20 a 22 23 4 a5 CHUGACH ELECTRIC ASSOCIATION HEARING ON SOUTHERN INTERTIE PROJECT November 13, 2001 Anchorage, Alaska KOH ASSOCIATES 1113 ©, Fireweed Lane, Buite 200 ‘Anchorage, Alaska’ 9980) 1909) 276-3856 102A 102B MR. MCKEOWN: Can you hear me all right? Do I have to speak right into that? MS. OXLEY: Yeah. And just so you know, that microphone won't amplify, it will just record. MR. MCKEOWN: Okay. So I can stand back here (indiscernible) . MS. OXLEY: So you can just speak comfortably. And Charlene will let you know if she can’t hear MR. MCKEOWN: ‘The reason I came to testify is not to speak against a permit but it’s against one of the routes and that’s route F which is the one that goes right through the Wildlife Refuge. Just a quick history, I’ve been in Anchorage for 46 years and have grown up using the Wildlife Refuge camping, hunting spot. My father, my sister, we grew up here, hunting there, fishing there, camping there. And I’ve taken my daughter in the: and many of my friends. In fact my sister’s ash spread in that area, I’m very familiar with route F. Spent a lot of nights there in a tent. It is one of the most wonderful places that you can go without going to the farthest reaches of AL to get away from crowds and people. And the way it currently exists the access is really only there in the winter and in the fall. And by doing that it’s allowed that to remain very unbothered, And I think the moose populations, the waterfall particularly concerned me in that area. Lynx, there's caribou in the hille up there off Binginian (ph) Creek. There's ROM ASSOCIATES rowed Lane, Bulte 200 “Alaska, 93503, a7e3386 my 102A Comment noted. 102B See response to written comment 17H — Audobon Alaska letter (12/04/01) regarding visual impacts and written response comments 14D and 14E — Alaska Center for the Environment letter (12/05/01) regarding impacts to wildlife. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 102C 103A 1s 16 uv 18 a 20 oT 2 as juat a number of issues that bother me quite a bit if this is stretched out to a 200 foot thing and a 70 foot tower through there. I’m concerned that even the scenic value for myself, but just the wildlife and other issues are enough to I would think look at some of the other options. I mean there is a utility corridor which kind of make: rings a bit of common sense to take route A or even follow the highway where we already have power lines. And I know there’ avalanche problems but they could be put in other areas, So essentially I think we -- to take route FP I think we really should look closely at it. It's one of the few places left and over the last 45 years or so the growth that we've nn in Anchorage and the Kenai Peninsula suggests that maybe we should try keep some of it aa it is, so that‘s really all I have to say MS. OXLEY: Thank you for your comments MR. MCKEOWN: Yep. MS. OXLEY: Jack Hession, And Jack, will you please when you get to the mic would you say your name correctly in case I've butchered it and identify any affiliations. MR. HESSION: Yes. Thank you Madam Chairman. My name is Jack Hession, I'm here tonight on behalf of the Sierra Club, and it’s Alaska Chapter. And it’s Knik group for that matter Thank you for this opportunity to comment on your proposal. In summary we would recommend the environmentally preferred alternative which is the Tesoro route, option A. And that 102C ‘The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment 1F — EPA (12/05/01). See also 21A — Wilderness Society form letter (12/03/01). 103A — The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment 1F — EPA (12/05/01). 103B 10 a. 12 n ue 1s 16 7 18 re) 20 coe 2 23 2 recommendation is based on an analysis of the Draft Impact Statement which makes it clear that there would be significant impacts on Refuge resources and values if the Enstar route were chosen. For example, I’11 just briefly mention some of them Nationally significant impacts to brown bears, black bears and moose, nationally significant impacts on wolves and lynx, similar impacts on recreation and land use, all adverse. Likewise significant impacts due to clearing of upland vegetation. Impacts, excuse me, on -- potential for locally and nationally significant impacts due to tree clearing near nest sites, impacts nationally significant on the visual values of the Refuge. Given these adv impacts it seems inconceivable that the U.S. Fish and Wildlife Service could find this Enstar route compatible with Refuge purpoi As you know, in order to find -- in order to approve such a proposal the U.S. Pish and Wildlife Service would have to find that this project is somehow compatible. TI cannot conceive of any circumstances in which this Enstar route would be considered compatible with Refuge values and resources And that’s the basis of our recommendation that the Tesoro route along the coast be chosen. It seems fairly obvious that if you have an alternative that costs slightly more but that totally avoids these adverse impacts on the Refuges that that’s the route that’s in the public interest. And we would urge the various agencies involved in this to come to that conclusion. I'l] leave it at KnOM ASSOCIATES 103B The Tesoro Route has been identified as the agency preferred alternative. Refer to response to comment 1F - EPA letter (12/05/01). See also the USFWS Compatibility Determination in Appendix A of the FEIS. 104A 105A a aa that and we'll submit detailed comments on the Draft Environmental Impact Statement. Thank you very much. OXLEY: Thank you for your comments. Shawn Wendling. And after Shawn we'll hear from Steve Coun and then Bill Nagengast. MR. WENDLING: I just wanted to come up and address the building line thinking that as a longtime Alaskan and consumer here in Anchorage, I think it’s really important that we take a close look and recognize that our power needs are constantly growing and affordability ies an important factor, quality of life. Having worked extensively in the arctic and seen the impact, hearing a lot about compatibility impact and compatibility of some of the wildlife with oil development and seeing that we've had some good compatibility I think that it’s just important to recognize that we can develop a resource and apply the technology that we have and do it in a responsible compatible manner. 80 I'd just like to affirm that I’m in favor of the intertie being built MS. OXLEY: Thank you. Steve Coun MR. COUN: Good evening, I’m Steve Coun, I’m Executive Director of Alaska Public Interest Research Group, a consumer group, 4 consumer watchdog. There are a number of r jons why I would argue that the -- this proposed intertie by -- on any route is wentially a dinosaur. Yesterday’s project conducted -- proposed using yesterday's logic It fails both economically 111) M. Tirewwed Lane, Suite 200 anchor 99803 Alesha 197i 374-38 104A Comment noted. 105A Refer to the General Response to Issue | (pgs. 1-3 to 1-4), Issue 13 (pg. 1-8), and Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding Project purpose and need, economic analysis, and adequacy of 105A cont. 105B 105C 20 fa 13 uM 1s 16 7 1 ww 20 2 22 23 Ty and environmentally and leaves unstudied alternatives that both more secure, more cost effective and did not exist in many years ago when the money -- the State money was encumbered to build this project. And so one must live in the present and the future when one is discussing a project that is projected to occur in the future. And that's my overarching theme. on matter of environment I would of course say that the least desirable is the Enstar route. It’s really a travesty in the sense that historically the other route was part and parcel of a compromise a long time ago to avoid the Refuge. But as to the issue that the gentleman just spoke about, I refer him and back to your own report on something that matters a great to both the lovers of wildlife and the consumers of wildlife, that is to say the moose On page 3-70 you say, and I quote briefly, the moose population is currently lower than what is prescribed in the Refuge comprehensive plan. Prescribed burns are utilized on the Kenai Wildlife Refuge a means of enhancing creating moose habitat, especially winter range. The presence of a transmission line could restrict the opportunity to apply prescribed burning. If burn programs are restricted the ability of the KNWR staff to create and maintain habitat to support the numbers of moose called for in the plan would be compromised. And then it goes on to deal with other things and then it says interference with the prescribed burn program would constitute a significant impact both locally and nationally 80 ASSOCIATES 105B Comment noted. 105C Affects to prescribed burning on the KNWR are described on pg. 3-143 of the DEIS. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 105C cont. 105D 10SE as 16 10 at each and every level from the subsistence or recreational hunter to the -- to those who are concerned about maintaining habitat, there is a glaring issue. That issue, by the way needs to be transposed into its economic cost terms. In many instances we seem to readily apply dollars to things like electric rates and then fail because somebody's moose in the freezer has an economic term and so do a viable habitat with wildlife. These things deserve to be, I mean crassly because this syatem is mich about that, dollarized along with everything else. This is not a project in any way, shape or form that could sustain itself if it were funded by private enterprise. We have both the RUS’s, the request made upon them, and money that was -~- $198 million dollars that was embargoed many years ago and has not been reviewed by our legislature. So in other words this is corporate welfare at its very -- with little or no indication that there -- that it’s going to read down to the benefit of the consumer. Better to send each and every Alaskan @ larger permanent fund check. It’s redundant technologically in the sense that -- in several senses. Apparently the intertie is requested both to provide some redundancy in case of avalanch and things of that nature and to supply additional electricity. Well, since the days that this was conceptualized we have moved in quantum fashion in terms of fuel sell technology and micro turbines. As for example, these matters are touched upon but are dismissed simply because they don’t Alaska 99503 1907) 276-3836 105D __ See Issue 13 (pg. 1-8) in Chapter | and Section 2.2.7 in Chapter 2 (pgs. 2-21 to 2-32) of the FEIS regarding environmental economic analysis. 105E See the General Response to Issue 14 in Chapter 1 (pgs. 1-8 to 1-9) of the FEIS regarding adequacy of alternatives analysis. 105E cont. 105F 105G n aa a Mu as 16 Ww 18 a 20 a 22 2 24 a 11 have much to do with bringing electricity from here to there ‘They need to be really looked at. They need to not only be looked at from a standpoint of economics and impact on the environment, but also because they didn’t exist way back when. And in the instances of avalanches obviously they are in some ways more protective of individual locations than essentially building the same thing twice. So I would encourage that to be done as well. And finally, in conclusion, I would like to suggest to you that the September 11th security issues are now a lair of issues that must be absorbed and considered. Our Governor has just spoken about millions upon millions of dollars that are going to be necessary to enhance our own security Alyeska is concerned about its pipeline, the northern oil fields of course are a matter of that integrated grid type transmission and technology products of yeateryear. And I say that quite confirmly -- with quite confidence, are going to be replaced with decentralized modalities that a: ecure for simply more all of us going down the road, or will require less by way of upkeep and securing, something that wasn't even thought about when this particular project was developed and designed I’ve touched on a number of areas, I am going to include some economic and some written testimony. It -- the figures offer little or no indication that in fact consumers will enjoy greater and cheaper electricity in Southcentral or that there is a need to do so. And left of course unstated is meeting the OM ASSOCIATES 111 %. Phrewed taps, Suite 200 ‘Anchorage, Alaska’ 99303 (909) 296-3586 105F 105G See response to written comment 15C — Alaska Public Interest Research Group letter (11/26/01) regarding security. See response to written comment 15F — Alaska Public Interest Research Group letter (11/26/01) regarding load growth. See also DEIS Section 3.7.3, Rate Impacts from the Project (pg. 3-189). Refer also to Issue | (pgs. 1-3 to 1-4) in the FEIS regarding need. 105G cont 106A 10 un 12 12 Kenai Peninsula‘s needs. I live both in Seward and in Anchorage and there’s a growing population there whose needs should not be ignored. Here again, the problem with dealing with something that has covered so many decades and so many years of analysis and study is that you have to sort of bring everything to the Present and project it to the future, my initial point. And I would appreciate it if you would do that as you reflect upon the testimony and this project. And I thank you all very much for the opportunity. MS. OXLEY: And thank you for speaking. The next person {8 Bill Nagengast MR. NAGENGAST: Good ning and thank you for the opportunity to speak a few words. My name is Bill Nagengast and I would like to just voice my strong support for the construction of this transmission line. It will I believe enhance the reliability of our electrical service, both here in Anchorage and for the folks down on the Kenai Peninsula will provide some redundancy which we do need. I also support it because of the economic value, it will allow better and more economic transfer of the energy that is now on the Peninsula to here in Anchorage as well as from Anchorage to Kenai when the need ari: + As far as the construction of the project goes, environmentally sensitive a: do need to be considered However I think we also need to remember that line construction technology has changed significantly from daya gone by. There ROM ASSOCIATES. ALL M. Pirewwed Lane, Suite 200 ‘anchocage, Alaska’ 99503 13909) 27623886 106A Comment noted. 107A 107B 10 uw 1a aa ot 1s 16 ww as a 20 a 22 23 a as are new mathods of construction and new ways of doing things that I think can be performed and come out with a very successful project. Thank you. MS. OXLEY: And thank you. Is there anyone else who wishes to testify at this time? Oh, I see, Randy’s got another list. Thank you. Vivian Mendenhall And then Steve Stanford and Michelle Wilson. MS. MENDENHALL: Good evening. My name is Vivian Mendenhall. I’m representing both the Alaska Office of the National Audubon Society and the Alaska Chapter -- and the Anchorage Chapter, I’m sorry, of the Society, whose area includes the northern Kenai Peninsula We support all reasonable measures to upgrade and maintain electricity supplies in our area. However, we are strongly opposed to the applicant's preferred route, the so called Enstar route, across Kenai National Wildlife Refuge. This route would have unacceptable impacts on the Refuge and its wildlife. Anda reasonable and prudent alternative to this route that would accomplish the same objectives without sacrificing valuable public resources. The Enstar route would cause unacceptable adverse impacts on wildlife of the Refuge. These impacts include loss of wildlife habitat and populations, wilderness qualities and the ability of Kenai National Wildlife Refuge to meat its legal mandai A power line in the Estar route would entially stop habitat management for moose, bears, wolv ind WOM ASPOCIATES 1119 4. Pirevesd Lane, uite 200 anchorage,’ Aisshs, 99503 1907) 276-3854 107A Comment noted. 107B The DEIS acknowledges that the Enstar Route would conflict with KNWR management plans (pg. 3-143). See also response to comment 13M — Alaska Center for the Environment letter (12/05/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 107B cont. 107C 10 a 42 a3 vy as 16 a7 vy as 20 a 22 a4 as 4 lynx in the eastern third of the Refuge. This is because Refuge managers would be obligated to put out every fire in the area in order to protect a transmission line that was built there. Periodic forest fires are important in the forest ecology of the Alaska interior. This hag been recognized over the last couple of decades. ‘They maintain the willow nasp and brush that are essential forage and cover for moose, lynx other wildlife Without fires the foreat loses these plants. The eastern half of the Kenai National Wildlife Refuge burned in 1947 and by now it‘s poor habitat for moose and lynx. and that’s -- these are low there as it says right in the DEIS. Whereas southwestern Refuge area which burned in 1969 supports high densities of wildlife being much better habitat up to this point. The Refuge Manager currently allows natural fires to burn throughout the eastern part of the refuge. It also does prescribed burning in a small part of thie area. The Enstar route would impair the Refuge’s habitat management at a nationally significant level as the DEIS acknowledges. The DEIS says the Enstar route would only impact habitats in the power line corridor itself, but that’s a gross understatement. rt says the line would interfere with prescribed burns but it completely neglects the much larger impact of preventing natural fires throughout that area. Hunting is an important xecreational use of Kenai National Wildlife Refuge as we've already heard. Among the most desired apecies are moose and ROM ASSOCIATES 1113 W. Pireveed Lane, Suite 200 ‘Anchorage, Alaska, 99303 (901) 276-3536 107C Recreational impacts are discussed in the DEIS (pg. 3-184). See response to written comments 5B — NMES (12/12/01) and 9B — Alaska DGC letter (12/05/01) regarding anadromous fish streams. See also response to written comments 14D and 14E - Alaska Center for the Environment form letter regarding impacts to brown bears and wildlife, and the USFWS Compatibility Determination in Appendix A of the FEIS. 107C cont. 107D 10 u a2 » ua as 16 7 18 as 20 2 22 a3 24 as 15 brown bear. Populations of both, excuse me, are below target levels. There hasn't even been a brown bear season since 1995 I understand. One hundred and fifty foot wide cleared power corridor would allow easier hunting access to the eastern part of the Refuge, which among other things include seven anagrimous (ph) fish streams where brown bears gather. We can foresee further hunting restrictions on moose with increased hunting acce: And possib -- probably increased loss of bears in defense of life and property even though no hunting season is open for them. They’ve been -- those have been increasing throughout the northern peninsula as a matter of fact. Several wildlife species of the Refuge depend on wilderness. Central third of the refuge has legal wilderness stetus, the eastern third is wilderness in character as the DBIS actually recognizes. Among the species that need larger areas of wilderness are brown bears, wolves and tundra swans. People might wonder about that, they live in Anchorage and see the bears in town all the time, however they’re here because they have adjacent areas of quite well protected wilderness on several sides. Even after construction is completed disturbance from increased human access would continue to affect those species in the area, at least for a certain distance out from the corridor. Recreation also would suffer Several lakes along the corridor are used for wilderness recreation, identified in the DBIS. Where people go to experience the ROM ASGOCLATES 1123 W. Pressed Lane, Suite 200 nachorage, "Alaska, 99503 1307) 296-3584 107D The DEIS recognizes recommendations for protection of brown bears, which include retaining large areas of continuous suitable habitat, and acknowledges that the Enstar Route could conflict with management objectives for brown bears (pgs. 3-68 to 3-69) and wilderness plans (pg. 3-143). See also response to comment 107C (above). 107D cont. 107E 107F 107G 16 1 beauty and the healing power of a wholly natural place. Those 2 qualities would be destroyed in all those areas by putting a 3 power line and a corridor right through them. I myself enjoy 4 flying my plane across the eastern Refuge past the mountains. 3 If the area were developed Id lose an important part of natural 6 Alaska that I enjoy and I probably wouldn’t go to that area anymore, I’d find some other way to get there. Chickaloon Flats is a state critical wildlife area. That’s the area at the 9 northeast corner of the Refuge right where the Chickaloon River 10 flows into Turnagain Arm. ‘Turnagain Arm population of Beluga 31 whales which is considered a depleted species by the National 12 Marine Fisheries Service calves and feeds in the Chickaloon Bay 13, flats. And up to 25,000 waterfowl according to the DES, and 14 shore birds, stage on the flats in the spring. When the birds 15 are migrating they gather there to feed. The DEIS does not 16 analyze how a power line could be buried in those flats as 17 called for the Enstar alternative during the applicant’s 1® preferred construction season without impacts on wildlife Though they do mention a couple of pl wwoiding the calving 20 «season of Beluga whales which is a part of that sensitive peak 21 period. In conclusion, the Enstar route would have major long lasting impacts on the Kenai National Wildlife Refuge, which is 23. a valuable public wildlife resource and wilderness The Refuge 24 is required by law to allow only uses that are compatible with 28 wildlife management and natural recreation. That‘s both in the ROM ASSOCIATES 111) M. Fireweed Lane, Suite 200 ‘Anchorage, Alaska” $9503 1907) 276-3854 107E See response to written comments 1N — EPA letter (12/05/01) regarding waterfowl. 107F See Chapter 2, Section 2.2.5 (pgs. 2-17 to 2-18) of the FEIS regarding beluga whales. 107G__ Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 107G cont. 107H 108A 7 3 Act that created the Kenai National Wildlife Refuge which is 2 ANILCA and in subsequent acts that define further what refuges 3. may allow and how they can determine that. The DEIS contains 4 flawed analy: The Enstar route is not the environmental preferred route, even though it’s the one that’s finally chosen 6 because of economic considerations alone. Furthermore, if the 7 real costs, the real value, of the wildlife and wilderness were @ determined according to accepted economic methods and compared 9 with the money value placed on the alternatives we believe that 1¢ it would also not be preferred on economic grounds either. We re to the EISB extensively revised to reflect better analyses. 12 And we'll be submitting much more extensive written comments 23 soon. Thank you ty MS. OXLEY: Thank you very mich. Steve Stanford 4s MR STANFORD: Hi, my name is Steve Stanford. I live here 16 in Anchorage but I'm also a property owner in Hope. And I have 27 to admit I have not read the draft, probably because I’m in 18 school and I have too much else to read. But what I did when I 19 first heard about the project, one of the things that came to mind was if -- and a real fundamental issue was if we have the 21 abilities to bury this line across the inlet and maintain it in 22 one of the highest tidal fluctuation areas in the world why 23 «can't we just go right off the coast of Nikiski and follow the 24 mud flats and render all these fire issu access issues, 35 maintenance issues, terrorism, whatever people bring up 107H See Issue 13 (pg. 1-8) in Chapter | and Section 2.2.7 in Chapter 2 of the FEIS (pgs. 2-21 to 2-32) regarding economic analysis. 108A The high cost of a cable installation along the coast from Nikiski to Anchorage would render the Project financially infeasible. See comment 108B (below) for a more detailed explanation. See also FEIS Section 2.2.1, Project Benefits and Costs (pgs. 2-1 to 2-4), and Section 2.2.3 Underground Construction Costs (pgs. 2-11 to 2-14) for further information. 108A cont. a3 Mu as 16 Bt Ty a 20 2 22 23 25 18 security, all that, it would just seem to make sense that we would just go right off and go mud flate all the way, just lay it in, when it’s down it’s done. Because what I’ve noticed, I mean obviously it is some redundancy. And, you know, the entities that do power and power management are always going to want to have some cush room. And I understand their logic is to maintain their grid and their basis and everything and I don’t really fault them for that. But what I do as an issue is again, some of the other topics that have been addressed by the other speakers. You're taking this 200 foot swath through basically one of the best pla on the whole Kenai Peninsula because you -- you know, as development’s going to occur all of those other areas are going to become major issues. And your especially your transmigration and all that other stuff with various speci: re going to be affected. And it just -- you know I look at this and I‘m thinking and if I was the director of this consortium I‘d want to, you know, just put it in the mud, just bury it, so I’m not screwing around with litigation, fires I mean there’s a host of iasues that will go on. And, of course, I would like to see in the next draft BIS that possibility at least costed out. You know, why was that not even touched? Beca' I know we have the ability to drop cable lines very well now, very efficiently, after working on the slope and seeing some of the -- even the technology we had going on up thei It's not that difficult. And I would be ROM ASSOCIATES 1113 4. Pireweed Lane, Suite 200 99303 108B 108C 108D 19 curious to see what is the cost compared to -- because we're and since we are also involving federal money, that this could be a justifiable cost in the sense of a long term cost maintenance How much will it cost? Is there any -- been any -- and I haven’t read that, but to look at the long term maintenance costs of maintaining this line, especially if you can factor in hypothetical events like fires and other things? What‘s that going to cost over the life of -- well, if the md line as you want to call it were to cost $130 million, who knows, I don’t know the figures. But if it wasn’t that mich more then with the federal monies being involved and all of the other contentions going on, you know, it’s possible that this consortium could spend $200,000.00 to $500,000.00 in litigation before they even get the line built. And so I -- it’s one of those things that I’d like to see in the next round of the EIS is not just two alternatives. Basically we have an industry picked alternative and then we have an old kind of muddled alternative on the Tesoro route. But there really has been no ~~ you know, usually you try and look at more options. And I and you look at the map and it just seems to make sense that you could just boom, boom But it’d be nice to see that in the next BIS, at least some kind of estimate. And the long term like annual yearly maintenance cost. How much is it really going to cost to maintain this above ground system and do all the associated prerequisites, error, all that stuff So I guess FROM ASSOCIATES. 3113 M. Firewed Lane, Sulte 200 ‘Anchorage, Alaska. 9950) 1307) 276-3886 = 108B Maintenance costs for both the Tesoro and Enstar Routes have been incorporated into overall cost evaluation. See DEIS Section 1.4.1, Construction and Life Cycle Costs (pg. 1-31). See also responses to comment 1H — EPA (12/05/01) for more information on Project costs. Installation of a submarine cable the entire distance from the Bernice Lake Substation on the Kenai Peninsula to the Pt. Woronzof substation in Anchorage would be very expensive, due to the high cost of submarine cable circuits and the long distance involved. In addition to installation of the submarine cables, it would be necessary to bring the cables onshore at intervals to install reactive compensation facilities. Reactive compensation involves the installation of specialized equipment in a substation to allow voltage support for the system or to increase power flow across a transmission line segment (DEIS pg. 2- 47). Reactive compensation is needed to offset the charging current in the submarine cables to allow the desired amount of power to flow between the Kenai Peninsula and Anchorage. While no engineering studies have been completed for this option, reactive compensation would at least be required at Bernice Lake Substation, a new location halfway to Pt. Possession, Pt. Possession, and the Pt. Woronzof Substation. The following is a comparison of the proposed project cost and the approximate cost for an all-submarine cable alternative using Route Options A, D, and N. For this comparison, costs for the various types of facilities required were adapted from the 1998 Power Engineers cost study (also listed in DEIS Table 1-12, pg. 1-31). The information for the proposed project is listed first. miles of submarine cable: 13.9 vs. 65 constructed cost: $99.5 vs. $217 million present worth of operation and maintenance costs: $4.3 vs. $4 million present worth of submarine cable replacement costs: $10.7 vs. $50 million total life cycle costs: $114.5 vs. $271 million The high cost of an all-submarine cable alternative would make the Project financially infeasible. For responses to 108C and 108D please see next page. 108E 109A a ty as 16 7 us aw 20 a 22 23 a 20 that’s about what I wanted to cover. Oh, and I was going to way, it‘d be nice for people who are testifying -- it’s one thing to be pro energy but give the route idea. Beca I think what's really going on here is not so much that we don’t need thie route or we don’t need a linkage, it’s the choices. 80 I think, you know, if the choice was fairly benign then you would have almost no opposition to this project. And it may be worth an extra, you know, $10, $20 million. I know that’s a lot of money, but in Al . well, you know So, anyway, thank you. MS. OXLEY: Thank you Steve, And Michelle Wilson. MS. WILSON: Hi, I’m Michelle Wilson speaking tonight on behalf of Alaska Center for the Environment. Alaska Center for the Environment is the state's largest nonprofit advocacy organization. We have over -- list of 20,000 -- excuse me, 20,000 members, or contacts. We have a strong concentration of our members based in Southcentral Alaska. And I wanted again by saying that Alaska Center for the Environment is committed to energy solutions for the Anchorage bowl and beyond that really look at energy solutions that aren‘t at the coat of our natural heritage. We're very concerned with this intertie project with it’s preferred alternative route at this time And we‘re also concerned at the long term implications of cable crossings, I'm glad to focus out int -- or talking about that tonight. And we have a couple questions regarding the history of cable crossings in the Knik Arm area well as the future proposala for two of oom AssocrATES 1119 M. Pireveed Lape, Quite 200 anchorage, Alaska, 99809 1907) 276-3836 108C See the General Response to Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding alternatives analysis. 108D See response to comment 108B (above). 108E Comment noted. 109A Comment noted. 109B 109C 109D ue 13 ae 17 us a a0 a 2 23 24 the main alternatives that are being proposed. First I'm I'd like to just -- I mean I'm just also interested in knowing if the rate payers or the consumers involved in Chugach Blectric were notified about this meeting tonight. Because I think a lot of rate payers with Chugach Electric should be at this meeting right now and knowing the alternatives that are being posed by Chugach Electric company. We were very excited when Chugach Blectric a few maybe months ago gave their rate payers the option to look at wind energy in Portage. And we think this ie @ great step in the right direction for Chugach Electric. Unfortunately it does ask rate payers if they'd be willing to pay more to have wind energy. And we thihk that actually projects like this that the state and federal governments are bringing to Chugach Electric to subsidize should actually be subsidizing more sustainable projects like wind energy. And the wind energy project in Portage is a great proposal because it would hook up with the existing power line and that’s one of the reasons why the Courts (ph) Creek alternative is really interest -- we're really interested in that alternative because of those options. So I‘d really like to hear more about the wind energy projects and other ideas that Chugach Electric has to offer rate payers here in Anchorage 0, let’s see. And then let’s just talk a little bit about this preferred alternative. There’s several reasons we agree with other folks that have spoken tonight, why we clearly oppose the preferred alternative through ROM ASSOCIATES 1219 Wt. Fireweed lane, Bulce 200 ‘Anchorage, Alesha, 99303 1907) 276-2854 109B Comments noted. Consultation and coordination efforts and public comment on the DEIS are described in Section S.6 and S.7 (pg. S-24), and Chapter 1, Section 1.2 of the FEIS. 109C Comments noted. The DEIS evaluated a number of alternatives, including wind energy and the Quartz Creek Route. See DEIS Section 2.2, Alternatives Studied and Eliminated from Detailed Study (pg. 2- 1). Specifically “Wind Generation” (pg. 2-6) and Quartz Creek Transmission Corridor (pg. 2-8). These alternatives do not meet the purpose and need for the Project. See General Response to Issue | (pgs. 1-3 to 1-4) and Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding purpose and need and alternatives analysis for the Project). 109D Comment noted. 