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HomeMy WebLinkAboutMahoney Lake Project FERC - Avail. of Env. Assessment 1997FEDERAL ENERGY REGULATORY COMMISSION ROUTING CODE —________ WASHINGTON, D.C. 20426 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 >) fk kon ko BILLING CODE 6717-01-M UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION City of Saxman ) Project No. 11393-001 ) Alaska NOTICE OF AVAILABILITY OF FINAL ENVIRONMENTAL ASSESSMENT (November 13, 1997) In accordance with the National Environmental Policy Act of 1969 and the Federal Energy Regulatory Commission's (Commission) regulations, 18 CFR Part 380 (Order No. 486, 52 F.R. 47897), the Office of Hydropower Licensing has reviewed the application for an original license for the major, unconstructed, Mahoney Lake Hydroelectric Project. The project would be located on Upper Mahoney lake and Upper Mahoney Creek near Ketchikan in Southeast Alaska. On July 14, 1997, the Commission staff issued and distributed to all parties a Draft Environmental Assessment (DEA) on the project, and requested that comments be filed with the Commission within 30 days. Comments were filed and are addressed in the Final environmental Assessment (FEA). The FEA contains the staff's analysis of the potential environmental impacts of the project and concludes that licensing the project, with appropriate environmental protective measures, would not constitute a major federal action that would significantly affect the quality of the human environment. Copies of the FEA are available for review in the Public Reference Room, Room 2A, of the Commission's offices at 888 First Street, N.E., Washington, D.C. 20426. Lois D. Cashell Secretary DC-A-11 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION wv 13 weL To the Agency/Party Addressed: In accordance with the National Environmental Policy Act of 1969 and the Federal Energy Regulatory Commission's regulations, 18 CFR Part 380 (Order No. 486, 52 F.R. 47897), Office of Hydropower Licensing staff have reviewed the application for, and prepared the enclosed Final Environmental Assessment (FEA) on the proposed Mahoney Lake Hydroelectric Project. The FEA contains the staff's analysis of the environmental impacts of the proposal and concludes that approval, with mitigative measures, would not constitute a major federal action significantly affecting the quality of the human environment. Enclosure: Final Environmental Assessment FINAL ENVIRONMENTAL ASSESSMENT FOR HYDROPOWER LICENSE Mahoney Lake Hydroelectric Project FERC Project No. 11393-001 Alaska Federal Energy Regulatory Commission Office of Hydropower Licensing Division of Licensing and Compliance 888 First Street, NE Washington, D.C. 20426 and USDA Forest Service Tongass National Forest Ketchikan Ranger District 3031 Tongass Avenue Ketchikan, Alaska 99901 yov AS) wu TABLE OF CONTENTS SUMMARY . 2. 6 6 6 6 ee ee we ew ew we we ee eh ee wt te ws iii I. APPLICATION 1 II. PURPOSE OF ACTION AND NEED re ROMER) 2 A. Purpose of Action 2 B. Need for Power 2 III. PROPOSED ACTION AND ALTERNATIVES . 4 A. Saxman's Proposal, oe 4 1. Project Facilities : : 4 3. Proposed Environmental Measures 7 B. Mandatory Conditions . . 9 1. Federal Land Manag jement Conditions ) i) 22) i502 9 2. Fish and Wildlife? "Somat Conditions . oe ee ee 20 C. Staff's Modification of eer Excposaly » 14 D. No-Action Alternative . . oe ee ee we 1M IV. CONSULTATION AND COMPLIANCE... . «1. ee ee eee ee ee 1h A. Agency Consultation eto rer =e Tow elt =) toile ite) . ead B. Interventions .........-+.4-4-4-++eeeee488 2D Cc. Scopin SUE EEN GN eecnGeanacnas D. Water Quality Certification 23 tous E. Coastal Zone Yana ementiActh = 555554260 16 2 26 F. Comments on the DI See Ge Sa es es ome ee Le V. ENVIRONMENTAL ANALYSIS . . oe ee ee 17 A. General Description of the Mahoney ‘creek Basin see oe 17 B. Cumulative Effects . . oe ee ee 17 C. Proposed Action and Action Alternatives |: 1): :::: 20 1. Geol and Soils Resources .........4.4. +. 20 2. Aquatic Resources. 24 3. Terrestrial Resources . 52 4. Threatened, Endangered and Sensitive Species 66 5. Aesthetic Resources 79 6. Cultural Resources . . 83 7. Recreation and other Land’ ‘uses : . 84 8. Socioeconomics .. . eee ww we ww we we OS D. No-Action Alternative 72 3222222220220... @7 VI. DEVELOPMENTAL ANALYSIS... .. 1... 1 ee ee ee ee ee 87 VII. COMPREHENSIVE DEVELOPMENT AND RECOMMENDED ALTERNATIVE . . .. 90 VIII. CONSISTENCY WITH COMPREHENSIVE PLANS ............ 94 IX. FINDING OF NO SIGNIFICANT IMPACT... .........4. 4.4. 97 X%. LITBRATURE CITED . 0... 2 2 eo ee ee se we ee we we we we we ww OF XI. LIST OF PREPARERS . 2... 2. 6 6 2 6 ee ee ee ee we we 101 XID.) UISTOF REVIEWERS 5 0 i sw ss es eee te 6 102 LIST OF FIGURES Figure 1. Location of the Mahoney Lake Project in Alaska. 2. Mahoney Lake Project features. 3. Project site on Revillagigedo Island. 4. Hydroelectric developments on Revillagigedo Island. 5. Estimated intragravel temperatures. : SIAN EWNE LIST OF TABLES Estimated average monthly flows in the project area. Water quality in Upper Mahoney Creek. Estimated average monthly Upper Mahoney Creek flows. Estimated average monthly Lower Mahoney Creek flows. Estimated salmon incubation cumulative degree days. Estimated change in post-project emergence time. Terrestrial habitats affected by the project. Estimated amounts of diesel fuel and resulting pollutants from equivalent amounts of generation. Appendices Appendix A. U.S. Forest Service conditions B. U.S. Fish and Wildlife Service conditions C. Alaska Department of Fish and Game conditions D. Comments on the DEA and staff responses ii 18 21 28 25 26 32 38 48 48 59 89 103 106 107 ait SUMMARY This environmental assessment analyzes the effects of constructing and operating the Mahoney Lake Project, and recommends license conditions should the Commission decide to issue a license for the project. In addition to Saxman's proposal, we consider the alternative of constructing and operating the project as proposed by Saxman with additional environmental measures, and a no-action alternative. Saxman is seeking benefits under Section 210 of the Public Utilities Regulatory Policy Act of 1978 (PURPA). As such, the U.S. Fish and Wildlife Service (FWS), the National Marine Fisheries Service (NMFS), and the Alaska Department of Fish and Game (ADFG) have mandatory conditioning authority. In addition, parts of the project would occupy lands within the Tongass National Forest, so the Forest Service also has mandatory conditioning authority over those parts of the project. Saxman has agreed to all of the conditions that have been filed on the project with the exception of a minimum flow condition filed by the FWS. Based on our analysis, we are recommending licensing the project as proposed by Saxman, including the conditions that have been filed, but with some additions. We recommend that: (1) Saxman prepare a plan for monitoring salmon emergence timing; (2) Saxman's proposals and the conditions filed on streamflow gaging and terrestrial resources be combined into terrestrial resource protection and gaging plans; (3) Saxman's proposals for visual resources be included in a visual resource protection plan; (4) Saxman develop a plan to formalize how public access to the project area would be managed; (5) Saxman prepare a final erosion and sedimentation control plan that includes the ADFG conditions for monitoring along with limits on construction activities that would directly involve Upper Mahoney Creek water; and (6) Saxman prepare a Cultural Resource Management Plan that includes protecting the Mahoney Mine site during construction. Licensed with our measures, the Mahoney Lake Project would be best adapted to a comprehensive plan for developing the Mahoney Creek Basin. Based on our independent analysis, issuing a license with our recommended measures would not be a major federal action significantly affecting the quality of the human environment . iii FINAL ENVIRONMENTAL ASSESSMENT FEDERAL ENERGY REGULATORY COMMISSION OFFICE OF HYDROPOWER LICENSING DIVISION OF LICENSING AND COMPLIANCE Mahoney Lake Hydroelectric Project FERC No. 11393-001, Alaska I. APPLICATION On May 31, 1996, the City of Saxman, Alaska (Saxman) filed with the Federal Energy Regulatory Commission (Commission) an application for a license to construct and operate the 9.6- megawatt (MW) Mahoney Lake Hydroelectric Project. Saxman also filed with their application an applicant-prepared environmental assessment (APEA) on the proposed project. The project would be located on Upper Mahoney Lake and Upper Mahoney Creek near Ketchikan in southeast Alaska (Figure 1), and would generate up to 46 million kilowatthours (kWh) per year of electrical energy. The project would occupy private land claimed by the Cape Fox Corporation under the Alaska Native Claims Settlement Act and about 114 acres of National Forest System land in the Tongass National Forest (TNF) managed by the U.S. Forest Service (FS). The FS, by Memorandum of Agreement (MOA) 1/ with Saxman and the Commission, agreed to participate in the APEA process, and has filed final conditions on the project under Section 4(e) of the Federal Power Act (FPA). Saxman is also seeking benefits under Section 210 of Figure 1. Project Location the Public Utilities 2/ The MOA was executed on January 13, 1995, and established procedures and responsibilities for cooperation in the preparation of the APEA. Regulatory Policy Act of 1978 (PURPA). As such, the U.S. Fish and Wildlife Service (FWS), the National Marine Fisheries Service (NMFS), and the Alaska Department of Fish and Game (ADFG) have mandatory conditioning authority under the procedures provided for at Section 30(c) of the FPA. The FWS and the ADFG have filed final conditions on the project. On July 14, 1997 we issued for comment a Draft Environmental Assessment (DEA) on the proposed project. We've received 7 comment letters. The comment letters are listed in Section IV.F. All comments received careful consideration, and some sections of the DEA have been modified as a result. Appendix D includes copies of the comment letters and our responses. II. PURPOSE OF ACTION AND NEED FOR POWER A. Purpose of Action The Commission must decide whether to issue a license for the project and what conditions to place on any license issued. Issuing a license would allow Saxman to construct and operate the project for a term of up to 50 years, making electric power from a renewable resource available. The FS must decide what license conditions are necessary for the adequate protection of National Forest Service System lands, and whether to issue a special use authorization, if required for those portions of the project that fall on FS lands, should the Commission decide to issue a new license. In this environmental assessment, we assess the environmental and economic effects of: (1) constructing and operating the project with the environmental measures proposed by Saxman; (2) constructing and operating the project as proposed by Saxman with additional recommended environmental measures; and (3) the no-action alternative. B. Need for Power The project would be located in the service area of Ketchikan Public Utilities (KPU), the utility division of the City of Ketchikan. KPU provides electrical service to all of Revillagigedo Island. The City of Saxman has no generating resources of their own and relies on KPU for all of their electrical service. KPU is an isolated electrical network with no interconnection to any other utility or transmission system outside their service territory, except for the Alaska Energy Authority's (AEA) Swan Lake Hydroelectric Project (FERC No. 2911). Saxman proposes to sell the entire output of the project to KPU. To assess the need for power, KPU's current resources and the projected regional need for power were reviewed. KPU's existing power generation resources include several hydroelectric projects with a combined annual average energy generation of about 65 million kWh. KPU also purchases power produced at the Swan Lake Project. The average energy output of the Swan Lake Project is about 76 million kWh per year. Thus, KPU's existing hydroelectric resources, on average, amount to 141 million kWh annually. KPU also owns about 15 MW of diesel generation capacity capable of generating an additional 100 million kWh per year by burning diesel fuel that is bulk purchased and barged to Ketchikan. Whenever KPU’s energy demand exceeds the capability of the combined hydropower resources, diesel units are operated to meet the difference. KPU's historical loads grew from 110,952,000 kWh per year in 1984 to about 162,000,000 kWh per year in 1995, an average annual growth of 3.5 percent, based on actual generation data from KPU. To project future load growth, several load growth forecasts were reviewed, including one prepared by KPU and the selected forecast prepared by the Institute of Social and Economic Research (ISER), University of Alaska (see Appendix E of the Application for License). Details of historical loads and energy forecasts are presented in Exhibit B of the Application for License. From the ISER forecast, the system load in the year 2000, the first year of Mahoney Lake operation, is projected to be about 174,000,000 kWh. This load would exceed, by about 33,000,000 kWh, the average generation capability of all hydroelectric resources in the system. Since all energy in excess of 141,000,000 kWh per year must currently be generated using diesel fuel-fired generators, a clear need for the project power output to offset this fuel generation would exist by the time the project could be constructed. Power from the Mahoney Lake Project would be useful in meeting a large portion of KPU's short- and long-term projected power needs. The project would displace diesel-fueled electric power generation and, thereby, conserve nonrenewable fossil fuels and reduce the emission of noxious byproducts caused by combustion of fossil fuels. Displacing fossil fuels would also reduce production of "greenhouse" gases and reduce risk of oil spills associated with the handling and storage of these fuels. This is particularly important in the pristine environment of southeast Alaska where the project would be located. If the project license is denied, the project's capacity would probably have to be replaced with diesel generation. As an alternative to diesel generation, KPU is also considering construction of a transmission line from Ketchikan to the Petersburg/Wrangell area (Swan Lake-Lake Tyee Intertie) to convey additional electrical power to the area. The construction cost and cost of energy from such a transmission line have not been completely established at this time, but preliminary analysis shows energy from such a transmission line would be more costly than KPU's current avoided costs. The Intertie is addressed in more detail in Section VI, Developmental Analysis. III. PROPOSED ACTION AND ALTERNATIVES A.__Saxman's Proposal 1.__Project Facilities (see Figure 2) The project would include: (1) a lake tap near the natural outlet of Upper Mahoney Lake about 75 feet below the normal water surface elevation; (2) a 1,700-foot-long upper tunnel; (3) a 300- square-foot, concrete valve house; (4) a buried, 12-inch-diameter bypass pipe from the valve house to Upper Mahoney Creek; (5) a 1,370-foot-long, partially-lined vertical shaft; (6) an 8-foot- diameter, 3,350-foot-long horseshoe-shaped lower tunnel; (7) a semi-underground powerhouse with a single twin-jet horizontal Pelton turbine having a generating capacity of 9.6 MW and a flow capacity that would range from a minimum of 8 cfs to a maximum of 78 cfs; (8) a 200-foot-long tailrace channel to convey water back to Upper Mahoney Creek; (9). 1 mile of buried 13.2-kv transmission line, 0.5 mile of buried 34.5-kV transmission line, and 3.1 miles of 34.5-kV overhead transmission line; (10) a switchyard; and (11) 2.6 miles of new access road. Upper Mahoney Lake, the lake tap intake, the upper tunnel, most of the lower tunnel, and most of the transmission line would be located on FS land, totaling 114 acres. The rest of the project (Lower Mahoney Lake, the powerhouse, and most of the project access road) would be located on land owned by the Cape Fox Corporation. 2._Project Operation The project's mode of operation would depend on the power purchaser's dispatching preference and could use two modes of operation. In the first and most likely mode, the project would be base loaded at a desired output level and, therefore, relatively constant flow level. Governing, or control, of the system frequency would be performed by one of the power purchaser's other generating resources in conjunction with a coordinated system. In the second mode of operation, the Mahoney Lake Project would be responsible for governing the system frequency. As such, the project would be operated in a peaking mode, reacting to load swings (load following) by increasing or decreasing output from the project seasonally, weekly, or daily. The effects of each of these modes on Upper and Lower Mahoney Lake elevations and Upper and Lower Mahoney Creek flows are discussed below. Figure 2. Mahoney Lake Project Features 5 Base Loading. With base loading, the unit would be set to a desired output level and left there for a period of time. Generally, the desired output from the unit would be established weekly and updated once or twice daily. Actual operation would vary based upon load, hydrology, and other unit availability within the system. During these load blocks, discharge from the unit would remain fairly constant. While some daily variability is expected, the average monthly project flows would be about equal to the flows that have been evaluated and presented in the body of this DEA and the Application for License. Lower Mahoney Lake, with a surface area of about 165 acres, would be expected to see little variation in elevation due to varying project flows on a day-to-day basis. At full turbine discharge (78 cfs), about 154 acre-feet of water per day could be released through the project into Lower Mahoney Lake. If Lower Mahoney Lake had a controlled outlet, this would equate to a maximum elevation change of slightly less than one foot. However, because the outlet to Lower Mahoney Lake is uncontrolled and water is allowed to spill freely, the changes in Lower Mahoney Lake elevation and Lower Mahoney Creek flows would be gradual due to changing turbine flows. Load Following. In this mode of operation, the unit would be programmed to adjust to increasing or decreasing system loads and frequency by varying the output, and hence the turbine discharge. The project would respond to load changes by varying output between 3 and 8 MW which corresponds to discharges between 25 and 65 cfs. The typical variation in load in KPU’s system is characterized by a morning and late afternoon peak with loads 2 to 3 MW less during the daytime and 7 to 8 MW less at night. This would mean that the project would ramp up and down twice a day according to the system load. Slight, and immediate variations in output would be expected at all times in response to instantaneous loads placed on the system. The length of time and the frequency of which the project could operate in this mode is a function of the amount of water available in storage and inflow to Upper Mahoney Lake. On a monthly basis, the impacts of this mode of operation on the elevation of Upper Mahoney Lake and releases into Upper Mahorey Creek would be similar to the base loading option described above. Water for the project would be withdrawn from Upper Mahoney Lake through the intake to the upper tunnel. The maximum lake drawdown would be about 70 feet, or within 10 feet of the intake. During normal water years, lake levels would be lowest from January through April when the project would use the natural inflows to the lake to generate power. Annual high inflows, usually occurring in May and June, would refill the lake and provide water for the project. The highest lake levels would be maintained from July through December, when the project would operate with inflows to the lake and excess inflows would spill into Upper Mahoney Creek at the natural outlet of Upper Mahoney Lake. Flows from the project would be discharged into Upper Mahoney Creek about 800 feet upstream from the Lower Mahoney. Lake delta. During low water years, the upper lake level may be lower for longer periods, while during high water years more water would spill into Upper Mahoney Creek. Flow Continuation. The turbine design would include a deflector to ensure continued water flow through the powerhouse and into Upper Mahoney Creek during short-term shutdowns. When the unit must be shutdown either as. an emergency due to mechanical or electrical failure, or just a normal unit shutdown, the deflectors would be swung into place in front of the jets, diverting the water away from the runner. Flow through the jets would be continued as long as desired. In this way, flow continuation downstream of the powerhouse could be maintained. A typical mode of operation for use of deflectors would be to set up the turbine so that if generation shuts down for any reason, the deflectors would swing into position,. and flow would be maintained through the turbine until such time as a plant operator can assess the reason for the plant shutdown. Flows through the turbine would be reduced to a minimum level when the deflectors are in place. If the unit could be restarted within a short amount of time, the deflectors would be left in place until the unit is restarted. If, however, it is clear that the turbine would have to be shutdown for an extended period, the flow through the jets would be slowly shut-off. Saxman proposes that the turbine for this project be operated in this way in order to maintain flow downstream of the powerhouse during most unplanned shutdowns. A 12-inch diameter bypass pipeline is also being proposed by Saxman to be installed from the Upper Mahoney Lake valve house to Upper Mahoney Creek. This bypass pipeline could be opened to provide supplemental stream flows downstream of the powerhouse if they were considered necessary during a prolonged shutdown of the powerhouse that occurred while salmon eggs or alevins were incubating in the upwelling area of Lower Mahoney Lake. The incubation period runs from late August through late May. This bypass pipeline would be capable of providing up to 10 cfs of additional flow into Upper Mahoney Creek. Saxman proposes to develop a plan with the agencies to determine the need and quantity, if any, for supplemental flows into Upper Mahoney Creek. 3.__Proposed Environmental Measures To protect and/or mitigate impacts on environmental resources, Saxman proposes to: (1) Provide erosion and sediment control measures during construction and operation of the project by implementing (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) the Erosion and Sediment Control Plan in Appendix B of the Application for License. Avoid/minimize impacts to sockeye salmon spawning grounds in Lower Mahoney Lake by constructing the powerhouse outlet 800 feet upstream of the lower lake. Provide a 5-cfs minimum flow or the naturally occurring streamflow, whichever is less, below the project tailrace. Saxman also proposes to include a 12-inch bypass pipe in the project design that would be capable of carrying up to 10 cfs of additional flow into Upper Mahoney Creek during prolonged plant shutdowns or if future studies indicate that additional flow is needed for sockeye incubation. ; Monitor the effects of the project on salmon passage through Lower Mahoney Creek, and salmon spawning in Lower Mahoney Lake. Bury the transmission line from the switchyard to the point west of an inactive eagle nest found in 1995 where the line turns south. Construction within 660 feet of the nest, if active, would be scheduled to occur from September 1 to March 1 to avoid the breeding season. Use raptor protection guidelines in the design of the overhead portion of the transmission line. Use existing topographical and vegetative features to screen the transmission line from observers at sea level on George Inlet, where possible. Avoid the area where sensitive plant species are located near the upper tunnel construction site. Include in construction plans, measures to safely store refuse to discourage nuisance black bear behavior. Develop a plan that would include aesthetic treatments for above-ground facilities to reduce contrast of the project facilities with the surrounding natural environment. To help minimize visual impacts during project construction, vegetation clearing would be limited to the extent feasible, cleared areas would be revegetated, rock sources for the access road would be located off the main road system, and clean-up of ground-disturbing activities would be continuous. Develop a Cultural Resources Management Plan to provide for consultation with the State Historic Preservation Officer _ (SHPO). The plan would outline procedures to be followed in the event that construction activities lead to the discovery of previously unidentified cultural sites. (13) Control access to the project area by gating and by issuing permits to minimize any increased hunting or trapping pressure that could result from having better access into the area. With one exception (FWS condition (2)) Saxman has also agreed to the mandatory conditions that have been filed on their proposal. These conditions are listed below and discussed in the body of the EA. B, Mandatory Conditions i1._Federal Land Management Conditions Since the project would occupy lands within the Tongass National Forest, the Forest Service (FS) has the authority to issue mandatory conditions under Section 4(e) of the FPA. 2/ In addition, Section 4(e) of the FPA prohibits the Commission from licensing a project that interferes or is not consistent with the purpose for which the National Forest was created. The FS provided their final conditions in a letter dated December 2, 1996, attached as Appendix A. Summarized below, they would require that Saxman: (1) Obtain a special-use authorization for the occupancy and use of National Forest System lands prior to any land-disturbing activities. (2) Obtain written approval from the Forest Service before changing the location of any constructed project features or facilities or the use of project lands and waters or any departure from the requirements of any approved exhibits filed with the Commission. (3) Consult with the Forest Service annually on the measures needed to ensure protection and development of the natural resource values of the project area. (4) Prepare a cultural resources management plan to protect previously unidentified archeological or historic sites that are discovered during project construction or operation. (5) File with the Commission a plan approved by the Forest Service for the control of erosion, and soil mass movement. 2/16 U.S.C. Section 797(e) - 2._Fish and Wildlife Agency Conditions Saxman is seeking benefits under Section 210 of the Public Utility Regulatory Policy Act of 1978 (PURPA), and believes that the project meets the definition under Section 292.202(p) of 18 CFR for a new diversion. As such, the U.S. Fish and Wildlife Service, the National Marine Fisheries Service, and the state agency exercising authority over the fish and wildlife resources of the state have mandatory conditioning authority under the Peo eed aoe provided for at Section 30(c) of the Federal Power Act (Act). 2. U.S. Fish and Wildlife Service (FWS) Conditions. By letter dated November 4, 1996, and revised by letters dated April 2, 1997, and August 12, 1997, the FWS filed conditions, attached as Appendix B. Summarized below, they would require that Saxman: (1) Route helicopter flights at least 1/4 mile from all active eagle nest trees and not construct within 660 feet, or blast within 1/2 mile, of active eagle nest trees between March 1 and August 31. (2) When Upper Mahoney Lake has filled by October 31, release from the Mahoney Lake Project, into Upper Mahoney Creek, a continuous minimum flow of 13 cfs for the protection and enhancement of salmon spawning and incubation in Lower Mahoney Lake. When Upper Mahoney Lake does not fill by October 31, the licensee shall release a continuous minimum flow of 13 cfs, or the inflow to Upper Mahoney Lake, whichever is less, from November 1 through April 30, for the protection of salmon spawning and incubation in Lower Mahoney Lake. The licensee shall limit releases from the Mahoney Lake Project to a maximum flow of 50 cfs from August 1 until Upper Mahoney Lake fills, or until October 31, whichever occurs first, to ensure sufficient storage is available to provide a continuous minimum flow of 13 cfs. (3) Provide flushing flows of 78 cfs in the tailrace for at least one period of 48 continuous hours, coinciding with a rainfall event, between May 1 and August 15 each year. (4) Implement the monitoring plan titled "Mahoney Lake Hydroelectric Project Aquatic Resources Monitoring Plan", transmitted to the FWS on May 9, 1996, except that the licensee need not calculate or implement an index of salmon abundance. Adult salmon passage in Lower Mahoney Creek shall be monitored for all salmon species through the first 3 years of operation, and sockeye salmon for the following 7 years, or until the FS, the NMFS, the FWS, and the ADFG are confident that the project’s flow regime does not negatively 3/ No conditions have been filed by the NMFS. 10 (5) affect salmon resources, whichever is longer. Any alternative to this plan must otherwise be specifically approved by the FWS. Provide a report to the FWS after three years of post- construction monitoring, describing salmon access to spawning habitat within Lower Mahoney Lake, and fish population status, with recommendations for improving salmon recruitment, or otherwise improving aquatic habitat conditions. Alaska Department of Fish and Game (ADFG) Conditions. By letter dated November 26, 1996, and revised by letter dated August 11, 1997 the ADFG filed the following conditions, attached as Appendix C. Summarized below, they would require that: Saxman: (1) (2) (3) (4) Protect mountain goats by not surface blasting between May 15 and June 30. Subsurface blasting may occur between May 15 and June 30 unless and until detrimental effects on parturient mountain goat nannies or newborn kids are determined to be occurring. Protect mountain goats by restricting air traffic to a 0.5- mile-wide corridor centered on Lower Mahoney Lake, Upper Mahoney Lake, and Ketchikan Lakes, including the two-lake basin upstream of Upper Mahoney Lake. In particular, the mountain goat habitats on Mahoney Mountain, John Mountain, and Fish Mountain, exclusive of the two-lake basin upstream of Upper Mahoney Lake are to be avoided at all times by project-associated aircraft. Monitor the effectiveness of erosion and sediment control measures through water quality sampling. From the initiation of construction and continuing for 60 days following the removal of all temporary erosion control structures, water samples shall be taken daily from Upper Mahoney Creek upstream and downstream of all construction activities, including all overland flow that crosses construction areas, but above the inlet to Lower Mahoney Lake, and analyzed for turbidity. If turbidity below the construction area measures greater than 5 nephelometric turbidity units (NTU) higher than the values obtained above the construction area, then all construction activities shall cease, sediment sources shall be located, and appropriate sediment control measures shall be implemented. Daily turbidity data shall be submitted to the ADFG Division of Habitat and Restoration office in Ketchikan weekly. Reduce the introduction of sediment to spawning gravel at the outlet of South Creek, by limiting road and bridge construction within 150 feet of South Creek to the period between June 15 and August 1. Exceptions to this condition 11 (5) (6) (7) (8) (9) may be granted in writing by the ADFG in response to detailed, site specific: proposals from the applicant. From August 1 through September 30, release from the Mahoney Lake Project, into Upper Mahoney Creek, a continuous minimum flow of 44 cfs, or the natural inflow to Upper Mahoney Lake, whichever is less, for the protection and enhancement of salmon passage through Lower Mahoney Creek into Lower Mahoney Lake. During August and September, whenever flows in Lower Mahoney Creek exceed 200 cfs, the project shall not operate, except under the following two conditions: (1) there are spill flows from Upper Mahoney Lake that would cause the flows in Lower Mahoney Creek to exceed 200 cfs whether the project were operating or not; and (2) flow releases by the project are necessary to maintain the minimum flow set by the U.S. Fish and Wildlife Service. The rate of flow from Lower Mahoney Lake shall be continuously monitored throughout the year to identify operational schemes to achieve these mandatory flows. Include fail-safe and redundant backup provisions in project design and operation to insure that flows are provided during routine maintenance periods and during emergency project shutdowns. Project design and operations should include remote monitoring and operation of all project components. Ensure that all discharge measurements comply with standards established by the U.S. Geological Survey (USGS) . Instantaneous discharge shall be measured in Upper Mahoney Creek on a continuous basis at a location between the tailrace and 75 feet downstream of the tailrace. Mean daily and continuous discharge data shall be submitted monthly to the ADFG Division of Habitat and Restoration office in Ketchikan, the ADFG Statewide Instream Flow Coordinator, and other interested parties, in documented electronic format for the first year of operation, and annually after that. If a rating curve or any other regression relationship is used to calculate discharge then the data used to build this regression relationship also must be submitted annually. Measure intragravel water temperature from a minimum of five locations throughout the spawning area in Lower Mahoney Lake at the mouth of Upper Mahoney Creek. These data shall be submitted monthly to the ADFG and other interested parties, in documented electronic format for the first year of operation, and annually after that. Measure instantaneous discharge continuously in Lower Mahoney Creek. Mean daily and continuous discharge data shall be submitted monthly to the ADFG and other interested parties, in documented electronic format for the first year of operation, and annually after that. If a rating curve or 12 any other regression relationship is used to calculate discharge then the data used to build this regression relationship also must be submitted annually. (10) Implement an ADFG-approved biotic monitoring plan to address potential effects, if, during project operation discharge and/or water temperature in Lower Mahoney Creek varies from the range of measured pre-project values and is determined by ADFG to pose a potential negative effect on the spawning, incubation, and/or rearing of sockeye salmon in Lower Mahoney Lake. After consulting with the FS, the NMFS, the FWS, and the ADFG, the licensee shall file with the Commission for approval, a plan outlining the methodologies to be used to calculate the pre-project discharge and temperature ranges in Upper Mahoney Creek and to determine any potentially adverse project effects on sockeye salmon, prior to any biotic monitoring mandated by the ADFG. The plan shall include a schedule for meeting with the consulted agencies at least once a year to review the study results and identify courses of action based on those results. (11) Notify the ADFG, the FERC, and other interested parties orally and in writing within 12 hours of the beginning of any flow noncompliance events. (12) Conduct sockeye salmon counts from August 1 through September 30, throughout Lower Mahoney Creek and the spawning areas at the mouths of South Creek and Upper Mahoney Creek every three days. Reports shall be submitted to the ADFG annually and monitoring shall continue until the ADFG is confident that project operation under the with- project flow regime, does not have negative effects on adult salmon migration. (13) Provide sufficient resources for an onsite representative of the ADFG to monitor the project during construction and for an ADFG representative to inspect the project once per month when the project is on line. (14) Include ADFG fishing and hunting regulations in employee/employer work standards and contracts for all employees, contractors, and subcontractors of the developer to prevent exploitation of species resulting from improved access to the project area. Penalties for violation should include termination of employment. The ADFG also recommended in the same letter that Saxman conduct onsite investigations to verify and describe fish distribution by species and life phase for this and all waters potentially affected by this project. This recommendation stems from a concern on the accuracy of a 1977 U.S. Fish and Wildlife Service study that found no evidence of Arctic graying in Upper 13 Mahoney Lake. We address this recommendation in the Aquatic Resources section of the EA. Cc, Staff's Modification of Saxman's Proposal ~ Based on the agency and other comments that have been filed, and our analysis in Sections V, VI, and VII, we are recommending some minor modifications to Saxman’s proposal. Given that Saxman has agreed to virtually all of the mandatory conditions that have been filed (except the FWS's 13-cfs Upper Mahoney Creek minimum flow) and we also agree with a number of those conditions, we are recommending that several of the measures be incorporated into resource protection plans that would be filed with the Commission. The plans that we are recommending include: (1) a final erosion, sedimentation control, and revegetation plan; (2) a terrestrial resources protection plan; (3) a visual resources protection plan; (4) a cultural resources management plan; and (5) a public access plan. We discuss our recommendations in the individual environmental resource sections of this EA, and why we chose them in the Comprehensive Development and Recommended Alternative sections. In this case, the agency conditions have been incorporated into Saxman’s proposal, and although some of these measures affect how Saxman must operate the project, they wouldn't have significant effects on the project’s power value. We, therefore, haven't separately analyzed the costs of these measures. D.__No-Action Alternative Under the no-action alternative (license denial), there would be no change to the physical, biological, or cultural resources of the area. The generation the proposed project would provide would not occur. Iv. CONSULTATION AND COMPLIANCE A. Agency Consultation The following entities commented on the application and APEA pursuant to the public notice requesting final terms and conditions, recommendations, and prescriptions, issued by the Commission on August 14, 1996. We've considered these comments in our analysis of the project. Entity Date of Letter Alaska Department of Fish and Game November 26, 1996 U.S. Fish and Wildlife Service November 4, 1996 Alaska Energy Authority September 23, 1996 Ketchikan Public Utilities November 7, 1996 City of Saxman, Alaska January 29, 1997 14 B, Interventions Timely motions to intervene were filed by: Alaska Energy Authority (AEA) - filed August 30, 1996 Ketchikan Public Utilities (KPU) - filed November 12, 1996 Untimely motions to intervene were filed by: U.S. Fish and Wildlife Service (FWS) - filed December 2, 1996 Joanne Klein (Klein) - filed December 5, 1996 Late intervention was granted to the FWS and Klein by a Commission notice dated January 27, 1997. Only one intervenor, Klein, is opposed to licensing the project. Klein is opposed to licensing because of a land dispute at the nearby Beaver Falls Hydroelectric Project, FERC No. 1922. Klein asks that Saxman not be issued a license until the land dispute at the Beaver Falls project is settled. c, Scoping Scoping document 1 (SD1) was distributed on March 8, 1995. The following entities commented. Entity ; Date of Letter Alaska Division of April 5, 1995 Governmental Coordination Ketchikan Public Utilities April 12, 1995 Alaska Department of Fish and Game May 11, 1995 Ketchikan Area Parks Advisory Board May 14, 1995 U.S. Fish and Wildlife Service May 19, 1995 Alaska Division of May 19, 1995 Governmental Coordination Alaska Energy Authority June 1, 1995 Senator Robin L. Taylor dune 7, 1995 Alaska Department of Fish and Game June 20, 1995 U.S. Forest Service June 21, 1995 Scoping document 2 (SD2), which included responses to the above entities' comments, was distributed on September 27, 1995. We address their environmental concerns in appropriate sections of this EA. D. Water Quality Certification On May 20, 1996, Saxman requested water quality certification under section 401 of the Clean Water Act by submitting to the Alaska Department of Environmental Conservation (ADEC) a copy of their application for a U.S. Army Corps of Engineers (Corps) permit to discharge dredged or fill material into navigable waters under Section 404 of the Clean Water Act. By agreement between the Corps and the ADEC, an application for the Corps permit may also serve as application for water quality certification. 15 On October 8, 1996, the ADEC acknowledged receipt of the City’s request (letter to Mark Dalton, HDR Alaska, Anchorage, Alaska, from David C. Sturdevant, 401 Certification Team Leader, Alaska Department of Environmental Conservation, Juneau, Alaska, October 8, 1996). If the ADEC doesn’t act on the request within one year from the date they received it, certification is deemed waived under section 4.38(f) (7) (ii) of the Commission's regulations. Saxman and the ADEC have agreed to initiate the one-year period in which the ADEC can deny or grant water quality certification of the project with October 18, 1996, the date that the Corps issued their Public Notice of Application for Permit for the project (letter to Mark Dalton, HDR Alaska, Anchorage, Alaska, from David C. Sturdevant, 401 Certification Team Leader, Alaska Department of Environmental Conservation, Juneau, Alaska, November 20, 1996). Since the ADEC has not acted on Saxman's request, certification is deemed waived. E. Coastal Zone Management Act Under the Coastal Zone Management Act of 1972 (CZMA), as amended, before the Commission can issue a license for a project, the state must find the project consistent with the state's Coastal Management Program. State review commences on receipt of a consistency certification which is submitted by the applicant. Concurrence by the state is presumed in the absence of a state's objection within six months after the state begins its review. In Alaska, the Division of Governmental Coordination (ADGC) coordinates the state's consistency review under the CZMA. By letter dated April 28, 1997, the ADGC advised staff that their CZMA review for the Mahoney Lake project began on October 30, 1996, thus marking April 30, 1997, as the 6-month deadline. ADGC review was temporarily suspended on November 23, 1996, so the state could obtain additional information from the applicant. In addition, the ADGC letter states that as of April 24, 1997, the information was not adequate to issue their finding, and, therefore, to fulfill the six-month requirement and preserve their ability to issue a finding, they object to the certification that the project is consistent with the Alaska CMP. The ADGC letter does indicate, however, that some additional information had been received from the applicant, and that after further coordination with the state agencies involved, the state's consistency finding would be forthcoming. 16 EF. Comments on the DEA Entity Date of Letter Alaska Department of Fish and Game August 11, 1997 U.S. Fish and Wildlife Service August 12, 1997 HDR Engineering, Inc. August 12, 1997 Alaska Department of Natural Resources August 21, 1997 Ketchikan Public Utilities August 29, 1997 U.S. Army Corps of Engineers September 2, 1997 HDR Engineering, Inc. October 23, 1997 V. ENVIRONMENTAL ANALYSIS In this section, we first describe the general environmental setting of the project area. We then discuss the site-specific and any cumulative effects of the resources affected by the project including the effects of the proposed action, action alternatives, and no action. A._General Description of the Mahoney Creek Basin The project would be located in Alaska on Revillagigedo Island. This island is located at the south end of the Alexander Archipelago, a belt of mountainous islands off the Alaskan coastal mainland (see Figures 1 and 3). Revillagigedo Island has an area of 2,352 square miles. In most places on the island, mountains rise sharply from the water’s edge. The island also has numerous lakes and countless short, swift streams that flow down to the ocean from natural lake outlets. The project would make use of such topography for power production. The project site itself is about five air miles northeast of Ketchikan, Alaska, in an undeveloped, forested area located on National Forest System lands and lands claimed by the Cape Fox Corporation. The affected environment sections, within the various resource areas below, describe the environmental setting in more detail. B. Cumulative Effects According to the Council on Environmental Quality's Regulations for implementing NEPA (Section 1508.7), an action may cause cumulative impacts on the environment if its impacts overlap in space and/or time with the impacts of other past, present and reasonably foreseeable future actions, regardless of what agency or person undertakes such other actions. Cumulative effects can result from individually minor but collectively significant actions taking place over a period of time, including hydropower and other land and water development activities. 17 Figure 3. Project site on Revillagigedo Island During the scoping process, the geographic scope of analysis for this project was defined, without objection, as the Mahoney Creek Basin. Scoping only identified aesthetics and recreation as resources to be analyzed for cumulative impacts. Based on our independent analysis, we conclude that project impacts on aesthetics and recreation would be site-specific and not cumulative in nature. We base this conclusion on the following: » The Mahoney Creek Basin and surrounding area are largely undeveloped. No other hydroelectric or non-hydroelectric development exists or is known to be planned in the basin. The only evidence of past human activity are some former logging areas and their respective access roads, and a zinc mine abandoned since 1949. » The area is predominantly mature evergreen forest with steep topography that would screen from view most impacts on 18 aesthetics, except those impacts visible from the air. In addition, most of the project structures would be underground. > The available information indicates that few people access the Mahoney Creek Basin, and the project would likely not draw a substantial amount of new users into the area. In their comments on the application and APEA, ADFG requests that, due to an increased interest in hydroelectric development in Southeast Alaska, we assess the overall socioeconomic and environmental effects of this proposed project with the effects of other projects currently proposed or operating. ADFG is concerned that individual assessments will inadvertently lead to one project negatively affecting another. They are also concerned that, cumulatively, the proposed and existing projects in Southeast Alaska could result in exaggerated negative environmental effects that could be overlooked when projects are independently evaluated. Southeast Alaska The Mahoney Lake Project, if constructed, would play a part in the continuing development of the old-growth temperate coastal rain forest of southeast Alaska. There are several new project proposals currently being advanced via the APEA process in Southeast Alaska: (1) Reynolds Creek, FERC No. 11480; (2) Lake Dorothy, FERC No. 11556; (3) Lace River, FERC No. 11553; (4) Otter Creek, FERC No. 11588; and (5) Upper Chilkoot, FERC No. 11319. 4/ Given the size of the land mass in question, this is a relatively small number of potential projects. In addition, none of these projects is on Revillagigedo Island, so the potential of their effects to interact with any of the potential effects identified for the Mahoney Lake Project is extremely small, if not nonexistent. Revillagigedo Island The Mahoney Lake Project is the only new project being proposed on Revillagigedo Island. However, there are four existing, licensed projects on Revillagigedo Island in fairly close proximity: (1) Swan Lake, FERC No. 2911; (2) Tyee Lake, FERC No. 3015; (3) Ketchikan Lakes, FERC No. 420; and (4) Beaver Falls, FERC No. 1922 (see Figure 4). 