109E 22 the heart of the Kenai National Wildlife Refuge But let’s -- I to talk @ little bit about the cable crossings. We think that they’re, one, cost prohibitive, and two, that they’re really a danger to our declining population of Cook Inlet Belugas. Residents of Anchorage and the Kenai Peninsula, we live here primarily because we enjoy the fish and wildlife and recreation opportunities of why we're here. And we really need to be careful about submarine cables when we're -- from -- according to the DIS those cable crossings are going to happen during the summertime and the most important time for Belugas in Cook Inle pecially the upper part of the inlet, is the summer months. And Chickaloon Bay, as has been mentioned, is a primary sensitive habitat area for Cook Inlet Belugas, it concentration area. If you've ever gone out there in the summertime it’s just amazing to look down and see hundreds and hundreds of Cook Inlet Belugas, although those are getting less and less, in this one region. And for subsistence -- I mean there’s lots of reasons why we want to maintain the Beluga population in our inlet and it’s a primary marine mammal for touriem and also just for the health of our quality of life here. So we're really concerned about the Chickaloon Bay cable crossing We're also concerned about seismic testing that would come at the result of cable crossings and cable lane and maintenance. Obviously cable cr -- cables have a, you know, 15 to 20 year life span, they're not, everyone who works for OM ASSOCIATES 1113 M. Tireweed Lane, Suite 200 sochorage, Alseha’ 99303 1907) 276-3886 109E See Chapter 2, Section 2.2.5 (pgs. 2-17 to 2-18) of the FEIS regarding beluga whales. See also responses to comment 1H — EPA letter (12/05/01) for more information on Project costs. 109E cont. 109F 109G a3 19 20 a a2 as 23 109F The submarine cable circuit installed in the Knik Arm in 1999 cost Chugach Electric here knows and others, that this ia not a term deal. And we want to know -- you know, the rate payers are going to have to cover the cost of the maintenance over the term. If something happens to those cable crossings they're they cost millions at times to repair, either bring in experts from other parts of the world. To us it just seems like when you're comparing maintaining cable crossings and fixing those compared to avalanches where you have to, you know, maybe build @ better avalanche safe power line, to us it seems like power lines above ground are a lot more cost effective and better than cable crossings. So questions we do have and would like to get answers to before the comment deadline, the Sth of December, is what are the cost of cables, how much does a submarine cable cost per foot versus an overhead wire, how many cables have you placed in -- or has Chugach Blectric or others placed in Knik Arm and at what cost and how many of them are still in use. Turnagain Arm has turbulent waters and we're concerned that that‘s not appropriate for cable crossings. While there have been cable crossings in the Knik area, you know, what are the dam -- the dangers of having one in the Turnagain Arm area The channels are undercut, the chaff and they fail and with turbulence they could also affect the shoreline areas. This goes back to another reason for us to support decentralized energy options versus cable crossings and other types of more centralized power lines And our concerns about the long term RON ASSOCIATES 111) MW, Pireweed Lane, guite 200 ‘Anchorage, Alaska’ $3502 1907) 276-3554 109G $650 per foot (installed cost). This circuit consists of four individual cables (three cables for the electrical circuit and one spare cable). The submarine cable circuit installed in 1990 cost $750 per foot. Costs for cables installed prior to 1990 are not available. When considering submarine cable costs, it should be kept in mind that submarine cable costs can vary widely because of the limited demand for submarine cables worldwide, as compared to overhead cables. The price paid for a submarine cable will depend on what other submarine cable Projects are ordering when a price is negotiated. The overhead line proposed for the Tesoro Route segment north of CCSRA would consist of three 1.1-inch-diameter aluminum/steel conductors (wires) suspended from guyed steel X frame structures. For comparison to the Submarine cable costs, the estimated cost of that overhead line circuit is $114 per foot (installed). Because of the large difference in the cost of a submarine cable circuit versus an overhead line circuit, it is always preferable to construct overhead lines where feasible rather than a submarine cable circuit. However, where an overhead line is not feasible, such as crossing the Turnagain Arm, submarine cable is proposed. There have been 14 cables installed in the Knik Arm between Pt. Woronzof and Pt. McKenzie since 1967. Currently, eight of these cables are in use. In addition, in 1981 a 230kV cable circuit was installed between the Six Mile East and West substations farther north up the Knik Arm. This 230kV submarine cable circuit (consisting of four individual cables) is currently in use. Therefore, the total number of submarine cables currently in use in the Knik Arm is 12. Submarine conditions and mitigation are described in Section 3.4 (pg. 3- 27) of the DEIS. See Chapter 2, Section 2.2.5 (pgs. 2-17 to 2-18) of the FEIS regarding beluga whales. See also General Response to Issue 14 (pgs. 1-8 to 1-9) in Chapter | of the FEIS regarding alternatives analysis. 109G cont. 109H 1091 1095 24 2 costs in terms of maintenance, repair and other maintenance 2 areas during the summer montha when the Belugas are there. @ between the 2. the Belugas, our biggest concern for Belugi 4 months of May and September where we'd like to see no [5 construction maintenance activities occur at all. And clearly 6 there's many arguments stated in the draft BIS and why the 7 Refuge preferred route is not good based on cumlative impacts @ of oil and gas production that already occurs in the Refuge. We 9 feel this is not compatible in terms of the cumulative impacts 40 that we feel that the species of special concern listing for the 41 Kenai Peninsula brown bear needs to be considered by every state 32 and federal and local agency that plans to do any projects in 13. that area. Power lines clearly also bring in increased human 14 access by snow machines in the winter and other users that some of which 45 traditionally don’t have access to thei rea! 16 a eligible wilderness. And we have a dr -- we have a new land 17° management plan coming up on the Kenai National Wildlife Refuge 18 in the coming year and folks are going to really want to talk 19 about some of these eligible wilderness areas. We are also 20 concerned about the fact that we're not going to be able to see 21 «prescribed burns in game unit 15 which will directly affect 22 «subsistence communities of Ninikchik, Hope and Cooper Landing 23° And we're, you know, not necessarily convinced that the Tesoro 24 route is the second best alternative. That route also brings in 25° a new road to an area outside the Refuge that would still bring ROM ASSOCTATES 1113 W, Fireveed Lane, Suite 200 ‘Aachorage, Alaska 99503 1907) 276-3554 109H See response to written comment 14C — Alaska 1091 109J Center for the Environment regarding cumulative impact analysis. The DEIS acknowledges that the Enstar Route would conflict with KNWR management plans (pg. 3-143). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. See response to written comment 130 — Alaska Center for the Environment letter (12/05/01) regarding prescribed burning and subsistence. No new long-term access for the Tesoro Route would be required, except for Option B (Link T-11) on Fire Island (which would not increase access to KNWR). See DEIS Summary (pg. S-6), and Section 2.6.2, Environmentally Preferred Alternative (pg. 2-59). See also Appendix B, Table B-1, and Section 2.5.3, Construction Access, Overhead Facilities (pg. 2-52), and the Mitigation Plan in Volume II of the FEIS. 109J cont. 109K 23 4 as 25 in increased access and impacts and adverse impacts to egion. And we would like to see a more thorough analysis of the Courts (ph) Creek alternative This is an existing line that already has disturbances that have taken place. And it seems like one of the main arguments against the Courts (ph) Creek alternative is the fact that there’s been avalanches in the past. During the avalanches of ~~ I couldn't remember if it was ‘88 or ‘89, certain power lines were taken out and so there was some construction done. There ~ I think there's ways to mitigate and move around that. You know, we have great technology this time and human evolution. We can, you build power lines that mitigate avalanche damages which is the better alternative than the other ones. And so, again, I'd like just to go back to looking at other alternatives like the wind energy project and other alternatives that aren‘t well analyzed in this project. And Rural Utility Services, I thank you for being here and look at this project. I think Alaska could really benefit from some rural utilities such as tidal energy in Cook Inlet, wind energy fuel cells that are long term sustainable solutions for the residents that love our natural heritage and wildlife and fish here. Thanks. MS OXLEY: Thank you Michelle. Are there others Randy on your list? Thank you. Is this Gregory? MR. ERRICO: Yes ma‘am. I support the power line. MS. OXLEY: Gregory, can you -~ for the record can you ROM ASGOCIATRS 111) M, Plreweed Lane, Suite 200 Alaeke 99503 tbr 76-3550 109K See response to written comment 20M — The Wilderness Society (12/05/01) and 21A — Wilderness Society form letter (12/03/01) regarding the Quartz Creek Route. See also the General Response to Issue 14 (pgs. 1-8 to 1-9) in Chapter 1 of the FEIS regarding alternatives analysis. 110A 111A 26 4 give your full name? 2 MR ERRICO: Gregory Michael Errico. I’m directly impacted by it. It would come up my back yard, the preferred 4 alternative route. But they have already taken into 5 consideration the impact to myself and my neighborhood as well 6 as the environment through that area by putting it underground 7 It also minimizes the submarine cable crossing and that’s why I'm voicing my support for the preferred route. Thank you ’ MS. OXLEY: Thank you. And Marcie, did you wish to 10 comment too? Is she still in the room Gregory? ua MR. ERRICO: I’11 go get her, she’s (indiscernible 2 MS. OXLEY: And while he’s doing that I’d just like to 13. make sure everybody understands that the comment period ia open 14 until December 5th There’s one more public hearing that’s 15 scheduled for tomorrow night in Soldotna. Otherwise the 16 comments need to be submitted in writing. And the handout you 17 picked up at the door gives you all the information about where 18 todo that Hello Marcie, did you have comments? wy MS. ERRICO: I did. 20 MS. OXLEY: Would you state your name, your full name? a MS ERRICO: My name is Marcie Errico. And I reside at 22 «1184 Oceanview right along the route along the railroad tracks. 23 And I just wanted to make a few comments about the applicant’s 24 route which I understand ie the preferred route for the 25 alignment Right along that railroad right of way is the ROM ASSOCIATES. Me, Eitwrond tape, Butte rage, Alaska. 99503 1989) 2763888 110A Comment noted. 111A cont. 111B 40 uw 12 » avy as 16 wv 18 19 20 a 22 23 24 a5 27 there's several things that go on there. There’s a small airstrip which I understand the intent was to underground line to north of the airstrip and I would highly encourage you to follow through with that thinking because of all the implications with the aircraft coming through there. The other aspect is that within that right of way there are sections where there’s some open green spaces but then there are also a number of heavily treed spaces that buffer the residential neighborhoods on either side of the railroad tracks. And to implement either an overhead or an underground route through that area there’s going to end up being a large amount of clearing that will have a great impact on the visual buffers within the neighborhood both for the residents as well as the people who use that area for recreation. That right of way xight along the railroad tracks is a very common activity area where people ski and walk their dogs even take their mountain bikes along there, it’ very active area, And one of the keasons it’s go active is it does have a natural setting buffers the users from the neighboring homes as well. And so to lose that vegetative buffer along there will definitely have an impact on the users That may be unavoidable. I guess my recommendation would be to pursue all possible means to limit the amount of clearing that needa to happen both for even if construction and for maintenance purpos Beca things are allowed to grow back after construction and they’re ROM ASSOCIATES 111) W. Pireweed Lane, Baite 200 ‘Anchorage, Alaska. 99503 19071 276-3956 111A 111B Comment noted. The proposed route will be underground near Flying Crown airstrip. See DEIS Section 3.6.3, Alternatives, Oceanview Park to International Substation via Alaska Railroad — Route Option K (pg. 3-147). The visual impacts and associated mitigation measures in this area are described on pgs. 3-258 to 3-260. These measures include undergrounding, selective tree clearing and the use of single poles as shown in Mitigation Plan in Volume II of the FEIS. 2 only cut just for the initial purposes those trees will take 2 to 40 years to grow back to the size that they are now. And so 111B cont. I guess I would just hope that in the proc of looking at preferred route that thought is given to the current users of that area as well as the residents and the -- kind of the aesthetic status of that area as kind of a nice pristine area to walk around in, Thank you 20 nu cty a3 ry as 16 uv a6 aw 20 a a2 23 4 as CHUGACH ELECTRIC ASSOCIATION HEARING ON SOUTHERN INTERTIE PROJECT November 14, 2001 Soldotna, Alaska RRQCEEDINGS FROM ASSOCLATES 112) M. Pireeed Lane, Suite 200 ‘Rochorage, Alaska’ 9950) 1907) 276-3858 10 n 42 as “ 1s a ” aw ty 20 ry 2 a a DR. STARK: Good evening, my name is Dr. Douglas Stark, I live in Homer, Alaska. My connection with this project goes back about 20 y 6 or 80. I was a major participant in a number of organizations including the energy committee of the Anchorage Chamber of Commerce, Susitna Power now and Susitna Finance Committee, promoting the Susitna project which was a dam on the Susitna River north of Talkeetna. As you may recall, at that time the State was flush with the money from the oil pipeline and there was a proposal to build a major dam which required a large amount of State funds. And our groups had basically the -- probably the lead responsibility in securing hundreds of millions of dollars that were appropriated for that project. What happened, of course, in 1986 was that the economy crashed which did two things It removed the source of funds and it also removed the justification for the project because of @ massive decrease in population of Alaska. We then continued to pursue the construction of the Bradley Lake project which, as you know, is one of the main reasons for building this intertie. OOH ASSOCIATES 11D) M. Plreweed Lane, Suite 200 Alaska’ 99503 ih a7bsa330 112A 112B as I'm alo a commercial pilot and I fly periodically between Homer and Anchorage. And basically I fly up the Enstar route and I’m very familiar with it. And of course I’ve read the Environmental Impact Statement. I happen to be a big supporter of brown bears, black bears and lynx. In various subdivisions that I’ve developed I’ve put in the covenants measures which protect the bears probably more than anybody would believe. f do feel though that the animals can adapt. I think there needs to be certain stipulations in the permit which would protect them both during construction and after construction, including not allowing removal of the roads so that people couldn’t drive up along the route. And I’m also very aware of the difference in the life cycle cost between the two routes, which is $15 million dollars. And as somebody that’s had a big hand -- oh by the way, what happened with the money that was left over, appropriated for the Susitna project and the Bradley Lake Project, became the rail belt energy fund which then became the major source of funding for the construction of the southern intertie. And of course also the northern intertie which is presently under construction. So basically I think that the Enstar route would not negatively impact the animals and I think that the money saved would be noticeable and could be put to somewhere else and I’m very much in favor of the En route. I'd be glad to answer any questions MS. OXLEY: They‘re not really here to ask questions, just Alesha 99803 W987i 276-3586 112A See response to comments 1M — EPA letter (12/05/01), and 112B 14D — Alaska Center for the Environment regarding impacts to brown bears. Comment noted. Additional information on project cost has been included in FEIS Chapter 2, Section 2.2.1 (pgs. 2-1 to 2-4). See also response to comment 1H — EPA letter (12/05/01). 113A ty 2 B 4 as 16 wv as a9 20 2 22 2 4 a5 to listen to yours DR. STARK: One way MS. OXLEY: Yeah. Thank you very much. Jack Dean MR. DEAN: Hi, my name is Jack Dean, I’m a retired fishery biologist. I retired from the Fish and Wildlife Service in 1987. And while I was employed I was the Project Leader down here at Kenai on the fishery program. And one of our projects was the study on the Chickaloon River that we studied in 1984 and 1985 and I was in charge of that study and I participated in it as much as we -- as I possibly could. The Chickaloon River supports the largest salmon runs on the north side of the Kenai Peninsula north of the Sterling Highway and it also provides the best brown bear habitat north of the Sterling Highway on the Kenai Peninsula. During our firet year of study the forest service had a brown bear study team that was studying brown bears here on the Kenai Peninsula and we were running into more brown bears than the brown bear study team was. in fact they started going out with us. And we weren‘t looking for brown bears. So it hi a notable brown bear population. 1 know the > some of the tagging studies don’t show that, but when you've got an area out there that’s very difficult to see bears from the air and if you do tag them from the air, or dart them from the air, the "a very few places where you can land out there to put a radio collar on them. So they're probably not represented as well as they should be in the bear studies around here, but NOM ASSOCIATES 1319 W. Pireweed Lane, suite 200 rege, Alaska’ 39503 1301) 276-3554 113A See Section 2.2.6 (pgs. 2-18 to 2-19) in Chapter | of the FEIS regarding impacts to brown bears. 113B 113C 113D 113E 10 n 12 1a vy as 16 7 a 1s a a2 20 there’s plenty of them out the: ‘The other concern or one of my concerns is that frankly thie National Wildlife Refuge here is being nickeled and dimed to death. We have town -- whole townships have been removed for either settlement or in the case of the Bradley Lake hydro project We've got oil wells and gas wells and gravel pits and highways, a natural gas line. And there seems to be -- it’s just an unending process. And so far I haven't seen any indication that the Fish and Wildlife Service quite frankly is opposing any of these developments Years ago yell, this Enstar pipeline, gas pipeline to Anchorage, was put in, oh I forget the time interval, but I think it was back in the 1970’. And at that time in order to stop anymore, you know, utility corridors across the Refuge the Fish and Wildlife Service willingly gave up this corridor along the coast on the Tesoro route and that was to be the route for utilities from Kenai to Anchorage. ‘The other thing is that back in the early 1980's this Refuge went through a comprehensive planning process which was also an environmental impact statement. And during that process they identified five different land categories on this Refuge, everything from wilderness to pave it over and make a parking lot out of it And with each of those land use categories they had a set of criteria that they went through and they -- and by table forum they said put in there what would be allowed and what wouldn’t be permitted in these various categories. They ha -- the top category was called AL 19895 276-3886 113B 113C 113D 113E See response to 14C — Alaska Center for the Environment regarding cumulative impact analysis. See response to 21A — Wilderness Society form letter (12/03/01). Comment noted. Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. 113E cont. 113F 113G a 1 wilderness, then they had one called minimal management, the 2 next one was traditional. And those three categories all said 3. that there would be no utility corridors permitted. Two of 4 those land categories will be crossed by this electric intertie. 5 If that comprehensive plan and Environmental Impact Statement is 6 still in place and still active I’m kind of wondering what we're even doing here this evening talking about an Enstar route. Another thing that bothers me is that in this Environmental s a mention 9 Impact Statement I can’t see any evidence that the: 10 of the $45 million dollars that the utility companies have to 11 buy this -- or to build this intertie and I’m kind of wondering 12 how that fits into this economic analysis with these real nice 13. cost benefit ratios on this thing. I suspect if we pulled out 14 the $45 million we wouldn’t be talking about this electric 15 intertie. Another thing that bothers me is that it seems like -- I know we have to go through this compatibility analysis on this thing, but I haven’t -- I don’t believe this regional office could find anything incompatible down here at Kenai quite frankly, to be real honest about it. And I don’t believe they have turned down a single development down here at least in the last six or eight years that I’ve been aware of. And I’m beginning quite frankly to wonder who the Fish and Wildlife Service represents on these things. Do they represent the resource or do they represent the developers? And with that T will leave -- that’s all I have to say. HON ASYOCLATES. JTL) W. Fireweed bane, Buite 269 Anchorage, Nawka” 99509 1809) 276 3544 113F 113G See DEIS Section 1.4.1, Construction and Life Cycle Costs (pg. 1-31). Of the $90.2 million cost for the Enstar Route, 46.8 million would be state grant funding (see Table 1-12). The remaining $43.2 million would be a cost shared by the six members of the IPG. Additional information on project cost has been included in FEIS Chapter 2, Section 2.2.1 (pgs. 2-1 to 2-4). See also response to comment 1H — EPA letter (12/05/01). Refer to the USFWS Compatibility Determination in Appendix A of the FEIS. CHAPTER 2 SUPPLEMENTAL INFORMATION CHAPTER 2 —- SUPPLEMENTAL INFORMATION 2.1 INTRODUCTION Information in this chapter addresses addenda, modifications, and corrections to the DEIS. This includes any additional information that was not included in the DEIS, modifications to information presented in the DEIS, and corrections to any erroneous information in the DEIS. 2.2. SUPPLEMENTAL INFORMATION In this section, additional or more detailed information has been added to the FEIS to supplement the DEIS and address comments and information requests received during the public comment period on the DEIS. The information includes (1) additional information on project benefits and costs including cost by route option, (2) a comparison of cost and technical factors of alternatives, (3) additional information regarding undergrounding of transmission lines, (4) expanded explanation on elimination of BESS as an alternative to the Project, (5) update on beluga whales, (6) update on Kenai Peninsula brown bears and wolverines, (7) environmental cost/benefit analysis review summary, and (8) additional information on avian collision. 2.2.1 Project Costs and Benefits The following information supplements the DEIS cost section (DEIS pages 1-31 through 1-32) and provides additional economic information for alternatives considered in detail. Construction and Life Cycle Costs The construction costs for the Project were estimated by Power Engineers, Inc. in 1996 and were updated in 1997/1998 (Power Engineers 1998) to reflect the facility requirements identified for the Project. The updated cost study also determined the present value of the operation and maintenance, and submarine cable replacement costs over the 40-year Project life. A discount rate of 4.5 percent was used as recommended by the Alaska Energy Authority (AEA) based on the long-term real cost of money (AEA March 1991). The results of this study are summarized in Tables 2-1 and 2-2 (pages 2-2 and 2-3) of the FEIS. For a description of the routes see Chapter 2, Sections 2.6.2 and 2.6.3 of the DEIS. Construction Cost To determine the construction cost for the Project, conceptual designs were prepared for each aspect of the Project and are documented in the Power Engineers Cost Summary Report (Power Engineers 1998). Determination of the construction costs included specifying typical overhead line structure types by line segment depending on expected weather and terrain conditions, and Southern Intertie Project Chapter 2 —- Supplemental Information Final EIS 2-1 July 2002 preparing preliminary layouts for the substation and cable transition stations. For the underground and submarine cable installations, typical cable sizes and installation techniques along with land and submarine ground or bottom conditions were reviewed as well. Where appropriate, vendor quotations for materials were obtained and combined with historical prices from actual projects. Estimated costs for the submarine cable and installation were compared to the actual bids received by CEA (January 1998) for replacement of their Knik Arm cables. Also included in the estimate were both winter and summer construction, and air support for transportation of personnel and materials. TABLE 2-1 SUMMARY OF COSTS AND COST/BENEFIT RATIOS (MILLIONS OF 1997 DOLLARS) Present Worth of | Present Worth of Cost/ Constructed] Operation and Submarine Cable | Total Life | Benefit Routes Cost___|Maintenance Costs! Replacement Costs | Cycle Costs | Ratio* i Tesoro Route Alternative via Pt. Campbell Route Options A, D and N $99.5 $4.3 $10.7 $114.5 1:25 via Fire Island Route Options A and B $99.4 $5.4 $13.0 $117.8 1.22 Pt. Woronzof via Submarine cable direct $106.2 $4.7 $13.2 $124.1 1.16 |Route Options A and C Enstar Route Alternative Soldotna South/Alaska Railroad [Route Options Es, F, H and K $202 $6.1 $3.3 $99.6 a Soldotna North/Alaska Railroad Route Options En, F, H and K $89.7 $6.1 $3.3 $99.1 1.45 ‘Soldotna South/Klatt Road Route Options Es, F, G and J $90.1 $3.8 $3.5 $97.4 1.47 Soldotna North/Klatt Road Route Options En, F, G and J $89.6 $3.8 $3.5 $96.9 1.48 Soldotna South/Old Seward Highway $90.1 $3.6 $2.8 $96.5 1.49 Route Options Es, F, I and M Soldotna North/Old Seward Highway $89.6 $3.6 $2.8 $96.0 1.49 [Route Options En, F, 1 and M * Project benefits are $143.5 million from Table 1-11 in the DEIS. IEs — E South En — E North Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-2 July 2002 TABLE 2-2 SUMMARY OF LIFE CYCLE COSTS BY ROUTE OPTION’ (MILLIONS OF 1997 DOLLARS) Present Worth of Present Worth of Route Constructed Operation and Submarine Cable Total Life Cycle Option Cost Maintenance Costs_| Replacement Costs Costs A $47.4 $3.2 $0.0 $50.6 B $52.0 $2.2 $13.0 $67.2 (e $58.7 $1.5 $13.2 $73.4 D $41.9 $0.9 $10.7 $53.5 N $10.1 $0.2 $0.0 $10.3 E North $17.7 $0.6 $0.0 $18.3 ESouth |_ $18.2 $0.6 $0.0 $18.8 F $28.1 $1.7 $0.0 $29.8 G $37.3 $0.9 $3.5 $41.7 H $36.1 $0.8 $3.3 $40.2 I $32.1 $0.8 $2.8 $35.7 uJ $6.3 $0.7 $0.0 $7.0 K $7.8 $2.9 $0.0 $10.7 M $11.6 $0.4 $0.0 $12.0 1, So that the individual route option costs will add up to the overall cost for one of the Tesoro or Enstar| alternatives, the costs are inclusive of all overhead line, land type underground cable, submarine cable, substation, transition station costs, and initial right-of-way costs occurring in a given route option. Environmental permitting and compliance monitoring costs are allocated across the route options. 2. Costs for Route Options A and F, common to the Tesoro and Enstar alternative routes, respectively, include} required reactive compensation modifications at Dave’s Creek Substation and the Bradley Lake to Soldotna! l Substation microwave upgrade (DEIS page 2-47) in the amount of approximately $6.5 million. Operation and Maintenance Costs Annual operation and maintenance costs were determined based on a typical program of annual maintenance for each type of facility, and the present worth was calculated over the life of the Project. Submarine Cable Replacement Costs Based on experience with submarine cables installed in the Knik Arm since 1967, CEA determined typical replacement intervals for submarine cables in that environment. The replacement intervals depend on whether the submarine cable is installed in an embedded or non- embedded configuration. The non-embedded configuration, in which the submarine cable is simply laid on the bottom, is used in locations where it is not practical to embed the cable. In the embedded configuration, the cable is physically buried in the bottom using special equipment. Based on discussions with CEA personnel, cable laying contractors experienced with conditions in the Knik and Turnagain arms, and bottom and side scan sonar surveys conducted along the proposed marine routes during the summer of 1996, appropriate replacement intervals for the Southern Intertie submarine cable were determined. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-3 July 2002 The cable replacement schedule for the non-embedded cables for Route Option C or D of the Tesoro Route is to replace two single-phase cables or one three-phase cable twice during the Project life (years 17 and 34), depending on the type of cable initially installed. Route Option B of the Tesoro Route has two submarine cable segments, one from Pt. Possession to Fire Island (Link T10) and one from Fire Island to Pt. Woronzof (Link T14). Link T10 from Pt. Possession to Fire Island extends out into the Cook Inlet where harsher marine conditions exist as compared to Route Option C or D. For Link T10, the cable would be non-embedded and the replacement schedule is to replace two single-phase or one three-phase cable three times during the Project life at 12-year intervals (years 12, 24 and 36). Marine conditions for Link T14 from Fire Island to Pt. Woronzof are such that the cables can be embedded, and so the cable replacement interval is one single-phase cable or one three-phase cable once during the Project life (year 30). For Route Option G, H, or I on the Enstar Route, the cable can be embedded for the entire distance and the cable replacement schedule for these routes is one single-phase cable or one three-phase cable once during the Project life (year 30). Life cycle costs are the sum of the constructed cost, plus the present worth over the Project life of the operation and maintenance and cable replacement costs. The present worth of the Project benefits is the total from Table 1-11 of the DEIS. Benefit/cost ratios are calculated for the Tesoro and Enstar routes as shown in Table 2-1 (page 2-2) of the FEIS. 2.2.2 Cost and Technical Comparison Discussion of Route Options The purpose of this discussion is to compare the various route option combinations for the Tesoro and Enstar alternatives, explain what combination of route options comprise a cost/technical preference for the Tesoro alternative and, separately, a cost/technical preference for the Enstar alternative. Tesoro Route Alternative The Tesoro Route alternative extends from the Bernice Lake Substation on the Kenai Peninsula to the Pt. Woronzof Substation in Anchorage. Route Option A, from Bernice Lake Substation to Pt. Possession, is common to all Tesoro Route alternatives. There are three route options for the remainder of the Tesoro Route alternative from Pt. Possession to Pt. Woronzof Substation that require an underwater crossing of the Turnagain Arm. The issues associated with the Turnagain Arm crossings vary significantly with each route option. Table 2-3 (on the following page) presents a comparison of the cost and submarine cable length for these route options. Following this table is a discussion comparing the route options with respect to cost, cable landing issues, marine issues, access for repairs, and an overall summary comparison of cost/technical factors for each option. Southern Intertie Project Chapter 2 —- Supplemental Information Final EIS 2-4 July 2002 TABLE 2-3 TESORO ROUTE ALTERNATIVES PT. POSSESSION TO PT. WORONZOF SUBSTATION (MILLIONS OF 1997 DOLLARS) Present Worth Present Worth of | of Submarine Miles of Operation and Cable Submarine |Constructed| Maintenance Replacement | Total Life Route Options Cable Cost Costs Costs Cycle Costs |Route Options D and N - via Pt. Campbell 13.9 $52.0 $1.1 $10.7 $63.8 Route Option B - via Fire Island 14.6 $52.0 $2.2 $13.0 $67.2 Route Option C - via Pt. IWoronzof direct 17.2 $58.7 $1.5 $13.2 $73.4 Cost As shown on Table 2-3, Route Options D and N would have the lowest total life cycle costs ($63.8 million) in comparison to Route Option B ($67.2 million) and Option C ($73.4 million). Route Options B and D/N have the same construction cost ($52 million), despite the fact that Route Option B requires 0.7 more mile of submarine cable. This is because the added submarine cable cost is offset by the lower cost overhead line facilities that can be installed on Fire Island, as compared to Route Option N from Pt. Campbell to Pt. Woronzof Substation, which would be all underground cable on land. However, when submarine cable replacement costs are added, Route Options D/N have a lower life cycle cost than Route Option B. Route Option C would require submarine cable for the entire distance from Pt. Possession to Pt. Woronzof. Because of this length of submarine cable, it is the most expensive route option. On a cost basis, Route Options D and N are preferred because of the lower overall cost of these options, primarily due to the shorter submarine cable required. Cable Landing Issues The following are comparisons of submarine cable landing issues associated with Route Options D and N, B, and C. These discussions focus on the differences between landings at Pt. Campbell, Pt. Woronzof, and on Fire Island. Southern Intertie Project Chapter 2 —- Supplemental Information Final EIS 2-5 July 2002 Pt. Campbell versus Pt. Woronzof Cable Landings Cable landing issues are straightforward for the Route Option D landing at Pt. Campbell. Horizontal directional drilling techniques would be used to drill under the vegetated intertidal area and the low bluff on the northwest side of the point. From there the line would continue northerly underground with land type underground cable (Route Option N), terminating in the Pt. Woronzof Substation. At Pt. Woronzof Substation a submarine cable landing is more difficult. A cable landing at Pt. Woronzof Substation would be required for Route Options B and C. Chugach has been installing submarine cables from Pt. Woronzof to Pt. Mackenzie across the Knik Arm at various times from 1967 until the most recent installation in 1999. Since that time, a large cable field has been constructed in the water off of the Pt. Woronzof Substation comprised of a total of 14 individual cables. In order to minimize the opportunity for damage to a single submarine cable, the individual submarine cables are installed separate from one another at distances from 70 to 200 feet. This results in the cables occupying a large area in the water (cable field) off Pt. Woronzof Substation. With respect to installation of the proposed Southern Intertie Project cables, it is not advisable to install submarine cables such that they cross one another in the water, as damage to both cables can occur during installation where the cables cross. Additionally, crossing the cables would preclude raising or retrieving the lower cable for repairs. As a result, each submarine cable must be routed to the shore in such a way that the cables do not cross one another. Considering the existing submarine cables off the Pt. Woronzof Substation, this will require that the Southern Intertie Project cables make landfall on the south side of the sewage plant and then proceed underground inland and then north into the Pt. Woronzof Substation. A steeper bluff in this area will require a longer directional bore under the bluff than at Pt. Woronzof Substation. This reroute adds approximately $760,000 to the cost of landing cables at Pt. Woronzof Substation. The cost of this reroute is included in the costs for Route Options B and C. For either Route Option B or C, horizontal directional drilling techniques would be used to drill under the bluff to make landfall. From a cable landing perspective, Route Option D to Pt. Campbell is preferred because of the relative ease of making landfall at Pt. Campbell and because of the inland approach to Pt. Woronzof Substation via Route Option N. The inland approach of Route Option N avoids conflicts with the existing cable field offshore at Pt. Woronzof Substation. Fire Island Cable Landings In all, Route Option B requires four submarine cable landings—Pt. Possession, two on Fire Island, and Pt. Woronzof. As a result, Route Option B is the least desirable option regarding submarine cable landings. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-6 July 2002 Marine Issues — Pt. Possession to Pt. Woronzof The cable replacement intervals scheduled for each of the three route options (B, C and D) reflect the relative marine conditions expected for each of the submarine cable segments. = Route Options C and D: Replace two single-phase cables or one three-phase cable twice during the Project life (years 17 and 34), depending on the type of cable initially installed. = Route Option B: There are two submarine cable segments, one from Pt. Possession to Fire Island (Link T10) and one from Fire Island to Pt. Woronzof (Link T14). Link T10 from Pt. Possession to Fire Island extends out into the Cook Inlet where harsher marine conditions exist based on the 1996 bottom and side scan sonar surveys, as compared to Route Option C or D. For Link T10, the cable would be non-embedded and the replacement schedule is to replace two single-phase or one three-phase cable three times during the Project life at 12-year intervals (years 12, 24 and 36). Marine conditions for Link T14 from Fire Island to Pt. Woronzof are such that the cables can be embedded, and so the cable replacement interval is one single-phase cable or one three-phase cable once during the Project life (year 30). Marine conditions are similar for Route Options C and D as they both follow approximately the same route across Turnagain Arm. Route Option D is preferred over Route Option C as the distance to be traversed by the submarine cable is much less (13.9 miles for D compared to 17.2 miles for C). Because submarine cable is quite expensive, the shorter the submarine cable distance the better the installation is from a construction/operations and life cycle perspective. This difference in submarine cable mileage required is primarily responsible for the added life cycle cost of $9.6 million for Route C over Route Options D and N. As noted, marine conditions for Route Option B/Link T10 from Pt. Possession to Fire Island are considerably harsher than Route Options C, and D/N. Submarine cables in this link are exposed to high tidal currents and bottom scouring. To account for this difference in marine conditions, the cable replacement interval was adjusted to represent the costs that would be expected for that route option. From a marine issues point of view, Route Option D to Pt. Campbell is preferred due to the relatively better marine conditions than for Route Option B, and because the length of submarine cable is much shorter than for Route Option C. Access for Repairs — Pt. Possession to Pt. Woronzof Reasonable access to the Southern Intertie Project facilities during the Project operating life is an important factor relating to how long it takes to identify problems, conduct repairs, and place the facility back into service. Submarine cable by its very nature poses more difficult access problems, as compared to accessing a transmission line on land. Additionally, repair or Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-7 July 2002 replacement of a submarine cable can require many months. Consequently, the shorter submarine cable crossing is preferred, retaining as much of the transmission line on land as is practical. From this perspective Route Options B and D/N retain more of the transmission line on land and are preferred over Route Option C, which is composed of all submarine cable. Comparing Route Options B and D, the overhead line of Option B is located on Fire Island and is not as easily accessible as the underground line of Option N, which is located on the mainland between Pt. Campbell and Pt. Woronzof. From an access point of view, Route Options D and N are preferred due to the shorter submarine cable length and the location of Route Option N on the mainland. Tesoro Alternative Route Options Preference — Pt. Possession to Pt. Woronzof A summary of the cost/technical factors for route options between Pt. Possession and Pt. Woronzof are shown in Table 2-4 (below). On an overall cost/technical basis, Route Options D and N are preferred over Route Option B or C. This results in a route preference for the Tesoro Route alternative of Route Options A, D and N extending from Bernice Lake Substation on the Kenai Peninsula to Pt. Possession (A), from Pt. Possession to Pt. Campbell via submarine cable (D), and from Pt. Campbell to Pt. Woronzof Substation via underground cable on land (N). TABLE 2-4 TESORO ALTERNATIVE COMPARISON OF COST/TECHNICAL FACTORS PT. POSSESSION TO PT. WORONZOF SUBSTATION (MILLIONS OF 1997 DOLLARS) Turnagain Length of Arm Route Submarine | Total Life Cable Marine | Access for | Cost/Technical Options Cable Cycle Costs | Landings Issues Repairs Preference Route Options D | 13.9 miles 1* 1* i= i Preferred Route and N — via Pt. $63.8 Option Campbell Route Option B — | 14.6 miles = 3" 3 = - via Fire Island $67.2 Route Option C— | 17.2 miles 34 oa =e 3m = Pt. Woronzof $73.4 Direct Enstar Route Alternative The Enstar Route alternative extends from the Soldotna Substation to the International Substation in Anchorage. Route option combinations are described below, followed by a discussion comparing route options with respect to cost, cable landing issues, marine issues, access issues, and an overall summary comparison of cost/technical factors for each option. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-8 July 2002 = On the Kenai Peninsula, two route options provide alternate routes from the Soldotna Substation to the southern end of Route Option F east of Sterling—Route Options E North and E South. = Route Option F, which is common to all Enstar Route alternatives, extends through the KNWR to the south shore of Turnagain Arm. = Three route options extend north from the south shore of Turnagain Arm at Burnt Island, across Turnagain Arm and through southern Anchorage to the International Substation. These options include G and J (via Klatt and Minnesota Drive), H and K (via Alaska Railroad), and L and M (via Old Seward Highway). Soldotna North and South Route Options From Soldotna Substation, Route Options E North and E South provide two options for reaching the southern end of Route Option F with overhead transmission lines. Table 2-5 below provides a cost comparison of the E North and E South route options. TABLE 2-5 ENSTAR ROUTE ALTERNATIVES SOLDOTNA NORTH AND SOUTH ROUTE OPTIONS (MILLIONS OF 1997 DOLLARS) Present Worth of Constructed Operation and Total Life Cycle Route Options Cost Maintenance Costs Costs IE North $17.7 $0.6 $18.3 IE South $18.2 $0.6 $18.8 The E North route option would require construction of an additional transmission line parallel to the existing transmission line corridor, extending north and east from the Soldotna Substation. The E South route option would not require an additional transmission line to be added parallel to an existing transmission line. Instead, the existing 69kV transmission line would be rebuilt and converted for operation at 138kV. This existing 69kV transmission line connects the Soldotna and Quartz Creek substations. To maintain this connection a 138/69kV transformer would be installed at the proposed Naptowne Substation near the southern end of Route Option F. The cost differential between the E North and E South route options is small. The E North route option would add a new transmission line to the existing corridor, resulting in a widening of that corridor. Consequently, the new line would conflict with existing land uses along the route. On the other hand, because the E South route option utilizes an existing transmission line, no new lines would be added and any conflicts with existing uses would be minimized. On this basis, Route Option E South is preferred. Southern Intertie Project Chapter 2 —- Supplemental Information Final EIS 2-9 July 2002 Burnt Island to International Substation Route Options From the southern shore of Turnagain Arm near Burnt Island to the International Substation there are three route option combinations. Table 2-6 below presents the costs for these three route options. TABLE 2-6 ENSTAR ROUTE ALTERNATIVES SOUTH SHORE TURNAGAIN ARM TO INTERNATIONAL SUBSTATION (MILLIONS OF 1997 DOLLARS) Present Worth of Operation Miles of and Present Worth of Total Submarine | Constructed| Maintenance | Submarine Cable | Life Cycle Route Options’ Cable Cost Costs Replacement Costs Costs $43.6 $1.6 $3.5 $48.7 - total Route Options G 112 and J i G - $37.3 G- $0.9 G - $3.5 G-$41.7 J - $6.3 J - $0.7 J- $0.0 J - $7.0 $43.9 $3.7 $3.3 $50.9 - total Route Options H 10.5 land K i H- $36.1 H- $0.8 H- $3.3 H - $40.2 K - $7.8 K - $2.9 K - $0.0 K- $10.7 $43.7 $1.2 $2.8 $47.7 - total Route Options I 9.0 land M ' I- $32.1 1- $0.8 I- $2.8 I - $35.7 M- $11.6 M - $0.4 M - $0.0 M- $12.0 Cost Constructed costs for all three route option alternatives are similar, despite the shorter or longer submarine cable crossings required. This is because of the offsetting costs of the overhead lines required for each option in southern Anchorage. For example, Route Option M along Old Seward Highway requires a triple circuit steel pole structure capable of supporting 138kV and 34.5kV circuits, as well as distribution lines. This is more expensive than a single circuit 138kV line. Route Option K along the Alaska Railroad requires a section of underground land cable along the route near the Flying Crown Airstrip, at a higher cost than if that section were overhead. Operation and maintenance costs for Route Option K are higher than for Route Option J or M because the Alaska Railroad charges an annual fee for the right-of-way. Route Option J or M are routed in public or acquired easements along streets, for which annual fees do not apply. Submarine cable replacement costs are proportional to the length of the crossing of the Turmagain Arm. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-10 July 2002 Based on total life cycle costs, the combination of Route Options I and M cost less than the other two route option combinations. However, because the construction costs for each of the three route options are nearly the same, and the costs associated with operations and maintenance and submarine cable replacement are future costs and are thus more uncertain, none of the three route options show a clear cost advantage over the other. Cable Landing Issues, Marine Issues, and Access Issues — G, H, and I The three Enstar alternative route options for crossing the Turnagain Arm are all very similar and are not significantly different from one route option combination to another considering submarine cable replacement intervals, marine issues, cable landing issues, and access for repair. This is in contrast to the Tesoro Route alternatives where the various crossings of the Turnagain Arm exhibit significant differences from one route option to another. For Route Options G, H and I on the Enstar Route, the submarine cable can be embedded for the entire distance across Turnagain Arm and the cable replacement schedule for these route options is one single-phase cable or one three-phase cable once during the Project life (year 30). Other than the length of the crossing, there are no significant differences between the route options related to cable replacement or marine issues. Cable landings for Route Options G, H and I are similar in that each one will require that horizontal directional drilling techniques be used to bore under the vegetated portion of the intertidal area and/or the bluff in order to make landfall. With regard to access for repairs, all three route option combinations are relatively equal, the only difference being the length of the submarine cable crossings. In southern Anchorage, the transmission lines along Route Options J, K and M are all equally accessible for repairs. Enstar Alternative Route Options Preference There is no strong cost/technical preference among the three route options for crossing the Turnagain Arm to International Substation. From a cost/technical perspective, an Enstar Alternative Route could be composed of Route Option E South from the Soldotna Substation to the Naptowne area, Route Option F through the KNWR, and then any one of the three route options to the International Substation in Anchorage (Route Options G/J, H/K, or I/M). 2.2.3 Underground Construction Costs The purpose of this discussion is to provide additional information regarding the undergrounding of small sections of the Tesoro Route (Option A) and the Enstar Route (Option F) through the KNWR as requested in comments received on the DEIS. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-11 July 2002 Tesoro Route Regarding undergrounding of short sections along the Tesoro Route north of Captain Cook SRA, the construction cost of 1 mile of overhead line in that area has been estimated to be approximately $600,000 per mile (Power Engineers 1998). To underground a | mile section, two transition stations would be required, as well as one circuit mile of underground cable installed in a duct bank casing pipe (see DEIS page B-26, Appendix B) and two or three concrete splicing vaults, depending on route conditions. The cost for undergrounding the 1-mile section is estimated to be $2.6 million. The ratio of underground to overhead costs is 4.3 to 1. There are many factors that affect the cost of the installation. Typically underground cables are installed in the summer (DEIS page 2-50) as the cross linked polyethylene cable and accessories (splices and terminators) become stiff in the winter and more difficult to handle and install. North of Captain Cook SRA, construction is proposed to occur during the winter (DEIS page 2-50). While access will be easier in the winter because the frozen ground and snow cover would provide a good base for a snow road, winter construction will require (1) the adding of an antifreeze component to the concrete or slurry casing fill to prevent the slurry from freezing before it is pumped into the casing; (2) temporary heating of buildings or tents for cable reel staging to allow the cable temperature to rise to minimum installation temperature; (3) temporary high voltage alternating current (HVAC) equipment for use at the concrete vaults for cable splicing; and (4) more expensive excavation due to the frozen ground. Also, difficulty with backfilling and compaction due to the frozen material would be expected. Enstar Route Route Option F, composed of Links E8, E9, and E10, of the Enstar Route alternative crosses the KNWR from the Naptowne Substation siting area on the north side of the Sterling Highway to the south shore of Turnagain Arm, near Burnt Island. The added construction cost of undergrounding this section of the Project is about $70 million (DEIS page 2-23, Bury Line through KNWR). To expand on the DEIS description, Table 2-7 compares the various factors associated with operating and constructing an overhead line through the KNWR versus undergrounding the line. Type of facility, outage frequencies, repairs, construction cost, operation and maintenance costs, and life cycle costs are compared. As shown in the table, the underground line is more expensive to construct than the overhead line ($19.8 million overhead versus $89.6 million underground). The same winter construction issues as discussed above for the Tesoro Route north of Captain Cook SRA also apply to the line route through the KNWR. While the underground facility has a lower outage frequency rate, the duration of the outages are much longer and the cost of repairs higher (operation and maintenance life cycle costs of $1.1 million overhead versus $2.2 million underground). Because of the high cost, undergrounding 138kV transmission lines is normally only considered for areas where overhead lines are not feasible due to public safety considerations, such as near airports or in the vicinity of high density developments, such as a downtown core area. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-12 July 2002 Repair of an overhead facility is relatively easy and repairs can normally be completed quickly, since all of the components are above ground and easily accessible. Underground facilities, in contrast, are primarily below ground and identification of the location, cause of the failure, and accessing the facility for repairs takes much longer. Additionally, an underground outage is generally longer in duration, in contrast to overhead lines where many outages are momentary (seconds or fractions of a second). This is why the industry average outage duration of 100 hours indicated in Table 2-7 below for underground outages, is much longer than for overhead. Overhead line outages, as indicated in the table, can be expected to vary from momentary, to minutes or a few hours. Another factor that would add to the complexity of operating an underground facility would be the remote location in the KNWR, and the average outage duration for a KNWR underground facility could reasonably be expected to be greater than the 100-hour average industry duration. Also, it should be understood that to support an underground cable installation across the KNWR, three above-ground reactive compensation stations, similar in appearance to a substation, would be required as part of the underground installation. For all of these reasons, and particularly due to the high construction cost, placing the line underground through the KNWR is not feasible (DEIS page 2-23). TABLE 2-7 COMPARISON OF OVERHEAD VERSUS UNDERGROUND THROUGH KNWR Route Option F 38.5 Miles (62.0 kilometer) Overhead Line Underground Line Facility Type Link E8 — 33.1 miles Links E8, E9 and E10 - 38.5 miles. Line would consist of (see Tables B1 Steel X Frame Structures 138kV solid dielectric XLPE cable installed in a duct bank- and B2 in Link E9 - 3.6 miles casing pipe. Three single-phase cables would be installed in the Appendix B of 1.0 mile - steel X frame duct system with one additional spare duct. Splicing vaults DEIS) structures would be installed every 1,500 to 2,500 feet depending on 2.6 miles - single wood pole specific site conditions. Three reactor stations would be structures required with a 20 MVAR reactor installed in each station. The Link E10 — 1.8 miles reactor sites are above-ground facilities that appear similar to a Single wood pole structures typical substation. Relative Line is located in a Based on industry data indicating an average unscheduled Performance Low/Moderate - snow/ice/wind | outage rate of 0.34/100km circuit/year* (for all failure types), area. Based on industry data indicating an average 8.4 outages of about 100 hours duration could be expected during the life of the Project. Approximately 70 percent of the unscheduled outage rate of outages would be due to internal component failure (cable, 1.8/100 miles/year**, typical splice or termination). The remaining 30 percent are due to performance would be 0.7 mechanical damage (dig-ins, etc.) and abnormal system outages per year or 28 outages conditions (lightning, etc.). Typically, failures or outages on during the life of the Project. underground lines are due to the failure of a component (splice Outage duration would be from minutes to hours with most outages being short; for example, momentary outages resulting from icing or high winds. or termination) and so are longer outages, rather than a momentary outage on an overhead line resulting from wind and/or ice on wires or structures. The 100-hour duration assumes that the necessary spare or replacement components are readily available near the site. If the replacement components need to be fabricated, then outage times can increase to several weeks or months. Southern Intertie Project Final EIS 2-13 Chapter 2 — Supplemental Information July 2002 TABLE 2-7 COMPARISON OF OVERHEAD VERSUS UNDERGROUND THROUGH KNWR Route Option F 38.5 Miles (62.0 kilometer) Overhead Line Underground Line [ Expected Because the line would be For the 8.4 failures expected during the Project life, repairs Repairs located in a Low/Moderate - would consist of replacing splices or pulling in new sections of snow/ice/wind area, and based cable into the ducts. For comparison purposes, assume that five on Chugach's operating failures will require replacement of deteriorated or failed experience with steel X frame splices or terminations and three failures would require and wood pole lines in Alaska, replacement of one cable section (in this case a new cable no long duration outages (24 to | would be pulled into a duct between pull boxes to replace the 72 hours) would be expected to failed cable). In one case assume that the cable has failed such occur during the 40-year Project | that the duct bank will need to be excavated and repaired, in life due to a structure failure. addition to pulling in a new cable (this could occur due to frost Normal maintenance would heave, excavation, or catastrophic cable failure damaging the include tightening hardware and | conduit). Splice replacement could be completed using structure guying and occasional | helicopter access to the site. For replacement of a cable section replacement of insulators, should | or duct repair, ground equipment would be required in order to one be damaged by gunshot for | transport the heavier cable materials and excavating equipment example. These types of to the site. problems would be identified through a regular line inspection program and repairs completed via helicopter during a scheduled outage. Construction Costs $19.8 $89.6 PW O&M Costs | $1.1 $2.2 Life Cycle Costs | $20.9 $91.8 * F. Farnetti, B. Riot, G. Bazzi, and C. Morris, "Reliability of Underground and Submarine High Voltage Cables," CIGRE Study Committee 21 S 38-91, Symposium Montreal 1991. ** M. G. Lauby, K. T. Khu, R. W. Polesky, R. E. Vandello, J. H. Doudna, P. J. Lehman, D. D. Klempel, "MAPP Bulk Transmission Outage Data Collection and Analysis," compiled in Applied Reliability Assessment in Electric Power Systems, Edited by R. Billinton, R. Allan, and L. Salvaderi, 1991. 2.2.4 Battery Energy Storage Systems The following is intended to clarify the explanation of why the BESS was eliminated as an alternative to the Project (DEIS pages 2-1 through 2-3). The reader is also directed to Section 1.3 of the DEIS (Purpose and Need for the Project) for a detailed discussion of each aspect of the purpose and need for the Project. Table 2-1, Alternative Screening Summary (DEIS page 2-2), summarizes the alternatives considered but eliminated and whether each alternative meets the Project purpose and need screening criteria. Each alternative is denoted as to whether it would meet, partially meet, or would not meet the screening criteria. As indicated in Table 2-1 (DEIS page 2-2), a BESS would partially meet some of the screening criteria, but due to its limited storage capacity would only Southern Intertie Project Final EIS Chapter 2 — Supplemental Information 2-14 July 2002 partially meet the purpose and need for the Project. For example, a BESS is designed to supply electricity to the system during an interruption for only 20 to 30 minutes. The BESS portion of Table 2-1 is shown below. From Table 2-1, DEIS Page 2-2 Alternative Screening Criteria for a BESS Beets Criteria Increase the reliability of the interconnected system partial Increase the power transfer capacity between the Kenai Peninsula and Anchorage partial Utilize the most economic generation mix to reduce costs partial Improve overall system stability during disturbances partial Reduce spinning reserve requirements partial Reduce transmission line losses no Reduce maintenance costs no Notes: yes = meets alternative screening criteria no = does not meet alternative screening criteria partial = partially meeting alternative screening criteria The reasons that a BESS would only partially meet the purpose and need for the Project are explained below, as they related to the Alternative Screening Criteria categories as shown in Table 2-1 above. Increase the Reliability of the Interconnected System and Improve Overall System Stability During Disturbances The use of a BESS as an alternative to the Project was studied in detail (Power Engineers 1997) (see Sections 1.3.1 and 1.3.4 in the DEIS). A BESS would only partially increase system reliability and stability. The benefit of the BESS is that during the first few moments of a system disturbance, a BESS would allow the system to continue to supply power to customers and would enhance the ability of the system to withstand the disturbance. However, the results of the Power Engineers study (1997) indicate that the BESS would introduce some instability into the system and increase the likelihood of the loss of the existing 115kV line, when the initial short circuit was on one of the other transmission lines. Additionally, once the 115kV line was lost, the Kenai Peninsula and Anchorage areas would become electrically separated and it could be necessary to drop customer load in one area or the other (load shedding) in order to avoid a blackout. As noted below, even with two BESS installed on the system, the secure power transfer capacity is still limited by system stability issues. So while the BESS would provide some partial benefits, it would not provide for the reliable and stable operation of the system at an increased power transfer capacity level. Increase the Power Transfer Capacity Between the Kenai Peninsula and Anchorage A BESS would only partially increase the secure power transfer capacity between the Kenai Peninsula and Anchorage (DEIS Section 1.3.2). The existing Quartz Creek transmission line is Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-15 July 2002 limited to transferring 70 MW of power for a secure transfer. To allow full use of the Kenai Peninsula generation, the secure transfer capacity needs to be increased to 125 MW (DEIS Page 1-8). The Power Engineers study evaluated a number of scenarios with a single BESS installed at various locations on the Kenai or in Anchorage, and also with two BESS’s installed, one in Anchorage and one on the Kenai. In the cases evaluated with a single BESS installed on the system, the secure transfer capacity remained at 70 MW, limited by system stability issues. With two BESS’s installed on the system, the secure power transfer capacity was increased to 90 MW. So while two BESS installations could partially increase the secure power transfer capacity, it would not increase the transfer capacity to the required 125 MW. Utilize the Most Economic Generation Mix to Reduce Costs Currently the existing system between the Kenai Peninsula and Anchorage is operated to maximize the transfers of economy energy, and coordinate the hydro and thermal generation resources on the Kenai Peninsula and in Anchorage, within the 70 MW limitation of the existing Quartz Creek transmission line (DEIS Section 1.3.3, Page 1-8). Standard utility practice is to determine generation requirements and operate individual generation plants in a mix in order to meet the instantaneous demand for power and produce the least cost power. The present limitation on power transfers between the Kenai Peninsula and Anchorage area results in a more expensive mix of power being generated from the existing power plants to supply the load than if the Project were in service (DEIS Page 1-23). As noted above, the BESS could only increase the 70 MW transfer capacity to 90 MW (with two BESS’s), not the required 125 MW, and so would only partially allow the most economic generation mix to be utilized to reduce costs. However, an increased transfer over the existing line also results in higher transmission line losses, which would partially offset savings in generating costs. In addition, a BESS would add costs to the system due to the energy losses inherent in the charging and discharging cycle of the batteries. Another factor to be considered is that with a second transmission line in service, the most economic mix of generation units can be utilized, even if one line is out of service. A BESS does not provide this benefit. Reduce Spinning Reserve Requirements Spinning reserves respond to changes in consumer demand and failures in the generation and transmission system (DEIS Section 1.3.5). Spinning reserves improve reliability, but they are often expensive because some generation units must be operated partially loaded. The hydroelectric capacity at Bradley Lake on the Kenai Peninsula could provide a less expensive source for spinning reserves that otherwise would be provided by thermal generating units in the Anchorage area. Transmission capacity between the Kenai Peninsula and Anchorage is a constraint on the transfer of spinning reserves between areas with only the single Quartz Creek transmission line in service (DEIS Page 1-26). Approximately 30 MW of spinning reserve can be transferred from the Kenai Peninsula to Anchorage over the existing line. This transfer of spinning reserves results from the practice of distributing these reserves so that they are not all lost with a single event. With a second line in service, it is estimated that up to 50 MW of Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-16 July 2002 spinning reserves could be transferred from the Kenai Peninsula to Anchorage (Decision Focus 1996) (DEIS page 1-27). A BESS located in Anchorage would contribute to spinning reserves in the Anchorage area. A BESS located on the Kenai would offset the spinning reserves already available from Bradley Lake. During an outage of the single 115kV Quartz Creek transmission line, a Kenai BESS could not supply spinning reserves to Anchorage, and Anchorage generation would have to provide spinning reserves the same as without a BESS. Only the installation of two BESS’ would result in the ability to reduce spinning reserves across the system. However, as noted previously, the installation of a BESS on the system results in electrical system stability problems and adds costs to the system. Consequently, a BESS could only partially reduce spinning reserve requirements. Reduce Transmission Line Losses and Reduce Maintenance Costs A BESS is designed to provide electrical support to the system during a disturbance in order to compensate instantaneously for imbalances between generation and load (DEIS Section 1.3.6). However, a BESS can only be operated to support the system for a very limited period of time (20 to 30 minutes). During normal operating conditions, a BESS is essentially on standby and does not affect the flow of power across the system. Since transmission line losses primarily result from the steady flow of power along lines, a BESS would not reduce transmission line losses. The reduction of maintenance costs is related to the planned maintenance of the existing Quartz Creek transmission line. Removing the line from service for reconstruction and conducting maintenance activities requires additional generation to be operated both on the Kenai Peninsula and in the Anchorage area to support the load, because with the line out of service generation resources can no longer be shared between the two areas. Because a BESS is designed to operate only during a disturbance and not to serve customer loads, the added generation resources would still have to be operated and a BESS would not reduce maintenance costs. In summary, the use of a BESS as an alternative to the Project was studied in detail (Power Engineers 1997). Considering the results of the electrical studies, the BESS only partially meets the purpose and need for the Project and was eliminated as an alternative to the Applicant’s proposal (DEIS Page 2-3). The cost of a BESS is also quite high. Typical costs range from $600,000 co $1,000,000 per MW, depending on how long the batteries must maintain the output and how often the batteries are cycled. Using this cost range, the cost of a single 40 MW BESS could range from $24 to $40 million. 