4/ Preliminary permits have been issued for other new projects in Southeast Alaska, but we typically don’t consider such projects in our cumulative assessment because historically only a small percentage have resulted in filed applications. 19 Major non-hydro developmental activities on the island include saw and pulp milling, logging, commercial fishing, and tourism-related businesses. These tend to cluster on the Tongass Narrows side of the island in and around the city of Ketchikan. There are also several water supply projects on the island, including Whitman Lake, Connel Lake, and Carlanna Lake (see Figure 4). The Mahoney Lake Project would contribute to an increasing human imprint on the George Inlet side of Revillagigedo Island because of the new access road and transmission line that would be constructed. However, if we expand the geographic scope of our analysis to include all of Revillagigedo Island, the environmental effects of the Mahoney Lake Project combined with the effects of the other licensed projects on the island would, for the reasons stated above, still be minor. In the individual resource sections of this EA, we discuss the site-specific effects that constructing and operating the project would have on environmental resources. Cc, Proposed Action and Action Alternatives 1. Geology and Soils Resources Affected Environment: The project area is very rugged, and steep to precipitous slopes are common. Since deglaciation, the dominant landscape-altering process has been mass wasting, including rock falls, rock slides, avalanches, landslides, and debris torrents. Rock falls from bedrock cliffs at the proposed project site are common, most notably from the cliffs along the left bank of Upper Mahoney Creek. Because the dip of bedding is 36 to 58 degrees into the slope, the potential for large rock slides there is low, but small to medium rock falls are common. The only large rock slide area that has been observed is at the southeastern corner of Upper Mahoney Lake. Only one landslide has been observed in the project area, just southeast of a right angle bend in Upper Mahoney Creek. Because the soil cover is not thick, landsliding does not appear to be a widespread form of mass wasting in the general vicinity. Although there are a number of faults within 3 to 4 miles of the project area, these faults do not appear to be active. The nearest historic earthquake was 45 miles from the project site. 20 Figure 4. Hydroelectric Development on Revillagigedo Island. Mahoney Lake Project. FERC No. 11383 (P) [Beaver Falts Project. FERC No. 1822 Ketchkan Lakes Project. FERC Mo. 420 Swan Lake Project FERC No. 2911 —— Bésting Transmission Lines « -- Swan LakelTyee interte (P) (P) Proposed 21 In general, soils in the project area are quite thin over bedrock because of extensive erosion following glaciation. Recent deposits include colluvium, stream alluvium, and muskeg. The colluvium at the project site includes talus/scree, avalanche deposits, and landslide deposits. Talus is quite abundant on the left bank of the outlet of Upper Mahoney Lake. Alluvium at the project site includes active stream deposits and alluvial fans. A significant delta has developed in the area between the proposed powerhouse site and the mouth of Upper Mahoney Creek where it empties into Lower Mahoney Lake. Although no significant deposits of muskeg are located in the upper portion of the project, some large muskeg areas exist on the southern shore of Lower Mahoney Lake. The powerhouse access road would pass over these organic soils. Environmental Impacts and Recommendations: Construction. Vegetation removal, excavation, and blasting during project construction would temporarily increase turbidity and sediment in the project area. About 16,000 cubic yards of rock and 2,000 cubic yards of soil would have to be excavated to construct the tunnel, powerhouse and tailrace. In addition, sediment production would increase during the construction of laydown areas, and while excavating overburden soils for staging areas, and access roads. Sediment from groundwater could also seep into the project tunnels during and shortly after construction until such seeps are grouted. Most construction-related sedimentation at the project would be the result of runoff. However, there is a potential for blasted rock to reach Mahoney Creek directly during powerhouse excavation. : Saxman has developed an Erosion and Sediment Control Plan (ESCP) that would be finalized when the project undergoes final design (see Appendix B of the Application for License). The ESCP includes measures for capturing sediment before it reaches Upper Mahoney Lake, Lower Mahoney Lake, or any of the creeks within the project area. The ESCP measures include using sediment ponds, sediment barriers, soil erosion matting and mulches, gabion walls, drains, etc. to prevent run-off. All excavation and blasting would be done under controlled conditions and would be subject to on-site monitoring. Groundwater seeps would be grouted shut and any major seepage that occurs would be collected and disposed of off site. The final ESCP would detail the specific measures to be used at specific locations at the project site. The ESCP also describes measures to revegetate disturbed areas. The FS and ADFG have filed conditions on soil erosion and sedimentation. The ADFG filed two conditions. One condition would require the licensee to monitor the effectiveness of ESCP measures via daily water quality sampling that would continue for 22 60 days after the removal of all temporary erosion control structures. If turbidity levels below construction areas measure greater than 5 NTU higher than those measured above the construction sites, construction would be stopped, the sediment source located, and appropriate control measures implemented. The second condition is meant to reduce the introduction of sediment to spawning gravel at the outlet of South Creek (a tributary on the south side of Lower Mahoney Lake). The condition would limit road and bridge construction within 150 feet of South Creek to the period between June 15 and August 1. Exceptions to this condition (such as clearing, grubbing, and road construction between 150 and 50 feet from South Creek, or bridge installation without activities within the limits of ordinary high water) could be granted in writing by the ADFG in response to detailed, site-specific proposals from Saxman. The FS condition is more general, and would require that Saxman file with the Commission an ESCP that has been previously approved by the FS before any land-disturbing activities begin. The measures described in Saxman’s ESCP should be effective in reducing soil erosion and sedimentation impacts during project construction to minimal levels. We recommend that the ESCP be finalized in consultation with the agencies, and that it include the ADFG conditions for monitoring and protecting South Creek spawning gravels. In addition to avoiding sediment reaching the salmon spawning area at the mouth of South Creek, construction activities that would directly involve Upper Mahoney Creek water, such as connecting the tailrace and bypass to the creek channel, should also be scheduled for June 15 - August 1. We discuss this issue in detail later in the Aquatic Resources section. The final plan should also include specific measures for revegetating areas disturbed during project construction. The powerhouse access road may be in the path of avalanches generated from the chutes to the west and southwest, thereby interrupting the normal flow of sediment to Lower Mahoney Lake. Similarly, this access road could be damaged or destroyed by such an avalanche, cutting off vehicular access to the powerhouse. Rock falls or a rock slide could foul the lake tap intake opening. Snow avalanches could damage the penstock where it is exposed at the ground surface between the upper tunnel and the shaft. The powerhouse tailrace could be blocked or damaged by debris torrent material. Saxman's Proposal To reduce the risk of rock debris falling into the lake tap intake, at-risk rock above the water line would be rockbolted. Rock traps would also be included in the design of the upper tunnel to intercept rock debris. Snow avalanches above the exposed portion of the penstock between the upper tunnel and the shaft would be diverted by a berm and énergy dissipator uphill of the penstock and the penstock would be 23 protected with a concrete housing. As part of the maintenance and operation plan, an operator would check for rock and organic debris at the end of the tailrace, particularly after storms and rain-on-snow events. The costs associated with these measures are part of the contingencies included in Saxman's cost estimate. Staff Analysis No comments or conditions have been filed on designing the project to avoid or mitigate impacts from rock falls or avalanches. However, because there is a possibility of rock falls and avalanche at the project site, Saxman’s proposed design measures seem reasonable and should be included in the final design of the project, if licensed. Minor, temporary, localized erosion would be unavoidable during project construction until disturbed surfaces are stabilized and revegetated. It is also likely that some amount of ground water seepage would occur in the tunnels after construction is completed. 2. Aquatic Resources Affected Environment: Upper Mahoney Lake, with a surface area of 74 acres, drains 2.1 square miles and provides useable storage of about 4,000 acre-feet. Its natural outflow forms Upper Mahoney Creek which runs about 1.3 miles over a steep, 27 percent gradient and discharges into the west end of Lower Mahoney Lake. The lower lake drains 5.7 square miles, including the Upper Mahoney watershed, and has a surface area of 164 acres, with 20,400 acre-feet of storage. Lower Mahoney Creek, the natural outlet from Lower Mahoney Lake, is a short, high gradient stream that connects Lower Mahoney Lake to tidewater at George Inlet. Water Quantity. Streamflow data were recorded in Upper Mahoney Creek near the outlet of Upper Mahoney Lake from 1978 through 1989 at USGS gage No. 15067900, and in Lower Mahoney Creek near the outlet of Lower Mahoney Lake intermittently for 27 years between 1920 and 1981 at USGS gage No. 15068000. Saxman used the records from these two gages to develop a 35-year record of streamflows for the project area. Table 1 shows the estimated average monthly runoff into Upper Mahoney Lake, streamflows into Lower Mahoney Lake from Upper Mahoney Creek, and outflows from Lower Mahoney Lake into Lower Mahoney Creek. 24 Table 1. Estimated average monthly flows in the project area (Saxman 1996). Runoff to Upper Upper Mahoney Lower Mahoney Mahoney Lake Creek flows Creek flows Month (cfs) (cfs) (cfs) October 70 92 176 November 45 59 127 December 19 25 84 January 31 : 40 58 February 24 32 55 March 17 23 46 April 25 33 68 May 61 81 13 dune 82 109 154 duly 61 81 125 August 45 59 107 September 53 70 118 The highest flows in the Mahoney system are in the spring and fall with the lowest flows occurring in the late summer and winter. The Mahoney Lakes area is subject to rapidly changing water levels due to storm runoff. A streamflow gage installed by the City in June 1994 on Upper Mahoney Creek near the proposed tailrace site measured changes in discharge of 1,000 cfs or more over only a couple of days duration. Lower Mahoney Lake levels rose about three feet between late August and late September 1994 when peak flows reached 239 cfs in Upper Mahoney Creek. About 800 feet upstream of Lower Mahoney Lake, at the proposed tailrace site, Upper Mahoney Creek flows over coarse alluvial deposits. During periods of low flow, the streamflow is mostly or exclusively below this substrate from about 300 feet downstream of the proposed tailrace site to Lower Mahoney Lake, resulting in a largely dry channel. These conditions can occur at any time of the year if there is little precipitation and/or snow melt to create runoff. During site visits, a dry channel was observed when flows measured near the proposed tailrace site were below about 20 cfs. The water flowing below the substrate of Upper Mahoney Creek upwells into Lower Mahoney Lake through a gravel delta area at the outlet of Upper Mahoney Creek. The upwelling flows appear to occur year-round, although in 1994, the upwelling lessened after lake levels rose in the fall. Water Rights. Saxman filed an Application for Water Right (#LAS 14359) on May 17, 1993, and an updated application on May 20, 1996, with the Alaska Department of Natural Resources for 50 million gallons of water per day (77.4 cfs) from Upper Mahoney Lake to operate the project. Water Quality. Saxman conducted studies between June 1994 and October 1995 to evaluate the existing water quality in the vicinity of the proposed project. All readings during the studies met applicable state water quality standards. 25 Water temperatures, dissolved oxygen (DO), pH, conductivity, turbidity, and total suspended sediment data were collected in Upper Mahoney Creek at the location of the proposed tailrace outflow (Table 2). Table 2. Water quality in Upper Mahoney Creek at the proposed tailrace site (Saxman 1996) . | Parameter Average Range Temperature Celsius (°C) 6.3 0.5 - 14.0 Dissolved Oxygen parts per million (ppm) 12.4 10.0 - 17.0 pH | 6.63 5.46 - 7.68 Conductivity microSiemans per 11.1 6.6 - 14.8 centimeter (mS/cm) Turbidity nephelomerri¢ turbidity <0.10 - 0.35 units (NTU) Total suspended sediment (ppm) 0.4 - 3.8 DO and temperature data were collected in Upper Mahoney Lake from its surface to a depth of 150 feet. The results of the temperature and DO profile monitoring in Upper Mahoney Lake indicate that the temperature variations are typical for an alpine lake. Surface temperatures fluctuated between about 0.5° Celsius (C) and 13° C, while temperatures at 80 feet below the surface, about the depth of the proposed lake tap, remained within one degree of 4° C. DO concentrations in Upper Mahoney Lake, at the surface and at proposed drawdown depth, ranged from 10.5 parts per million (ppm) to 12 ppm. Water temperatures were recorded in the upwelling area of Lower Mahoney Lake at 4 inches above the gravel substrate. Intragravel groundwater temperatures at the upwelling were recorded at a depth of 10 inches below the surface of the substrate. Air temperatures were recorded near the channel of Upper Mahoney Creek at the proposed tailrace site. The continuous water and air temperature monitoring in Upper Mahoney Lake, Upper Mahoney Creek, and Lower Mahoney Lake were used to determine correlations with the temperatures of air, water in the stream channel, and water in Upper and Lower Mahoney Lakes. The study findings support a direct connection between flows in Upper Mahoney Creek and the intragravel zone; and a 26 strong correlation between surface and groundwater temperatures and air temperatures. Air temperatures for the city of Ketchikan, Alaska, corrected for the proposed project location, and water temperatures for Upper Mahoney Creek were used to estimate the existing range of intragravel groundwater temperatures in the Lower Mahoney Lake upwelling (Figure 5).- Fisheries. Saxman conducted fish surveys in Lower Mahoney Lake and the anadromous reach of Upper Mahoney Creek during June 14-17, and August 29-September 1, 1994, using electroshocking, minnow traps, beach seining, angling, and visual observation from ground and boat. Lower Mahoney Lake is a clear lake with visibility to a depth of 20 feet or more under calm conditions. Sockeye salmon spawning surveys were conducted in Lower Mahoney Lake during August 29-September 1, and September 22-24, 1994. Salmon migration movements and numbers in Lower Mahoney Creek were surveyed during August and September 1995. In July 1995, a stream depth monitor (pressure transducer) was established near the steepest waterfalls in Lower Mahoney Creek, about 165 feet downstream from Lower Mahoney Lake, so that salmon movements could be associated with stream discharge. Upper Mahoney Lake is a high altitude lake with no known fish resources. Long periods of ice cover, infertile conditions, and lack of accessibility to fish from lower altitudes suggest that fish were not native to the lake. An attempt was made to stock Arctic grayling in the lake in 1966, but an evaluation in 1977 by the FWS provided no evidence of survival (letter from Gary L. Hickman, Assistant Area Director, Alaska Area Office, U.S. Fish and Wildlife Service, Anchorage, Alaska to Colonel George R. Robertson, District Engineer, Alaska Deere: Corps of Engineers, Anchorage, Alaska, dated January 23, 1978). Upper Mahoney Creek Upper Mahoney Creek is too steep throughout most of its length to provide fish habitat. The most downstream waterfall, about 1,000 feet upstream from Lower Mahoney Lake, is a permanent barrier to fish passage. As described earlier, from about 500 feet upstream of Lower Mahoney Lake, some streamflow runs below the substrate and surfaces through the delta area at the outlet of Upper Mahoney Creek. At low flows all streamflow runs beneath the substrate in this reach. Small numbers of slow-growing Dolly Varden occupy permanent pools near the proposed powerhouse site, and the lower end of the stream provides some habitat for resident Dolly Varden from Lower Mahoney Lake during the times of the year when flow is present in the stream channel. 27 14.00 12.00 7° 10.00 ‘Temperature (Celsius) & 8 Month Figure 5. Estimated range of natural intragravel temperatures in cheaLcuse Mahoney Lake upwelling at the outlet of Upper Mahoney Creek (Source: Saxman 1996). Lower Mahoney Lake provides spawning and rearing habitat for sockeye salmon. Historical records are lacking but a single observation of Lower Mahoney Creek in 1956 recorded 10,000-15,000 sockeye salmon en route to Lower Mahoney Lake. Intermittent stream counts on file with the ADFG in more recent years have recorded numbers of less than 1,000. In 1994, 200 sockeye were observed on the spawning grounds and total escapement to the lake was estimated at 300 to 600. Sockeye spawning locations correspond with upwellings in the delta areas at the outlets of Upper Mahoney Creek and South Creek (a tributary to the south side of Lower Mahoney Lake) with about 75 percent of fish spawning along the toe of the Upper Mahoney Creek delta and 25 percent at the South Creek delta. Spawning depths ranged from 1.5 to 23 feet with most spawning occurring at depths of 6 to 16 feet. The results of the surveys strongly suggest that the salmon were selecting areas where upwelling groundwater is present, providing optimum conditions for egg development . 28 Sockeye salmon spawning in Lower Mahoney Lake occurs from mid-August to late September. Sockeye eggs hatch in midwinter as alevins (pre-emergent fry) but do not emerge from the gravel as free swimming fry until May or early June. Juvenile sockeye salmon rear in Lower Mahoney Lake for 1 to 2 years prior to outmigrating to saltwater in the early spring. The adults return to the Lower Mahoney Lake spawning grounds after 3 to 4 years at sea. Three juvenile coho salmon and one juvenile rainbow trout/steelhead were caught in the Lower Mahoney Lake surveys in 1994, indicating that some spawning ‘by these species had probably occurred in the lake or its tributaries. The FWS reports that some coho salmon and steelhead trout spawn in the upwelling areas (letter from Jon R. Nickles, Chief, Ecological Services Office, U.S. Fish and Wildlife Service, Anchorage, Alaska, April 2, 1997). Coho spawn in September or October and emerge by mid-June. Steelhead spawn in April to May, and emerge by mid-July. Incubation of anadromous fish eggs, therefore, appears to occur in the upwelling area from mid-August until mid-July. Lower Mahoney Lake supports a dense population of resident, slow-growing Dolly Varden; these fish probably do not get much larger than 6 or 7 inches. Previous reports (Corps of Engineers 1978 and 1983) indicate that the lake also contained resident kokanee and cutthroat trout, but these species were not observed during the 1994 study. Lower Mahoney Creek serves as a migratory corridor for sockeye salmon en route to and from Lower Mahoney Lake and provides limited spawning habitat for pink and chum salmon. Because of several cascades and falls, Lower Mahoney Creek can only be traversed through its entire length by adults of the strongest swimming fish species. Observations in late August of 1994 and 1995 indicated that at low flow most fish were blocked 165 feet downstream from the lake by a cascade where the flow drops about 10 feet through a 45-degree chute between boulders. During moderate flows, sockeye salmon, coho salmon, and steelhead trout are able to negotiate the falls and reach Lower Mahoney Lake. According to the ADFG’s files, intermittent stream surveys since 1943 have documented up to 6,000 pink salmon, 1,000 chum salmon, and small numbers of coho salmon in Lower Mahoney Creek. In 1994 and 1995, 1,215 and 3,600 pink salmon, respectively, were counted. Pink salmon spawn primarily at the lower end of the stream within the intertidal zone. The 1994 survey recorded a few chum salmon in the intertidal zone. Lower Mahoney Creek also provides limited rearing habitat for rainbow trout/steelhead. 29 Environmental Impacts and Recommendation: iS: Construction Water quality. Runoff from construction activities may increase downstream turbidity and sedimentation, which could disrupt salmon spawning and smother eggs. a Saxman proposes to construct a powerhouse and tailrace along Upper Mahoney Creek and a 30-foot-long bridge span across South Creek about 1,000 feet upstream of Lower Mahoney Lake. The ADFG has submitted a condition that Saxman take daily turbidity readings from Upper Mahoney Creek upstream and downstream of all construction activities, including all overland flow that crosses construction areas. If turbidity below the construction area measures more than 5 NTU higher than the values obtained above the construction area, then all construction activities would cease until the sediment sources are located and appropriate sediment control measures are implemented. Turbidity monitoring would start with the beginning of construction and continue for 60 days following the removal of all temporary erosion control structures. Turbidity data would be submitted to the ADFG weekly. The ADFG has also submitted a condition that road and bridge construction within 150 feet of South Creek occur only between June 15 and August 1, unless the ADFG grants an exception in writing, to reduce the introduction of sediment to spawning gravel at the outlet of South Creek. Saxman has agreed to accept the conditions of the ADFG regarding limiting construction activities at both streams. Fisheries surveys show that sockeye salmon in Lower Mahoney Lake spawn at the outlets of both Upper Mahoney Creek and South Creek. We agree that spawning grounds should be protected from any construction effects. Therefore, the limits on construction activities around South Creek should also apply to construction activities that would directly involve Upper Mahoney Creek water, such as connecting the tailrace and bypass pipe to the creek channel. These measures should be included in the final erosion and sedimentation control plan that we are recommending be filed with the Commission. We would expect Saxman to notify the Commission if construction activities are interrupted because of high turbidity. If the ADFG grants any exceptions to restrictions on bridge construction at South Creek, we recommend that Saxman file the excepted conditions with the Commission for approval. 30 Operation Minimum flows in Upper Mahoney Creek The successful development of salmon eggs and alevins depends on an adequate exchange of water through their gravel environment to supply oxygen and to remove metabolic waste products. f Saxman initially proposed to develop a plan, in consultation with the resource agencies, to determine the need and quantity, if any, for supplemental flows into Upper Mahoney Creek. Subsequently, Saxman agreed to accept a year- round, 5-cfs minimum flow, or naturally occurring streamflow, whichever is less, below the proposed tailrace site (letter from Michael V. Stimac, Manager, Licensing and Environmental Services, HDR Engineering, Inc., Bellevue, Washington, April 14, 1997). The FWS initially submitted a condition that would require a continuous minimum flow of 30 cfs in Upper Mahoney Creek below the tailrace from August 1 through July 15, to maintain streamflow through salmon spawning areas. After reviewing hydrology records in consultation with Saxman, the FWS modified their condition to require instantaneous flows at or above 13 cfs year-round when the project is on-line. When the project is off- line, the average daily flow would have to equal or exceed 13 cfs. Instantaneous flows between 5 and 13 cfs would be allowed for a maximum of 48 hours per calendar month, from November 1 through April 30, during or immediately following periods of low precipitation; however, these low flows may only occur during a maximum of one winter in any period of five consecutive winters. Flushing flows of 78 cfs would also be required in the tailrace for at least one period of 48 continuous hours, coinciding with a rainfall event, between May 1 and August 15 each year. The ADFG has submitted a condition requiring that if, during project operation, discharge in Upper Mahoney Creek varies from the range of measured pre-project values and poses a potential negative effect on the spawning, incubation, and/or rearing of sockeye salmon in Lower Mahoney Lake, Saxman would be required to formulate and implement an ADFG approved biotic monitoring plan to address any potential effects. The ADFG has also submitted a condition that Saxman notify the ADFG, the Commission, and other interested parties whenever required flows are not achieved, orally and in writing, within 12 hours of the beginning of any non-compliance event. Staff Analysis Water exchange in the Lower Mahoney Lake spawning gravel is provided by upwelling water in the delta area at the outflow of Upper Mahoney Creek. While it is unknown how other groundwater sources may influence the upwelling, Saxman’s monitoring indicates that the volume of water in the upwelling 31 may be determined in large part by the flow in Upper Mahoney Creek, even at flows as low as 5 cfs. Estimated pre- and post-project flows in Upper Mahoney Creek (Table 3) indicate that average monthly post-project flows would be higher than the average monthly pre-project flows from December through April, lower from May through August, and about the same from September through November. Consequently, the effect of the project would be to moderate the existing seasonal flow extremes. Saxman believes that a 5-cfs minimum flow would maintain conditions at better than existing levels because it would be reliably available at most times. According to Saxman’s hydrologic simulations, flows in Upper Mahoney Creek equal or exceed 5 cfs in December 89 percent of the time. December historically has had the lowest winter flows. FWS recommends 13 cfs because it represents the 50 percent exceedence (median) flow for December. The FWS also calculated a minimum flow using the “Montana method” as described and supported by Tennant (1976). The Montana method asserts that good to excellent conditions during winter months could be maintained with flows equal to 25 percent of the average annual flow. The average annual flow in Upper Mahoney Creek is 59 cfs, making 15 cfs an adequate flow using the Montana method. Table 3. Estimated average pre- and post-project flows in Upper Mahoney Creek in cubic feet per second (cfs) (Saxman, 1996). Pre-project average upper Post -project Mahoney Creek average upper flows Post-project | Mahoney Creek flows downstream of average downstream of Month powerhouse turbine powerhouse (cfs) flows (cfs) (cfs) October November December January February March April May June July August September 32 Saxman doesn’t believe that the Tennant (1976) instream flow findings should be applied to the project because the habitat to be protected is in the lake, not Upper Mahoney Creek. The FWS believes that Tennant (1976) is appropriate because it is the streamflow that maintains the upwelling. Saxman’s monitoring results show that the upwelling is largely influenced by Upper Mahoney Creek flows. Therefore, we believe that the Upper Mahoney Creek flows provide the best available information to estimate the minimum flows needed to maintain the upwelling. Losses during incubation are generally influenced by the degree of crowding during spawning and by environmental conditions (Groot and Margolis 1991). Crowding may result either in egg deposition in marginally suitable spawning areas or increased density in more suitable spawning areas. Since upwelling groundwater provides the stable conditions needed during incubation, a weaker upwelling from decreased flows may not be able to protect the eggs and/or alevins from temperature extremes and freezing (Groot and Margolis 1991). During August and September, when sockeye salmon are spawning, the existing monthly flows in Upper Mahoney Creek average 59 and 70 cfs, respectively (Table 3). A 13-cfs minimum flow could significantly reduce the amount of flow during spawning. Eggs deposited in upwelling areas supported by an instantaneous 13-cfs minimum flow, however, may remain viable because 13 cfs could maintain the incubation area at existing minimum conditions. Eggs deposited in the marginal areas not supported by the 13-cfs flow may be vulnerable to freezing under existing conditions and post-project conditions. A 5-cfs minimum flow would provide about 8 and 7 percent, respectively, of the average pre-project flows during August and September. A 5-cfs minimum flow could increase crowding during spawning and place more eggs in marginal areas. If the project were not operating, the flows could go as low as 13 cfs as an average daily minimum (FWS’s condition), or as low as the naturally occurring stream flow, including flows below 5 cfs. If the project were off-line between mid-August to late- September, the upwelling area available to spawning salmon could further be reduced by flows below the minimum flows for on-line operation. Because a minimum flow of either 5 or 13 cfs, or off-line conditions, could potentially cause crowded conditions during spawning, post-project monitoring would be needed to determine the effects of reduced flows during spawning. We believe that any effects from reduced flows on spawning conditions could be identified from the data collected by ADFG’s conditions for continuously recording discharges below the tailrace, and conducting spawning surveys at the outlet of Upper Mahoney Creek. These ADFG conditions are discussed in the sections on Lower 33 Mahoney Creek fish passage, Flow continuation, Mode of operation, and Upwelling temperatures. To accommodate low water years, the FWS condition would allow the project to release less than 13 cfs for 48 hours during winter months in one year out of five consecutive years. The hydrologic record developed by Saxman, however, shows that during low water years, the inflow to Upper Mahoney Lake averages 13 cfs or less in December and January. If Upper Mahoney Lake were not completely refilled in the fall because of low water conditions, the project may not be able to maintain a 13-cfs minimum flow in Upper Mahoney Creek throughout the winter months, even if the flow requirement was relaxed for 48 hours each month. We recommend that Saxman implement the minimum flow condition submitted by the FWS because it would better represent existing conditions than a 5-cfs minimum flow. Since the 13-cfs condition is based on stream-specific data for the low-flow winter month, we agree that it would be more appropriate for Upper Mahoney Creek than the 15 cfs calculated using the Montana method, a more generic, but commonly accepted method. The Montana method calculation is close enough to 13 cfs, however, t support the condition submitted by the FWS over the 5 cfs proposed by Saxman. Because 13 cfs is the median flow for what has been historically the low flow winter month, it should be sufficient to protect the resource during periods when the project is either shutdown or running at a very low output. In low water years, however, water may not be available to maintain a 13-cfs minimum flow during the winter months. Therefore, we further recommend that in years when Upper Mahoney Lake cannot be completely refilled by November 1 because of low water conditions, the minimum flow in Upper Mahoney Creek below the tailrace, from November 1 through April 30, would be 13 cfs, or the instantaneous inflow to Upper Mahoney Lake, whichever is less. By letter dated July 11, 1997, we asked the FWS to modify their minimum flow conditions for years when low water conditions prevent complete filling of Upper Mahoney Lake by November 1. We received a response from Interior, dated August 12, 1997, agreeing with our request as long as project operation does not interfere with filling Upper Mahoney Lake. Interior recommends that the project be restricted to a maximum discharge of 50 cfs from August 1 until Upper Mahoney Lake fills, or October 31, whichever occurs first. We agree that Interior's recommendation is reasonable based on the existing average inflow to Upper Mahoney Lake for August and September (Table 1), and would ensur that Upper Mahoney Lake would refill by November 1 in all but th most extreme years. The ADFG may require biotic monitoring if post-project discharges differ from pre-project ranges, but doesn’t specify if 34 the range of flows would be calculated by daily, monthly, seasonal, or other time periods, whether flow averages or extremes would be used, whether the historical flows of record would be used or Saxman’s measured flows, or how any effects to the sockeye resource would be determined. Since compliance with license conditions is determined by the Commission, we need to consider how each condition could be interpreted and met. We believe the methodologies for this monitoring should be defined by Saxman, in consultation with the FS, the NMFS, the FWS, and the ADFG, and submitted to the Commission in the form of a plan for approval, prior to the start of project operation. By letter dated July 11, 1997, we asked the ADFG to modify their condition to allow for Saxman in consultation with the FS, the NMFS, the FWS, and the ADFG, to define the methodologies, and submit them to the Commission for approval. The ADFG's response, dated August 11, 1997, concurs with our request and recommends that Saxman and the agencies meet on a scheduled basis, at least once a year, to review study results and identify courses of actions required based on the results. We agree with the ADFG that an ongoing program to review and address the study results is reasonable, and recommend its adoption. The ADFG further recommends that the funding for these studies be placed in an escrow account. While we understand the ADFG's desire to secure funding for the study, we don't believe an escrow account is necessary at this time. We would, however, recommend that as part of the report filed for Commission approval on the studies methodologies, Saxman file an itemized list of estimated costs for the studies and a statement of how these costs would be met. ADFG’s 12-hour reporting condition would require earlier reporting than commonly required by the Commission; however, considering the low minimum flow requirement, the unpredictability of project flows with an undefined operational mode (see Mode of operation), and the sensitivity of the early life stages to be protected by the flows, we recommend that Saxman be required to report any violations of required flows in Upper Mahoney Creek, if they occur, within 12 hours. Flushing flows. A FWS condition would require the release of an annual 48-hour, 78-cfs flushing flow, coinciding with a rainfall event between May 1 and August 15. We agree with the FWS that an annual flushing flow would be needed to flush silt from the gravel in the upwelling area. Tennant (1976) recommends flushing flows equal to 200 percent of the average annual flow, about 118 cfs in Upper Mahoney Creek. The FWS condition would require the project to release 78 cfs into the tailrace, rather than providing 78 cfs as measured downstream of the tailrace. Therefore, if the project were to discharge 78 cfs in combination with bypassed reach flows from a major rainfall, an adequate flushing could be achieved. 35 Lower Mahoney Creek fish passage. By altering the discharge into Lower Mahoney Creek, the project could delay or prevent the upstream migration of salmon into Lower Mahoney Lake. Saxman’s Proposal During pre-filing consultation, Saxman developed a monitoring plan titled “Mahoney Lake Hydroelectric Project Aquatic Resources Plan”, and sent it to the resource agencies on May 9, 1996. In their application for a project license, Saxman proposes to incorporate the salmon monitoring features of the plan. 5/ Under Saxman's proposal, discharge data would continue to be collected in Lower Mahoney Creek for the duration of the license. Saxman would monitor flow data from an existing continuously recording stream depth monitor near the steepest cascade in Lower Mahoney Creek, and observe salmon movement through Lower Mahoney Creek during the upstream migration period. Onsite observations would be conducted by a trained technician supervised by a fisheries biologist every 3 days between August 1 and September 30, and may be more frequent when significant numbers of salmon are present. Saxman would release flows high enough to ensure passage when onsite observers identify that any migrating salmon are present in Lower Mahoney, Creek below the steepest cascade. The number of salmon would be counted by species, and associated with the flows recorded at passage. Saxman would conduct the onsite monitoring during the pre- construction period, during construction, and for the first 3 years of operation. The results of the monitoring program would be used to develop a simplified index of salmon abundance to predict the optimal times of sockeye presence and the minimum flows necessary for salmon passage. Onsite observations of adult sockeye migration would continue for the next 7 years, but would be limited to the predicted periods of sockeye passage from the indexed data. The FWS has submitted a condition that Saxman implement their Mahoney Lake Hydroelectric Project Aquatic Resources Plan, or an alternative plan approved by the FWS. The FWS has also submitted a condition that Saxman provide a report to the FWS after 3 years of post-construction monitoring, describing salmon 5/ In addition to salmon passage monitoring, Saxman's Mahoney Lake Hydroelectric Project Aquatic Resources Plan would continue pre-construction temperature monitoring in the Upper Mahoney Creek delta area through the first 3 years of project operation to determine the project’s effects on sockeye egg incubation and correlate temperature monitoring data with powerhouse discharge to examine the relationship between the project’s flow and water quality in the upwelling (see Upwelling temperatures) . 36 access to spawning habitat within Lower Mahoney Lake, fish population status, and making recommendations for improving salmon recruitment, or otherwise improving aquatic habitat conditions. If the results of the monitoring show any potentially adverse project effects, Saxman would have to negotiate a remedial plan with the resource agencies, and then implement the plan. The ADFG has submitted conditions that would require that Saxman: . manage the storage and release of water from Upper Mahoney Lake to maintain Lower Mahoney Creek flows between 120 and 200 cfs from August 1 through September 30, and continuously monitor flows from Lower Mahoney Lake throughout the year to identify operational schemes to achieve these flows; . conduct annual sockeye salmon counts throughout Lower Mahoney Creek and the spawning areas at the outlets of South Creek and Upper Mahoney Creek every 3 days from August 1 through September 30, and report the counts to the ADFG annually, until the ADFG is confident that the project's flow regime does not negatively affect adult salmon migration; and . notify the ADFG, the Commission, and other interested parties whenever required flows are not achieved, orally and in writing, within 12 hours of the beginning of any non- compliance event. Under the ADFG’s condition, project flows would be regulated to maintain between 120 and 200 cfs in Lower Mahoney Creek to ensure upstream salmon passage throughout the migration period, rather than rely on site observations or prediction of salmon presence, and the annual sockeye counts could continue for an indefinite number of years. Saxman has agreed to the agencies’ conditions. Staff Analysis Saxman’s studies found that sockeye salmon are unable to move past the steepest cascade in Lower Mahoney Creek when flows are in the range of 20 to 50 cfs, but flows in the range of 120 to 160 cfs appear to allow passage. Dry conditions prevented observation of fish behavior at flows between these ranges. The topography of the falls area suggests that flows in the range of 100 to 200 cfs allow fish to bypass the falls by following a natural trough on the south side of the stream. At flows of less than 75 cfs, this trough carries little water and forces the fish to attempt to jump the falls. During the 1994 study, flows peaking at about 500 cfs in Lower Mahoney Lake appeared to flush downstream salmon holding in Lower Mahoney Creek, preventing them from reaching Lower Mahoney Lake. aw Table 4 shows that under existing conditions, flows in Lower Mahoney Creek average near the threshold for passage during August and September, indicating that the salmon may enter the lake during brief periods of higher than average flows after storms, as observed during Saxman’s Lower Mahoney Creek surveys. Under Saxman’s proposed mode of operation, low or high flow extremes could occur during August and September, but the average monthly flows would be similar to the existing average monthly flows. Table 4. Estimated average monthly pre- and post-project flows in cubic feet per second (cfs) in Lower Mahoney Creek (Saxman_1996) . Estimated average Estimated average pre-project post-project flows in flows in Lower Mahoney Creek Lower Mahoney Creek (cfs) (cfs) October November December January February March September Based on drainage area, the project would affect 36.8 percent §/ of the Lower Mahoney Creek watershed. Therefore, when inflow to Lower Mahoney Creek is 120 cfs, the inflow to Upper Mahoney Lake would be about 44 cfs. To meet the ADFG flow condition of 120-200 cfs during upstream migration, the project would need to release at least 44 cfs. Because existing flows average less than 120 cfs in Lower Mahoney Creek in August and September (Table 4), the project would be required to release in excess of 44 cfs most of the time. Inflows to Upper Mahoney Lake during August and September are less than 44 cfs almost half of the time (Table 1). Additionally, with Saxman’s proposal, once the project is operating at full capacity based on the storage &/ The Upper Mahoney Lake watershed, including any spill flows from Upper Mahoney Lake, represents 36.8 percent of the Lower Mahoney Creek drainage area. Runoff into Upper Mahoney Creek, independent of Upper Mahoney Lake represents 11.8 percent. The runoff into Upper Mahoney Lake and the runoff into Upper Mahoney Creek together, then, make up 48.6 percent of the Lower Mahoney Creek drainage. 38 available in Upper Mahoney Lake, projected for the year 2017, some of the August inflows to Upper Mahoney Lake would be used to refill the lake. A 120-cfs minimum flow in Lower Mahoney Creek may require an adjusted refilling schedule for Upper Mahoney Lake. During low water years it would be necessary to limit project operations prior to August to try to maintain adequate storage to meet the minimum flow requirement in Lower Mahoney Creek. Under some conditions, it would be beyond the capacity of the project to release enough flow to maintain an instantaneous 120-cfs minimum flow in Lower Mahoney Creek, even if the water were available in Upper Mahoney Lake. We looked at the minimum instantaneous discharges for each August and September for the 27 years of record in Lower Mahoney Creek. Flows of 78 cfs from the project (maximum turbine output) would require at least 42 cfs from all other parts of the Lower Mahoney Lake watershed to reach a minimum flow of 120 cfs in Lower Mahoney Creek. For each August and September of record, instantaneous minimums in Lower Mahoney Creek fell below 42 cfs in 81 percent of the months, indicating that during low flow periods, even at maximum generation, the project could not maintain the 120-cfs minimum flow in Lower Mahoney Creek. When the project is shut down for maintenance or emergencies, turbine releases would not be possible. Flow releases when the project is not generating are discussed below under Flow Continuation. During naturally high flows it would be impossible for the project to prevent the flows in Lower Mahoney Creek from exceeding ADFG's 200-cfs maximum flow requirement because the project could reduce flows by only 78 cfs. Since the Upper Mahoney Lake and Upper Mahoney Creek runoff flows account for 48.6 percent of the flows in Lower Mahoney Creek, when flows in Upper Mahoney Creek reach 97 cfs, independent of any project influence, flows in Lower Mahoney Creek would exceed 200 cfs. Saxman’'s monitoring results from August and September 1994, showed two separate events, totaling 3 days, when flows in Upper Mahoney Creek exceeded 175 cfs (97 cfs plus 78 cfs) (Saxman 1995). During the early years of operation, while the project is operating at 57 percent of project capacity, based on available storage, Upper Mahoney Lake would be full during August and September; and after the project reaches full capacity, the lake is projected to be full by September 1. When Upper Mahoney Lake is full, spill flows could occur with any storm event. Spill flows and/or high runoff flows into the bypassed reach would make a 200-cfs maximum flow beyond the control of the project. By letter dated July 11, 1997, we asked. the ADFG to modify their conditions for a 120-cfs minimum flow in Lower Mahoney Creek during August and September to allow for a minimum flow from the project of 44 cfs, the project’s drainage area 39 proportion of 120 cfs in Lower Mahoney Creek, or the natural inflow to Upper Mahoney Lake, whichever is less. We also asked the ADFG to modify their condition for a 200 cfs minimum flow in Lower Mahoney Creek during August and September to allow for flow conditions beyond the control of the project. We proposed that the project not be operated during August and September when flows in Lower Mahoney Creek exceed 200 cfs except under two conditions: (1) there are spill flows from Upper Mahoney Lake that would cause the flows in Lower Mahoney Creek to exceed 200 cfs whether the project were operating or not; and (2) flow releases by the project are necessary to maintain the U.S. Fish and Wildlife Service’s (FWS) mandatory minimum flow requirement in Upper Mahoney Creek. In their August 11, 1997, response, the ADFG agrees with our recommendations for flows in Lower Mahoney Creek with the understanding that sufficient studies would be preformed prior, during, and after construction to better define fish passage requirements for the Lower Mahoney watershed. The ADFG would further require that any alternative flow regime established by the studies be implemented. We agree that the ADFG's modifications to their original condition are reasonable because all parties have agreed on the need for additional studies relating to salmon passage in Lower Mahoney Creek. We agree that adult salmon passage in Lower Mahoney Creek should be monitored for all salmon species through the first 3 years of operation and sockeye salmon for the following 7 years, or until the FS, the NMFS, the FWS, and the ADFG are confident that the project’s flow regime does not negatively affect salmon resources, whichever is longer. We don’t believe that an adequate index of abundance could be developed from the first 3 years of project operation because: (1) adjustments in the early years would be