2.2.5 Update on Beluga Whales After the review of comments on the DEIS, NMFS was contacted in January 2002 to discuss beluga whale mitigation measures and construction timing in more detail. NMFS prefers a July- August construction season for the submarine cable crossings, since Spring (May-June) is the Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-17 July 2002 most sensitive time for belugas because of salmon runs and calving. The DEIS stated that construction would be avoided mid-June to mid-July. The construction season is now proposed during the July-August time frame. Construction could not occur during the winter months because of ice in Turnagain Arm. The new proposed construction season for submarine cable crossings will also comply with issues raised by ADF&G over conflicts with the hunting season in the Anchorage Coastal Wildlife Refuge, which begins September 1. Construction operations for cable laying will be completed prior to September. The issue of beluga whale sightings during construction operations was also discussed. The cable laying portion of the two-month (July to August) submarine cable construction period would be two to four weeks, depending on the route selected. During this period there is the potential that the construction barge could encounter beluga whales. During the cable laying operation it would not be possible for the barge to stop engines upon the sighting of a whale, as the barge would drift and damage to the cable is likely to result. NMFS noted that the stop work request for belugas within 2,000 feet was a typical request; however, in the case of this type of operation the barge would be allowed to maintain course and speed unless a collision is eminent. The speed of the barge during cable installation operations varies depending on the type of activity. For cable laying without embedding the cable in the bottom, barge speed would typically be in the range of 1 to 2 miles per hour. For cable laying and embedding, the barge speed would be less than 0.2 miles per hour, and could be much slower depending on bottom conditions. Since this cable laying operation is not expected to have in-water noise other than the barge vessel and water jet excavation/trenching machine, NMFS was satisfied with the proposed plan of action. 2.2.6 Update on Kenai Peninsula Brown Bears and Wolverines Brown Bear Numerous comments were received regarding potential impacts to the Kenai Peninsula brown bear, and concerns raised by the Interagency Brown Bear Study Team (IBBST) regarding the Project. Impacts to brown bears are discussed in the DEIS, Section 3.5.3, Terrestrial - Wildlife, Brown Bears (pg. 3-60, 3-68); Section 3.5.4, Alternatives, Enstar to Chickaloon Bay - Route Option F, Brown Bear (pg. 3-90); Section 3.6.3, Alternatives, Enstar to Chickaloon Bay - Route Option F, Environmental Consequences (pg. 3-143); and Section 3.12.2, Cumulative Impact Process, Brown Bear (pg. 3-281), and Table 3-37, Cumulative Impact Analysis (pg. 3-295). As mentioned in the DEIS, Project consultants met with the IBBST over the course of the Project to review habitat assessment criteria and areas of particular importance regarding the Project (pg. 3- 61, 3-62), and this information has been reflected in the impact assessment in the DEIS. Subsequently, in November 2001, the IBBST published a report titled A Conservation Assessment of the Kenai Peninsula Brown Bear. The report highlighted the following issues of concern: = Population Parameters: a population census has not yet been conducted for Kenai Peninsula brown bears, although a DNA-based census is planned to begin in 2002. The estimated population of Kenai Peninsula brown bears is 250 to 300. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-18 July 2002 = GH 2 NE = Distribution and Movements: data show a trend that bears are located within 1 kilometer of freshwater during May to October as a result of the presence and abundance of salmon. = Bear-Human Interactions: Reducing defense of life or property mortalities is a vital component of brown bear management. Bears near roads and trails are at a higher risk of being killed by humans. Any loss of female bears has a negative effect on the sustainability of brown bear population and is a critical concern for the wildlife managers. The brown bear model for cumulative effects found that human activities had reduced habitat effectiveness. Wolverines Wolverines were not selected as an evaluation species in the DEIS because it was assumed that potential impacts of the Project on this species would be similar to those for brown bear. However, comments on the DEIS have requested additional information on the potential impacts to wolverine specifically. The following additional information on the current status of the wolverine is provided below (Source: USFWS 2002. Some potential effects of the Southern Intertie Project transmission line project’s proposed Enstar Route on fish and wildlife habitats and populations on the Kenai National Wildlife Refuge). “Lack of human access and the presence of large unfragmented “refugia” appear most important to maintaining wolverine population viability (Hatler 1989) and the character of wolverine habitat most readily apparent is its isolation from the presence and influence of humans (Banci 1994). The extirpation of wolverine through the eastern provinces of Canada and the Midwestern United States most likely coincided with the westward advancement of civilization (Banci 1994). Over-harvest and displacement by humans may have forced wolverine out of lowland habitats and into the more isolated tracts of its present day distribution. In British Columbia, female wolverines, unlike males, appear to avoid crossing large reservoirs and the Trans Canada highway (Krebs and Lewis 1998). Under heavy trapping or hunting pressure, wolverine populations can decline over a large area because of their naturally low density and reproductive potential (Magoun 1985). In Alaska, wolverine harvest has declined statewide by 38 percent over the last 20 years (Golden et al. 1993) and in northwestern Alaska harvest has declined 75 percent since the winter of 1977-1978. Wolverine population densities are naturally low and their homes ranges extremely large. In south-central Alaska, annual home ranges for males and postparous females were 535 and 105 kilometers squared, respectively (Whiteman et al. 1986). Wolverines in south- central Alaska utilized significantly different elevational strata during different seasons averaging 1,043 and 818 meters for April through October (summer) and November through March (winter), respectively (Ibid). It was believed that during summers wolverines fed on Arctic ground squirrels (Spermophilus parryii) and other small mammals and ground nesting birds. In winter, wolverines moved to lower elevations where they fed primarily on moose and caribou carcasses resulting from gray wolf kills Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-19 July 2002 and starvation. In Alaska, Magoun and Copeland (1998) expressed concern for wolverine populations near large human population centers and recommended that land managers consider limiting wolverine harvests and reducing human disturbance in wolverine denning habitat. Banci (1994) and Landa (1997) recommended that protection for wolverines should be extended to travel and dispersal corridors between denning and foraging habitats. On February 23-24, 1995 on the Kenai Peninsula, Alaska USFWS surveyed a 2,050 kilometers squared wolverine study area at the north end of the Kenai Mountains between Turnagain Arm and the Kenai River and between Quartz Creek/Six-Mile Creek valley and the foothills to the east of the Enstar gas pipeline (Golden 1996). The tracks of five individual wolverines were counted during the survey, which resulted in a calculated population size of 19.7 wolverines for a density estimate of 5.2 wolverines/1,000 km’. This density was similar to densities of 4.7 to 5.2 wolverines/1,000 km? estimated during comparable surveys in the surrounding habitats of the eastern Talkeetna Mountains, northern Chugach Range, western Chugach Range, and the Chugach Mountains east of Anchorage. Of significance to the proposed Enstar Route in regards to wolverines on the KNWR is the following information: (1) there is an estimate of wolverine densities, based on the best available wolverine aerial survey technique, in the mountainous, surveyed area east of the Enstar Pipeline (5.2 wolverine/1,000 km’); (2) despite the relative higher densities of wolverine east of the Enstar Pipeline, few wolverines are harvested (7 in 27 years) or observed in the lowlands on the KNWR west of the Enstar Pipeline; (3) most of the wolverine harvest in GMU 15A has occurred along the Enstar Pipeline. The absence/scarcity of wolverines on the northern KNWR lowlands, despite relatively high moose densities and the availability of moose winter and wolf kills is difficult to explain. The dispersal of young female wolverines and their survival is likely the limiting factor in the recovery of vacant habitats (Bianci 1994:122). The fact that most of the wolverines trapped in GMU ISA are taken along the existing Enstar Pipeline corridor and few are taken over a huge area west of the corridor suggests that wolverines dispersing from relatively high density and presumably denning areas (Magoun and Copeland 1992) from the east to west, and wolverines seasonally moving from high to low elevations during the winter (Whitman et al. 1986) and during the trapping season, are subject to high trapping mortality rates along the Enstar Pipeline corridor. Making access along the existing Enstar Pipeline easier and more efficient by creating an additional and wider cleared right-of-way for the transmission line is not likely to decrease, but increase trapping pressure along a 20-mile front of the foothills where it is apparently intercepting dispersing and seasonal moving wolverines. At some future, but currently unknown, level of access and human use, the Enstar corridor could become a barrier to the movements of female wolverine (Krebs and Lewis 1999) and further decrease the opportunities for wolverine to colonize lowland habitat on the Kenai Peninsula.” Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-20 July 2002 2.2.7 Environmental Cost-Benefit Analysis Summary The Issue A number of reviewers for the DEIS commented that the cost-benefit analysis and socioeconomic impact assessment presented for the Project failed to account for impacts on various natural resources in the KNWR and other areas of the Kenai Peninsula. Some example comments included: “The most serious inadequacy of the DEIS, from our perspective, is that neither the benefit/cost analysis or the socio-economic impact analysis makes any attempt to account for the loss of wildlife or outdoor recreation values.” (Anchorage Audubon Society, Inc., December 4, 2001) “The most egregious example of problems with the benefit/cost analysis is that it leaves out the cost of any lost opportunities that the project will impose on the use of other resources, particularly wildlife and outdoor recreation.” (Anchorage Audubon Society, Inc., op. cit.) “The DEIS fails to provide an economic cost-benefit analysis that thoroughly addresses long-term environmental costs, notably for loss of nationally and regionally significant wildlife, scenic values, eligible Wilderness areas in the Kenai National Wildlife Refuge, and outdoor recreation opportunities.” (Alaska Center for the Environment, December 5, 2001) “Economic issues are dealt with insufficiently in the DEIS. There is no real cost benefit analysis of the proposed project in the DEIS. The DEIS does not take into account any of the costs associated with loss of habitat and impacts on wildlife...in the Kenai Refuge, in addition to others.” (The Wilderness Society, December 5, 2001) These comments reflect on the scope of the economic and social impact investigations conducted for the Project. The reviewers contend that insufficient attention was paid to accounting for potential impacts on environmental resources and associated experiences, but which should nonetheless be incorporated into the balancing of costs and benefits by the Project’s sponsors.! It follows that if the Project were to irretrievably degrade these wildlife and habitat resources, not only would the existence values be lost, but also the derivative economic values associated with consumptive use (e.g., hunting and fishing) or non-use, or passive use (e.g., viewing and recreation) of the resources. It is accounting adequately for these things that the reviewers say is lacking in the DEIS. ‘In the economist’s lexicon these are called “public goods”—things like air, wildlife, sunsets, etc —which cannot be owned or rationed, and therefore do not have market values. Although there may be costs associated with gaining access to the resource, the actual consumption or experiencing of it is free. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-21 July 2002 The Southern Intertie Project’s Cost-Benefit Analysis A cost-benefit analysis (CBA) is an accounting tool. The purpose of CBA is to determine whether a proposed activity will yield more utility than that of the resources consumed in its implementation. Conventionally, the values of the resources consumed (costs) and useful goods and services produced (benefits) are denominated in terms of money. If the ratio of prospective benefits to projected costs is greater than unity, then the Project is deemed economically beneficial—i.e., society would get back more than it would have to give up to accomplish the objective, and it should be undertaken. By means of discounting, the values of projected future streams of income and outgo are brought back to the present and netted out to determine whether the net present value of the Project is positive or negative. If it is positive, then the Project’s sponsors and investors are likely to commit to the action. If not, then they go back to the planning board and try to devise cost savings and/or benefits enhancements in the Project design. The CBA presented in Chapter 1 of the DEIS analyzed the market-valued parameters of the Project. Construction and operating costs for the Tesoro and Enstar alternatives were compared to users’ rate savings and other market-valued benefits of power supply reliability in the Rail Belt over the 40-year life of the Project. The resulting cost/benefit ratios were found to be positive, with or without the incorporation of a $48 million grant from the state.’ The socioeconomic impact assessment of the Project in Chapter 3 commented on possible long-term impacts of the SIP on the regional economic benefits of tourism and recreation related to the Kenai Peninsula’s natural attractions, but did not attempt a quantitative analysis owing to the Project’s lack of obvious threat to the area’s principal environmental attractions.° Reviewing the cost-benefit analysis in Chapter 1 of the DEIS, Table 1-12 (page 1-31) shows the Enstar Route’s benefit/cost (B/C) ratio equaling 1.44, based on a present value of costs of construction and operation of $99.6 million divided into total Project benefits of $143.5 million. The difference between total monetized costs and benefits—$43.9 million—represents the net value of the Project to the economy. Under cost-benefit accounting, that margin of net benefit could be traded off against losses in environmental asset values (however reckoned in monetary terms) up to the point where the cost/benefit ratio fell to unity. With a cost/benefit ratio less than 1.0, the Project would not be economically justified. The $43.9 million figure, however, is the present worth of the Project’s net benefits over a 40-year period, and should be converted to an annualized value in order to be comparable to the valuation basis used to estimate environmental values. Using the Project’s discount rate of 4.5 percent over 40 years, the annualized value of the Project’s net benefits is $2.39 million. This is the value that could be used for the Enstar Route to > The two sets of benefit/cost ratios cited in the text (Table 1-12, page 1-31) showed the B/C ratios for, respectively, the statewide economy and for the Project sponsors and investors. > DEIS, p. 3-184: “Of itself, the Project would not seriously damage the area’s tourist and recreation trade. It would not affect the majority of people using the area’s fishing, hunting, camping and hiking resources. The red salmon run would still fill up every motel, resort, RV and bed and breakfast space every July. However, if people came to fear a “graffiti” effect, i.e., that one degradation of the setting leads to another and then another and another one after that, then perhaps a line would have be drawn on what additional changes to the landscape should be permitted. This would apply not only to essential infrastructure like roads and power facilities, but also to the borough encouraging development of subdivisions in remote areas like Gray Cliffs/Moose Point, where all the accoutrements of residential life would have to be inserted into a mostly undisturbed setting.” Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-22 July 2002 at trade off environmental costs attributable to the Project to the point where the B/C ratio drops to unity.* Such a trade-off analysis is presented later in this discussion. There are two aspects to the CBA debate that need to be addressed first, however: a practical and methodological one, and an institutional one. The methodological and practical issues concern the omission in the analysis of non-market-valued public goods which might conceivably be reduced by project alternatives—namely the non-use values associated with the existence, option and bequest values of wildlife habitat and animals and the passive uses of the setting in the form of wildlife viewing and outdoor recreation, and how to put them in the same ledger with the Project’s measurable costs and benefits. This issue will be discussed at greater length in the following subsection. The institutional aspect of the debate is even more fundamental: are the lead and cooperating agencies that are parties to the federal permit-granting action for the SIP required to include a completely quantified co-measurable cost-benefit analysis in their documentation and evaluation of the proposed action, including a dollar-denominated accounting of the non-use environmental values for natural resources that might be affected (notably wildlife habitat and animals in the KNWR)? Addressing the permitting aspect first, federal agencies are required to evaluate the economic impacts of their regulatory actions under Executive Order 12866 (1993) and subsequent implementing rules from the Office of Management and Budget”, as well as various administrative statutes. The Environmental Protection Agency has issued its Guidelines for Preparing Economic Analyses (last updated in September 2000), and individual agencies have promulgated their rules for complying with the order. In a survey of government use of cost- benefit analysis by the public interest research firm Resources for the Future, the authors noted: “Currently, CBA is variously required, endorsed, circumscribed, or eliminated by statute. Agencies subject to OMB guidelines must use CBA unless a statute (or a court) requires otherwise, but there is considerable discretion in the guidelines as to how it is used. Therefore, the nature and extent of the use of CBA vary not only because of statutory provisions but for a host of reasons related to agency history, the training and interests of agency executives and staff, interpretations of statutory requirements, deadlines and resource constraints, and the like.”® * The comparable value for the Tesoro route would be $1.58 million per year, based on net Project benefits over 40 years of $29.0 million. The annualized value is the annuity due each year to amortize the present value of the Project at 4.5% over 40 years. > Guidelines to Standardize Measures of Costs and Benefits and the Format of Accounting Statements (OMB M-00- 08, March 22, 2000). Under Section 12(a) of E.O. 12866, agencies are to “include both quantifiable measures (to the fullest extent that these can be usefully estimated) and qualitative measures of costs and benefits that are difficult to quantify, but nevertheless essential to consider...” Kopp, Raymond J., Alan J. Krupnick, and Michael Toman. Cost-Benefit Analysis and Regulatory Reform: An Assessment of the Science and Art. RFF Decision Paper 97-19. (Washington, DC, January 1997; page 45). Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-23 July 2002 In the present action, the federal USFWS is not required to use a cost-benefit analysis in its Compatibility Determination for uses of the KNWR. Under the ANILCA of 1980, permitted uses of the land are described in qualitative terms, and the administrators of the Refuge are not obliged to consider monetary or economic factors in their consideration of applications for permits. The DEIS provides abundant documentation and expert judgment to the likely environmental impacts of implementing the proposed action, which the KNWR managers will incorporate into their decision-making. The other two agencies party to the permit action—the RUS and the USACE—presumably could or would consider costs and benefits of the Project in their deliberations. In view, however, of the overarching scope of the USFWS’s role in determining the permitability of either of the alternative alignments proposed for the SIP where they pass through the KNWR, the contribution would appear to be small that some dollar-denominated valuation of non-market environmental assets along the rights-of-way could make to the balancing decision process. In other words, one questions whether the decision-making process would materially benefit from an effort to assign monetary values to the environmental assets cited above. The State of Environmental Cost-Benefit Analysis In recent decades, concerns about environmental degradation and unsustainable rates of resource exploitation have led to attempts to incorporate the costs of losses of environmental quality and diversity into the Project feasibility calculus. The problem that confronts resource allocation decision-makers in their balancing of a project’s costs and benefits is determining what weights to place on non-commeasurable values: how to weigh the dollar costs of manpower, materials and equipment consumed in the Project and the benefits of reliable electric power supply against losses in environmental values like wildlife habitat and species success or survival rates? Dollar- denominated things are easy to scale; the market generally does a good job in matching supply and demand at market-clearing prices. By virtue of their spending behavior, people reveal their preferences for how much and what quality of goods and services they need. But for resources that cannot be captured or harvested and sold, either because they are too elusive or impossible to confine or because it is against the law, the market does not objectively reveal people’s preferences (or values) for them. Such resources have “non-use,” or “passive use” values.’ For these kinds of resources, one must somehow get people to state what their preferences would be, since they cannot be objectively revealed. There are several approaches to valuing environmental assets. Where environmental assets can be used, in the sense that the user makes physical contact with natural resources (e.g., hunting, fishing, hiking, trekking, and other outdoors recreation based on undertaking activities in a given locale or setting), a proxy for the value of the resources is the sum of the expenses incurred to get there and carry out the activity. The “travel cost method” is a popular approach because people reveal by their expenditures and travel behavior what the particular experience is worth to them. 7 Non-use values include the value of the existence of the resource, the option to use the resource at some future time, or the value of passing the existence values to future generations. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-24 July 2002 fe The values that result from this approach are considered as a lower bound of the range of possible use values, however, because the technique is not able to elicit how much a person might ultimately be willing to pay to experience the particular activity or preserve its existence.* For non-use values, notably species existence and aesthetic features, their values must be defined indirectly, by means of hypothetical markets that seek to show how much utility (expressed in dollars) an individual would be willing to trade off in exchange for avoiding a postulated change in the quantity or quality (or both) of the natural resource or amenity. This is called “contingent valuation,” where people’s valuation of the resource is stated (by means of the survey) rather than revealed (through the marketplace). The notion of payment vehicle is central and critical, because to be valid the respondent in a contingent valuation survey has to believe that he or she would have to give up something of value (money) and therefore not have it to spend on something else in order to preserve the amenity. In such a survey, a large number of people believed to be neutral (unbiased) to the outcome of a resource allocation issue are surveyed as to how much they would be willing to pay to avoid some stated degree of loss of the resource (or, conversely, would be willing to accept in compensation for a postulated degree of loss). The results of the survey—e.g., the dollars per household that respondents would be willing to be taxed to preserve a certain natural resource—are subjected to statistical analysis and then extrapolated to the general population to yield a measure of the aggregate value of the potential loss to society. These values in turn would be incorporated into the formal cost-benefit analysis. The economics literature is rife with debates over the validity of the contingent valuation method (CVM).” Various federal and state environmental protection and resource management agencies have approved use of CVM in cost-benefit analyses, although with strict instructions to deter introduction of bias into survey questions and interpretation of responses. Agencies and practitioners acknowledge that such surveys are lengthy and expensive, and that the results are narrowly applicable. In practice, regulatory agency use of cost-benefit analysis embodies an amalgam of monetary and non-monetarily quantifiable values where passive-use environmental assets are involved, in recognition of the uncertainty of validity of CVM results. Often, it is left to expert opinion as to what weights are to be assigned to environmental costs.!° 5 Some people are willing to pay more for a good or service than its current market price. The excess of a person’s demand for some quantity of a good or service over its current price measures his/her willingness to pay to obtain the full value of the item. In economics jargon this extra margin of demand is called “consumer surplus,” and in the case of environmental assets serves as a measure of the individual’s willingness to pay for unpriced environmental services. ° See, for example, UCLA Department of Economics, Recent Literature on Contingent Valuation Methods for | Valuing Environmental Goods at http://www.sscnet.ucla.edu/ssc/labs/cameron/nrs98/cvinv.htm (March 16, 2001); U.S. Environmental Protection Agency, Guidelines for Preparing Economic Analyses. EPA 240-R 00-003 (September 2000); Kopp, R.J., et al., Cost-Benefit Analysis and Regulatory Reform: An Assessment of the Science and the Art. Discussion Paper 97-19, Resources for the Future (Washington, D.C., January 1997); and Carson, R.T., et al., Contingent Valuation: Controversies and Evidence. Environmental and Resource Economics, 19: 173-210, 2001). '© Which often descends into a debate over whose expert is the most credible. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-25 July 2002 Examples of Economic Valuation of Wildlife Refuge Services It might be useful at this point to cite some studies of environmental assets in Alaska. The Institute of Social and Economic Research (ISER), University of Alaska Anchorage, has a long record of applied research on the state’s economic resources, some of which includes investigations of the economic value of wildlife refuges. Most pertinent to the Southern Intertie Project cost-benefit debate is The Kenai National Wildlife Refuge: Economic Importance, by Scott Goldsmith and Alexandra Hill (ISER, May 15, 2000, for the USFWS). Based on a 1997 survey of visitor spending for activities in the Refuge (denoted “On Site”—mainly recreational and sport fishing on the Kenai River) as well as for those dependent upon the Refuge’s resources (“Refuge Dependent”—mainly for off-shore commercial fishing of salmon spawning on streams in the Refuge), and employing an input-output regional economic model of the Kenai Borough economy, the ISER study estimates the amount of employment and income in the borough in 1997 attributable to the Refuge. , During 1997 recreational visitors spent $21 million on trips to the KNWR for sport fishing and hunting, non-consumptive uses (e.g., hiking and wildlife viewing), and incidental use (where the visitors’ primary purpose for the trip to the Kenai Peninsula was not to visit the Refuge). Another $28 million was spent for sport fishing trips to places not on the Refuge but where the target species were dependent on habitat provided by the refuge. Finally, about $23 million of the total of $58 million value of Cook Inlet commercial fisheries was estimated to be based on fish hatched and reared on the Refuge. In all, the gross sales value of activities associated with the KNWR amounted to an estimated $72 million in 1997. Quoting from the study: “The total On Site economic significance of the Refuge is the same as the recreational On Site economic significance, because commercial fishing occurs off the refuge. This is 407 jobs (annual average) and $8.7 million in annul payroll. The total Refuge Dependent economic significance combines the jobs generated by refuge dependent recreational visits with those generated by the commercial fishery. This results in a total of 1,492 jobs and an-associated total payroll of $40.4 million.”"! In sum, then, On Site and Refuge Dependent spending attributable to the KNWR generated the equivalent of 1,492 jobs and $40.4 million in labor income in the Kenai Peninsula Borough (annual averages, in 1997 dollars). These values represent, respectively, 5.67 percent of total borough employment and 5.72 percent of total borough labor income (salaries, wages, and self- employment earnings) in 1997.’ It should be noted that a portion of these jobs and earnings are based on Refuge-related recreational expenditures of borough residents, which represent about one-third of the total $49.1 million in On Site and Refuge Dependent spending, exclusive of commercial fishing receipts. It is the employment and income coming from the other two-thirds of the non-commercial fishing "! Op. cit., page 9. "2 Op. cit., pp. A-4, A-6. Total Borough employment in 1997 amounted to 26,330 jobs, while total labor earnings amounted to $706.7 million. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-26 July 2002 money plus the commercial fishing receipts that support the growth of the local economy, being the purchasing power entering the local economy from outside rather than being recycled local earnings (which eventually diminishes due to leakages to savings, taxes, and imports of non- local goods and services). This distinction is important because it distinguishes the local economic significance of the KNWR from its economic impact. As the ISER study notes, “[w]hile economic significance looks at how much economic activity can be traced to the refuge, economic impact tries to estimate how much smaller the Borough economy would be if those activities could not take place. In some cases, if refuge activities were not available, the spending they generate would be displaced to other Kenai Borough activities, with little impact on total jobs and payroll. In other cases, the spending would occur elsewhere in Alaska or out of state. In those cases, the total Borough economy would be smaller.”