necessary to determine the best operational approach to maintain the mandatory flows; (2) emergents during the first year of project operation may not return to Lower Mahoney Creek as adults for 4 to 6 years; and (3) the project would be operating at 57 percent of capacity based on the available storage in Upper Mahoney Lake. The potential project effects on emergence timing are discussed below under Upwelling temperatures. We asked the FWS to modify their monitoring condition to allow for our monitoring recommendations without requiring Saxman to calculate and use an index of salmon abundance. Interior, in their August 12, 1997, response to our request to the FWS, agrees with our recommendation to monitor salmon passage without the use of an index of abundance. The ADFG’s 12-hour reporting condition would require earlier reporting than commonly required by the Commission. Because Saxman proposes no defined operational mode, however, flows through the project would vary unpredictably (see the section on 40 t is limited to . Also, upstream salmon movemen ecient reer igher than average flows. ere Ores) velssreee nevis Capential to maintain the project's eacere ze nBrobe a cae oe Ma tomey ore be required to report any violations of n be requir See ee itioes TEV Mahoney Creek, if they occur, within 12 hours. laska Department of ted August 21, 1997, the A mature! amoices (aDNR} commented on our flow recommendations for Lower Mahoney Creek. g with conditioning a minimum flow ee re eee ena proportion of the drainage aren Socauae the project would have the capacity to revenseter re eecaEace Fouts higher flows for limited periods of sa . ate ative the ADNR asks us to review the pre-projecey = h eel ic records for August and September to ae pee probabilities for the eae eee ee oxcaeieay canis par eastoe pereede ae es be waioreian at the historic flows in rate, frequency, and duration. The flow window for salmon passage has noe peenkderinaeis re however, Saxman's studies susseat cae owe rOnee Sea ee uate k allow passage. Seer ee man inegicceeks would correspond to project discharges into Upper Mahoney Creek of 44 and 74 cfs. i tt and September the average daily flows for Augus £ Mee raeees hydrologic record developed by Saxe OES aho ey Creek (described in the affected eny onan poreces Amuacie Resources section). We found chat aCe aoe En oa Creek, over 34 years, n ; veer at the time in August, and 45 percent in September Our review of the hydrologic record, however jtishowed that der existing conditions there is no pattern to Me Die wees eal icular range of flows occurs. Flows between Renae Aacee rT Scar unpredictably at anytime during August an are api dase from lees they | G8y 222 set, Meenetoy dates with , able to : aReustrer pentener Raraset the target flows consistent with historical patterns. j ith active storage, th the ADNR that a project w: ee oes higher than the instantaneous Se can Bein {imited eriods of time. Over time, though, the pro. ect icanion 3 1 as Unae, is available within its drainage noes prnedexte cS hich the drainage lel da be See eerec uses tor ae and the pr h ee eer eoiaod design would allow for 4,000 acre feet 41 of usable storage, which would provide a continuous 44 cfs flow lasting for 46 days and nights. We agree with Interior that minimum flows are necessary during the winter and spring months to Protect the sockeye eggs and alevins, making these priority seasons for any use of stored water. Maintaining adequate incubation conditions at the upwelling in Lower Mahoney Lake at all times is critical to reproductive success, while passage through Lower Mahoney Creek could be adequately maintained by selective flow adjustments for brief periods as directed by the on-site observers. Under existing conditions, spawners have only intermittent access to Lower Mahoney Lake. During low water years the natural inflow for August to Upper Mahoney Lake would average less than 44 cfs. Any required release of 44 cfs would have to use the stored water. Because the winter need for stored water is also greater in low water years, a continuous flow of 44 cfs in August and September could take water that would be needed during the winter months. We continue to believe that flow requirements based on drainage area proportions provide the best approximation of existing conditions. Releasing a minimum flow of 44 cfs, whenever it is available as instantaneous inflow to Upper Mahoney Lake, would provide a minimum flow of 120 cfs in Lower Mahoney Creek just as it does under existing conditions. If the instantaneous inflow to Upper Mahoney Lake falls below 44 cfs, then the flows in Lower Mahoney Creek would not reach 120 cfs even if there were no project. The minimum flows for salmon passage would be provided as closely as possible to existing conditions, maintaining the probabilities of the minimum flows for salmon passage that occur under existing conditions. Flow continuation. When the Project is shut down for emergencies or routine maintenance, flows below the powerhouse would decrease, potentially dewatering incubating salmon eggs and alevins. Saxman proposes to construct a 12-inch- diameter flow continuation pipeline between the valve house and Upper Mahoney Creek that would allow up to 10 cfs to be released into the bypassed reach about 1,500 feet downstream of Upper Mahoney Lake during long-term shutdowns. During emergency and short-term shutdowns, flows at the powerhouse would be reduced to the minimum turbine capacity (8 cfs) and a flow deflector would redirect flows past the turbine and into the tailrace. The ADFG has submitted a condition that the project incorporate a fail-safe and redundant back-up system to ensure that flows are provided during routine maintenance periods and emergency shutdowns. The ADFG believes that the Proposed 12- 42 inch-diameter pipeline may be inadequate to meet this requirement. Saxman has agreed to accept the ADFG’s condition regarding the flow continuation pipeline. Staff Analysis Based on drainage area, the portion of Upper Mahoney Creek that would be bypassed by the project contributes about 24 percent of the flow below the proposed tailrace site, and the Upper Mahoney Lake watershed, which would be regulated by the project, contributes about 76 percent. If the minimum flow in Upper Mahoney Creek was 5 cfs, as Saxman proposes, then the project would have to provide 4 cfs most of the time (76 percent of 5 cfs). If the minimum flow was set at 13 cfs, as submitted by the FWS, the project would have to provide 10 cfs most of the time. Under existing conditions, however, the bypassed reach flow can fall below 1 cfs during very low flows, which would require the pipeline to convey more than the project's proportion of any established minimum flow to maintain the minimum flow requirement. The proposed capacity of the pipeline would be adequate to convey a 5-cfs minimum flow, but not a 13-cfs minimum flow. The ADFG's modified minimum flow condition for Lower Mahoney Creek would allow for minimum project flows up to 44 cfs. We agree that a flow continuation pipeline adequate to maintain any required minimum flows in Upper and Lower Mahoney Creeks would best protect aquatic resources during project shutdowns. Therefore, we recommend that the capacity of the flow continuation pipeline be adequate to maintain any minimum flows required of the project. Minimum flow requirements for the project are discussed in the Minimum flows in Upper Mahoney Creek and Lower Mahoney Creek fish passage sections. Mode of operation. Sockeye salmon characteristically spawn along lake shores where upwelling water provides circulation through the redds (nest depressions), stable flow conditions, and protection from freezing (Groot and Margolis 1991). Fluctuating flows may dewater redds and disrupt spawning salmonids. Saxman’s Proposal Saxman proposes an unrestricted mode of operation. Neither the FWS nor the ADFG have submitted conditions on the mode of operation for the project. The ADFG, however, has submitted a condition that the project design and operations include remote monitoring and operation of all project components. As proposed, the project could be operated as load following or base loading. With load following, or 43 peaking, flows through the project could change instantaneously between 0 to 78 cfs several times during a 24-hour period according to the energy demand, as long as any flow requirements for Upper and Lower Mahoney Creeks are met. With base loading, flows through the project may be constant for periods as long as a week, with one or two daily fluctuations that would be smaller than with a peaking operation. Saxman could operate the project in either mode at different times. Further, when the upper lake is drawn down, the project could operate with only the inflows to Upper Mahoney Lake. Upper Mahoney Creek downstream from the proposed tailrace site has a gravel, cobble, and boulder substrate, with deep pools and three major log jams producing three falls from 3 to 6.5 feet in height. About 300 feet upstream from Lower Mahoney Lake, the stream splits into two branches with lower gradients and gravel substrates. The outlets of the two branches form the gravel delta used by sockeye salmon. It appears that the channel features would attenuate flow fluctuations due to project operations, moderating any potential affects in the upwelling areas. Since Saxman would not be restricted to one mode of operation, however, it would be beneficial to monitor flow fluctuations so that we can understand what the operational effects are on sockeye spawning and incubation and have the information available to address any concerns about peoject operations. We believe that any effects could be determined from the data collected by the ADFG’s required monitoring programs with little additional cost. The ADFG would require Saxman to continuously record discharges and temperatures, and conduct spawning surveys at the outlet of Upper Mahoney Creek, as discussed in the Minimum flows in Upper Mahoney Creek, Lower Mahoney Creek fish passage, Upwelling temperatures, and Streamflow gaging sections. Therefore, we recommend that Saxman, in consultation with the FS, the NMFS, the FWS, and the ADFG, develop a plan, for Commission approval, to evaluate any effects from flow fluctuations caused by the project on the spawning and incubation of sockeye salmon below the project. If any adverse effects to sockeye spawning or incuisation from flow fluctuations are found, we recommend that Saxman consult with the resource agencies to develop a plan to remedy the adverse effects and submit it to the Commission for approval. Saxman would fully automate the project. All plant functions and equipment conditions would be monitored remotely using a System Control and Data Acquisition (SCADA) system. If problems arise, the project would be shut down automatically and the project operator in Ketchikan would be notified by a telephone autodialer. We agree that a remotely monitored and operated project would help protect aquatic resources and 44 recommend that Saxman implement the automated features as proposed. Streamflow gaging. Gaging is necessary to ensure compliance with any flow requirements. p Saxman proposes to leave in place for the duration of the project, the streamflow monitoring devices they've installed: (1) a continuously recording streamflow gage installed in June 1994 in Upper Mahoney Creek near the proposed tailrace site; and (2) a continuously recording stream depth monitor installed in July 1995 in Lower Mahoney Creek about 165 feet downstream from Lower Mahoney Lake. The ADFG has submitted a condition that instantaneous flow discharges be monitored continuously, according to standards established by the USGS, in Upper Mahoney Creek, within 75 feet downstream of the tailrace and in Lower Mahoney Creek. The ADFG has also submitted a condition that mean daily and continuous discharge data, in documented electronic format, including the basis for any regression calculations, be submitted for both sites to the ADFG and other interested parties, monthly for the first year of operation and annually after the first year. Saxman has agreed to accept the conditions of the ADFG regarding streamflow monitoring and data reporting. We agree that discharges should be monitored in both locations to ensure compliance with any required flows, and to determine the best operational strategies to minimize any project effects on the sockeye salmon in Lower Mahoney Lake. Upwelling temperatures. Changes to the temperatures of upwelling groundwater could affect the emergence timing of fry since the rate of development of incubating salmon eggs and alevins is dependent on temperature. fe Saxman proposes to continue a temperature monitoring program begun in June 1994 that continuously records lake water and intragravel temperatures at two locations in the spawning area of Lower Mahoney Lake at the outlet of Upper Mahoney Creek, through construction, and for at least 3 years after the project begins operating. The FWS has submitted a condition 7/ that Saxman continue pre-construction temperature monitoring in the Upper Mahoney Creek delta area through the first 3 years of project operation to determine the project's effects on sockeye egg incubation, and 2/ From Saxman’s “Mahoney Lake Hydroelectric Project Aquatic Resources Monitoring Plan” sent to the resource agencies on May 9, 1996. 45 correlate temperature monitoring data with powerhouse discharge to examine the relationship between the project’s flow and water quality in the upwelling. The ADFG has submitted a condition that Saxman measure intragravel water temperatures from a minimum of five locations throughout the spawning area at the outlet of Upper Mahoney Creek, and submit the data monthly to the ADFG and other interested parties, in documented electronic format, for the first year of operation and annually after the first year. The ADFG has also submitted a condition that if, during project operation, the water temperatures in Upper Mahoney Creek vary from the range of measured pre-project values and is determined by ADFG to pose a potentially negative effect on the spawning, incubation, and/or rearing of sockeye salmon in Lower Mahoney Lake, Saxman would have to formulate and implement an ADFG approved biotic monitoring plan to address any potential effects. Saxman has agreed to accept the conditions of the FWS and the ADFG regarding temperature monitoring and data reporting. Ketchikan Public Utilities recommends that a study be conducted to measure any effects on water temperature and DO, because project-related temperature increases may adversely affect spawning fish. Upper Mahoney Creek cascades over many waterfalls, thoroughly mixing the water with the surrounding air. This action causes stream temperatures at the proposed tailrace site to closely correspond to the air temperatures. Flows released from Upper Mahoney Lake through the project would have temperatures corresponding to the water temperature at the project intake, rather than the water temperatures in Upper Mahoney Creek. Saxman’s temperature monitoring shows that air temperatures influence the Upper Mahoney Lake water temperatures up to depths of about 20 feet. When the surface of the lake would be 20 feet or more above the intake the water temperature at the intake would be 4° C. When the surface of the lake would be within 20 feet of the intake, the water temperature at the intake would be about the same as the air temperature above the water. Therefore, at drawdowns within 20 feet of the intake, the tailrace water temperatures would correspond more closely to natural temperature fluctuations seen in Upper Mahoney Creek and the spawning gravel. Initially the project would operate at 57 percent of project capacity based on available storage in Upper Mahoney Lake, and Upper Mahoney Lake levels would remain higher than 20 feet above the intake year-round. At full capacity, projected for year 46 2017, the lake levels are projected to be within 20 feet of the intake during March and April in average and high water years, and from January through May in low water years. The average monthly temperatures in the spawning gravel at the outlet of Upper Mahoney Creek (Figure 1) under existing conditions drop from about 12°C to about 4° C from August to late November. Intragravel temperatures range from 0.5° C to 3° C from late November through May, reaching about 8°C in June. In Lower Mahoney Lake, sockeye salmon spawn from mid August through late September, with the peak probably occurring in mid- September. Emergence occurs during May and June. The accumulation of temperature units or degree days 8/ from the time of egg fertilization determines the time of fry emergence from the gravel. Relatively small changes in the water temperature regime can cause significant variation in hatching and emergence times when accumulated over a period of months. Table 5 shows the estimated degree-day accumulation within the spawning gravel starting from September 1 and October 1 (representing late spawners) for the estimated average existing temperatures and for the predicted post-project temperatures. If the post-project estimate results in fewer degree days accumulated by June 30 than under pre-project conditions, the post-project time to emergence would be longer because more days would be needed to accumulate enough degrees for development. Conversely, if more degree days are accumulated through June 30, then emergence would be earlier. Table 6 shows, in calendar days, the estimated increase or decrease in the average post-project incubation periods from the pre-project averages. To calculate the post-project calendar days, we divided the cumulative degree days for a given period in Table 6 by the number of calendar days in the same period to reach an average number of degrees per day. This daily average was then divided into the difference in the number of degree days between the pre-project and post-project estimates. 8/ A degree day represents the number of degrees above 0° C for a 24-hour period. For example, if the water temperature for the first day of incubation is 8° Cc, it would contribute 8 degree days. 47 Table 5. Estimated cumulative degree days during salmon incubation (Saxman 1996). Estimated cumulative degree days at predicted post-project gravel temperatures Estimated cumulative ree xr Mahoney Lake days at sicetar Uppe! levels higher than Upper Mahoney Lake 20 feet above the evels within 20 sxever intake feet of the intake eon een eee r_around in the sprii Avg. 1 to a 1266 637 Oct. 1 to Sensis 946 398 Table 6. Staff-estimated change in average emergence time in calendar days after the project is operational based on Table 5 data. e levels’ upper Mahoney Pre-project # po a etic se tak incubation period the intake of the intake year-round in the spring Sept. 1 to June 30 33 day increase 50 day increase Oct. 1 to June 30 4 day decrease 12 day increase During the early years of project operation, we calculate that the average incubation period could be as long as 33 additional calendar days, and as long as 50 additional calendar days once the project is at full capacity. Salmon fry that emerge in June under existing conditions could emerge in July or August, after operations begin. Fry that have not emerged by August could be displaced by the next year’s spawners. Because spawning occurs during a period when natural water temperatures are falling, eggs from early spawners are exposed to warmer initial conditions than late spawners. Once the project 48 is operational, the early spawners would receive colder water earlier in the incubation period than under natural conditions. Altered conditions early in the incubation period would not affect late spawners, and may be the reason that the estimated cumulative degree days for late spawners are closer to the estimated existing degree days. Incubating sockeye eggs and alevins have some ability to compensate for changes in temperature regimes (Groot and Margolis 1991). Such adaptations allow the sockeye to emerge at the same time each year even though the natural temperatures vary from year to year. It is unknown, though, to what extent the sockeye in Lower Mahoney Lake would be able to compensate for the altered temperature regime. Natural selective pressures work to adjust the life histories of individual salmon populations to favor emergence at the optimum time for survival (Groot and Margolis 1991). If emergence is early, it may occur before enough food is available. With late emergence, their smaller size may result in the fry being more susceptible to predation and competition for food from other species. Either early or late emergence, if realized, could affect the survival of the Lower Mahoney Lake sockeye resource. The range of minimum to maximum post-project estimated cumulative degree days for proposed drawdowns at 57 percent and full capacity, based on available storage in Upper Mahoney Lake, would fall within the estimated range of pre-project cumulative degree days. (For example, from Table 6, the estimated time to emergence for an incubation period starting September 1 under existing conditions ranges from 637 to 2,260 cumulative degree days. All corresponding post-project emergence estimates are between 637 and 2,260.) The average days to emergence; however, are estimated to shift significantly (Table 7). A shift in the average emergence timing may indicate that a significant number of individuals are emerging at a less optimal time. Historical observations indicate that the number of sockeye salmon spawning in Lower Mahoney Lake may have declined substantially over the last 40 years for unknown reasons. If so, it would be difficult to separate the project's effects from any other factors affecting the Lower Mahoney Lake sockeye resource. Long-term effects to the temperature regime within the spawning gravels at the outflow of Upper Mahoney Creek would be unavoidable. We would prefer to see emergence timing monitored for an earlier indication of the project’s effects, if any, on the sockeye than could be obtained by monitoring the returning adults 4 to 6 years later. Further, since there may be other factors affecting the number of sockeye salmon in Lower Mahoney Lake, we believe that emergent monitoring at the South Creek 49 spawning area would better identify whether any effects on the sockeye were project related or from other factors. The ADFG may require biotic monitoring if post-project temperature data vary from pre-project ranges, but has not specified whether the range of temperatures would be calculated by daily, monthly, seasonal, or other time periods, whether temperature averages or extremes would be used, or how any effects on the sockeye resource would be determined. We asked the ADFG to modify their condition to allow for Saxman in consultation with the FS, the NMFS, the FWS, and the ADFG, to define the methodologies, and submit them to the Commission for approval. The ADFG concurs with our request, and recommends that Saxman and the agencies meet on a scheduled basis, at least once a year to review study results and identify courses of actions required based on those results. We agree with the ADFG that an ongoing program to review and address the study results is reasonable, and recommend its adoption. As water temperatures increase, the water loses its capacity to absorb oxygen from the atmosphere, resulting in lower DO concentrations. Intragravel DO concentrations of 8 ppm are needed to protect early life stage salmonids (Environmental Protection Agency 1986). DO concentrations of 8 ppm or higher could be maintained when intragravel water temperatures equal 26° C or lower (Cole 1983). Under existing conditions, intragravel temperatures reach about 15° C (figure 1), while the highest estimated temperature with the project would be 7° C. With or without the project, water temperatures at the site would remain cold enough to protect against low DO conditions. Therefore, we don't believe that DO monitoring is needed. Fisheries surveys. The ADFG requests that fisheries surveys be conducted in all waters potentially affected by the project. The ADFG asks to review the procedures and schedule for the surveys, and to participate in the onsite sampling. The ADFG’s concern is whether a 1977 survey by the FWS accurately concluded that no Arctic grayling survived the 1966 introduction in Upper Mahoney Lake, because the survey methods were not detailed in Saxman’s reference citing the survey results. 9/ As part of the application process, Saxman conducted fisheries surveys of Upper Mahoney Creek, Lower Mahoney Lake, and Lower Mahoney Creek, and incorporated the results of prior surveys from an environmental evaluation of the Mahoney a/ Saxman’s reference is a letter from Gary L. Hickman, Assistant Area Director, Alaska Area Office, U.S. Fish and Wildlife Service, Anchorage, Alaska to Colonel George. R. Robertson, District Engineer, Alaska District, Corps of Engineers, Anchorage, Alaska, dated January 23, 1978. 50 Lakes drainage for hydropower in the late 1970's by the Corps. The methodologies and findings for the surveys conducted by Saxman are documented in Appendix D of Saxman’s application. The results of the FWS‘s 1977 fisheries surveys of Upper and Lower Mahoney Lakes were documented in the 1978 letter from the FWS to the Corps. Saxman provided copies of the FWS letter to the ADFG and other interested parties as part of the final consultation document (Saxman 1994) for Saxman’s proposed project. The ADFG and other resource agencies, while participating in the consultation and scoping process, did not request additional fisheries surveys. 10/ No new information has been provided by any party that would indicate the need for new fisheries surveys or raise questions about the results of the surveys that have already been conducted by the FWS or Saxman. Therefore, we don’t believe that additional fisheries surveys are necessary. Access to project facilities. The ADFG has submitted a condition that Saxman provide sufficient resources for an onsite representative of the ADFG to monitor the project during construction and inspect the project once per month when it is on line. Saxman has agreed to accept the conditions of the ADFG regarding onsite access of personnel from the ADFG. Staff analysis We agree with ADFG’s condition to allow agency personnel access to project facilities to the extent that the inspections are not to determine compliance. Allowing state agency personnel access to the project site for the purpose of reviewing the project's operation and facilities as they relate to fish and wildlife measures, would provide the Commission, Saxman, and the resource agencies with valuable information. It could also assist the Commission to carry out its responsibilities for monitoring the effectiveness of the recommended measures. The Commission, however, would determine compliance with any license terms and conditions. Because of ately reasons and property liability, we believe appropriate notification must be given to Saxman prior to any site visit. Regular visits by Saxman during construction and operation would be required to attend to the project facilities. We 10/ During the scoping process Saxman solicited requests for additional studies. Responses were received from the ADFG (letter from Jack Gustafson, Area Habitat Biologist, Alaska Department of Fish and Game, Ketchikan, Alaska, May 11, 1995) and the FWS (letter from Nevin D. Holmberg, Field Supervisor, U.S. Fish and Wildlife Service, Juneau, Alaska, May 19, 1995). Neither agency requested fisheries surveys. 51 believe that an ADFG representative could accompany Saxman’s representative at little additional cost. Therefore, we recommend that Saxman provide sufficient resources for onsite visits as required by the ADFG. Lower Mahoney Lake levels. Seasonal fluctuations in the discharge from Upper Mahoney Creek resulting from project operation could affect the surface level of Lower Mahoney Lake. g Saxman proposes to alter the existing outflow from Upper Mahoney Lake so that post-project flows into Lower Mahoney Lake could be higher than pre-project flows during the periods when Upper Mahoney Lake is being drawn down, and lower than pre-project flows while Upper Mahoney Lake is being refilled. The resource agencies did not submit any conditions regarding Lower Mahoney Lake levels. During periods when Upper Mahoney Lake is spilling or being drawn down, any increased flows to Lower Mahoney Lake would flow through the uncontrolled outlet into Lower Mahoney Creek. Since Saxman would operate the project to control Lower Mahoney Creek flows as much as possible during August and September to allow upstream salmon migration, we don’t believe that project related high flows could adversely affect the water levels in Lower Mahoney Lake. Under existing conditions, the estimated lowest average monthly flow in dry water years is 11 cfs, or 22 acre-feet per day. Once project operation begins, the lowest flows would occur in low water years after the project has reached full capacity based on available storage in Upper Mahoney Lake, during periods when Upper Mahoney Lake is refilling, and no flow is being released through the turbines. With the FWS’s minimum flow requirement, the lowest minimum flow most of the time would be 13 cfs, or 26 acre-feet per day. The project-related difference in inflows to Lower Mahoney Lake would average about 4 acre-feet per day. With Saxman’s 5-cfs minimum flow, or 10 acre-feet per day, the project related difference in inflows to Lower Mahoney Lake would average about 11 acre-feet per day. With either minimum flow, the reduction in inflows would be so small compared to Lower Mahoney Lake’s volume of 20,400 acre-feet, that we don’t believe any project related adjustments to flows could adversely affect the water levels in Lower Mahoney Lake. Unavoidable adverse impacts: None. 52 3. Terrestrial Resources Affected Environment : Vegetation. The primary vegetative habitat types in the project area are the Sitka spruce/western hemlock forest association, western hemlock/red cedar forest association, subalpine wet meadows, shrub thickets in disturbed areas, muskegs/shore pine forest association, and riparian forests. The two dominant forest types, the spruce/hemlock and hemlock/red cedar complexes, share similarities: they have old growth and mature characteristics that are common to southeast Alaska; can occur on poorly-drained, weakly-developed soils that are subject to flooding; may be found on steep slopes of mineral or organic substrates; and are climax or near climax communities (Viereck et al. 1992). Upper Mahoney Lake, at elevation 1,959 feet mean sea level, and the site downstream of the upper lake where tunnel construction is proposed, are in the subalpine vegetation zone. Where slopes are stable enough for vegetation to become well established, they support scattered conifers, often in krummholz form 11/, with a dense low shrub and herb cover. Alder and salmonberry thickets occur in sites that are recently disturbed by slope instability, snow avalanches, or dynamic creek channels. Mature forests surround much of the lower lake and dominate the access road and transmission line routes. At low elevations, the forests on these sites are dominated by western hemlock and western red cedar. On better drained sites, including some steep slopes and on alluvial fans, the forests are dominated by western hemlock and Sitka spruce. These forests share many understory species with the less well-drained forests. Alaska yellow cedar and mountain hemlock become prominent in the forests as elevation increases. Upper Mahoney Creek below the proposed powerhouse site flows across an alluvial fan. Its substrate and vegetation are disturbed in sites nearest the creek by flooding, sediment deposition, and shifting channels. The forest on this alluvial fan is dominated by tall Sitka spruce and western hemlock and is highly productive. Red alder trees are adjacent to the active stream channels and the understory is dominated by salmonberry in the more recently disturbed areas closer to the stream, and by Devil's club and blueberry on less disturbed sites farther from the stream (DeMeo et al. 1992). Other riparian habitats in the project area are very narrow because of the steep adjacent slopes. /, Krummholz represents scrubby, stunted trees often forming a characteristic zone at the limit of tree growth in higher mountains. 53 Wetlands. The maritime climate in southeast Alaska largely influences the diversity of lush vegetation and causes wetland habitats to be pervasive on Revillagigedo Island. The National Wetland Inventory map (Ketchikan B-5, Alaska; scale 1:63,360) shows extensive forested and muskeg wetlands in low-elevation areas of the project area. Because of: (a) the abundant rainfall in the project area, (b) impeded drainage due to shallow bedrock near the surface, (c) compacted glacial till substrate, and (d) saturated soils that may have anaerobic conditions, most of the forested sites in the project area meet the definition of wetlands. 12/ The three general types of wetlands in the project area are: wet western hemlock/red cedar forests, muskegs and shore pine forests, and subalpine wet meadows. These wetland types are described in detail in Appendix F of the Application for License. Western hemlock/cedar forest occurs along much of the access road route and most of the transmission line route. These sites are kept wet by downslope drainage that is prevented from infiltrating by shallow bedrock or till. Their most important functions are for wildlife habitat, although many of the habitat qualities are not directly related to the wet character of the land. The wet hemlock/cedar forests provide seasonal or year- round forage for a variety of species including deer and bear, and the more closed stands provide thermal cover important to deer in winter. Because surface water runs through these areas, exported detritus supports downstream food webs. Similar to upland forest vegetation, these wetland forest plants also shade creeks and help maintain cool water temperature, provide cover for fish, and deposit detritus into the channel. Muskegs are an open habitat dominated by mosses, low shrubs, sedges, and herbs. On their edges they blend into shore pine forests mixed with red cedar. The most important ecosystem functions of this type of wetland are their ability to help protect water quality and provide edge habitat for wildlife. These wetlands provide early spring and summer forage for deer, berries and other forage for black bears, deer fawn birthing 12/ Wetlands are generally defined as lands transitional between terrestrial and aquatic systems where the water table is usually at or near the surface, or the land is covered by shallow water (Cowardin et al. 1979). Wetland ecosystems are lands where water saturation is the dominant factor that determines the nature of soil development and the types of plant and animal communities living in and on the surface. Wetlands must: (1) predominantly support hydrophytic vegetation, (2) have predominantly undrained hydric soils, and/or (3) be saturated with water at some time during the growing season of each year. 54 areas, shrubby edge habitat for breeding and feeding of songbirds, nesting habitat for water birds, and corridors for relatively easy winter travel for predators. Muskegs occupy many sites within the project area that are not steeply sloped, including small ponds having aquatic plants. Subalpine wet meadows are watered by seepage from upslope and by rivulets running through them. The vegetation is primarily herbaceous, dominated by sedges and flowering forbs. The important functions of the subalpine wet meadows are providing wildlife habitat and supporting biodiversity by harboring rare plants. Two FS sensitive species, the choris bog orchid and the goose grass sedge, have been documented in wetlands near the upper lake and the upper tunnel construction site. Herbs in these meadows provide summer forage for various wildlife. Wildlife. The project area supports a diversity of animal species. This includes the Sitka black-tailed deer and mountain goat, which are the only ungulates in the project area. In environments like southeast Alaska, it has been shown that deer prefer the quality understory forage of old growth forest and that the carrying capacity of this habitat type exceeds that of early successional stages (Wallmo and Schoen 1980). Winter range for the Sitka blacktails lies in the old growth forest north of Lower Mahoney Lake, and also to the south along the proposed transmission line route. Fifteen mountain goats, transplanted to the Upper Mahoney Lake area in 1991, have adapted well. Radio telemetry observations show that the animals are scattered throughout the high peaks to the south of the project site. The highest concentration of observations was on a ridge just northwest of Lower Mahoney Lake. A small group of radio-collared mountain goats is located just north of a small wet meadow near the proposed upper tunnel construction area. In southern southeast Alaska where snows are wet and may not blow off ridges, mountain goats use timbered areas for foraging as alpine areas become buried in the winter (Fox et al. 1989). In the spring, mountain goats feed on shrubs and forbs in south-facing avalanche chutes. They move up to subalpine and alpine habitats as soon as snowmelt allows (Fox et al. 1989, FS 1991). Black bears are common in the project area but are not abundant. Because their preferred habitat is forest openings with berries, grasses, and succulent forbs, black bears are mostly limited to foraging in muskegs near the project area. Several members of the weasel family that live in the project area include the pine marten, mink, and river otter. Beaver live in Lower Mahoney Lake using alder, willow, and cottonwood as forage and building material. Other rodents in the area include squirrels, voles, and mice. Shrews and bats also live in the project area. 55 The Mahoney Lakes do not attract many waterfowl or ocean going seabirds; however, these species occur in George Inlet at certain times of year. Shorebirds and marsh species could be found around lake shores or in muskeg areas and the American dipper is common along the shores of Lower Mahoney Lake and Lower Mahoney Creek. The intertidal delta at the mouth of Lower Mahoney Creek could be used by many varieties of gulls, shorebirds, and waterfowl as both residents and migrants. Gallinaceous birds in the project area include blue grouse, spruce grouse, and rock and willow ptarmigan. Grouse inhabit forest environments with shrubby understories or open areas for foraging. Raptors in the project area include the sharp-shinned hawk, merlin, American kestrel, red-tailed hawk, great gray owl, boreal owl, and great horned owl. Mature forests provide habitat for a variety of songbirds, some of which are specialized for old- growth conditions, such as the northern three-toed woodpecker, ruby-crowned kinglet, and Townsend's warbler. Riparian and other shrubby habitats are used by vireos, flycatchers, and thrushes for foraging and nesting. Savannah sparrows use muskegs and other open, partially shrubby habitats. Although federally listed as threatened in the lower 48 conterminous States, the bald eagle is common throughout southeast Alaska, and is not listed in the state as threatened or endangered, nor is it a candidate for listing. This species requires tall trees close to water as nest sites and perches. The FWS has identified two occupied bald eagle nests located north of Lower Mahoney Lake (letter from M. Jacobson, Eagle Management Specialist, U.S. Fish and Wildlife Service, Juneau, Alaska, to HDR Engineering Inc., Anchorage, Alaska, June 29, 1994) and along the shore of George Inlet, 840 to 4,300 feet from the existing forest road. A survey in July 1995, located an inactive eagle nest southeast of Lower Mahoney Lake within about 200 feet of the proposed transmission line centerline. Environmental Impacts and Recommendations: Vegetation Construction Constructing the project would both directly and indirectly affect vegetation at the project site. ig No mitigation measures have been proposed and no conditions or recommendations have been filed on vegetation impacts. However, Saxman's ESCP does include measures for revegtating areas disturbed by project construction. The calculated acreages that would be directly and indirectly affected by project construction are shown in Table 7. A total of 99.4 acres would be permanently eliminated or altered by constructing and operating the project, 56 and an additional 77.1 acres would be indirectly affected. 13/ Clearing of project area vegetation could also result in increased runoff from cleared sites. Saxman's proposed ESCP describes measures for minimizing erosion and runoff, and we discuss them in the Geology and Soils section. We don't believe that any mitigative measures beyond what Saxman is proposing are needed for the project because: (1) clearing would be kept to a minimum; (2) most disturbed sites would revegetate naturally, and Saxman has included revegetation measures in their ESCP; and (3) the transmission line right-of- way would be maintained in the shrub and sapling stage for the duration of the license. Operation e No mitigation measures have been proposed and no conditions or recommendations have been filed on vegetation impacts during project operation. The water table on some shallow slopes next to Upper Mahoney Lake may vary with the lake's surface elevation. Lake drawdown may result in drying of these habitats but, if it does, it would probably only affect areas within a foot or two of the ordinary high lake surface elevation. A drawdown is proposed from about November through July. Any soil moisture fluctuations would likely cause changes in the plant communities. Upper Mahoney Creek from the upper lake outlet to the tailrace (Figure 2) would be largely dewatered each year from about November through July because there would generally be no outflow from the upper lake during that period. Some plant species in this drainage might change immediately adjacent to, and in the creek as a result of the seasonal reduction of this water source. The steep rocky sites in the spray zone of the waterfall would also be deprived of some water for the early part of each growing season. However, changes in this portion of the creek would be small and of little consequence to vegetation or wildlife resources. Therefore, we are not recommending any mitigation measures. Wetlands Various project components would be located in, or would indirectly affect wetlands (see Table 7). 13/ Indirect impacts are those effects in adjacent forested and non-forested areas from project clearing and construction, such as increased light penetration and altered forest community. S77, if Because of the extent of wetlands in the project area, wetland impacts could not be entirely avoided. Saxman states that the project design includes many measures to minimize wetland impacts including avoiding impacts, minimizing effects that cannot be wholly avoided, and compensating for unavoidable adverse consequences. Thus, the road would be constructed to a width sufficient for only a single vehicle, with passing areas to accommodate two-way traffic. Only the minimum width of vegetation would be cleared to allow construction of the road (and transmission line where they are parallel). Culverts under the access road would be sized and placed to maintain existing surface water drainage patterns to the extent possible. Grubbing of existing vegetation would occur only within the footprint of permanent structures, thus minimizing soil disturbance in areas cleared for construction and in the transmission line corridor. The overhead transmission line route would be cleared and the line installed using helicopter transport. Soil disturbance for constructing the line would be limited to placement of poles. The fill pad for the switchyard would be no larger than necessary to accommodate the structures and operations. No conditions or mitigation recommendations have been filed on wetlands impacts. Project construction is expected to permanently eliminate or alter about 48.8 acres of western hemlock/cedar forest wetlands, about 1 acre of subalpine and shrub thickets, 3.1 acres of muskeg/open shore pine forest wetlands, and about 0.9 acre of subalpine wet meadows. There would also be an additional 49.7 acres of hemlock/cedar wetlands indirectly affected from disturbance. 14/ About 0.4 acre of subalpine meadow would be affected by drawdown of Upper Mahoney Lake during project operation. Project components that would primarily be sited in wetlands are linear features, such as the access road and transmission line, that could not be substantially re-routed. The switchyard site, which is in a muskeg, was chosen because it is the closest site to the powerhouse deemed safe from potential damage by avalanches. The proposed switchyard would require widening of the existing road and would cover a minimal area. Part of the upper spoil disposal site, resulting from the upper tunnel construction, would be sited in a subalpine wet meadow. Disposal of this material in uplands does not appear practical because of the lack of accessible uplands and cost. 14/ Wetland forests adjacent to cleared areas would experience dense understory growth because of increased light penetration. 58 Table 7. Terrestrial habitat types directly and indirectly affected by the project (Saxman 1996). is fewer oaereem Jarmpem me Pt typnel cpnatruction gubalpine conifer iki site, valye house est and s. BeRES BEAEE access thicker thicket Rowerbouges, eesameee e(weste: ck Fores: lower spoil disposal a sekrPseezt Eeteeetecty tise, persee(™pstere Bevezpousg to) forest penlsck/rea cedar ‘ores! ski shore pine ‘Or’ Se/ . switchyard guskeg/shore pine ks he galeehyacdto existing | Porese/ "nore Pine forest road penlsch/rea cedar orest Sitka BERGER" PSEeee elgsttss} sz 5 ~ o x ° 5 ° 9 = A ° » » ¥ & a jenigck/red cedar Sitka fEntoek"Porest 59 Most of the access road and buried electrical transmission line from the powerhouse to the switchyard, the switchyard itself, and the road from the switchyard north to the existing access road would be located in forested and muskeg wetlands. These project components would eliminate some wetland areas and alter the vegetation of adjacent cleared wetlands, particularly in the forested areas. The overhead transmission line would traverse forested wetlands for much of its route, causing a change in the forest and adjacent site vegetation as the route is cleared and maintained. Installation of the access road and switchyard would minimally reduce runoff detention abilities of muskegs and wetland forests. Wildlife habitat qualities of forested areas would be lost and altered as early and mid-successional vegetation types would be cleared. Stream shading (primarily along Lower Mahoney Creek) would also be lessened where clearing occurs. We conclude that because of the extent of wetlands in the project area and project design features to minimize wetland loss, upland alternatives for locating project components are not available or practicable. Further, the wetland acreage that would be affected by the project is minor when compared to the overall extent of wetlands on Revillagigedo Island and in the project vicinity. The subalpine wet meadows along Upper Mahoney Lake's shoreline support a sensitive orchid that could be affected by lake drawdown for part of the year. The effect on this plant by the project is described in the Threatened and Endangered and Sensitive Species section of this EA and in the Biological Evaluation for Plants (Leggett 1995). Wildlife Construction Construction-related noise and human activity could temporarily displace mountain goats, deer, black bear, marten, grouse, waterfowl, raptors and perching birds. These animals may be forced to relocate into habitats that may not be suitable. Certain construction noise effects, such as equipment use and blasting could interrupt nesting or mating. Few species, if any, habituate to repeated loud bursts of noise. Such impacts are not expected during project operation because the project would be fully automated and remotely operated thereby requiring much fewer people on-site. Mountain Goats g Saxman states that human disturbance to mountain goats could be decreased by avoiding flying over the ridge to the northwest of Lower Mahoney Lake that is frequently used by goats. 