! After netting out Borough residents’ spending effects related to the Refuge, the net impact of non-local resident spending and commercial fishing for On Site and Refuge Dependent uses of the KNWR is estimated at 1,183 jobs and $33.9 million in annual labor income (or 4.5 percent of local yearly jobs and 4.8 percent of local earnings). Per the ISER study, these are the jobs and income in the Kenai Peninsula Borough that would be lost if the KNWR recreational and other attractions and amenities were no longer available. The study goes on to point out that these values do not represent the totality of environmental- economic values associated with the Refuge, but rather that they provide a lower bound measure of its total value. The study did not attempt to compute the refuge’s total economic value. Instead, it discussed the notion that some people would be willing to pay more than they actually did for their recreational activities, and that the total economic value of the refuge would be the sum of actual expenditures plus additional willingness to pay amounts. Also, the study discussed foregone opportunities of residents who were willing to accept lower incomes and reduced employment opportunities in order to live closer to the refuge, citing these as another component (albeit unquantified) of the economic value of the refuge. Finally, the study mentions that a portion of the value of the Cook Inlet fisheries harvest would accrue to the refuge as well as such non-use values as existence and option values for the wildlife. These extra-marginal values (i.e., amounts in excess of actual cash expenditures) are called the “net economic value” of the Refuge. What dollar value could be assigned to this unaccounted-for net economic value? A similar study done of the Bristol Bay national wildlife refuges for the USFWS by ISER is instructive. This study, also conducted in 1997, looked at the economic significance, economic impact, and economic value of the Alaska Peninsula/Becharof National Wildlife Refuge Complex and the Izambek and Togiak National Wildlife Refuges.'* For comparison, spending in, and deriving from, the three refuge areas supported about 3,225 jobs and $126.8 million in personal income in the Bristol Bay area versus the 1,492 jobs and $40.4 million in labor income accruing from the KNWR to the Kenai Peninsula Borough regional economy. The Bristol Bay refuges study states 8 Op. cit., page 9. 4 US. Fish and Wildlife Service. Bristol Bay Economic Assessment Final Draft Executive Summary: December 3, 1998. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-27 July 2002 that most of the net economic value of the Bristol Bay refuges is not in their consumptive use values but in their non-use values. The portion of the estimated net economic value of all the refuges’ consumptive uses (e.g., subsistence fishing and hunting, and commercial fishing and processing) in 1997 was approximately $82 million—about two-thirds from subsistence activities and one-third from commercial fish harvesting and processing—but the non-use value of the refuges was put at $2.3 billion to $4.6 billion.!* A subsequent study by ISER for the Alaska Conservation Foundation’® explains the methodology for the above estimate, and also provides a basis for extrapolating such economic valuations to other refuges. The $2.3 - $4.6 billion figure was based on a contingent valuation study that determined that U.S. households (which numbered about 92 million in 1997) would be willing to pay $25 to $50 per year, on the average, to preserve wildlife habitats in all of Alaska’s refuges.'’ Updating the data to 2001, the analysis suggests that American households collectively value Alaska’s conservation units (wildlife refuges) at $1.89 per household per million acres. Thus, on that basis, the annual non-use environmental value (i.e., net economic value) of the 152 million acres comprising all of Alaska’s conservation areas is $29.65 billion.'® It might be noted, in contrast, that the contingent valuation study done in 1992 for the Exxon Valdez oil spill yielded a willingness to pay for U.S. households of $3 per year (derived from a one-time payment of $31 to avoid another spill over a 10-year period), which extrapolates to a total value of $309 million for the environmental non-use values of the Prince William Sound region.'® On the basis of the $25 willingness to pay per household per year value from ISER’s Healthy Alaska Ecosystems study, the net economic value of KNWR’s 1.7 million acres would amount to approximately $330 million per year. Alternatively, at the $3 level per household expressed for the Exxon Valdez spill, the KNWR’s net economic (i.e., non-use environmental) value would be about $40 million per year. Another indication of the environmental value of the KNWR can be derived by combining the results of ISER’s study of the Refuge’s economic significance to the Kenai Peninsula Borough economy and a series of surveys and analyses by the ADF&G on the attitudes of a sample of Alaskan and non-Alaskan visitors towards wildlife.”” ISER’s KNWR study reported the number of recreation visits to the Refuge in 1997 and the amounts people spent associated with those visits. The ADF&G surveys included a set of contingent valuation questions designed to elicit statements of how much people would be willing to pay for a guaranteed view of various species of wildlife over and above the actual amounts expended on their trips. These data were used to 'S Bristol Bay Economic Assessment Final Draft Executive Summary: December 3, 1998. Page 5. 16 ISER, 2001. The Economic Importance of Healthy Alaska Ecosystems, by Steve Colt. (Anchorage, January 2, 2001) " Op. cit. Table 22, p. 41. (Anchorage, January 2, 2001) 18 Based on 103 million households in the USA willing to pay the lower bound value of $25 per household per year to preserve Alaskan wildlife refuges (op. cit., Table 23, p. 42). '° The product of 103 million households’ average WTP of $3 per year. (op. cit., Table 23, p. 42). 20 Alaska Department of Fish and Game: Alaska Voters, Alaska Hunters, and Alaska Non-Resident Hunters: Their Wildlife Related Trip Characteristics and Economics (ADFG, Anchorage, 1994), and Alaska Non-Resident Visitors: Their Attitudes Towards Wildlife and Wildlife Related Trip Characteristics and Economics (ADFG, Anchorage, 1997; both by SuzAnne M. Miller and Dr. Daniel W. McCollum). Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-28 July 2002 estimate the net economic values that the sample of residents and non-residents placed on their wildlife-related trips to various regions of the state in the early 1990s. By multiplying the numbers of visitors to the KNWR by the net economic values estimated in the ADF&G studies, another rough indication of the non-use environmental value of the Refuge can be derived. The ISER study of the KNWR reports a total of 292,114 visits to points inside the Refuge in 19977! plus another 250,192 to points outside the Refuge to fish for species dependent on Refuge habitats (mainly for salmon on the lower Kenai River). The ADF&G studies indicated that Alaskan residents on average valued the non-use environmental value of their wildlife-related trips to south-central Alaska destinations at about $185**, while non-Alaskan visitors indicated an average value of about $400”. Considering just the visits to on-site locations in the KNWR, the aggregate net economic value that could be associated with the Alaskan residents visiting the refuge in 1997 (for whatever purpose) would be on the order of $43 million, while the non- Alaskan visitors’ share amounted to about $24 million, for a grand total net economic value of $67 million. This figure does not have a time dimension, being based on anticipated trip experience during one’s lifetime rather than making an annual outlay (e.g., like an insurance premium) to preserve a resource. The annualized equivalent value of the $67 million net economic value would be $3.64 million per year, assuming an interest rate of 4.5 percent and a term of 40 years (the terms for the Southern Intertie Project’s cost-benefit analysis). This is the amount that on-site visitors to the KNWR presumably would be willing to pay each year in excess of actual dollar costs of access to ensure the opportunity of viewing the various wildlife species living in the Refuge. Following the foregoing computations, it would appear appropriate to add both the economic impact values (1,492 jobs and $40.4 million in annual labor income) and the value of the net economic benefits of the environmental assets of the Refuge to the cost side of the SIP’s cost/benefit equation to see whether the ratio would remain positive after burdening the Project with the potential loss (i.e., cost) of the Refuge’s environmental values. This would not be correct, however, unless some adjustments were first made to the value figures to exclude resources that would not be affected by the transmission Project. Only if it could be sustained that that the Southern Intertie Project jeopardized all of the environmental assets throughout the entirety of the KNWR would it be appropriate to charge the Project with the full net economic value (however estimated) of its environmental values. The Enstar alternative’s routing would, however, affect only a narrow portion of the northern part of the KNWR, while the Tesoro Route alignment would affect virtually none of the KNWR. Some adjustment would need to be made to 21 Sport fishing—85,890; big-game hunting—3,250; other hunting—6,000; non-consumptive uses (e.g., wildlife viewing, hiking)—16,974; and incidental visits (where the Refuge was not the primary purpose of the trip)— 180,000, for a total of 292,114. Twenty-eight percent of the on-site visits were made by local (KPB) residents (82,146), while 51% were from other parts of the state (150,083), leaving 21% from non-Alaska residents (59,885). More than four-fifths of the fishing trips to refuge-dependent places outside the KNWR were made by Alaskan residents. ISER, op. cit, p. B-2. » ADFG, 1994; weighted average derived from data in Table A-13, p. A-57. Net economic values varied by species, ranging from $86 for whales to $557 for grizzly bears. Different values were registered for trips to other areas, such as Southeastern Alaska, Interior Alaska, Arctic Alaska, etc. 3 ADFG, 1997, Table C-3, p. C-23. NEVs ranged from $419 per trip to see eagles to $546 to see brown bears. > Per breakdown of numbers of on-site visitors by place of origin in footnote 19. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-29 July 2002 exclude from the calculation base those portions and aspects of the Refuge that would not be affected by the Project. For example, the primary recreational use of the Refuge is sport fishing, most of which occurs on the Kenai River. The Enstar alignment’s southern variant, which would cross the river at two points after departing the Soldotna Substation, would have at most a negligible aesthetic effect on fishing activities and none on the quality or viability of the habitat. Such non-consumptive uses as wildlife viewing and hiking in the Refuge would be affected only in the vicinity of the Enstar right-of-way (again aesthetically) most of which is remote from the usual locations of recreational activities in the Refuge. This analysis thus frames the issue for proponents and opponents of the Project: (1) what is an appropriate basis for valuation of the Refuge’s non-use environmental values at risk from the Project—i.e., what are people willing to pay to preserve its environmental assets from perceived risks? And, (2) what is the scientific basis for defining how much loss could occur out of the totality of the Refuge’s environmental services to wildlife? What is the likely percentage? Unless the latter can be meaningfully described and quantified to an appropriate survey audience, a valid contingent valuation study cannot be done. And unless that can be done, a fully quantified economic-environmental cost-benefit analysis cannot be performed. It is not being argued that the Project—particularly the Enstar alternative—would not have some impact on the environmental qualities of the Refuge. The crucial question is, of course, how much? In short, the economic and environmental values of the Refuge would have to be discounted to account properly for just the asset values that might be affected by the Project. The problem is that it is exceedingly difficult to quantify such risks as, for example, how much more vulnerable are the bears, moose, and other animals to human contact with the widened right-of- way versus with the existing condition. Can the biologists tell us with any certainty how the wildlife will respond to a given change in their habitat? Then, even if they can, how can that parameter be translated into terms that a lay respondent in a contingent valuation survey could relate to his or her sense of values and make reasonable, but still hypothetical trade-offs of giving up some purchasing power in exchange for an uncertain assurance that the money would guarantee the preservation of the habitat’s viability? What is the significance of, say, a five or ten percent increase in the probability of bear-human encounters along the Enstar Route in the Refuge as a result of widening the existing right-of-way? What is the most likely number, and then what is the significance of that value in terms of the long-term viability of the bears (and other wildlife)? These are the kinds of information that have to be specified in a contingent valuation survey to elicit valid judgments. Wrap Up and Conclusions If the use and non-use values of the elements of the Refuge’s environmental assets that would likely be irreversibly damaged by the Project amounted to at least $2.39 million per year (see page 2-30, above), then the Enstar Route alternative would have to be deemed unjustifiable from Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-30 July 2002 an economic efficiency standpoint. The question is, again, what is the appropriate value for the Refuge assets truly at risk?”° Both the proponents and critics of the Southern Intertie Project are faced with a dilemma over the accounting for the costs and benefits of the Project: how to fairly incorporate and reflect the values of environmental resources consumed or affected by the Project’s construction and operating activities. On the one hand, the Project’s sponsors have recognized the burdens their Project is likely to impose on the environment and have proposed mitigating measures (see DEIS Appendix D; the mitigation measures’ costs are included in the cost-benefit analysis) to avoid or minimize adverse impacts. Thus, they have endeavored to identify and characterize the potential ecological impacts of the proposed action in the DEIS. Conversely, some commenters seek to prevent or minimize any adverse effects on the natural environment, and are disposed to oppose any disturbance to the natural setting—in particular that of the KNWR—in the belief that the equilibrium between the habitat and its dependents is very fragile and that any changes in the natural setting will set off irreversible damages. It follows naturally that the advocates of conservation will want to place as high a price as possible on the value of environmental services the Refuge provides to its occupants—animal and human—so that resource values will not be irretrievably disturbed or damaged by industrial intrusions like transmission lines. The environmental economics profession has endeavored to bridge the divide by developing such tools as the contingent valuation method to facilitate evaluation of costs and benefits. But, as noted earlier, controversy still surrounds its employment. A perspective of the problem may be gained from considering a number of questions about how the Southern Intertie Project’s cost- benefit equation might be broadened to include use and non-use environmental asset values: = As discussed above, since the proposed action would involve only a small portion of the KNWR area, how much of the refuge-wide value of environmental assets (which, depending on the valuation methodology employed, could range from several tens of millions of dollars to several hundred million) should be included in the cost accounting? For example, salmon fishing on the Kenai River, which accounts for the majority of local and visitor visitation and consumptive recreational spending in the refuge, would be minimally affected by any of the proposed alignments and would have essentially no impact on the species’ habitat. Are the environmental values associated with salmon abundance different from those for brown bears and moose? = Is proportional acreage a suitable metric, or are there non-linear relationships between habitat disturbance and species viability that would alter the weighting? If so, how much, taking into consideration any differences in habitat characteristics in the transmission corridor versus elsewhere in the refuge? = Is a Lower-48 dominated survey base for the contingent valuation analysis of the KNWR’s environmental asset values necessarily the most suitable, and is it reasonable to 5 Again noting that all of the Refuge’s environmental values would not be at risk from the SIP, but only some portion of those in the vicinity of the right-of-way. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-31 July 2002 extrapolate the Refuge’s constituency to the entire population of the United States? Should the views of Alaska’s residents and actual visitors to the Refuge carry greater weight? m Are the existing contingent valuation data applicable? = If acontingent valuation survey was to be undertaken to support the Project’s cost-benefit analysis, who would arbitrate the selection of consultants and design and testing of the survey instrument? (It is assumed that the environmental community would not accept the results of a survey that did not have their approval any more than vice-versa.) These questions give a sense of the difficulties in accounting for non-market environmental values in cost-benefit analysis. Practical considerations precluded undertaking a survey of tourism and recreation and related environmental values on the upper Kenai Peninsula at the time the EVAL for the Project was being written, including deadlines on research, budget constraints, and—most importantly—keeping a perspective on the scope of the investigations relative to the scale of potential disturbances to the environmental setting. It must not be overlooked that there is an alternative to the Enstar Route that avoids the issues of passing through the Kenai National Wildlife Refuge. Except for a tiny parcel of land at the northern tip of the peninsula where the transmission line transitions from overhead to submarine, the Tesoro Route lies totally outside the Refuge and would impose no burden on its environmental values. The Tesoro Route was designated as the environmentally preferred alternative, and, in fact, its higher costs and lower benefit/cost ratio relative to the Enstar Route’s reflect the incremental (i.e., mitigation) costs of avoiding the Refuge. It is our opinion that the DEIS provides an adequate database for the permitting agencies to evaluate the relative costs and benefits of the Project, both monetary and non-monetary. Given the state of controversy over the validity of the contingent valuation method and the opportunities for biased results in any but the most extensive and expensive surveys, the scope and potential environmental impacts of the proposed project do not merit such an undertaking. 2.2.8 Avian Collision Mitigation A specific comment on the DEIS suggested that the DEIS does not seem to take into account birds that use freshwater habitats during the day and raft in Cook Inlet at night. It was noted that during the winter, large rafts of resting waterfowl can be observed on Cook Inlet. These birds could be at special risk of collision with an overhead transmission line on the Tesoro Route because they are flying at dusk into a setting sun and may not be able to see the transmission lines. Following is a discussion regarding the potential for bird collisions on the Tesoro Route and the mitigation measures proposed to reduce the potential for avian collision. The Tesoro Route is located between extensive wetlands to the east located on the KNWR and the shoreline of Upper Cook Inlet to the west. Although it seems to be logical that birds tend to move between the lakes and wetlands and the marine waters of Upper Cook Inlet, several Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-32 July 2002 environmental factors tend to discourage bird movement toward the inlet and across the Tesoro Route. Some of the major factors include: = Most of the land west of the route is forested with only a few small ponds and wetlands or ponds between the route and the bluff along Cook Inlet. = The shoreline of the upper inlet along this area supports essentially no salt marsh habitat, which might attract birds (National Wetlands Inventory maps). = Marine waters of Upper Cook Inlet are subject to strong currents and high turbidity levels throughout the year and provide little habitat, if any, for waterfowl feeding or resting. = Intertidal and subtidal invertebrates (sea duck prey) in the upper inlet along this area are extremely sparse due to the strong currents, ice scour, and very high turbidity (B. Driskell, Marine Biologist, WBD Associates, personal communications). = The distance across open water to the wetlands on the other side of the inlet would tend to inhibit regular movement between these two areas (Bill Larned, Pilot/Biologist, USFWS, personal communication). = Most birds are breeding during the summer months. Movements are generally restricted to more defined areas and most activities focus on nesting, brood-rearing, and molting. Based on these factors, little movement of waterfowl would be expected across the Tesoro Route towards Cook Inlet at any time of the year. During the winter months, ice is the dominant controlling force in the Upper Cook Inlet. Ice flows, cakes, and broken ice move back and forth with the tide throughout much of the winter. This regular ice cover in conjunction with the lack of feeding habitat for sea ducks would result in even less use (if any) by wintering sea ducks than during the summer. The ponds and lake on the KNWR would be frozen and there would be essentially no movement across the Tesoro Route during this time of year. The only wintering birds in the Upper Cook Inlet are the rock sandpiper and remain along the shoreline (Robert Gill, USGS, personal communication). Surveys of wintering sea ducks and other marine birds along the eastern shoreline of Cook Inlet generally do not encounter rafting sea ducks north of Ninilchik, in the Lower Cook Inlet, approximately 20 miles south of the Kenai River. However, wintering waterfowl (primarily goldeneyes, mergansers, and mallards) have been observed in ice-free portions of the Kenai River, and in Cook Inlet near the mouth of the Kenai River. Presumably these birds move between Cook Inlet and the river, although they would not be expected to routinely cross the proposed transmission line north of Nikiski (Bill Larned, USFWS, personal communication, 2002). As discussed in Chapter 3 of the DEIS, Turnagain Arm is one of the main migration routes in this region and Chickaloon Flats is one of the primary staging areas in Turnagain Arm. Chickaloon Flats is approximately 5 to 20 miles east of the Tesoro Route. In spring, some Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-33 July 2002 migratory movements of birds could be expected between Chickaloon Flats and the Susitna River Flats on the west side of the Upper Cook Inlet. Portions of these birds would be expected to pass over the Tesoro Route at some location. Migratory movements are generally at a much higher elevation than local movements, except during inclement weather and poor visibility. No movement corridors have been identified for migrating birds across this portion of the route (Bill Larned, USFWS, personal communications, 2000). In winter, ice cover on freshwater lakes and ponds limits use of lakes and wetlands in interior portions of the peninsula. Concentrations of ice cover would be expected to associate with salt marsh habitats along the coast or river delta, and would tend to limit exposure to the transmission line. As a case in point, transmission lines at the head of Turnagain Arm (Quartz Creek Line) have not been identified as a collision hazard to migrating birds and are not marked. During the breeding season, waterfowl and other waterbirds are dispersed throughout the areas. Nesting and brood-rearing and subsequent feather molt (flightless period) limit the movements of most birds. As young birds from the local population are beginning to fly in late summer (including trumpeter swans and loons), they become more vulnerable to collision with wires. Some species such as loon are more vulnerable due to their low flight patterns. Movement would be generally throughout the lakes and large wetland complexes east of the Tesoro Route. Transmission lines closest to water bodies or open wetlands would be expected to create the greatest obstacles. These lines would be marked within 4 mile of these areas to increase the visibility, and the locations of these marked areas have been provided in the mitigation plan (see FEIS Volume II — Mitigation Plan). During fall migration, Chickaloon Flats is also used for staging of waterfowl. Flight paths to the Chickaloon Flats coming from the west could potentially cross over the Tesoro Route along a broad front. Since the distance between the route and Chickaloon Flats is approximately 5 to 20 miles, the risk of collision would be expected to be quite low, except during adverse weather. Random local movement of waterfowl preparing for migration could come into contact with the lines, but marked lines would lower the potential for collision. The effectiveness of marking the static line and conductors is highly dependent on the specific location and the type of marker used. Considering other transmission lines and distribution lines throughout the peninsula and their proximity to water bodies and wetlands, marking the lines on the Tesoro Route within %4 mile of water bodies and open forest cover would be considered a conservative approach to reducing potential collision hazards to waterfowl. 2.3. UPDATED INFORMATION AND CORRECTIONS The following are updated information and corrections to the DEIS organized by Chapter, Appendix, or Reference sections. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-34 July 2002 Chapter 3 — Affected Environment and Environmental Consequences 3.5.1 Terrestrial Vegetation Table 3-3, pg. 3-36 — The marten should be removed from the table, as the marten is known to occur only in a limited portion of the KNWR. The arctic shrew should be removed from the table, as it does not occur on the Kenai Peninsula. The pigmy shrew and the common shrew should be included in this table rather than the arctic shrew. 3.5.3 Terrestrial — Wildlife Table 3-7, pg. 3-57 — Collared pikas and Arctic ground squirrels should be removed from the table and corresponding text as they'are not known to occur in the Project study area. Pg. 3-58 — The Canada lynx is no longer a candidate species, but was officially declared a threatened species in the contiguous United States by the USFWS on March 24, 2000. In addition, it should be qualified that the lynx population was depressed in the 1980s. Closure of the lynx seasons from the mid-1980s to the mid-1990s on the Kenai Peninsula presumably allowed the lynx population to recover to natural but cyclic level by the mid-1990s. Birds, pg. 3-64 — As a point of clarification, power lines constructed along the proposed Enstar Route pose a greater threat than the Tesoro Route to trumpeter swans because they are the largest-bodied bird using the Project area. Large bodied birds are more susceptible than small birds to power line collisions. Power lines along the proposed Enstar Route are a greater threat to trumpeter swans because of the documented trumpeter swan staging areas at the Lower Moose River and Watson Lake and their known migratory route that passes through Chickaloon Flats. 3.5.4 Alternatives Tesoro Route — Bernice Lake to Pt. Possession — Route Option A, pg. 3-71 - Hunting and trapping also appear to be the main cause of mortality among adult lynx on the KNWR (Bailey et al. 1986) and trapping along the edge of a cleared power line right-of-way might increase trapping mortality as lynx move along the edge. It is questionable that the clearing of the power line right-of-way would have any short-term or long-term benefits to snowshoe hares and lynx. This is because hares are reluctant to colonize areas with little protective cover from predators - protective cover that would be absent after clearing, then periodically removed to protect the power lines. In faster-tree-growing-areas of the southern boreal forest (Quebec), hares avoided clear-cut areas (similar to power line rights-of- way) for at least 10 years (Bellefeuille et al. 2000; Potvin et al. 1999). It was also concluded that it may take 30 years for hares to increase to peak densities in that environment (Ferron et al. 1998). That observation is supported by similar observations on the Kenai Peninsula. It took over 20 years for snowshoe hares to reach substantial population levels in the extensive 1969 burn on Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-35 July 2002 the refuge. Habitat structure is highly important to hares and a minimum lateral cover of 70 percent is recommended for suitable hare habitat (Litvaitis et al. 1985)—a value unlikely to be found in a power line right-of-way. It is likely that the power line right-of-way would be cleared at least once if not twice or more in 20 years, thus periodically removing any protective cover for hares. 3.5.8 Alternatives (Drainage Basins) Chickaloon River Drainage Basin, pg. 3-109 — The gradient of 4.7 feet per mile listed in the DEIS is incorrect. The Chickaloon River has an average gradient of 25 feet per mile (4.7 m/km). The estimated Chickaloon River salmon numbers in the DEIS are also incorrect. During investigation of the Chickaloon River, pink salmon was the most abundant salmon species with an estimated even year (1984) spawning escapement of 100,000 fish. Chinook salmon and sockeye salmon were estimated at 3,000 to 5,000 and 4,000 to 6,000 fish, respectively. No estimates were obtained for coho salmon or Dolly Varden. Big and Little Indian Creek Drainage Basins, pg. 3-110 — The gradient for Big Indian Creek of 31 feet per mile listed in the DEIS is incorrect. The Big Indian Creek has an average gradient of 131 feet per mile (24.8 m/km). In addition, the statement in the DEIS that both Little and Big Indian Creek “support small runs of chinook salmon” is incorrect. Big Indian Creek has spawning populations of Chinook, pink, sockeye, and coho salmon. Little Indian Creek supports coho and pink salmon. Populations in these streams have not been studied, so little is known of the run size or timing. 3.7.1 Affected Environment (Socioeconomic) The following information updates DEIS Section 3.7.1 using the 2000 Census Data, which was not available at the time the DEIS was published. Tables from the DEIS have also been updated to include this information; table numbers are the same as those used in the DEIS for easy reference. This updated 2000 Census Data does not affect conclusions presented in the DEIS regarding socioeconomic impacts. Socioeconomic Inventory Updated demographic and economic information for the study area was gathered from these sources (in addition to sources listed on DEIS pg. 3-150): = Municipality of Anchorage General Government Operating Budget, 2001 = Anchorage School District Financial Report, FY 2002-2003 = Kenai Peninsula Borough General Fund, FY 2000-2001 Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-36 July 2002 = Kenai Peninsula Borough School District FY01 Budget 1990 and 2000 U.S. Censuses of Population and Housing = U.S. Bureau of Economic Analysis Regional Economic Information System (REIS) (2002) = US. Bureau of Labor Statistics (2002) Kenai Peninsula Borough Demographic Summary The population of the KPB has increased 22 percent since 1990, reaching 49,691 in 2000 (Table 3-11). Since 1990, the rate has been approximately 2.0 percent per year. Population estimates for the KPB are broken into two census subareas, the Kenai-Cook Inlet subarea and the Seward subarea, with the Kenai-Cook Inlet subarea accounting for 90 percent of the KPB population in 1999. Major population concentrations within the KPB occur in the City of Kenai (6,942), community of Sterling (4,705), City of Homer (3,946), City of Soldotna (3,759) and Nikiski (4,327). TABLE 3-11 (Rev 2000) KPB AND COMMUNITIES WITHIN PROJECT AREA RACIAL COMPOSITION, 2000 KPB Kenai |_Nikiski Soldotna Total Population* 49,691 6,942 4,327 3,759) White** 42,841 5,745 3,77 3,310} Black** 229 34 5 ll American Indian, Eskimo, Aleut** 3,713} 607) 327 187 Asian, Pacific Islander** 566 131 53 79) Other Race** 415 78) 36) 48 Two or more races 1,927 347 135 124 * Between 1990 and 2000, the KPB population increased from 40,802 to 49,691 (21.8%). ** Reporting one race. Source: U.S. Census Bureau, "2000 U.S. Census of Population and Housing, Summary File 1-A (2001). The population of Kenai has increased 6.3 percent since 1990, with an average annual growth rate of 0.9 percent. The City of Soldotna’s population increased from 3,482 in 1990 to 3,759 in 2000. The fast-growing community of Nikiski had a 2000 population of 4,327, up 60 percent from 1990. In 2000, the KPB had a total population of 49,691 of which 86 percent were white and seven percent were American Indian, Eskimo, and Aleut. In 1990, approximately 7.5 percent of the population was below the poverty level. Census 2000 data on income and poverty will not be available until mid- to late 2002. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-37 July 2002 Economic Summary Total employment in the KPB was estimated at 27,236 as of 1999 (Table 3-14) (BEA 2002). The largest industries in terms of employment were trade (wholesale and retail) and professional services, which include health and education services. These two industries accounted for 45 percent of total employment in the KPB. The cities of Kenai and Soldotna showed the same pattern, with trade and professional services accounting for the most employment. Nikiski was different in that mining (oil and gas) accounted for the greatest employment, followed by trade and manufacturing. The U.S. Bureau of Economic Analysis (BEA) employment estimates for 1990, 1995, and 1999 are presented in Table 3-14. BEA estimates that total employment in the KPB has increased from 22,328 to 27,236 over a nine-year period, an increase of 22 percent. Census 2000 data on local employment will be available mid- to late 2002. TABLE 3-14 (Rev 2000) KENAI PENINSULA BOROUGH EMPLOYMENT, 1990, 1995, 1999 % Change Industry 1990 | 1995 | 1999 1990-99 [Farm employment 129) 97 92 -28.7% |Agricultural services, forestry, fisheries 2,498) 2,014! 2,666 6.7% Mining 1,186] 1,222} 1,181 -0.4%| Construction 1,321] 1,583] __1,836 39.0% Manufacturing 2,187| 2,158 1,804 -17.5%| ‘Transportation and public utilities 1,345 1,493 1,427| 6.1%) ‘Wholesale trade 484 556 596] 23.1%} Retail trade 3,018] 4,266] 4,698) 55.7% Finance, insurance and real estate 1,053) 1,109 1,319) 25.3% Services 5,251| 6,293) 6,989) 33.1% Federal government cc) 849 815) 7.2%) State and local government 3,096} 3,757} _ 3,813 23.2% Total Full-time and Part-time Employment 22,328] 25,397| 27,236 22.0% Source: U.S. Bureau of Economic Analysis, "Regional Economic Information Service." (2002). Includes farmers, proprietors, and self-employed. The total personal income for the KPB in 1999 was estimated at $1.248 billion, according to the BEA. Per capita income was estimated at $25,478 for the KPB in 1999. Census 2000 data on local income will be available mid- to late 2002. Housing Summary According to the 2000 U.S. Census, the KPB had a total of 24,871 housing units, up from 19,364 in 1990. The City of Kenai accounted for 3,003 of the KPB’s housing units, up from 2,681 in Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-38 July 2002 1990. Soldotna had a total of 1,670 housing units, up from 1,457 units in 1990. The 2000 Census reported 1,766 housing units in the community of Nikiski, up from 1,009 in 1990. Fiscal Summary Total general government revenues totaled $56.61 million in 2001 (KPB 2002). Intergovernmental revenues accounted for 19 percent of total revenues, property and motor vehicle taxes accounted for 48 percent, and sales taxes accounted for another 23 percent. General fund expenditures totaled $60.17 million. The Kenai Peninsula School District’s total budget for Fiscal Year 2000-2002 amounted to $73.56 million, with property taxes and intergovernmental transfers providing the bulk of operating funds (KPB School District, 2002). Municipality of Anchorage Demographic Summary The population of Anchorage has grown by 15 percent between 1990 and 2000, reaching 260,283 in 2000 (Table 3-16). Since 1990, the rate of growth has been approximately 1.4 percent per year. TABLE 3-16 (Rev 2000) HISTORICAL POPULATION ESTIMATES ANCHORAGE AND KPB % Change 1990- Area 1980 1990 2000 2000 Municipality of Anchorage 174,431 226,338 260,283 15.0% KPB 25,282| 40,802 49,691 21.8% Kenai 4,324 6,327 6,942) 9.7% Nikiski 1,109 2,743 4,327 57.7% Soldotna 2,320} 3,482| 3,759} 8.0% Sources: Alaska Department of Labor, Research and Analysis Section, Demographics Unit, 2002. U.S. Bureau of the Census, Census of Population and Housing, 1980, 1990, 2000. According to the U.S. Census Bureau, Anchorage had a total population 260,283 in 2000 of which 72 percent were white, 6 percent black, 7 percent American Indian, Eskimo or Aleut, 6 percent Asian or Pacific Islander, and 8 percent other (Table 3-18). Total personal income in Anchorage amounted to $8.717 billion in 1999, averaging $33,813 per person (BEA 2001). Southern Intertie Project Chapter 2 —- Supplemental Information Final EIS 2-39 July 2002 TABLE 3-18 (Rev 2000) ANCHORAGE - MUNICIPALITY OF ANCHORAGE RACIAL COMPOSITION, 2000 Total Population* 260,283 White 188,009 Black 15,199) American Indian, Eskimo, Aleut 18,941 Asian, Pacific Islander 16,856) Other Race 5,703 Two or more races 153575 Source: U.S. Census Bureau, "2000 U.S. Census of Population and Housing” (2001). Economic Summary Historical data on Anchorage employment are presented in Table 3-20. Employment has increased steadily from 1990 to 1999 at an average annual rate of approximately 1.36 percent. Over that time period, employment has increased primarily in services and trade while decreasing in federal employment and mining. Unemployment in Anchorage was estimated at 4.7 percent in 2000, slightly higher than the U.S. average rate of 4.0 percent. Between 1990 and 1995, the Anchorage rate was consistently lower than the U.S. average, after recovering from high unemployment during the late 1980s, but during the latter half of the decade the local unemployment rate rose slightly higher than the national rate (Table 3-21) (Bureau of Labor Statistics, 2002). TABLE 3-20 (Rev 2000) ANCHORAGE EMPLOYMENT, 1990, 1995, 1999 % Change Industry 1990 | 1995 | 1999 |1990-99 [Farm employment 0) d OQ} 0.0% Agricultural services, forestry, fisheries 2,201] 2,066) 2,455) 11.5% Mining 5,902 4,490) 4,055] -31.3% Construction 7,870| 9,100, 9,728] 23.6% Manufacturing _ 2,860} 2,916) 2,880) 0.7% ‘Transportation and public utilities 12,535|_13,777|_ 16,146] 28.8%) (Wholesale trade 6,080} 6,910) 7,071) 16.3% Retail trade 23,968] 28,070] 29,754] 24.1%) Finance, insurance and real estate 12,458) 12,443} 13,700|_ 10.0% Services 42,023|_ 47,834] 54,492} 29.7% Federal government 23,825} 22,033] 20,238] -15.1% State and local government 15,890 _ 17,120) 17,704] 11.4%) Total Full-time and Part-time Employment 155,612) 166,759] 178,223} 14.5% Source: U.S. Bureau of Economic Analysis, "Regional Economic Information Service." (2002). Includes farmers, proprietors, and self-employed. Southern Intertie Project Final EIS 2-40 Chapter 2 — Supplemental Information July 2002 The mining industry, including oil and gas, had the highest average monthly wage in the Anchorage area in 1999, at $7,485, and retail trade had the lowest average monthly wage at $1,704. The average monthly wage for all industries was $2,958. Table 3-22 lists historical wage information for Anchorage for 1990, 1995, and 1999. TABLE 3-21 ANNUAL UNEMPLOYMENT RATE IN U.S., ALASKA, AND ANCHORAGE, 1990-2000 Year US. Alaska Anchorage 1990 5.6% 7.0% 5.1% 1991 6.8%) 8.7%) 6.8% 1992 71.5% 9.2% 7.3%) 1993 6.9%) 71.71% 5.9% 1994 6.1% 7.8% 5.6% 1995 5.6% 7.3%) 5.2% 1996 5.4% 7.8% 5.5% 1997 4.9% 7.9% 5.8%) 1998 4.5% 5.8% 4.1% 1999 4.2% 6.4% 4.5% 2000 4.0% 6.6% 4.7% Source: U.S. Bureau of Labor Statistics, 2002 TABLE 3-22 (Rev 2000) ANCHORAGE AVERAGE MONTHLY WAGE BY INDUSTRY, 1990, 1995, 1999 % Change Industry 1990 1995 1999 1990-99 Private Sector 2,446) 2,595 2,791 14.1%) Agricultural services, forestry, fisheries 1,483 1,744) 1,963) 32.4%) (Mining 6,239) 7,199) 7,485 20.0% (Construction 3,743) 3,885 4,090 9.3% Manufacturing 2,037 2,472 2,812 38.0% (Transportation and public utilities 2,940) 3,459 3,674 25.0%| [Wholesale trade 2,780) 2,843 3,051 9.7% Retail trade 1,457) 1,507 1,704| 17.0% \Finance, insurance and real estate 2,404) 2,785 3,148 30.9% Services 1,935) 2,177 2,370 22.5% Government Sector 2,960] 3,443 Sort 20.8%! [Federal 2,820 3,380) 4,010 42.2% State 2,911 3,366] 3,061 5.2% Local 3,182) 3,588 3,595, 13.0% Total All Industries 2,658) 2,789) 2,958) 11.3% Source: Alaska Department of Labor and Workforce Development, Research and Analysis Section, "Employment and Earnings Summary Report, 1999." Southern Intertie Project Final EIS 2-41 Chapter 2 — Supplemental Information July 2002 Housing Summary There were 100,368 housing units within the Municipality of Anchorage in as of the 2000 Census. Fiscal Summary Property and other local taxes provide the largest revenue source for the Municipality of Anchorage, making up approximately 53 percent of total government revenues (there are no sales taxes in Anchorage). Intergovernmental revenues accounted for 13 percent. Total general- fund revenues were estimated at $91.47 million for 2001 (Municipality of Anchorage 2002). The Anchorage School District’s budget for FY 2000-2001 totaled $448.66 million, with local property taxes covering 30 percent of the funds. Intergovernmental transfers provided much of the balance (Anchorage School District, 2002). The total assessed value of taxable property in the school district in 2000 was reported as $15.98 billion. 3.8.1 Affected Environment (Subsistence) The following statement in the DEIS (pg. 3-206) is incorrect, and is deleted: “No specific designation has been made by the Federal Subsistence Board providing a priority to a particular group having customary and traditional subsistence practices in Unit 15A.” 3.8.2 Environmental Consequences (Subsistence) The statement found in the DEIS (pg. 3-209): “There appears to be no negative impact on populations of relevant species that would impair subsistence practices” is revised for purposes of clarity to the following: “Although the proposed project is likely to have adverse impacts on the moose population of the KNWR through impeded habitat improvement actions such a prescribed burning, it is not anticipated that such impacts to the moose population or other species will negatively affect subsistence opportunities on the refuge.” 3.12.2 Cumulative Impact Process Table 3-35, p. 3-288 Southern Intertie Project: planned or future projects 38.3 miles in length; 150 feet wide right-of-way; 696 acres of land used. Cumulative total of acres should be 129,283 acres. Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-42 July 2002 Chapter 4 — Scoping. Consultation, and Coordination 4.6 Authorizations and Permitting Requirements Table 4-6 Environmental Laws, Authority, and Related Statutes and Orders (pg. 4-23). Add: 16 U.S.C. 4601 et seq. Land and Water Conservation Fund Act of 1965. 4.6.2 Permits In Table 4-7, pages 4-26 and 4-27, the correct address for DNR/Parks and Outdoor Recreation is 550 W. 7 Ave., Suite 1380, Anchorage, Alaska, 99501-3561. Table 4-7 (pg. 4-26) National Park Service also administers the LWCFA in coordination with DNR/Parks and Outdoor Recreation. Appendix B pg. B-26 HVAC means high voltage alternating current. References Table 1-2, pg. R-1, #8 should be Comprehensive Avalanche Atlas, Alaska Mountain Safety Center, Inc, October 1991 #9 becomes #10, so on up to #13 becomes #14 Southern Intertie Project Chapter 2 — Supplemental Information Final EIS 2-43 July 2002 APPENDIX A USFWS COMPATIBILITY DETERMINATION United States Department of the Interior KENAI NATIONAL WILDLIFE REFUGE P.O. Box 2139 Soldotna, Alaska 99669-2139 IN REPLY REFER TO: (907) 262-7021 COMPATIBILITY DETERMINATION The National Wildlife Refuge System Administration Act of 1966, as amended by the National Wildlife Refuge System Improvement Act of 1997, 16 U.S.C 668dd-668ee, states that “The Secretary is authorized, under regulations as [s] he may prescribe, to - (A) permit the use of any area within the [National Wildlife Refuge] System for any purpose, including but not limited to hunting, fishing, public recreation and accommodations, and access whenever [s] he determines that such uses are compatible” and that “... the Secretary shall not initiate or permit a new use of a refuge or expand, renew, or extend an existing use of a refuge, unless the Secretary has determined that the use is a compatible use and that the use is not inconsistent with public safety.”” A compatible use is defined as “‘A proposed or existing wildlife-dependent recreational use or any other use of a national wildlife refuge that, based on sound professional judgement, will not materially interfere with or detract from the fulfillment of the National Wildlife Refuge System mission or the purposes of the national wildlife refuge.”’ The compatibility determination is to be a written determination signed and dated by the Refuge Manager and Regional Chief, signifying that a proposed or existing use of a national wildlife refuge is a compatible use or is not a compatible use. Applicable compatibility regulations in 50 CFR Parts 25, 26, and 29 were published in the Federal Register October 18, 2000 (Vol. 65, No. 202, pp 62458 - 62483). Use: Southern Intertie Project Refuge Name: Kenai National Wildlife Refuge (KNWR) Establishing and Acquisition Authorities: Established as the Kenai National Moose Range by Executive Order 8979 on December 16, 1941. The boundaries were modified, purposes expanded, and name changed to Kenai National Wildlife Refuge under provisions of the Alaska National Interest Lands Conservation Act (ANILCA) on December 2, 1980 (Public Law 96-487 Stat. 2371). Refuge Purposes: EO 8979 purpose: “...protect[ing] the natural breeding and feeding range of the giant Kenai moose on the Kenai Peninsula, Alaska...”. Page 1 of 9 ANILCA purposes: “(i) to conserve fish and wildlife populations and habitats in their natural diversity including, but not limited to moose, bear, mountain goats, Dall sheep, wolves and other furbearers, salmonoids and other fish, waterfowl and other migratory and nonmigratory birds; (ii) to fulfill the international treaty obligations of the United States with respect to fish and wildlife and their habitats; (iii) to ensure to the maximum extent practicable and in a manner consistent with the purposes set forth in paragraph (i), water quality and necessary water quantity with the refuge; (iv) to provide in a manner consistent with subparagraphs (i) and (ii), opportunities for scientific research, interpretation, environmental education, and land management training; and (v) to provide, in a manner compatible with these purposes, opportunities for fish and wildlife- oriented recreation.” The Wilderness Act of 1964 (Public Law 88-577) purposes are to secure an enduring resource of wilderness, to protect and preserve the wilderness character of areas within the National Wilderness Preservation System, and to administer this wilderness system for the use and enjoyment of the American people in a way that will leave them unimpaired for future use and enjoyment as wilderness. Policy (FWS 603 2.8) requires that pre-ANILCA purposes remain in force and effect, except to the extent that they may be inconsistent with ANILCA or the Alaska Native Claims Settlement Act, but such purposes only apply to those areas of the Refuge in existence prior to ANILCA. The Executive Order purpose to protect Kenai moose, however, is treated as complimentary to the broader ANILCA purpose of conserving fish and wildlife populations; therefore, no special attention is given the Executive Order purpose in this compatibility review process. Sec. 4(a) of the Wilderness Act provides that the purposes of the Act are to be within and supplemental to the purposes for which National Wildlife Refuges are established and administered. These purposes are applied to the approximately 1.3 million acres of Congressionally designated wilderness within the KNWR. They are also applied to the remaining approximately 700,000 acres of Refuge lands (that are not designated as wilderness) in any way that the proposed use might effect the designated wildemess areas. National Wildlife Refuge System Mission: To administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of the fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans. Description of Use: The Southern Intertie Project is proposed by The Intertie Participants Group (IPG) and entails the construction of a 138 kilovolt electric transmission line for approximately 73.4 miles from the Soldotna Substation to Anchorage, of which approximately 38.3 miles would be constructed along what is known as the Enstar Route through the Kenai National Wildlife Refuge. Members of the IPG include Golden Valley Electric Association, Matanuska Electric Page 2 of 9 Association, Chugach Electric Association, Anchorage Municipal Light and Power, Homer Electric Association, and the City of Seward. The Enstar Route is one of two primary alternatives evaluated in a Draft Environmental Impact Statement (DEIS) that was released on October 3, 2001 and is the preferred alterative of the applicant. The other route evaluated in the DEIS is known as the Tesoro Route which follows the coast from Nikiski to Pt. Possession along the northwest boundary of the Refuge. The Tesoro Route was found to be the environmentally preferred alternative evaluated in the DEIS. The IPG has filed for a right-of-way permit for the Enstar Route consistent with the requirements of Title XI of ANILCA. The DEIS, a required element of the Title XI application process, was developed primarily by IPG contractors under the direction of the Rural Utilities Service (the lead Federal agency for the process). The U.S. Fish and Wildlife Service (Service) and U.S. Army Corp of Engineers were cooperating agencies. The proposed project is located within the Railbelt electrical systems power grid that electrically connects central and south-central Alaska from Homer to Fairbanks. The system allows the participating utility companies to sell and buy power to and from each other, taking advantage of lower costs in other areas, and to provide back-up power to each other. The purpose of the proposed Southern Intertie Project is to address deficiencies in the existing Railbelt electrical system south of Anchorage. Specifically, the project would increase the power transfer capability over the existing Quartz Creek transmission line (to enable the full utilization of the 120 MW generating capacity of the Bradley Lake Hydroelectric Project) and to provide reliable back-up power in the event of outages of the Quartz Creek (existing) transmission line (which is located in historical avalanche areas, and subject to outages from ice, wind, and snow loading). Either the Enstar Route through the Refuge, or the Tesoro Route to the north of the Refuge, meet the purpose and need of the proposed project. The Enstar Route option is estimated to cost $ 99.6 million over the life of the project; the Tesoro Route is estimated to cost $ 114 million over the life of the project. Both the Enstar and Tesoro Route options have several variants in the proposed routes where they.would cross the Turnagin Arm of Cook Inlet and enter the city of Anchorage. The proposed Enstar alternative would begin with an overhead transmission line at the existing substation located outside of the Refuge in Soldotna, replacing an existing 69kV line, running south and then east to the Enstar Pipeline Corridor. The Enstar Pipeline is a buried natural gas pipeline that transports gas from producing fields on the Kenai Peninsula to Anchorage. The right-of-way permit for the line was issued in 1960 by the Bureau of Land Management (BLM). Official notice of the transfer of management responsibility for the line to the Service was received from the BLM in December 1998. The proposed transmission line would parallel the buried pipeline and require a 150- foot right-of-way through the Refuge, in addition to the 50- foot existing pipeline right-of-way. The right-of-way would be cleared of trees and other woody vegetation to allow safe operation and maintenance of the transmission line (including the removal of any hazard trees within or outside the proposed right-of-way that might fall onto the Page 3 of 9 line). The overhead transmission line would be constructed with conductors supported on steel or wood 90-foot tall towers. A submarine cable would be used for crossing Turnagin Arm, a distance of approximately 10.5 miles. The proposed construction season for most of the project would be April to October; however, winter construction would be undertaken through the Refuge in order to minimize environmental impacts. A complete description of the proposed project, and the affected environment, is found in the September 2001 Southern Intertie Project DEIS. Availability of Resources: Right-of-way clearing and construction of the proposed transmission line would increase public access and utility company activity into a large portion of the Refuge necessitating the increase of on-the-ground and aerial monitoring, site visits, evaluation, and law enforcement. Currently additional resources to accomplish the additional monitoring, evaluation, and enforcement are not available and the activities could not be undertaken without reductions in other Refuge program areas. Additional staff time required is estimated at: biology (160 hours), pilots (104 hours), park rangers (LE) (208 hours), and management/administration (32 hours), for an annual estimated additional staff cost of $16,900. Additional vehicle, airplane, and equipment and supply costs are estimated at $19,100, for a total annual estimated additional cost of $36,000. Anticipated Impacts of the Use: The DEIS provides an evaluation of the anticipated impacts of the proposed action between the two alternatives analyzed. These impacts are summarized on pp S-22 through S-26 of the DEIS summary document. For the proposed Enstar Route through the Refuge, significant and cumulative impacts which would be short and long term, were predicted to vegetation and wetlands. These would be expected to be irreversible and irretrievable impacts for the life of the project. When evaluating birds, including bald eagles, trumpeter swans and waterfowl in general, the DEIS recognized the potential for local and nationally significant impacts on the Refuge. These included cumulative irreversible and irretrievable impacts during the life of the project. Similarly the DEIS predicted cumulative irreversible and irretrievable impacts to large mammals (including brown bears, black bears, moose, and caribou) on the Refuge. The impacts to brown bears, black bears, and moose were predicted to be nationally significant. Predators, including wolves and lynx, were also predicted to suffer nationally significant impacts. Nationally significant impacts were also projected to recreation and land use (citing conflicts with Refuge management plans and qualification criteria for wilderness designation) and to visual aesthetics because of degradation of natural scenic quality and visual intrusion to residential, recreational, and travel-way views. In part because of the impacts summarized above , the DEIS rejected the Enstar Route as the environmentally preferred alternative for the Southern Intertie Project, stating: “The environmentally preferred alternative is the Tesoro Route, Option A from Bernice Lake Page 4 of 9 Substation to Pt. Possession, combined with a submarine cable crossing of the Turnagin Arm from Pt. Possession directly to Pt. Woronzof (Route Option C) for a total of 61.3 miles. This route is environmentally preferred because it exhibits on balance, lower overall environmental impacts than the other alternatives, as shown on Table 2-11 in the DEIS.” “Any of the other Tesoro Route alternatives would also exhibit overall lower environmental impacts than the Applicant’s proposed alternative and other Enstar Route options, primarily because of the impacts of the Enstar Route where it crosses the KNWR on the Kenai Peninsula...” [DEIS p 2-60]. Direct, indirect, and cumulative impacts are predicted to occur for the proposed project in two categories: (1) impacts associated with ground disturbance that occurs during construction (clearing vegetation for right-of-way and access; preparing tower sites; assembling and erecting tower structures; stringing conductors - wire pulling and splicing sites), and (2) long-term impacts associated with the presence of the line and associated facilities, and maintenance of the right-of-way clearing. A significant impact to biological resources, as defined in the DEIS Table 3-1, would occur under the following conditions: (1) the resource or species has a designated legal status or protection; (2) the project creates wildlife hazards not currently present in the environment, or the resource has a high susceptibility to the kinds of impacts associated with the project and project- related impacts could result in disturbance, injury, death, or decreased productivity; (3) the project results in a loss of habitat due to right-of-way clearing, or the resource has a high value and quality as wildlife habitat, characterized by high species richness and/or providing critical resources for species of concern; (4) the project results in improved public access into areas that are currently difficult to reach, or the resource is of limited availability within the Project study area; and (5) the project conflicts with or creates obstacles to federal, state, or local resource or wildlife management plans. The DEIS explains on p 3-6 that, “A national context [of significance] considers resource status at the national level, and federal resource protection. For example, wildlife within KNWR is considered a national resource due to the USFWS mandate to protect wildlife. Adverse impacts on wildlife within the KNWR are considered nationally significant.” The proposed power line along the Enstar Route would change fire management actions and modify Refuge wildlife management goals for the area. Wildfire zoning changes would result in changing suppression response from “modified” to “full” in order to protect the integrity of the power line. The project would also not only impact management of wildfire, but would hinder the Refuge prescribed fire program. The Refuge’s Moose/Habitat Management Plan authorizes a prescribed burning effort to enhance habitat for moose, and calls for manipulating 2,000 to 4,000 acres per year. The Refuge’s Comprehensive Conservation Plan sets a population objective for moose in Game Management Subunit (GMS) 15A (the area of the proposed project) at 3,600. Page 5 of 9 The 1995 population estimate for the area was less than 2,000 moose - well below the stated objective, and the only acceptable means to substantially increase moose numbers is through habitat enhancement. The Moose/Habitat Management Plan calls for manipulation of habitats in the Refuge land management categories of “Moderate” and “Traditional”. Within GMS 15A there are approximately 185,000 acres in these two KNWR land management categories. If the Southern Intertie is built along the proposed Enstar Route, it could interfere with normal prescribed burning procedures in approximately 75,400 acres of land in “Moderate” and “Traditional” categories east of the Moose River. The power line could reduce by 41 % Refuge habitats that can be manipulated using normal prescribed burning techniques. Public Review and Comment: Public review and comment on the Southern Intertie Project was primarily accomplished through the review of the DEIS. The publication of the DEIS was followed by a 60-day comment period (closing December 5, 2001). Public hearings were held October 30, 2001 in Washington, D.C.; November 13, 2001 in Anchorage, Alaska; and November 14, 2001 in Soldotna, Alaska. Notice of the DEIS, hearings, and comment period was published in the Federal Register (Vol. 66, No. 192, pp 50396-50397) Wednesday, October 3, 2001. The DEIS, announcements of availability, and the Federal Register Notice gave notice of the Service’s compatibility determination process, and solicited public comment regarding compatibility simultaneously with comments associated with other aspects of the proposed project and related processes. Additionally, the Refuge published a separate announcement in the Anchorage Daily News Legal Section on October 24, 2001, and provided additional information at their compatibility web site (http://www.r7.fws.gov/compatibility/). The issue of compatibility was primarily addressed on pages 1-35 and 1-36 of the DEIS. Copies of the DEIS were mailed to any requester, were provided at public libraries in Anchorage, Chugiak-Eagle River, Girdwood, Hope, Cooper Landing, Soldotna, and Kenai, and made available on the web at http://www.usda.gov/rus/water/ees/eis.htm. The U.S. Department of Agriculture - Rural Utilities Service (RUS) was the lead federal agency for the project and DEIS. Comments, including those regarding Refuge compatibility issues, were sent primarily to RUS; however, most comments were also copied to the Refuge Manager. Total comments received included 6 from Federal agencies, 3 from State agencies, 2 from local agencies, 11 from special interest organizations, 72 individuals (37 of which were in similar form), and over 1200 e:mails and faxes (most of which were in similar form). The Refuge Manager received a letter from the Center for Biological Diversity that expressed opposition to the project and 1 fax, 4 letters, and 1,215 e:mails from citizens opposed to putting the power line through the Refuge. The e:mails were received from people in 45 states, Washington, D.C., The Virgin Islands, and 12 foreign countries (Australia 4, England 1, China 1, Page 6 of 9 Ireland 1, Scotland 2, Canada 8, Brazil 3, The Netherlands 8, France 1, Uruguay 1, Sweden 1, and Belgium 1). Three e:mails were received from citizens that supported the proposed Enstar Route through the Refuge. Letters and/or e:mails received from 9 organizations or agencies, including the State of Alaska, Wilderness Society, Sierra Club, Audubon Alaska, Defenders of Wildlife, the Environmental Protection Agency, Anchorage Audubon, Friends of Kenai National Wildlife Refuge, and the National Wildlife Refuge Association. Concern over the Enstar Route was expressed in some form from each of these commenters. Most comments regarding compatibility were general and stated that the proposed project was not compatible, the Refuge should be protected, or other statements that demonstrated opposition to the proposed action. Additionally, two letters were received far in advance of the public comment period regarding the proposed project. A February 14, 2000 letter from the Alaska Public Interest Research Group to the Rural Utilities Service, with copy to the U.S. Fish and Wildlife Service, submitted a draft report entitled, The Southern Intertie: Who Will Pay? The letter stated that the research summarized in their report indicated that the intertie was not needed, not cost effective, and posed serous risks to Turnagin Arm and the KNWR. Also, a letter dated February 15, 2000 from the Alaska Department of Fish and Game to the KNWR manager stated that the proposed power line project through the Refuge had the potential to negatively impact brown bears, a species that the State of Alaska listed as a “population of special concern” on the Kenai Peninsula. A complete set of all comments received has been retained as part of the administrative record for this project. Determination (check one below): X___ Use is Not Compatible Use is Compatible With Following Stipulations Stipulations Necessary to Ensure Compatibility: Not applicable Justification: The proposed construction, operation, and maintenance of a 38.3 mile overhead transmission line through the Kenai National Wildlife Refuge materially interferes with and detracts from the Congressionally mandated purposes for which the Refuge was established, and with the Mission of the National Wildlife Refuge System. Potential stipulations to ensure compatibility, within the context of the proposed action, were deemed inadequate given the overall nature of the project. Only those mitigative measures Page 7 of 9 addressed in the DEIS, and application for a right-of-way permit, were evaluated (i.e. consideration was not given to such actions as burying the transmission line through the Enstar route within the Refuge because it was not proposed by the applicant, nor was it felt to be economically feasible by the applicant). Refuge Purposes The proposed use materially interferes with and detracts from KNWR’s primary purpose to conserve fish and wildlife populations and habitats in their natural diversity. It would cause significant, and largely unmitigated, habitat fragmentation, modification and/or loss along its entire route through the Refuge. Policy (Refuge Management: Part 603 National Wildlife Refuge System Uses 2.5) states, “Uses that we reasonably may anticipate to reduce the quality or quantity or fragment habitats on a national wildlife refuge will not be compatible.” The proposed use materially interferes with and detracts from KNWR’s purpose to fulfill the international treaty obligations of the United States with respect to fish and wildlife and their habitats. The loss of migratory bird habitat, and threat of mortality to a variety of migratory birds throughout the entire life of the proposed project, materially interferes with the Refuge’s ability to implement the general agreements to conserve migratory birds found in treaties with Great Britain (for Canada), Mexico, Russia, and Japan. Availability of water would not be expected to be a problem, and while water quality may be impacted during construction, or through site-specific erosion during the life of the proposed project, these impacts should be of short duration and can be mitigated; therefore, the proposed use is not believed to exceed the compatibility threshold for ensuring water quality and necessary water quantity. Likewise, impacts to the Refuge’s programs for scientific research, interpretation, environmental education, and land management training would not be expected to be significantly impacted by the proposed project. The Refuge’s purpose to provide for opportunities for fish and wildlife-oriented recreation would be influenced by the proposed action. Additional access created by the new