60 To protect parturient nannies and newborn kids, an ADFG condition would require that surface blasting activities not occur between May 15 and June 30. Subsurface blasting, however, would be allowed during this period unless such activities are shown to be having adverse effects on these animals. In addition, an ADFG condition would limit air traffic to a 0.5- mile-wide corridor centered on the project area to limit effects on mountain goats of all life stages. The ADFG condition would also require that known mountain goat habitats on Mahoney Mountain, John Mountain, and Fish Mountain, be avoided at all times by project aircraft. Saxman agrees to these conditions. Chadwick (1983) reports that mountain goat populations are more sensitive to disturbances than any other big game species in North America. Because mountain goats are particularly sensitive to human-caused noise, such as low level helicopter flights during the kidding period, we believe that minimizing potential disturbance to mountain goats is prudent. Therefore, we recommend that the ADFG conditions on avoiding mountain goat disturbance be included in any license that is issued for the project. Clearing of forested habitats in lower elevations would not occur where goats are known to winter. However, about 0.8 acre of goat forage would be unavoidably lost in the subalpine wet meadow near the upper tunnel from construction activities. This meadow would be permanently covered by the upper spoils pile. The remainder of the disturbed construction site would be revegetated. Black bear. In addition to increased human activity and associated noise, project construction would also generate waste that may increase human-bear conflicts. fe Saxman states that their construction plans would include measures to safely store refuse to discourage potential nuisance black bear behavior which could result in bears being destroyed. We agree and recommend that plans be developed for the appropriate handling and disposal of food and garbage to discourage bear-human encounters and otherwise discourage wildlife habituation toward people. Marten and other small mammals. The project could result in loss of marten den sites in cleared old growth forest. However; the expected acreage lost is relatively small and marten populations in the area are low enough for adjacent habitat to absorb any displaced individuals. Small mammal populations in the project area would not be adversely affected by the project. Those living in proposed construction areas would be displaced 61 but the area disturbed is small relative to the total amount of similar habitat available. Birds. @ To minimize noise disturbance, Saxman proposes that the timing of various construction activities occur during the non-breeding seasons of raptors. Timing construction activities to avoid effects on mating and nesting is reasonable and should be incorporated into the project construction plans. Raptors and perching birds would mainly be affected by the loss of old growth forest habitat. Loss of this habitat would impact cavity nesters and other specialized species. However, the amount of habitat lost is not expected to be significant relative to that available. Some species could benefit from increased zones of early successional vegetation resulting from clearing. Early successional vegetation is ideal forage and cover for grouse adults and young. Project clearings would increase the early successional vegetation that would provide increased forage for grouse populations. Human Access. Construction of the project access road could increase human use of the project area by hunters, trappers, fishermen, and nonconsumptive users. This road would also cross deer winter range. Construction workers would also have access to the fish and wildlife resources of the project area. ie To minimize pressure on wildlife caused by unauthorized human access, Saxman proposes to control human access into the project area by using gates, and by issuing permits to those requesting ground access to the project area. An ADFG-filed condition would require that Saxman incorporate ADFG fishing ,and hunting regulations into employee/employer work standards and contracts for all employees, contractors, and subcontractors to prevent exploitation of species. Penalties for violation would include termination of employment . Additional human presence due to easier access could increase pressure on game species and furbearers, and could increase wildlife disturbances in general. We believe that road gating and regulated permit issuance would help control, but would not eliminate, unauthorized public use of the project area. In addition, we note that ADFG harvest statistics show that increasing the percentage of roaded area does not necessarily increase the percent of potential population harvested (FS 1991). However, since we've received no requests 62 for keeping the proposed new access road open, we don’t object to the road being gated so long as people can gain access through a permitting system. We agree that the ADFG condition on worker standards would further protect the wildlife of the project area from increased human pressure during the construction period: Bald Eagle. The Bald Eagle Protection Act prohibits molesting or disturbing bald eagles, their nests, eggs, or young. The three bald eagle nests around Lower Mahoney Lake are along an existing forest road route and outside the range of adverse disturbance. The FWS establishes a 330-foot minimum buffer zone of desired undisturbed habitat surrounding all bald eagle nest trees (letter from Nevin D. Holmberg, Field Supervisor, U.S. Fish and Wildlife Service, Juneau, Alaska to HDR Engineering Inc., Bellevue, Washington, May 19, 1995). A larger buffer may be necessary if vegetation or topography don't adequately screen a nest from view within this zone. In addition, no construction is permitted within 660 feet from any eagle nest between March 1 and May 31, and active nests should be avoided between March 1 and August 31. One inactive bald eagle nest observed during a 1995 survey could be located close enough to the proposed buried transmission line that birds using the nest could be affected. Saxman’s Proposal One measure that Saxman proposes includes burying the transmission cable from the switchyard about one half mile to a point west of the eagle nest. Saxman also proposes to move the transmission line as much as possible to attain the desired 330-foot minimum buffer zone around the nest. An FWS-filed condition would require that Saxman mitigate disturbance during the bald eagle breeding season by routing helicopter flights at least 1/4 mile away from active nest trees, and by not constructing within 660 feet, nor blasting within 0.5 mile from any active eagle nest trees between March 1 and August 31. Staff Analysis Implementing the FWS measures would be consistent with the Bald Eagle Protection Act requirement to conserve and protect nesting populations within the geographic range of this species. We therefore recommend that each of these bald eagle measures, including extending the buried portion of Cat e line, be included in any license issued for the project. Qperation River otter, mink and beaver. River otter and mink that may use Upper Mahoney Creek could be affected by dewatering Upper Mahoney Creek above the tailrace. Drawdowns in Upper Mahoney 63 Lake would eliminate lake overflow from December to August, decreasing available riparian habitat. Flows would also decrease somewhat in Upper Mahoney Creek below the powerhouse from February to September. Because of the mobility of these mustelids, it is probable they would find suitable habitat in other nearby creeks and Lower Mahoney Lake. The project would not significantly alter water levels in Lower Mahoney Lake and therefore beaver in Lower Mahoney Lake would not be adversely affected by project operation. Transmission Line Sitka black-tailed deer. The transmission line to Beaver Falls would result in about 77 acres of forest being cleared, and maintenance along this route would include periodic clearing of trees. The dense shrubby growth that the clearing would promote from increased sunlight and moisture, could potentially cause overcrowding of winter ranges in this area. Although increased shrubs from project clearing would make travel within the corridor more difficult, it is not likely to inhibit the movement of deer populations to other ranges. Therefore, we are not recommending any mitigative measures. Raptor protection. Birds are affected by aerial utility structures in two major ways: electrocution and collision (Electric Power Research Institute 1993). The proposed, 3.1- mile-long, 34.5-kV, overhead transmission line could present electrocution and collision hazards to bald eagles and other large birds in the project area. e Saxman plans to design the line according to the raptor protection guidelines of Olendorff, et al. (1981) and the Avian Power Line Interactions Committee (APLIC 1994) to avoid or greatly minimize potential bird electrocution and collision. According to Olendorff, et al. (1981), transmission lines less than 69 kV could pose an electrocution hazard to birds particularly because of the possibility of bird wings touching two energized conductors simultaneously. During prefiling consultation, the FWS recommended the use of the raptor protection practices by Olendorff, et al. (letter from Nevin D. Holmberg, Field Supervisor, U.S. Fish and Wildlife Service, Juneau Alaska to Michael Stimac, Licensing Specialist, HDR Engineering Inc., Bellevue, Washington, May 19, 1995). 15/ 15/ The widely-accepted Olendorff, et al. guidance, which emphasizes bird electrocution hazards, has been updated by Suggested Practices for Raptor Protection on Power Lines: The State of the Art in 1996 (APLIC 1996) and by Mitigating Bird Collisions with Power Lines: the State of the Art in 1994 (APLIC 1994) which are based on more recent raptor protection research. 64 The 34.5-kV transmission line would be located in an area used by bald eagles, trumpeter swans, and other large birds. During conditions of heavy fog, strong electrical and rain storms, and other severe climatic events, it is possible that the overhead transmission line and associated poles would be a collision hazard to small and large birds, including eagles (Avery, et al. 1980). A literature review shows that raptor collisions with transmission lines are random, low level, and generally inconsequential. Eagles have keen eyesight, use relatively slow flapping flight speed, and become conditioned to the presence of transmission lines (Olendorff and Lehman 1986). However, because of the diversity of birds in the project area, long-term collision prevention measures would help prevent such hazards to bald eagles and the other birds of the area, particularly during inclement weather. We believe transmission line design considerations to prevent or minimize collision hazards should include line design, aerial marker spheres, swinging plates, spiral vibration dampers, bird flight diverters, or avifaune spirals. We, therefore, recommend, as a license condition, that Saxman, after consulting with the agencies, prepare and file for Commission approval, a transmission line raptor protection plan that considers the most recent APLIC guidance documents to safeguard bald eagles and other birds in the area of the proposed aerial transmission line from any possible electrocution and collision hazards. Unavoidable Adverse Impacts: Vegetation. Vegetation clearing for project construction of the proposed lake tap, tunnel, valve house, air vent, upper shaft building, spoil disposal sites, powerhouse, tailrace, staging area, transmission lines, switchyard, and access road would result in the long-term conversion of about 99 acres of old growth coniferous forest and mature muskeg. This vegetation alteration includes about 22 acres for project structures and roads, and about 77 acres for establishment of the transmission line corridor. There could also be changes in less than one acre of alpine lakeshore and streamside plant communities resulting from dewatering. In addition, there would be an increase in density of understory vegetation on about 77 acres of land adjacent to cleared areas, as a result of increased sunlight and altered environmental influences. Early successional vegetation that would develop after clearing would provide desired early successional forbs and shrubs for black bear. Wetlands. Project construction would permanently eliminate about 53.8 acres of wet subalpine meadows, muskegs, open shore pine forests, and western hemlock/western red cedar forests. About 50.1 acres of the same type of wetlands would be indirectly affected from eliminating runoff detention, reducing wildlife 65 forage, eliminating shade in streams, and other indirect effects of wetland clearing and disturbance. Wildlife. Project construction would cause temporary wildlife displacement due to construction noise and activity, including blasting. Noise from project operation is not expected to cause long-term adverse effects on wildlife. 4. Threatened, Endangered and Sensitive Species Affected Environment; Endangered Species Act (ESA) - Listed Species. During informal consultation, the NMFS and FWS identified species under their jurisdiction that may occur in the proposed project area. The NMFS identified six marine species: (1) the endangered humpback whale; (2) the endangered Snake River sockeye salmon; (3) the delisted gray whale; 16/ (4) the threatened Stellar sea lion; (5) the threatened Snake River spring/summer chinook salmon; and (6) the threatened Snake River fall chinook salmon (letter from Tamra Farris, Southeast Alaska Office Supervisor, National Marine Fisheries Service, Juneau, Alaska to Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, June 17, 1994). The FWS identified the endangered American peregrine falcon and the delisted Arctic peregrine falcon 17/ (letter from John Lindell, Endangered Species Biologist, U.S. Fish and Wildlife Service, Juneau, Alaska to Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, June 21, 1994). No federally listed threatened or endangered plant species have been found at or near the project area (Duffy 1994). 16/ Although the northeast Pacific population of the gray whale was delisted from the endangered category (Federal Register Vol. 59, No. 115, pp. 31094-31095, June 16, 1994) and is no longer protected under the ESA, the NMFS must monitor this species for a minimum of five years following its delisting. Federal agencies are requested to voluntarily consider the gray whale in their planning processes. 12/ Although the Arctic peregrine falcon was delisted from the threatened category (Federal Register Vol. 59, No. 192, pp. 50796-50805, October 5, 1994) and is no longe: protected under the ESA, the FWS must monitor this species for five years following its delisting. Federal agencies are requested to voluntarily consider the Arctic peregrine falcon in their planning processes. 66 Humpback whales can be found in a wide range of oceans from tropical islands to shallow continental coasts (ADFG, FWS, NMFS, Bureau of Land Management, and FS 1994). This species is among the most abundant of the eight endangered whales that occur in Southeast Alaska waters. It has been estimated that from 300 to 500 humpbacks inhabit Southeast shallow coastal areas during the summer and fall. The local distribution appears to be directly correlated with density and seasonal availability of prey, including herring and euphausiids. In Alaska, humpbacks feed mostly on krill and small fish such as herring, or capelin, and some feed in the same area year after year. Prior to commercial whaling, the North Pacific humpback whale population was estimated at around 15,000 animals, but current populations estimates are 1,000 to 1,200. There are no other known factors contributing to their decline, and it isn't currently known whether the population is increasing or decreasing. The northeast Pacific gray whale population has a long migration route where they mate and calve in December in sheltered lagoons along the Baja peninsula, and spend the summer feeding in the Bering Sea (Jones and Swartz 1984). Their movements are twice annually along Southeast Alaska during migration. During migration, gray whales feed at the surface on small fish, but are normally bottom feeders of tubeworms and benthic amphipod crustaceans (Connor and Peterson 1994). The northeast Pacific population of the gray whale, estimated at 17,000 to 18,000, appears to be increasing at about 3.2 percent annually for the last 20 years. Although whaling exploitation in the early part of this century vastly reduced the population sizes, legislation in 1937 has apparently contributed to the recovery of this species. In addition to historic over harvesting, other threats to this species has been increased boat traffic and curiosity by the gray whale of small boats. This species is among whale watchers' favorite. Stellar Sea Lion Stellar sea lions forage mostly in near- shore areas and over the continental shelf. Important food sources include schooling fish such as pollock, herring, salmon, eulachon, and cephalopod mollusks. The causes of the 70 percent decline in the Stellar sea lion population in Alaska between the mid-1970s and the present are unknown. Possible causes are disease; environmental change; reductions in available food resources; effects of commercial fisheries; commercial harvests of sea lion pups; harvests of adults for subsistence and scientific: research; predation by 67 sharks, killer whales, and brown bears; inadequacy of harvesting regulations; and other human incidence (ADFG, FWS, NMFS, Bureau of Land Management, and FS 1994). The last population estimate was about 64,000 animals and the decline was continuing. The occurrence of this species in the project vicinity is expected to be only as transients and not in high numbers (telephone conversation between Andy Grossman, Fisheries Biologist, National Marine Fisheries Service, Juneau, Alaska and Carl Keller, Wildlife Biologist, Federal Energy Regulatory Commission Washington, D.C., June 12, 1997). These species of salmon share the same general life cycle. During the spring in Idaho, eggs are deposited and fertilized in freshwater gravels nests (called redds). After hatching, the juvenile sockeye salmon use the stream or lake they were born in as a nursery area for one to three years. Spring/summer chinook live in the nursery areas for one year, but fall chinook remain in the nursery areas for only a few months. Sockeye and spring/summer chinooks leave their nursery areas and start migrating to the ocean in the spring but fall chinook start migrating to the ocear in the summer. In the ocean, these salmon range from northern California to the Gulf of Alaska where they spend two to four years to maturity before returning to freshwater. Historically, these salmon species were widely distributed throughout the Snake River. For example, the sockeye salmon has declined in abundance more than any other Northwest salmon and therefore was listed as endangered in 1994. Causes of the Snake River sockeye and chinook salmon declines range from over harvesting, habitat destruction and modification, impairment to downstream and upstream (freshwater) migrations, hatchery impacts, marine mammal predation, poor ocean survival, logging, grazing, mining, road building, and other human-induced effects. The NMFS has proposed a recovery plan for threatened and endangered Snake River salmon. The goal of the plan is to restore health of the Columbia and Snake River ecosystems, and recover the Snake River salmon stocks. The actions are designed to improve ecosystem integrity and stability during the more critical early stages and migration stages of the salmon life cycles. The American peregrine falcon breeds and raises its young in interior portions of Alaska but may pass through the Ketchikan area during seasonal migration. It is highly migratory and may winter as far south as Argentina. The American peregrine seems to have recovered in numbers as a result of restrictions on organochloride pesticide use and because of successful reintroduction of captive-bred individuals. In nature, these chemicals have caused eggshell thinning and poor 68 reproductive success among peregrine falcons. No organochloride pesticides are authorized for use on the Tongass National Forest. Because American peregrine populations in Alaska are increasing (Ambrose et al. 1988), the FWS proposes removal of this species from the threatened and endangered wildlife list and the critical habitat designation (Federal Register Vol. 60, No. 126, June 30, 1995). Its principal prey are shorebirds and waterfowl, but it also consumes songbirds (FS 1991). Because the project area does not support large numbers of shorebirds or waterfowl, peregrine falcons are not expected to forage in the project area. There is no designated critical habitat for the American peregrine in the project area and no individuals of this subspecies have been observed in the project area. As with the American peregrine, the Arctic peregrine falcon populations declined following World War II as a result of organochlorine pesticides use. After over 20 years of restriction on the use of these chemicals marked by steady progress toward recovery, reproductive rates of arctic peregrines have steadily increased, and populations continue to rise. About 250 known pairs nest in Alaska and thousands nest throughout arctic North America. Arctic peregrines nest in tundra regions of Alaska, Canada, and Greenland and migrate through mid North American latitudes and winter in Latin America. This species occurs in southeast Alaska only during the migration periods (FS 1991). In Alaska, this species nests mostly along rivers in the northern and western parts of the state. Nests are positioned on cliffs or bluffs usually near rivers or lakes that provide habitat for shorebirds, waterfowl, and songbirds on which the falcons prey. There has been no reported observation of the Arctic peregrine falcon in the project vicinity. Fish and Wildlife Service Species of Concern. The FWS lists the following species of concern (formerly Category 2 candidate species under the ESA) that may occur in the project area: goose- grass sedge, thick-glume reedgrass, marbled murrelet, Queen Charlotte goshawk, harlequin duck, and Alexander Archipelago wolf, and spotted frog (letter from John Lindell, Endangered Species Biologist, U.S. Fish and Wildlife Service, Juneau, Alaska, to Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, June 21, 1994; letter from Nevin D. Holmberg, Field Supervisor, U.S. Fish and Wildlife Service, Juneau, Alaska to Michael V. Stimac, Licensing Coordinator, HDR Engineering Inc., Bellevue, Washington, May 19, 1995). These species may become candidates for future listing as endangered or threatened but presently, there is inconclusive information on actual distribution. af . The primary geographic range of the goose-grass sedge in Alaska is the southeast 69 panhandle south to Queen Charlotte Island. Although there have been only six occurrences of this species south of Juneau, scientists believe its preferred habitat is high mountain elevations at high latitudes from timberline to the alpine, and almost always in or at the water's edge (Standley 1985). The goose-grass sedge appears to be an early successional species, colonizing shallow, wet, organic loamy soils along streams and lake shores, and in seep areas of gentle terrain. The soils in its preferred habitat are usually very shallow and have a high content of stones and gravel. The vegetation surrounding the desired habitat is usually moist meadows or tundra and also occupies alpine habitats. In some areas it may be one of the first plants to stabilize stream banks and wet soils of high elevation terraces. A summer 1994 plant survey identified a population of about 500 individual goose-grass plants in a fen (a flat, marshy wetland) draining into Upper Mahoney Creek (Duffy 1994). This site is near the proposed upper tunnel, but outside the project construction area. This site is one of two documented occurrences of this species on Revillagigedo Island and there are at least 11 additional sightings in Alaska. = e . This species occurs in a variety of habitats including beach meadows and marshy wet areas, lake shores, sandy or rocky soils, and