right-of-way may allow additional users and uses of the area over what currently exist. This, however, would potentially negatively impact the users and uses that are currently in the area, and could ultimately result in use restrictions that would significantly impact current users and uses. The adverse impact of the proposed project to recreational users due to visual effects, and the loss of amore natural experience along the route also may outweigh the value of any additional access provided, especially since there is already access to the area. The DEIS recognized significant visual impacts and impacts to land use and recreation. The resources to monitor impacts, and enforce regulations for potential new uses of the area, are also lacking. Policy (Refuge Management: Part 603 National Wildlife Refuge System Uses 2.11 and 2.12) directs that if Page 8 of 9 vm as adequate resources are not available to properly manage a use, then the use is not compatible. The proposed use would not occur in Congressionally designated wilderness. There are wilderness-related issues to the proposal, such as impacting the view from designated wilderness areas, looking beyond the wilderness boundaries to the project area, and potentially impacting future wilderness designations for current or future wilderness study areas. While these issues may be significant wilderness management issues, they do not significantly influence the compatibility determination. System Mission The proposed use materially interferes with and detracts from the National Wildlife Refuge System Mission of administering lands and waters for the conservation, management, and restoration of fish, wildlife, and plant resources, and their habitats. The project would not only fragment, modify, or destroy significant wildlife habitats, it also would likely impede significant wildlife management efforts, especially implementation of prescribed fire activity called for generally in the Refuge’s Comprehensive Conservation Plan, and specifically in the Refuge’s Moose/Habitat Management Plan. aed Wet G-4-07 (Signature and Date) Signature: Refuge Manager: 7 Concurrence: Regional Chief: SHA o| O22 (Signatur and Date) N/A Mandatory 10- or 15-year Re-evaluation Date: Page 9 of 9 APPENDIX B USACE DRAFT SECTION 404(b)(1) EVALUATION APPENDIX B Department of Army Corps of Engineers Alaska District Draft Section 404(b)(1) Evaluation Southern Intertie Project File No. 2-991212 Turnagain Arm 45 June 2002 Draft Section 404(b)(1) Evaluation Department of Army, Corps of Engineers Proposed Southern Intertie Project File number: 2-991212, Turnagain Arm 45 Notation: This is a draft Section 404(b)(1) Evaluation based on analysis of the data presented in the Final Environmental Impact Statement (FEIS) and is without a finding of “Compliance or Non- compliance” with the guidelines. The intent of this draft evaluation is to inform the public on the extent of resource impact, subject to the Clean Water Act, and to promote coordination with resource agencies. A final 404(b)(1) Evaluation will be part of the U.S. Army Corps of Engineers (USACE) Record of Decision. I. Introduction A. Project Description: The proposed project is to construct a 74-mile, 138kV electrical transmission line between the Kenai Peninsula and Anchorage, in southcentral Alaska. The route for which the applicant has applied would begin at the Soldotna Substation, within the NW1/4, section 26, T. 5 N., R. 10 W., Seward Meridian (SM), east of Soldotna, and proceed as an overhead line in a northeasterly direction across the Kenai Peninsula, following the Enstar natural gas pipeline corridor through the Kenai National Wildlife Refuge (KNWR). The line would cross Turnagain Arm as a submarine cable, entering the arm at Chickaloon Bay, adjacent to Burnt Island, and landing at Oceanview Park in south Anchorage. It would then follow the Alaska Railroad right-of-way north, terminating at the International Substation in the SE1/4, section 36, T. 13.N., R. 4W., S.M., in Anchorage. This proposal, as submitted by the applicant, follows route options E-South, F, H and K, and is collectively referred to as the Enstar Route. Approximately 83% of the line would be attached to overhead tower structures, 16% of the line would consist of submarine cabling and approximately 1% would be installed underground. The transmission line would make two aerial crossings of the Kenai River, a navigable water of the United States. At all stream crossings, tower structures would maintain a 200’ minimum setback. If possible, wetlands would be spanned. Any tower requiring siting in a wetland would be pile-supported. Submarine electric cable would be threaded under the vegetated intertidal estuaries of Turnagain Arm by use of horizontal directional drilling from adjacent upland areas. To cross Turnagain Arm, a water-jetting machine, towed behind the cable-laying barge, would cut a narrow trench in the basin substrate into which the marine cable would be laid. Tidal currents would redeposit the sediments, closing the trench and burying the cable. B. Purpose and Need: The Southern Intertie Transmission Line Project (SIP) is a system improvement project. The line would correct existing deficiencies by providing a second line to accomplish the following: = Increase reliability of the Railbelt electrical system and power supply to consumers by providing a second path for electrical power during interruptions of the existing Quartz Creek line and by reducing load-shedding requirements in case of system disturbances. = Increase electrical transfer capability of the transmission system between the Kenai Peninsula and Anchorage from 70 megawatts (MW) to 125 MW, reduce operating costs by allowing for more economical usage of existing generation sources, decrease overall system requirements for spinning reserves, and improve electrical system stability. = Provide adequate access to power entitlements from the Bradley Lake hydroelectric generating station for the utilities north of the Kenai Peninsula, allow the Bradley Lake generation to be more fully utilized to reduce system-operating costs through increased hydrothermal coordination, and provide additional spinning reserves to the system north of the Kenai Peninsula. Additional information on the purpose and need of the SIP, including existing system operations, proposed project background, studies conducted, and the benefits and costs analysis can be found in Chapter 1 of the DEIS. C. Agency Involvement: The USACE received an application for Transportation and Utility Systems and Facilities on Federal Lands, on August 5, 1999, from the Intertie Participants Group (IPG), to construct a 138kV electrical transmission line between the Kenai Peninsula and the City of Anchorage in south-central Alaska. The IPG’s proposed route for the transmission line would partially site the project within the Kenai National Wildlife Refuge, the Kenai River Comprehensive Management Plan Boundaries, and the Anchorage Coastal Wildlife Refuge. Jurisdiction over this project proposal has been established by USACE under three Federal laws. Section 404 of the Clean Water Act (33 U.S.C. 1344) applies to the discharge of dredged or fill material into waters of the United States. The substantive evaluation requirements of this act are within the guidelines developed by the Administrator of the Environmental Protection Agency (EPA) in conjunction with the Secretary of the Army, published in 40 CFR, Part 230 and referred to as the 404(b)(1) Guidelines. Jurisdiction under Section 10 of the Rivers and Harbors Act (33 U.S.C. 403) requires authorization for work in or over any navigable water of the United States. This jurisdiction includes the line spanning the Kenai River and the marine crossing of Turnagain Arm. The applicant's proposal would route the transmission line across the Kenai National Wildlife Refuge (KNWR), a Conservation System Unit identified in the Alaska National Interest Lands Conservation Act (ANILCA) (43 CFR Part 36). Title XI of this Act, Transportation and Utility Systems in and Across, and Access into, Conservation Systems Units, allows authorizing federal agencies to review a proposal in accordance with the procedures set fourth in this title. This review follows the guidelines established in the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321-4347). The Rural Utilities Service (RUS), of the US Department of Agriculture, is the Lead Federal Agency in the NEPA review for the SIP. The IPG intends to submit an application to RUS for financial assistance to fund partial construction of the transmission line. Pursuant to RUS Environmental Policies and Procedures (7 CFR Part 1794), providing funding for the project would constitute a major federal action for the agency. The U.S. Fish and Wildlife Service (USFW), as Federal Manager of the KNWR, has permitting authority over the applicants proposed route selection to cross Refuge Lands. The USFW is a cooperating agency in the NEPA review and is responsible for the decision to issue or deny a Right-of-Way permit for the line to cross the KNWR. The USACE, a permitting agency based on the authorities listed above, is also a cooperating agency in the NEPA review of the SIP. Il. Alternatives A. Overview of Alternatives: All chapter and section references made in this Draft 404(b)(1) Evaluation refer to the SIP DEIS. Chapter 2 contains discussion of the alternatives identified during the scoping process, including alternatives eliminated from detailed study for failing to meet the applicant’s purpose and need, and alternatives determined to be impracticable when considering public interest factors. Alternatives carried forward for detailed evaluation “A include: 1) the no-action-alternative, 2) the Tesoro alternative (a route generally paralleling the Tesoro gas pipeline along the western edge of the Kenai Peninsula), and 3) the Enstar alternative (the applicant's proposed alternative). Chapter 2 also provides details on construction, operation, maintenance and abandonment of the facilities associated with the alternatives route options. B. Alternatives Evaluated in Detail: 1) No action: The no-action alternative would preclude realization of the benefits from construction of the SIP. Potential cost savings of the project would remain as costs embedded in the electricity rates paid by consumers. Cost savings would be unrealized in areas of capacity sharing, economic energy transfer, reliability, spinning reserve sharing, reduced line maintenance costs, avoidance of minimum generation on the Kenai Peninsula, and avoidance of the practice of not loading the Quartz Creek transmission line during bad weather and construction. The no-action alternative does not address the problems that the project has been designed to solve and does not meet the applicant’s purpose and need objectives. Further discussion of this alternative can be found in Chapter 2.3.1. 2) Tesoro Route: The Tesoro Route (option A) begins at the existing Bernice Lake Substation near Nikiski and generally parallels the Tesoro pipeline along the west coast of the Kenai Peninsula to Pt. Possession. In 1964 Congress modified the west boundary of the KNWR, pulling it inland from the coast, to create a transportation and utility corridor for anticipated future development needs of the Kenai Peninsula Borough. The Tesoro route would be located within this transportation/utility corridor. The cable would be installed underground through Captain Cook SRA, satisfying requirements of the Land and Water Conservation Fund Act (LWCFA). Crossing Native owned lands near Grey Cliff Lake and at Pt. Possession would require a permit pursuant to Section 22(g) of the Alaska Native Claims Settlement Act (ANCSA). A transition facility at Pt. Possession would convert the overhead line to submarine cable before entering Turnagain Arm. From Pt. Possession, there are three route options being considered for crossing Turnagain Arm, with each option terminating at the existing Pt. Woronzof Substation. Route Option D would cross the Arm from Pt. Possession to Pt. Campbell. From the Pt. Campbell landing, underground cable would continue through Kincaid Park and the Ted Stevens Anchorage International Airport before terminating at the Pt. Woronzof substation. The total length of the Tesoro route utilizing Route Option D is 62.0 miles with an estimated construction cost of $99.5 million. Route Option B crosses Turnagain Arm from Pt. Possession to Fire Island. The submarine cable would transition to an overhead line, traverse the length of Fire Island, and convert back to submarine cable to cross the mudflats to the Point Woronzof Substation. This option would require two transition facilities on Fire Island. The submarine cable between Pt. Possession and Fire Island would also encounter undesirable marine conditions that feature extreme tidal currents and rocky substrate. The cable would be exposed to tidal scouring elements that would likely result in more frequent cable failures and increased maintenance costs. The total length of the Tesoro route using Option B is 63.2 miles, with estimated construction costs of $99.4 million. Route Option C crosses Turnagain Arm as a submarine cable from Pt. Possession directly to a landing at the Pt. Woronzof Substation. A concern identified with this option is the presence of a ‘cable field’ located just offshore of the proposed landing site. There are several submarine cables, which cross the Knik Arm between Pt. Mackenzie and Pt. Woronzof, already buried in this area. To avoid laying cables on top of existing cables, Route Option C would land cables south of the Anchorage Waste Water Treatment Facility and access the Pt. Woronzof substation from the east. The length of this route option is 61.3 miles with an estimated construction cost of $106.2 million. 3) Enstar Route: This route begins as an overhead transmission line at the existing Soldotna substation. There are two route options from this substation, both of which intersect the Enstar Pipeline corridor in section 1, T. 5 N., R. 8 W., SM. Route Option E-North would run north from the Soldotna substation before turning east to intersect the Enstar Pipeline corridor. This 21.6-mile section of line would primarily run parallel to an existing power line between the Soldotna substation and Enstar Pipeline. Route Option E-South would replace an existing 69kV transmission line. This route begins by heading south from the Soldotna substation, then turns east and finally to the north. The overhead line would cross the Kenai River twice before intersecting the Enstar Pipeline corridor. Route Option E-South is 19.0 miles long and the IPG’s proposed route. From the point where the above-described route options intersect the existing Enstar Pipeline, the Enstar alternative parallels the pipeline corridor in a northeasterly direction through the KNWR. Along this 38.5 mile section of line, the existing gas line access trail would be utilized to construct the transmission line. The 50’ corridor would be widened to approximately 200’ in order accommodate the addition of the transmission line. The transmission line would meet Turnagain Arm on the east end of Chickaloon Bay near Burnt Island. A transition facility would convert the overhead line to marine cable where it would continue across the Arm along one of three route options. At each of the three Anchorage landing site options, a transition facility would convert the marine cable back to an underground or overhead line and continue to the International Substation, located at the Chugach Electric Headquarters building near the intersection of Minnesota Drive and International Airport Road. The three route options across Turnagain Arm fan out from the transition facility located adjacent to Burnt Island. Route Option G would cross the Arm following a due north direction from Burnt Island, landing near Klatt Road in south Anchorage. From a transition facility here, this route would continue as Option J, an overhead line, and parallel Minnesota Drive north, terminating at the International Substation. This Enstar Alternative, following Route Options G and J, is 73.8 miles long and has an estimated construction cost of $90.1 million. Route Option | would cross Turnagain Arm from Burnt Island as a marine cable, landing near the confluence of Rabbit Creek in south Anchorage. From a transition facility located here, an overhead line would continue as Route Option M, following the Old Seward Highway north to International Airport Road, and then turning west to the International substation. This Enstar Alternative, along Route Options | and M, is 75.4 miles long with an estimated construction cost of $90.1 million. Route Option H crosses Turnagain Arm from Burnt Island to a landing at Oceanview Park in south Anchorage. As Route Option K, the line would continue underground along the edge of Oceanview Park and an adjacent light airplane landing strip to the north. At this point the cable would transition to an overhead line and continue north, within the Alaska Railroad Corporation right-of-way, to the International substation. This route, selected by the IPG as their proposed route and submitted on the ANILCA application, consists of line segments E-South, F, H, and K. Collectively known as the Enstar Route, this proposal is 73.4 miles in length, with an estimated construction cost of $90.2 million. Additional information and detailed descriptions of the facilities associated with the Enstar Proposal and optional Tesoro Route alternative can be found in Chapter 2.3.2 and 2.4. Ill. Affected Environment A. Inventoried Environment: The resources identified as being important in the scoping process, inventoried during data collection and described in detail by Chapter 3 include: = Climate and Air Quality (Chapter 3.2) * Earth and Water Resources (Chapter 3.3) = Marine Environment (Chapter 3.4) = Biological (Chapter 3.5) Land Use and Recreation (Chapter 3.6) Socioeconomics and Tourism (Chapter 3.7) Subsistence (Chapter 3.8) Visual (Chapter 3.9) Cultural and Historical (Chapter 3.10) Electric and Magnetic Fields and Noise (Chapter 3.11) The DEIS contains resource descriptions, explanation of the data gathering methods, and inventory results. Chapter 3 also describes anticipated project impacts to these resources, and the expected environmental consequences. Information on proposed mitigation measures to minimize resource impacts, and any residual resource damage, is also summarized in Chapter 3. B. Types of Impacts: Resource quantity and sensitivity were analyzed to determine potential impact levels for the identified resources. The quantity of a resource impacted is simply the summation of affected resource units. For example, known bald eagle nesting sites within .5 mile of the projects’ influence zone, can be compared between the alternatives by counting the number of active nesting trees along each route. Determining resource sensitivity requires a more subjective approach. Considerations can include resource values, endangered species listing, existing land use patterns, special area designations, management plan implementation, or other resource parameters. The combination of these two assessment variables determines the level of impact assigned to each resource category. Impacts are categorized into three primary types: 1) Direct impacts are caused by the action and occur at the same time and place. 2) Indirect impacts caused by the action occur later in time or are farther removed. 3) Cumulative impacts result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions. These impacts may be individually minor but collectively significant. Resource impacts can be further categorized into these secondary types: 1) Short-term impacts are associated with the initial ground disturbance or construction phase of the project. 2) Long-term impacts affect the resource during the operation and maintenance phases, or over the project's lifetime. Resource impacts are also evaluated to determine their significance. As defined in NEPA, Council on Environmental Quality Regulation 1508.27, significance requires considerations of both context and intensity. The factors of context and intensity are discussed in Chapter 3.1.2. Definitions for significant impact, by resource, were established to provide a means of interpreting which issues are associated with each resource in the project area, which impacts are relevant to the resource, and how those impacts must affect the resource to be considered significant. These definitions are provided in Table 3-1. Impact significance is evaluated within three levels of context: local, regional, and national. The local context for the SIP is defined as the immediate vicinity of the alternative routes. The regional context depends on resource distribution and interactions. For example, the regional context for evaluation of impact significance on brown bear resources would be the Kenai Peninsula, because the population of brown bears on the Peninsula is believed to experience little, if any, immigration from or emigration to other brown bear populations. A national context considers resource status at the national level, and federal mandates for resource protection. For example, wildlife within the KNWR is considered a national resource due to the USFWS mandate to protect wildlife. Significant impacts on wildlife within the KNWR are considered nationally significant. A cumulative impact, as defined by the Council on Environmental Quality (40 CFR 1508.7), is the impact on the environment that results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes other such actions. Cumulative impacts can result from individually minor, but collectively significant, actions taking place over a period of time. These reasonably foreseeable future actions refer to future action projections, or estimates, of what is likely to take place when a proposed action is implemented. They are not part of the proposed action but are projections being made so that future impacts, cumulative and otherwise, can be estimated as required by NEPA. A complete discussion of the SIP cumulative impacts can be found in Chapter 3.12. Finally, as part of the project description, the IPG has proposed incorporating mitigation measures that minimize construction and maintenance activity impacts to the natural environment. These measures are referred to as ‘standard practice project mitigation’ and are summarized in Volume II, Table D-1. Where warranted, on a case-by-case basis, mitigation beyond these generic measures has been recommended to further reduce adverse impacts. The selective mitigation measures are identified in Volume II, Table D-2. In discussing the environmental consequences of the proposed project below, descriptions of resource impacts take into consideration the mitigating affects of these measures. A detailed mitigation plan is provided in Volume II of the FEIS. C. Environmental Consequences to Aquatic Resources Resulting from the Discharge of Fill or Dredged Material: The 404(b)(1) Evaluation is a document based on guidelines set forth in 40 CFR, Part 230. The purpose of these guidelines is to maintain the chemical, physical, and biological integrity of waters of the U.S. by controlling the discharges of fill material. Fundamental to these guidelines is the precept that no discharge of fill material shall be permitted if there is a practicable alternative to the proposed discharge that would have less adverse impact on the aquatic ecosystem, so long as the alternative does not have other significant adverse environmental consequences. Therefore, the following discussion will focus on aquatic resource characteristics that would be impacted by the proposed project, and the anticipated consequences. Marine Environment (Chapter 3.4): Waters of upper Cook Inlet and Turnagain Arm are well mixed due to large tidal fluctuations and high current velocities. Salinity, temperature, and suspended sediment loads vary with season, water depth, and tidal cycle. Embedment of the transmission line across Turnagain Arm would result in a discharge of dredged material. Though important differences between the Enstar proposal and Tesoro alternative can be found in the basin substrates, shifting bathymetries, potential impacts from ice scour, and steep shore slopes, a discharge along either route is not expected to have more than a minimal effect on water quality in Turnagain Arm. A transmission line along IPG’s proposed Enstar Route would enter Turnagain Arm on the east side of Chickaloon Bay, near Burnt Island. The Route Options across the Arm (G, H, and !) would fan out from this point and proceed to the three different landing sites. This area of Turnagain Arm is characterized by wide mud flats at low tide and deep glacial sediments across the entire width. Distribution of these sediments, ranging from silty fine sand to sandy silt, indicate about a 90 percent sand content near tidal channels and about 10 percent sand content near shorelines adjacent to Anchorage and Chickaloon Bay. The Turnagain Arm flood tide is stronger than the ebb tide, carrying more sediment into the Arm than is drained out. The geological conditions found in this area of the basin would allow the submarine cable to be embedded in the seafloor, resulting in enhanced reliability, reduced maintenance costs, and a longer cable life. The transmission line following the Tesoro Route alternative would enter Turnagain Arm at Pt. Possession and follow the eastern flank of Cook Inlet north. All three Route Options (B, C, and D) would cross the mouth of Turnagain Arm, with two options landing at Pt. Woronzof (B, and C), and route option D coming ashore at Pt. Campbell. The landing points on the north side of Turnagain Arm are characterized by wide mud flats, similar to those found with the Enstar Proposal. The submarine cable could be embedded in the sediments here and offer the same reliability advantages listed above. The southern portion of the Tesoro Route’s marine crossing, offshore from Pt. Possession, offers less favorable geologic conditions for marine cable reliability. The Pt. Possession area exhibits easily eroded bluffs that consistently expose a large number of glacially deposited boulders. These boulders, moved by sea-ice rafting and shifted by strong tidal currents, have produced several boulder patches in the western portion of Turnagain Arm. Seafloor boulder patches have been recorded between Pt. Possession and Fire Island, and between Pt. Possession and Pt. Campbell, at water depths between 20 and 50 feet mean low low water (MLLW), and in the deep channels at depths of 60 to 90 feet MLLW. The boulders diminish in size and number to the east of Pt. Possession, near the Chickaloon Bay area. The submarine cable cannot be embedded in areas where scoured bottom conditions or boulder fields occur. Unburied cables are at an increased risk to cable failure from tidal currents, ice scouring and other hazards. Anticipated replacement of damaged submarine cables has been calculated into project maintenance cost estimates, summarized in Table 2-1 of the FEIS. Along both the Enstar proposal and Tesoro Route alternative, submarine cable would be subject to impacts and scouring from ice floes and pressure ridges. Sea ice forms in Cook Inlet and Turnagain Arm in the autumn, remaining through the winter months and melting with warmer water temperatures in the spring. Much of the ice, formed on tidal flats and lifted during flood tides, is incorporated into large ice floes. Pressure ridges up to 20 feet can form on the floe peripheries from collisions with other floes. Areas most susceptible to ice scouring inc'ude the mudflats and adjacent seafloor slopes between Pt. Campbell, Pt. Woronzof, and Fire Island, in the Anchorage Bowl area from Pt. Campbell to Potter Marsh, at Pt. Possession, and in Chickaloon Bay. Turbulent tides, throughout Cook Inlet and Turnagain Arm, create changing conditions in the seafloor profile. Channels cut into the seafloor by the tide are constantly shifting and changing in size, with channel sides being particularly susceptible to erosion. Saltmarsh estuaries are found in low-lying coastal areas (e.g., below the coastal bluffs in the Anchorage area) and at the mouths of river systems (e.g., Chickaloon River at Chickaloon Bay, Kenai River, and Swanson River in Captain Cook SRA). These estuaries, considered to be extremely sensitive to disturbance, provide some of the most important habitat for wildlife in the study area. They are important feeding and resting areas for migrating waterfowl and shorebirds, especially at Chickaloon Bay. Bears feed on anadromous fish at estuaries at the mouths of streams during the summer and fall, and forage for grasses in the spring. Inter-tidal mudflats and estuarine open water areas function as habitat for low densities of epifaunal marine invertebrates, marine and anadromous fish, and feeding areas for beluga whales (Delphinapterus leucas) and harbor seals (Phoca vitulina). If impacted, it can take several years for saltmarsh vegetation to recover. Installation of the transmission line through intertidal transition areas, between terrestrial and marine environments, would utilize similar construction techniques along both routes. The IPG’s Enstar proposal would enter Turnagain Arm at the east end of Chickaloon Bay, near Burnt Island, and exit on the Anchorage side at Oceanview Park. On both sides of this Turnagain Arm crossing, submarine cable would be threaded under vegetated saltmarsh estuaries by horizontal directional drilling (HDD) from the adjacent upland bluffs. This construction technique can span distances up to 4000’ and allow the submarine cable to be installed under sensitive areas without mechanical trenching. On the waterward side of the saltmarshes, the HDD installed cable would transition into a mechanically excavated trench through the remaining intertidal mud flats. A trench, four feet wide by five feet deep, would be excavated with backhoes or bulldozers during low tide periods with spoilings being sidecast adjacent to the trench. The submarine cable would be laid into the trench and covered with the excavated material. No appreciable environmental consequences are anticipated as a result of trenching tidal mudflats along either the Enstar or Tesoro Routes. The acreages of saltmarsh habitat within the right-of-way of the proposed project alternatives are summarized in Table 3-5 below. A concern identified with the SIP crossing Turnagain Arm is the recent decline of the Cook Inlet beluga whale population. Beluga whales, which have been included on the state’s list of species of special concern, are commonly found in the intertidal and nearshore areas of Turnagain Arm and Cook Inlet. The distribution of beluga whale habitat is shown in Volume Il, Figure MV-17. Concentrations of fish occur primarily in the early spring to late fall (March through November), usually at the mouths of rivers, and the whales frequent these waters during this time to feed on smelt and adult salmon. Beluga calving areas in Cook Inlet have not been identified, but it is now believed that calving may occur in May and June, particularly in estuaries such as Chickaloon Bay. Discussions have been held with the National Marine Fisheries Service (NMFS) regarding construction activities and timing windows that would reduce contact with beluga whales. The secondary impacts resulting from cable laying operations are not expected to degrade habitat or result in whale mortality along this route. However, although an analysis has been performed, the cumulative impacts of installing a submarine cable along the Enstar Route are unknown. Table 3-5 (DEIS table modified for this document) ACREAGES OF WETLAND VEGETATION CROSSED (CLEARED) FOR THE ALTERNATIVE ROUTES Black Spruce Bogs & Route Option Muskeg Meadows Saltmarsh° Totals Tesoro Route A 0.0 77.6 0.0 77.6 B 0.0 0.0 2.8 2.8 Cc 0.0 0.0 0.0 0.0 D 0.0 0.0 0.0 0.0 Tesoro (Anchorage) Route N t 0.0 0.0 0.5 0.5 Enstar Route E-North 0.0 74.6 0.0 74.6 E-South 0.0 55 0.0 65 F 72.2 57.0 0.9 130.1 G 0.0 0.0 2.3 2.3 H 0.0 0.0 9.7 9.7 | 0.0 0.0 1.2 1.2 Enstar (Anchorage) Route J 0.0 0.2 0.05 0.25 K 0.1 0.0 0.0 0.1 M 0.0 0.0 0.9 0.9 Route Comparison of Total Aquatic Impacts Tesoro Route: (Environmentally Preferred Alternative) 77.6 acres crossed Enstar Route: (Applicant’s Proposed Route) 145.4 acres crossed °All potential impacts to saltmarsh will be avoided by horizontal directional drilling. Wetlands (Chapter 3.5): As defined by USACE, wetlands are those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. The wetlands along each route were inventoried using aerial photographs, National Wetland Inventory maps, and by direct observation while flying each route in helicopters. Distribution of the identified wetlands are summarized in the Vegetation Cover/Wetland Maps in Volume II, Figures MV-6 through MV-8. As a result of the mitigation measures incorporated into the proposed project, no discharge of fill material is anticipated into any wetland community along either route alternative. The IPG has prescribed utilizing existing pipeline access roads, without improvements, along both routes. In addition, construction activities would be confined to the winter season and only tracked or low-pressure tired equipment would be used within a confined right-of-way area. These restrictions are intended to prevent rutting and drainage pattern changes in areas with compressible soils. Placement of overhead towers for the transmission line would skirt wetlands where possible, and attempt to span wetlands that cannot be avoided. If a tower must be placed in an area with incompetent soils (i.e. peat soils), installation of the foundation will be pile-driven without a discharge. There are no direct wetland impacts anticipated, along either route, from excavation activities or the discharge of fill material. Vegetation removal, by selective cutting and periodic mowing, will result in a long-term direct impact to wetlands and uplands located within the proposed project corridor. Clearing would be conducted without disturbance to mineral soil (i.e. utilizing machetes and chainsaws, or hydro-axe machines) and these activities are not typically subject to USACE jurisdiction. However, prescribed burns are utilized as a management tool on the KNWR to enhance and create moose habitat. Lack of vegetation along the proposed route, coupled with the presence of the transmission line, would restrict opportunities to conduct controlled burning sessions. Constraining the burn program would inhibit the ability of KNWR staff to create and maintain habitat to support the moose populations prescribed in the Comprehensive Conservation Plan. This would constitute an impact considered significant on a national level. Detailed discussion of these impacts can be found in Chapter 3.3 and 3.5. The impact significance of removing wetland vegetation on the refuge is listed in Table 2-11A, the acres of wetlands impacted are summarized in Table 3-5 (this document), and cumulative wetland impact analysis can be found in Chapter 3.12.2. Streams, Rivers and Floodplains (Chapter 3.3): The Enstar proposal would cross several streams on the Kenai Peninsula and within the Anchorage Bowl. Primary among these proposed stream crossings is the Kenai River, which the transmission line would span twice. The Kenai River is a navigable water of the U.S. and subject to Section 10 jurisdiction. The E-South route option would replace an existing 69kV line, following the same right-of-way. The new 138kV transmission line would span the Kenai River at the same two locations, River Miles 28.0 and 39.3. Tower placement, adjacent to the Kenai River, would remain at the current locations; only the height of the structures would change, increasing approximately 20 feet. The river crossings are not expected to impact navigational, a primary consideration in the Section 10 review. Other Kenai Peninsula streams that would be crossed by the Enstar proposal include the Funny River, Chickaloon River, Mystery Creek, Big and Little Indian Creeks, Burnt Island Creek, and several unnamed tributary streams. Within the Anchorage Bowl area, Route Options H and K, would span Campbell Creek and Furrow Creek. The Tesoro Route alternative would cross the Swanson River, Bishop Creek, Scaup Creek, Otter Creek, Seven Egg Creek, and Miller Creek, all located on the Kenai Peninsula. This route would not cross any streams in the Anchorage area. Transmission line stream crossings are addressed in the standard practice project mitigation measures, summarized in Table D-1. Item 10 states: “Stream crossings will be as near as possible at right angles to streams. Bridges or culverts would be installed where necessary. All construction and maintenance activities shall be conducted in a manner that would minimize disturbance to vegetation, drainage channels, and intermittent or perennial stream banks. Towers will be sited with a minimum distance of 200 feet from streams.” Incorporating the project mitigation measures prescribed, would prevent any direct impact from excavation activities or discharges of fill material in the creeks, streams, and rivers crossed by the SIP. 10 Streamside vegetation removal within the KNWR would result in a long-term significant impact to an aquatic resource, similar to those described to wetland vegetative clearing above. Although this activity would be conducted without disturbance to mineral soil and is not typically captured under USACE jurisdiction, vegetative clearing is considered a nationally significant impact because of its affect on inhibiting the prescribed burn program. Furthermore, other indirect impacts of clearing activities include increased sediment levels in water run-off, increased siltation of on stream substrates, reduced foraging habitat for out-migrating juvenile fish, and decreased cover for wildlife species which utilize the anadromous fish resource. Additional discussion of indirect project impacts is discussed in Chapter 3, and in the cumulative impact analysis summarized in Chapter 3.12.2. E. Conclusion: Embedment of the submarine cable across Turnagain Arm is the only anticipated discharge of dredged or fill material being proposed by the SIP. Cable embedment is proposed along both the Enstar proposal and Tesoro Route alternative. Anticipated impacts to the marine environment attributable to this discharge have been identified. The potential impacts, when minimized by the prescribed mitigation measures, are not considered significant. Direct secondary impacts resulting from clearing riparian and wetland vegetation within the KNWR, associated with the Enstar proposal and summarized in Table 2-11A, would be significant. The USFW is mandated to manage the refuge pursuant to the National Wildlife Refuge System Improvement Act of 1997 and ANILCA. Project impacts resulting from the transmission line and right-of-way clearing would constrain the USFW in conducting controlled burns to maintain wildlife habitat as prescribed in the Comprehensive Management Plan. Although clearing activities in riparian areas and wetlands would be similar along the Tesoro alternative, fewer acres of aquatic vegetation would be removed, cleared areas would not located on the KNWR, and therefore the impacts would not be considered significant. Compliance with the 404(b)(1) guidelines requires that no permit be issued for the discharge of dredged or fill material that would cause or contribute to significant degradation to waters of the U.S. Based on the information within the DEIS, the Tesoro Route is a less damaging practicable alternative to the applicant's Enstar proposal, without significant impacts to aquatic resources. This draft 404(b)(1) Evaluation is the substantive criterion used in evaluating discharges of dredged or fill material under section 404 of the Clean Water Act. As previously stated, this document is a draft evaluation and is without a finding of “Compliance or Noncompliance” with the Section 404(b)(1) guidelines. It should also be noted that this document does not take into consideration whether the project is in, or contrary to, the public interest. Pursuant to 33 CFR, Par 325.3(c)(1): “The decision whether to issue a permit will be based on an evaluation of the probable impact including cumulative impacts of the proposed activity on the public interest. That decision will reflect the national concern for both protection and utilization of important resources. The benefit which may reasonably be expected to accrue from the proposal must be balanced against its reasonably foreseeable detriments. All factors which may be relevant to the proposal will be considered including the cumulative effects thereof; among those are conservation, economics, aesthetics, general environmental concerns, wetlands, historic properties, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shoreline erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, considerations of property ownership and in general, the needs and welfare of the people.” The USACE permit decision, based on public interest factors and a finding of “Compliance or Noncompliance” with Section 404(b)(1) guidelines, will be made by the Alaska District Engineer and published in the Record of Decision. 11 Draft Section 404(b)(1) Evaluation For the Proposed Southern Intertie Project File number: 2-991212, Turnagain Arm 45 I. Evaluation of Compliance with 404(b)(1) Guidelines (restrictions on discharge, 40 CFR 230.10): (An * is marked above the answer that would indicate noncompliance with the guidelines. No * marked signifies the question does not relate to compliance or noncompliance with the guidelines. An “X” simply marks the answer to the question posed.) a. Alternatives test: i) Based on the discussion in FEIS, are there a available, practicable alternatives having less adverse X impact on the aquatic ecosystem and without other Yes significant adverse environmental consequences that do not involve discharges into "waters of the United States" or at other locations within these waters? ii) Based on FEIS, if the project is in a special aquatic site and is not water dependent, has applicant clearly demonstrated that there are no practicable alternative Yes sites available? b. Special restriction. Will the discharge: i) violate state water quality standards? i (The State of Alaska Department of Environmental Conservation has not yet reviewed the SIP for401 water Yes quality certification.) ii) violate toxic effluent standards (under Section 307 of the Act) Yes iii) jeopardize endangered or threatened species or a their critical habitat? Yes iv) violate standards set by the Department of , Commerce to protect marine sanctuaries? Yes v) evaluation of the information in the FEIS indicates that the proposed discharge material meets testing X 12 No * No exclusion criteria for the following reason(s): Yes (X) based on the information contained in the FEIS, the material is not a carrier of contaminants. () the levels of contaminants are substantially similar at the extraction and disposal sites and the discharge is not likely to result in degradation of the disposal site and pollutants will not be transported to less contaminated areas. () acceptable constraints are available and will be implemented to reduce contamination to acceptable levels within the disposal site and prevent contaminants from being transported beyond the boundaries of the disposal site. No c. Other restrictions. Will the discharge contribute to significant degradation of “waters of the United States" through adverse impacts to: i) human health or welfare, through pollution of municipal water supplies, fish, shellfish, wildlife and X special aquatic sites? Yes ii) life stages of aquatic life and other wildlife? X Yes iii) diversity, productivity and stability of the aquatic rn life and other wildlife or wildlife habitat or loss of the X capacity of wetland to assimilate nutrients, purify water Yes or reduce wave energy? iv) recreational, aesthetic and economic values? d. Actions to minimize potential adverse impacts (mitigation). Will all appropriate and practicable steps (40 CFR 230.70-77) X be taken to minimize the potential adverse impacts of the Yes discharge on the aquatic ecosystem? 13 No No No No No Findings of Compliance or Non-compliance (40 CFR 230.12): (_) The discharge complies with the guidelines. (_) The discharge complies with the guidelines, with the inclusion of the appropriate and practicable conditions listed above (in III.B.2.b.iv) to minimize pollution or adverse effects to the affected ecosystem. (_) The discharge fails to comply with the requirements of these guidelines because: (X) There is a practicable alternative to the proposed discharge that would have less adverse effect on the aquatic ecosystem and that alternative does not have other significant adverse environmental consequences. There are on-site uplands available which would minimize the placement of fill in wetlands. (X) The proposed discharge will result in significant degradation of the aquatic ecosystem under 40 CFR 230.10(b) or (c). ( ) The discharge does not include all appropriate and practicable measures to minimize potential harm to the aquatic ecosystem, namely the use of upland alternatives. 14 Southern Intertie Project Project Fact Sheet - August 2001 Project Description The Southern Intertie Project involves the construction of a 138 kilovolt (kV) transmission line between Anchorage and the Kenai Peninsula, and is proposed by a group of Railbelt utilities known as_ the _ Intertie Participants Group (IPG). Two sets of alternatives have been identified for the transmission line route; one would follow the Tesoro Pipeline, the other would follow the Enstar Pipeline. IPG prefers the Enstar Route that would originate at the Soldotna Substation, proceed through the Kenai National Wildlife Refuge (KNWR) to near Burnt Island, then cross through the Turnagain Arm landing in Anchorage at Alaska Railroad/Oceanview. The route through Anchorage would follow the Alaska Railroad to the International Substation. Several routing alternatives for both the Enstar and Tesoro routes have been identified (see map on back Page). This project is needed because the existing Railbelt electrical system is inadequate south of Anchorage. Originally constructed in 1960, the 115kV Quartz Creek line currently provides the sole path for sharing electrical trans- mission between the Kenai Peninsula and the Anchorage (FP Se 6 a 6 2 2 2 2 es a [_] _ DEIS, hard-copy [1] DEIS, CD ROM area. A new transmission line interconnection between these load areas will assist in efficiently utilizing generating plants across the system, and reliably distribute that power to the load centers. Project Status A draft environmental impact state- ment (DEIS) is currently being prepared by Rural Utilities Service (RUS) in cooperation with the U.S. Fish and Wildlife Service, KNWR, and U.S. Army Corp of Engineers and will be available for public review in September or October. The publication of the DEIS is fol- lowed by a 60-day public review period. Public hearings have tentatively been scheduled for October 30 in Washington, D.C.; November 7 in Soldotna; and November 8 _ in Anchorage. Specific hearing dates and locations will be announced in the Federal Register and in local newspapers. Public comments on the DEIS should be submitted to RUS at the address to the right. For instructions on how to request a copy of the DEIS for review, see the box below. Copies of the DEIS will also be available for review at all Anchorage public libraries, as well as the Hope, Cooper Landing, Soldotna, and Kenai public libraries. | would like to review the DEIS. Please send me the following (check one only) to the address noted below: Name: Do you want to receive a copy of the DEIS? If so, please fill out the attached response card and return it by September 7, 2001 to: EPG, Inc. 4350 E. Camelback Road, Suite G-200 Phoenix, Arizona 85018 Note: The DEIS will also be available for review on the RUS website, http://www.usda.gov/rus /water/ees/eis.htm Comments on the DEIS should be submitted to: Lawrence R. Wolfe USDA - Rural Utilities Service 1400 Independence Ave. SW, Stop 1571 Washington, D.C. 20250-1571 lwolfe@rus.usda.gov Agency: Address: City/State/Zip: Please place form in an envelope and mail to EPG, Inc., 4350 E. Camelback Rd, Ste. G-200, Phoenix, AZ 85018 i Requests can also be submitted via phone (602) 956-4370, or e-mail at info@epgaz.com es ees ee ; i i i (a) Summary only i Be Environmental Planning Group 4350 E. Camelback Road, Suite G-200 Phoenix, Arizona 85018 ——— Proposed Enstar route ASS Alternative Enstar routes Oe 2 ee g Se Ou o: eee? ® Wn 2 fo ° - a —_——s es Alternative Tesoro route @®-®- route options es Z Z 2 iw x = SS a Wy Wu = ke Z O 51036 Federal Register/Vol. 66, No. 194/Friday, October 5, 2001/ Notices information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Respondents/Affected Entities: NPDES permittees, including publicly owned treatment works, privately owned treatment works, industrial facilities, and storm water permittees, and sewage sludge handlers and domestic septage haulers. Estimated Number of Respondents: 86,135. Frequency of Response: varied, but for the most part at least annually. Estimated Total Annual Hour Burden: 15,041,011. Estimated Total Annualized Capital, O&M Cost Burden: $0. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the addresses listed above. Please refer to EPA ICR No. 0229.15 and OMB Control No. 2040-0004 in any correspondence. Dated: September 26, 2001. Oscar Morales, Director, Collection Strategies Division. [FR Doc. 01-25011 Filed 104-01; 8:45 am] BILLING CODE 6560-50-P ENVIRONMENTAL PROTECTION AGENCY [ER-FRL-6622-4] Environmental Impact Statements; Notice of Availability Responsible Agency: Office of Federal Activities, General Information (202) 564-7167 or www.epa.gov/oeca/ofa. Weekly receipt of Environmental Impact Statements Filed September 24, 2001 Through September 28, 2001 Pursuant to 40 CFR 1506.9. EIS No. 010362, Final EIS, BLM, CA, Cadiz Groundwater Storage and Dry- Year Supply Program, Construction and Operation, Amendment of the California Desert Conservation Area (CDCA) Plan, Issuance of Right-of- Way Grants and Permits, San Bernardino County, CA, Due: November 05, 2001, Contact: James Williams (909) 697-5390. EIS No. 010363, Draft EIS, FRC, ME, Presumpscot River Projects, Relicensing of Five Hydroelectric Projects for Construction and Operation, Dundee Project (FERC No. 2942); Gambo Project (FERC No. 2931); Little Falls Project (FERC No. 2932); Mallison Falls Project (FERC No. 2941) and Saccarappa Project (FERC No. 2897), Cumberland County, ME, Due: December 04, 2001, Contact: James Haimes (202) 219— 2780. This document is available on the Internet at: http://www. ferc.fed.us/ online/htm. EIS No. 010364, Draft EIS, FHW, PA, Blair Mill Road Corridor Improvement Project, Widening of Blair Mill Road between Welsh Road, Horsham Road and between Moreland Avenue and County Line Road in Horsham and Upper Moreland Townships, Montgomery County, PA, Due: November 23, 2001, Contact: James A Cheatham (717) 221-3461. EIS No. 010365, Draft EIS, RUS, AK, Southern Intertie Project, Constructing and Operating a new 138kV Transmission Line between the Kenai Peninsula and Anchorage, Right-of-Way Permit, Special-Use Permit, COE Section 10 and 404 Permit, Kenai Peninsula to Anchorage, AK, Due: December 05, 2001, Contact: Lawrence R. Wolfe (202) 720-1784. This document is available on the Internet at: http:// www.usda.gov/rus/water/ees/eis/htm. EIS No. 010366, Draft EIS, AFS, OR, Lemolo Watershed Projects, Implementing the Objectives for Management Areas 5 and 10 and Matrix Lands, Umpqua National Forest, Diamond Lake Ranger District, Douglas County, OR, Due: November 19, 2001, Contact: Patrick S. Williams (541) 498-2531. EIS No. 010367, Draft EIS, BIA, CA, NV, Truckee River Water Quality Settlement Agreement-Federal Water Right Acquisition, Implementation, Truckee River, Placer County, CA and Washoe, Storey and Lyon Counties, NV, Due: December 03, 2001, Contact: Tom Strekal (775) 887-3500. EIS No. 010368, Final Supplement, JUS, Cannabis Eradication in the Contiguous United States and Hawaii, Updated Information on Herbicidal Eradication New Scientific Data, Due: November 05, 2001, Contact: Joyce M. Elliott (202) 307-8923. This document is available on the Internet at: http://www.dea.gov/pubs/pblist.htm. EIS No. 010369, Draft EIS, NPS, GA, Fort Frederica National Monument General Management Plan, Implementation, Saint Simons Island, Glynn County, GA, Due: December 15, 2001, Contact: Mike Tennent (912) 638-3630. EIS No. 010370, Draft EIS, BIA, CA, Teayawa Energy Center, Construction and Operation of a 600 megawatt (MW) (nominal output), Natural-Gas- Fired, Combined-Cycle Energy Center, On Indian Trust Land, Torres Martinez Desert Cahuilla Indians Tribe, Coachella Valley, Riverside County, CA, Due: December 03, 2001, Contact: William Allan (916) 978- 6043. EIS No. 010371, Draft Supplement, AFS, CA, Herger-Feinstein Quincy Library Group Forest Act Pilot Project, Proposel to Analyze Options for Maintaining Defensible Fuel Profile Zones (DFPZs), Lassen, Plumas and Tahoe National Forests, Shasta, Lassen, Tehama, Yuba, Plumas and Battle Counties, CA, Due: November 19, 2001, Contact: David Arrasmith (916) 492-7559. Amended Notices EIS No. 010024, Draft EIS, FAA, CA, Los Angeles International Airports, Proposed Master Plan Improvements on Runway, New Taxiwaytops, New Terminal, New Air Cargo and Maintenance, Funding, Los Angeles, Los Angeles County, CA, Due: November 9, 2001, Contact: David B. Kessler (310) 725-3615. Revision of FR Notice Published on 02/ 02/2001: CEQ Review Period Ending on 09/24/2001 has been Extended to 11/09/2001. Dated: October 2, 2001. Joseph C. Montgomery, Director, NEPA Compliance Division, Office of Federal Activities. [FR Doc. 01-25025 Filed 10—4—-01; 8:45 am] BILLING CODE 6560-S0-U ENVIRONMENTAL PROTECTION AGENCY [ER-FRL-6622-5] Environmental Impact Statements and Regulations; Availability of EPA Comments Availability of EPA comments prepared pursuant to the Environmental Review Process (ERP), under section 309 of the Clean Air Act and section 102(2)(c) of the National Environmental Policy Act as amended. Requests for copies of EPA comments can be directed to the Office of Federal Activities at (202) 260-5076. An explanation of the ratings assigned to draft environmental impact statements (EISs) was published in FR dated May 18, 2001 (66 FR 27647). Draft EISs ERP No. D-AFS-F65029-IL Rating EC2, Midewin National Tallgrass, Proposed Land and Resource Management Plan, Implementation, Prairie Plan Development, Will County, IL. 50396 Federal Register/Vol. 66, No. 192/Wednesday, October 3, 2001/ Notices cooperative associations and for the purpose of assisting cooperative associations in developing methods of business and market analysis. (4) acquire from all available sources, information concerning crop prospects, supply, demand, current receipts, exports, imports, and prices of agricultural products handled or marketed by cooperative associations, and to employ qualified commodity marketing specialists to summarize and analyze this information and disseminate the same among cooperative associations and others.” RBS also has a stated objective to “assist U.S. farmer cooperatives to expand their participation in international trade of agricultural products and supplies and to review their progress.” As trade agreements are implemented and domestic farm supports are reduced, a global presence is increasingly important to producers, their communities, and to job-creation and retention in agri- and food-related industries. Measurement and monitoring of cooperatives’ global presence are stated objectives of RBS’s International Trade Program. In order to carry out the agency’s mission and objectives, RBS needs to collect information from the cooperative community. This information collection is designed to provide time-series data that will provide a better understanding of the opportunities and limitations of producer-owned cooperatives in global markets. The data provide the'basis for research on trade-related issues affecting cooperatives, and background for trade- related policy analysis. Beginning in 1980, RBS’s predecessor agency Agricultural Cooperative Service (ACS) collected cooperative trade data: at five year intervals. Value of cooperative exports by commodity and _ destination were measured, as well as _ information related to method of sale. Values of imports by cooperatives, by commodity and country of origin were collected in 1986 and 1991. Since 1997, - data have been collected on an annual basis (OMB No. 0570-0020), as it had become apparent that data collected at intervals longer than one year do not provide for meaningful analysis. Further, data collected prior to 1997 had been strictly limited to exports and . , imports, neglecting other important .,. international arrangements such as strategic alliances and foreign direct-. - investment. A more comprehensive, annual data set accomplishes stated CS objectives to measure and monitor cooperatives’ global presence. These data are generally not available to RBS unless provided by the cooperatives. “Notice of Availability of a 1 Draft 7s _Environmental Impact Statement ~ AGENCY: Rural Utilities Service; USDA.” Estimate of Burden: Public reporting burden for this collection of information is estimated to average one (1) hour per response. Respondents: Cooperatives involved in international activities. Estimated Number of Respondents: 127. Estimated Number of Responses per Respondent: one per year. Estimated Total Annual Burden on Respondents: 127 hours. Copies of this information collection can be obtained from Jean Mosley, Regulations and Paperwork Management Branch, at (202) 692-0041. Comments Comments are invited on: (a) Whether the proposed collection of information is necessary for the proper performance of the function of the Agency, including whether the information will have practical utility; (b) the accuracy of the Agency’s estimate of the burden of the proposed collection of information including the validity of the methodology and assumptions used; (c) ways to enhance the quality, utility, and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on those who are to respond, including through use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology. Comments may be sent to Jean Mosley, Regulations and Paperwork Management Branch, U.S. Department of Agriculture, Rural Development; 1400 Independence Avenue SW. ; Stop 0742,. > Washington, DC 20250. All responses this notice will be summarized and _; included in the request for OMB approval. All comments will also become a matter of a public record... ~~. “Dated: August 24, 2001. . io rng "John Rosso, BE Acting Administrator, Rural ee Jodi * Cooperative Service. AS oi ee {FR Doc. 01-24670 Filed- 30-2-01; 8:45 am} _ BAUNG CODE 3410-xY-P oan » DEPARTMENT OF AGRICULTURE Rural Utilities, Service: ies ACTION: Notice of availability of a draft environmental impact statement. = SUMMARY: Notice is hereby given that the Rural Utilities Service (RUS), has released for public review and comment a Draft Environmental Impact Statement (DEIS) for the Southern Intertie Project. The project being proposed by the Intertie Participants Group (IPG) is the construction of a 138 kilovolt (kV) transmission line between the Kenai Peninsula and Anchorage, Alaska. The RUS is the lead Federal agency in the environmental review process. The U.S. Fish and Wildlife Service (USFWS) and the U.S. Army Corps of Engineers (USACE) are serving as cooperating agencies. Three public hearings have been scheduled during the review and comment period on the DEIS. The dates and locations of these hearings are described below. DATES: The public hearing dates are: 1. October 30, 2001, 2 p.m. to 4 p.m., Washington, DC 2. November 13, 2001, 7 p.m. to 9 p.m., Anchorage, Alaska 3. November 14, 2001, 7 p.m. to 9 p.m., Soldotna, Alaska ADDRESSES: The public hearing locations are: 1, Washington, DC—U.S. Fish and Wildlife Service, 4401 North Fairfax Drive, Room 200 A/B, Arlington, VA 2. Anchorage, AK—Loussac Library, 3600 Denali Street, Wilda Marston Theater, Anchorage, AK 3. Soldotna, AK—Kenai Peninsula Borough Administration Building, 144 North Binkley Street, Kenai Peninsula Borough Chambers, Soldotna, AK FOR INFORMATION CONTACT: Lawrence R. “Wolfe, Senior Environmental Protection ‘Specialist, Engineering and ‘Environmental Staff, USDA Rural sUtilities Service, Stop 1571, 1400 Independence Avenue, SW., Washington, DC 20250-1571, telephone (202) 720-1784. The-E-mail address is: Twolfe@rus.usda.gov: “SUPPLEMENTARY INFORMATION: The IPG “has proposed a new 138 kV ‘tfansmission line in order to improve the overall Railbelt electrical system ‘reliability and energy transfer capabilities between the Kenai ~~ Peninsula and Anchorage. The IPG * proposed alternative, the Enstar Route, would connect the Soldotna Substation on the-Kenai Peninsula with the International Substation in Anchorage. This alternative would parallel the » Enstar Pipeline through the Kenai National Wildlife Refuge (KNWR). A second alternative, the Tesoro Route, would connect the Bernice Lake Substation on the Kenai Peninsula with ‘ the Pt. Woronzof Substation in Anchorage. This alternative would parallel the Tesoro Pipeline from the Federal Register/Vol. 66, No. 192/ Wednesday, October 3, 2001/ Notices 50397 Captain Cook State Recreational Area to Pt. Possession. The DEIS analyzes the potential impacts of constructing and operating a 138 kV transmission line along both the Enstar and Tesoro Routes. The DEIS evaluates a number of routing alternatives and related system improvements between the proposed substation connections, as well as alternative technologies and the no- action alternative. The RUS, USACE, and USFWS will issue final decisions regarding the IPG proposal at the conclusion of the environmental review process. Regardless of which routing alternatives are selected, certain construction activities will require a Department of the Army permit. A copy of the Public Notice of Application for Permit is included in the DEIS. Comments on the permit application may be submitted to the USACE directly or may be included with other comments on the DEIS. The USFWS must decide whether to issue a right-of-way permit to the IPG to construct and operate the proposed facilities on lands within the KNWR. The decision will be made in accordance with the requirements of Title XI of the Alaska National Interest Lands Conservation Act (ANILCA) (Pub. L. 96-487) for access by transportation and utility systems across conservation system units in Alaska. Title XI of ANILCA stipulates that public hearings be held in Washington, DC and Alaska during the DEIS review period. The USFWS must also prepare a compatibility determination in accordance with the as amended, for any proposed faciliti on lands within the KNWR. The compatibility determination will be - prepared by the USFWS following th public review and comment period on’ the DEIS. Public comments received °* during the review will be used in the: compatibility determination process. < Copies of the DEIS are available for tet . Federal.Government-identified in thi: will be +23 2+ - fequired to procure the commodity public review at the following public libraries in Anchorage: Z.J. Loussac | ;<; Public Library; Chugiak-Eagle Public, : Library; Gerrish (Girdwood) Branch Library; Mountain View Branch Library; - Muldoon Branch Library; and the Samson-Dimond Public Library. Copies will also be available for review at the following libraries on the Kenai Peninsula: Hope Community Library; Cooper Landing Community Library; , Soldotna Public Library; and Kenai Community Library. In Washington, D.C., copies are available for review at RUS offices. A copy of the DEIS is also ; available for review online at http:// 5 www.usda.gov/rus/water/ees/eis.htm. , "SUPPLEMENTARY INFORMATION: This’ oan opportu: Public comments concerning the adequacy and accuracy of the DEIS will be accepted during a 60 day comment period ending December 5, 2001. Comments should be sent to Lawrence R. Wolfe at the address provided above. Dated: September 26, 2001. Alfred Rodgers, Acting Assistant Administrator, Electric Program, Rural Utilities Service. (FR Doc. 01-24740 Filed 10-2-01; 8:45 am] BILLING CODE 3410-15-P COMMITTEE FOR PURCHASE FROM PEOPLE WHO ARE BLIND OR SEVERELY DISABLED Procurement List; Proposed Addition AGENCY: Committee for Purchase From People Who Are Blind or Severely Disabled. ACTION: Proposed addition to Procurement List. SUMMARY: The Committee is proposing to add to the Procurement List a commodity to be furnished by nonprofit agencies employing persons who are blind or have other severe disabilities. COMMENTS MUST BE RECEIVED ON OR BEFORE: November 2, 2001. ADDRESSES: Committee for Purchase From People Who Are Blind or Severely Disabled, Jefferson Plaza 2, Suite 10800, 1421 Jefferson Davis-Highway, _, FURTHER INFORMATION CONTACT: Sheryl Di Kennerly (703) 603-7740. notice is published pursuant to 41 U.S.C. 47(a)(2) and-41 CFR 51-2,3" Its’ purpose is to provide ‘interested | | persons _Ifthe Committee approves the:ijs+. proposed addition, the entities:of the notice for each commodity _disted below from nonprofit agencies Arlington, Virginia 22202-3259. irements of the ie National Wildlife Refuge System sll nity'to submit comments on * the possible impact of the proposed. actions. ae 2. The action will result in authorizing small entities to furnish the commodity to the Government. 3. There are no known regulatory alternatives which would accomplish the objectives of the Javits-Wagner- O’Day Act (41 U.S.C. 46—48c) in connection with the commodity proposed for addition to the Procurement List. Comments on this certification are invited. Commenters should identify the statement(s) underlying the certification on which they are providing additional information. The following commodity is proposed for addition to Procurement List for production by the nonprofit agencies listed: Commodity Cap, Utility, USMC 8405-01-485-4299 8405-01—485-4304 8405-01-485-4305 8405-01-485-4307 8405-01-485-4308 8405-01-485-4309 8405-01-485-4313 8405-01-485-4314 8405-01-485-4315 8405—01-485-4316 8405-01-485-4317 8405-01-485-4318 8405—00-NSH-1001 8405-00-NSH-1002 8405-00-NSH-1003 8405—-00-NSH-1004 8405-00-NSH-1005 8405-00-NSH-1006 8405-00-NSH-1007 8405-00-NSH-1008 8405-00—-NSH-1009 8405—00-NSH-1010 8405400-NSH-1011 *», 8405-00-NSH-1012 .,NPA: Southeastern Kentucky! Rehabilitation Industries) lac. Corbin, ~* Kentucky - Government Agency: U.S. Marine Corps ‘Sheryl Ds Kennerly, Director, Information Management {FR Doc. di-24723 Filed 10-2-91; 8:45 am} __DEPARTMENT OF COMMERCE employing persons »wh’are blind of 2 4 anternational Trade Administration have other severe disabilities. I certify that the foll6witig@ctfin' Wills” 2 Notice of Final Determination of Sales - rat Less Than Fair Value: Certain Hot- not have a significant impact on a substantial number of small éhtities. The major factors considered for this certification were: . . 1. The action will not resultin any y additional reporting, recordkeeping or. - owe YX. other compliance requirements for-small - entities otherthan the small : <1! -organizations'that will furnish the .<:. - commodity:to the Government. °° _[A-834-806] ‘ Rolled Carbon Steel Fiat Products 2From Kazaktistan “AGENCY: Teaport Administration, ‘International Trade Administration, Department of Commerce, . SACTION: Notice of final determination in the less than fair value investigation of