forest openings from sea level to the alpine zone (Muller 1991; FS 1991; telephone conversation between V. Moran, Endangered Species Coordinator, U.S. Fish and Wildlife Service, Anchorage, Alaska, and Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, May 17, 1995). These habitat types occur in the project area, so the plant may exist there. However, it was not observed in the project area during surveys of suitable habitat (Duffy 1994). Marbled Murrelet. The marbled murrelet is a small seabird that spends most of its time along coastal areas from Alaska to central California and feeds primarily on small fish and invertebrates in near-shore marine waters (Federal Register Vol.60, No.154, pp.40892-40908, August 10, 1995). They nest in old-growth and mature forest in southeast Alaska, often far inland from the ocean (FS 1991, West 1993). Marbled murrelet population numbers are thought to be declining in the lower forty-eight. The greatest threat is nesting habitat loss and modification due to logging, development, and fragmentation of nesting stands (Federal Register Vol.65, No. 119., pp. 28362-28367, June 20, 1991; Pacific Seabird Group 1995). The George Inlet area has old-growth and mature forest along narrow inlets which is typical of their preferred habitat (personal communication between K. Kulitz, Migratory Bird Specialist, U.S. Fish and Wildlife Service, Migratory Bird 70 Management, Anchorage, Alaska, and Sally Boggs, Biologist, HDR Engineering Inc., Anchorage, Alaska, June 8, 1995). While there are several suitable habitats for marbled murrelets, the old- growth forest west of Lower Mahoney Lake and slopes north and west of the lake offer highly suitable habitat. The forests along the transmission line route are less suitable because they are lower volume forests. Marbled murrelets were detected in the project area during July 1995 surveys, although the survey intensity did not allow for locating nests. At Lower Mahoney Lake, the high number of observations and birds' behavior indicate they may breed on the slopes or in the riparian forest at the west end of the lake. Murrelets were also observed in lower numbers flying near the south end of the proposed power line route. The Queen Charlotte goshawk is the primary subspecies of the northern goshawk that uses southeast Alaska. The Queen Charlotte goshawk was considered for listing as threatened, but in the June 29, 1995 Federal Register, the FWS decided not to list it. Queen Charlotte goshawks are forest raptors that prefer large unfragmented stands of productive mature timber with a dense canopy and an open understory at low elevations. Most of the mature forest habitat in the project area may be suitable for both hunting and nesting (Crocker-Bedford 1994). Coniferous forests are preferred over deciduous forests. The bird shows a lower habitat specificity in the winter, often ranging into other habitats. The project area is within the potential home range of several possible nest sites, so goshawks could use the forested areas for foraging (letter from E. West, Assistant Professor of Biology, Alaska Natural Heritage Program, Environment and Natural Resources Institute, University of Alaska, Anchorage, Alaska to Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, May 21, 1994). During July 1995, the forested parts of the project area on National Forest System land (mostly the transmission line route) were surveyed for nesting goshawks using the FS survey protocol procedures. The survey focused on the proposed transmission line and a portion of the access road where goshawks would likely nest. No responses were detected from this survey. i . In selected areas of its range, such as the Aleutian Islands and parts of British Columbia, the harlequin duck is abundant. But because much of their worldwide range lies in remote regions, accurate populations and distribution has been difficult to determine. Harlequin ducks live in southeast Alaska but are not known to nest in the Alexander Archipelago, which includes the area of Mahoney Lake (telephone conversation between S. Heinl, Biologist, Alaska Department of Fish and Game, 71 Ketchikan, Alaska and Sally Boggs, Biologist, HDR Engineering, Inc., Anchorage, Alaska, June 22, 1995). Their non-breeding habitat is near shore marine waters along rocky coasts (Armstrong 1983; letter from E. West, Assistant Professor of Biology, Alaska Natural Heritage Program, Environment and Natural Resources Institute, University of Alaska, Anchorage, Alaska to Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, May 21, 1994). They may winter in and migrate through the project area, possibly using Lower Mahoney Lake. Harlequin ducks usually nest along rocky shores adjacent to rapids of turbulent mountain streams. Harlequin appear to select the largest anadromous salmon streams for nesting (Crowley 1993) . The nests are located along first order tributaries near timberline, on steep southwest-facing slopes, and positioned beneath old growth forests. Well concealed nests are generally composed of a thin layer of grass, with dry twigs and leaves, and lined with down. Females incubate assiduously and appear to have a high degree of fidelity when nesting. . Alexander Archipelago wolves are present on Revillagigedo Island and likely use the project area (letter from John Lindell, Endangered Species Biologist, U.S. Fish and Wildlife Service, Juneau, Alaska, to Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, June 21, 1994). There are about eight wolf packs, numbering two to eight individuals each, on Revillagigedo Island. Wolf numbers and range are dependent on deer populations (Steiglitz 1994). Deer use most forest habitats in southeast Alaska but prefer old- growth stands, and particularly old-growth stands with a high timber volume, especially in winter. Gray wolves may also eat beaver, mountain goat, mice, grouse, salmon, and berries. Denning wolves require some open space, such as muskeg, near the den opening (Ketchikan District Coastal Zone Management Plan 1991). Wolf scat was observed east of Lower Mahoney Lake during the June 1994 field surveys. . Throughout their range, spotted frogs are generally found in grassy areas along streams, rivers, and lakes (telephone conversation between S. Grossman, Biologist, U.S. Fish and Wildlife Service, Juneau, Alaska and Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska., May 23, 1995). In southeast Alaska, they tend to occur on the mainland in ponds near the mouths of major rivers running westward through the coast range. They may breed in muskegs and beaver ponds (West 1993, Iverson 1995). This frog is not an old-growth obligate, but forested areas may represent important refugia from further population losses (Blaustein, et al. 1995). The specific reasons for its decline are unknown but researchers speculate the principle causes are habitat loss due to encroachment, climatic changes, lake acidification as a consequence of climate change, increased UV-B radiation due to ozone depletion, and competition 72 with introduced species (Blaustein, et al. 1995, Waters 1992, Hayes and Jennings 1986). Recent surveys in southeast Alaska have documented the spotted frog. Because the project area is not associated with any major rivers, it is unlikely that the frogs would be found there. The only suitable habitat in the project area could be along the south shore of Lower Mahoney Lake. A July 1995, baited ey survey along the lake shore of Lower Mahoney Lake revealed no frogs. Forest Service Sensitive Species. The FS lists 12 sensitive plant species that might occur in the project area (facsimile transmittal from P. Krosse, Ecologist, Tongass National Forest, Ketchikan Supervisor's Office, Ketchikan, Alaska to Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, May 23, 1995). These species and potential project impacts on them are described in the Biological Evaluation for Plants (Leggett 1995). Field surveys for plant species in the project area and on National Forest System lands were conducted in September 1994, and July 1995 (Duffy 1994, Leggett 1995) and populations of two FS sensitive species in the project area were found: the goose- grass sedge and choris bog orchid. The goose-grass sedge was previously discussed as a FWS species of concern. Animals listed as sensitive by the FS and that might occur in the project area are the trumpeter swan, Queen Charlotte subspecies of northern goshawk, osprey, and Peale's peregrine falcon. These species' use of the project area are described in the Biological Evaluation for Animals for this project (Boggs 1995). The FS sensitive species, Queen Charlotte Goshawk, is also a FWS species of concern and was previously discussed. Suitable habitats of the choris bog orchid are non-saline, moist sites dominated by low herbaceous vegetation, wet lakeshores, wet alpine and subalpine meadows, and fens. During the 1994 and 1995 plant surveys in the project area, 10 orchid populations were located in the vicinity of the project. Numbers of individual plants at the 10 sites varied from three individuals to as many as 1,192 (Leggett 1995). Orchid populations that could be affected by project construction or operation were found at three locations along the shore of Upper Mahoney Lake and near the upper tunnel construction area (memorandum from Anne Leggett, Biologist, HDR Engineering Inc., Ree ane Alaska to Mahoney Hydro Project File, August 16, 1995). Although trumpeter swans are not known to nest in the Ketchikan area, they may occur there during migration and overwintering, and are likely to use the Lower Mahoney Lake area (telephone conversation between C. Burns, Wildlife Biologist, Tongass National Forest, Ketchikan, Alaska and Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, ae April 18 and May 24, 1995). Since water levels in the lower lake would not be significantly altered, this could provide suitable temporary swan habitat. As lakes freeze, the trumpeters move to saltwater inlets and lagoons for feeding and loafing. No trumpeter swans have been observed in the project area. Qsprey. Ospreys appear to be rare in southeast Alaska (telephone conversation between S.L. Blatt, Biologist, Tongass National Forest, Petersburg Ranger District, Petersburg, Alaska and Sally Boggs, Biologist, HDR Bay inet ing Inc., Anchorage, Alaska, June 7, 1995). Those passing through the project area during migration between northern Alaska and their wintering areas in Mexico are unlikely to nest (telephone conversation between J. Gustafson, Habitat Biologist, Alaska Department of Fish and Game, Ketchikan, Alaska and Sally Boggs, Biologist, HDR Engineering Inc., Anchorage, Alaska, June 5, 1995), but may stop at the lower lake to rest and feed on fish. This species has been rarely sighted in George Inlet. No nests were observed during the 1994 field survey and no individuals were seen during the summer 1995 field season. Available nest sites and foraging areas, however, do not appear to be limiting. ‘ . In southeast Alaska, Peale's peregrine falcons nest nearly exclusively on cliffs on or near the outer coast, facing the open ocean, and are thought to feed predominantly on seabirds (FS 1991). Their nest distribution is closely associated with large sea bird colonies on the outer coast or nearby islands (FS 1991). Their nests are generally on ledges of vertical rocky cliffs at heights ranging from 40 to 1,200 feet (letter from E. West, Assistant Professor of Biology, Alaska Natural Heritage Program, Environment and Natural Resources Institute, University of Alaska, Anchorage, Alaska to Anne Leggett, Biologist, HDR Engineering Inc., Anchorage, Alaska, May 21, 1994). Because the project area is located on a narrow inlet far from the ocean and any large seabird colonies, it is unlikely the birds nest or use the project area. No Peale's falcons were sighted during the 1994 and 1995 field surveys. Environmental Impacts and Recommendations: ESA-listed species. Marine species. A Biological Evaluation for Animals (Boggs, 1995) has been prepared for the project. The biological evaluation concludes that the project should have no impact on the viability of the population of the listed salmon, sea lion, and whale species because no work associated with the proposed project would occur in the marine environment except for shippinc of equipment and materials to the project area. In their comments on the biological evaluation, the NMFS states that the project would not be likely to affect endangered or threatened marine species (letter from Steven Pennmoyer, Director, Alaska Region, National Marine Fisheries Service, Juneau, Alaska to Ann 74 Leggett, project Biologist, HDR Engineering, Inc., Anchorage Alaska, dated January 12, 1996). NMFS also states that their comments conclude Section 7 consultation requirements for the project. Therefore, no further action or consultation under Section 7 of the Act for marine species is required. We agree with this assessment, and conclude that the Proposed project is not likely to adversely affect the humpback and gray whales, Stellar sea lion, Snake River Sockeye, Snake River fall chinook, and Snake River spring/summer chinook for the following reasons: (1) these species are either in small numbers or possible transients (humpback whale, Stellars sea lions, Snake River sockeye and chinook salmon) to the project area, or aren't in the project vicinity (gray whale); (2) critical life cycle stages of these species would not be affected by project development; (3) human-induced impacts from project construction and operation are not expected to adversely affect these species; (4) there are no sea lion rookeries or haulouts in or near the project area; and (5) there would be no expected impact on Population viability of these species. + The Biological Evaluation for Animals concludes that the project is not expected to impact the American peregrine falcon because: (1) the falcon is likely to only occur in the project area as a transient during seasonal migrations; (2) the project area doesn’t support large numbers of the falcon’s primary prey species - shorebirds and waterfowl; and (3) the project’s primary impact would be clearing about 88.5 acres of forest and muskeg, which are not important habitats for the falcon. In their comments on the biological evaluation for animals, the FWS states that populations of the American peregrine falcon would not likely be adversely affected by the proposed project (letter from John Lindell, U.S. Fish and Wildlife Service, Endangered Species Specialist, Juneau, Alaska, to Anne Leggett, Project Biologist, HDR Engineering, Inc., Anchorage, Alaska, dated January 17, 1996). Therefore, no further action on this species under Section 7 of the ESA is required. We agree with the Biological Evaluation and the FWS findings. As with the American peregrine, the delisted Arctic peregrine falcon occurs in southeast Alaska only during the migration periods (FS, 1991). There has been no reported observation of the Arctic peregrine falcon in the project vicinity, and we conclude, therefore, that the project would have no impact on the delisted Arctic peregrine falcon. Fish and Wildlife Service Species of Concern. = : The project's potential to adversely impact the goose-grass (lenticular) sedge (also a FS Sensitive Species) is low because the known site near the upper tunnel, estimated at about 500 plants, would not be directly 75 and can be avoided. In addition, Leggett (1995) states eae geographic distribution of this species has not peer well explored and speculates that there may be other un! ne io occurrences of this sedge in the project area. Because pate wide geographic range, from the western Aleutians to mon ane lack of highly specific habitat requirements (other t a substrate), the overall risk to this species from projec ae activities appears to be low. Although the propose projec t not likely to affect the goose grass sedge, Saxman proposes ei protect this species along with the FS sensitive species, choris bog orchid. = . _Thick-glume peedorase mas tnctasourd i vey of most of the project area but is mos ely to Sarita anaicne shoreline of Leer Mee eee eee eg raat tte cted in the water levels o: ease cries e unlikely that plants adjacent to the lake would be affected. Marbled Murrelet. Marbled murrelets occur an the projecten is possible they breed in the high-volume, old-g arene Phe west end of Lower Mahoney Lake (ner eor a aa communication between K. Kuletz, Migratory Bird Specia ee 8. Fish and Wildlife Service, Migratory Bird Management, Anchorage, Alaska and Sally Boggs, Biologist, HDR Engineering Inc., Anchorage, Alaska, June 8, 1995). No murrelet neato ere Bate identified in the project area. The prosece would c ene al 6.8 acres of highly suitable habitat in this area for the ‘ proposed access road and powerhouse site, thus decreasing che number of potential murrelet nest sites. The transmission ine route also includes some suitable habitat. Clearing of creee would also allow greater access by predators to old-growt nesting sites. vely small amount of preferred habitat loss and Scekateet heniene Yegradat ion should not affect the popu tac onice marbled murrelets on Revillagigedo Island, eee vA ecoeeen of their sizeable numbers. Marbled murrelets could be : ures or displaced by construction noise, but project conseZuge ee operation are not likely to cause a loss of population vial y or lead toward federal listing. . It is possible that Eber cueen " shawk (also a FS sensitive species) uses the projec’ parteynitoaegh no goshawk detections were observed during a 1995 survey, most of the forest habitat in the project area is suitable for both hunting and nesting. The Queen charicets goshawk has been documented to travel up to 34 miles from re nest and there have been five potential nest sites within 3 miles from the project area. Goshawks using these nests may forage in the Mahoney Lakes areas. 76 Project construction would clear trees and alter understory growth of about 176 acres of mature forest, thus reducing possible foraging and nesting value for the Queen Charlotte goshawk. During construction, potential foraging goshawks could be temporarily displaced by noise and human activity. Because the project would result in a small area of disturbance relative to the goshawk's home range, it is not expected that this species would be adversely affected by the project. The project is not likely to cause a loss of population viability or lead toward federal listing of the Queen Charlotte goshawk. Harlequin ducks may use Lower Mahoney Lake and Mahoney Creek during overwintering and migration. The habitats and water levels of these water bodies should not be significantly affected by the project. Although no permanent impacts are expected, individual ducks could be temporarily disturbed or displaced by noise and activity associated with construction. Alexander Archipelago Wolf. The Alexander Archipelago wolf is likely to occur in the project area (Boggs 1994). Wolf numbers vary according to the prey, in this case, Sitka black- tailed deer. Since the deer population is not expected to be diminished by this project, no adverse effect is foreseen to the wolves of the area from loss of prey base. However, fall and winter construction of the transmission line could temporarily drive deer away from the winter range in these areas and likewise cause temporary relocation of wolves. Also, increased access to the Mahoney Lakes area could result in increased deer hunting and wolf trapping. Spotted Frog. No suitable habitat nor spotted frogs were identified during a survey in 1995, and it is unlikely that spotted frogs would be affected anywhere in the project area. Forest Service Sensitive Species. Choris Bog Orchid. Lowering Upper Mahoney Lake surface elevation could result in temporary drying of some orchid habitat immediately adjacent to the lake, and cause about 140 orchid plants in that zone to lose vigor or die. However, there are individual plants above the normal water line of the lakeshore that would not be affected by lake water level fluctuations. Three known orchid plants at the upper tunnel construction site would also be destroyed during construction. The plants potentially harmed by construction and lake drawdown represent 7 to 9 percent of the approximately 1,570 choris bog orchid individuals counted in the bowl surrounding Upper Mahoney Lake and the tunnel site (Leggett 1995). Less than about 25 percent of the suitable habitat within that area has been examined, so the proportion of plants potentially impacted could actually be much lower. Many other areas of suitable habitat in drainages surrounding the project area have not been surveyed for sensitive 77 plants. It is unlikely the orchid populations in the Upper Mahoney Lake area would be adversely affected by this project because only a small portion of its known population could potentially be harmed. Therefore, the project poses minimal risk to the viability of the species within the Revillagigedo Island ecological province. Although the project may affect individuals of the choris bog orchid, it is not likely to lead to federal listing or cause a loss of viability of this species. To mitigate potential impacts to the FS sensitive species, goose grass sedge and choris bog orchid, Saxman proposes to require non-disturbance of the known sites of these species by stipulating so in project permits and/or plan sheets. Areas would be cordoned off with silt fences or similar material to delineate these areas. We agree that fencing the known sensitive plant populations, where practical, would protect them from disturbance. Therefore, we believe that any license issued for this project should require fencing, and that appropriate plant protection measures should be developed after consultation with the FS and FWS. Trumpeter Swan. No trumpeter swan habitat would likely be affected by the project because the upper lake is frozen all winter and probably during migration. The water flow regime during project operation would not significantly alter levels in the lower lake. In the long-term, the project should not affect migrating or overwintering swans or other waterfowl. Any winter construction of the lower tunnel, powerhouse, access road, and transmission line could disturb overwintering swans from blasting, heavy equipment operation, and other human activity. However, this disturbance would be Lemporany 3 The project is not likely to cause a loss of population viability. . Although ospreys could be disturbed and displaced by human activity and from noise during project construction, possible use of the lower lake by osprey would be unaffected by the project. u . The project is not expected to affect the Peale's peregrine because (a) the project area would not attract this species, (b) the project is located on a narrow inlet away from the open ocean, (c) there are no large seabird colonies near the project, (d) there are no suitable vertical rocky ledges adjacent to open water, and (e) there is no critical habitat for the Peale's peregrine at the project site. Therefore, the project would have no impact on the Peale's peregrine falcon. Unavoidable Adverse Impacts: About 140 individual choris bog orchid plants could be destroyed by drawdown of the Upper Mahoney Lake and construction 78 at the upper tunnel construction site. However, this impact would not affect the continued existence of this species on Revillagigedo Island. Clearing of the forested area at the powerhouse site and along the road and transmission line alignments would eliminate 99.4 acres and severely degrade an additional 77.1 acres of possible foraging and nesting habitat for the Queen Charlotte goshawk. This same habitat is considered forage for the Alexander Archipelago wolf's primary prey, the Sitka black-tailed deer, and its loss could affect local populations of Alexander wolf. Clearing would also eliminate 6.8 acres of potential highly suitable nesting habitat for the marbled murrelet. During construction, noise and human activity around the lower lake could disturb and cause temporary displacement of the following FWS species of concern and FS sensitive species: marbled murrelet, Queen Charlotte goshawk, harlequin duck, trumpeter swan, and osprey. 5. Aesthetic Resources Affected Environment: The area around the site of the proposed Mahoney Lake Project is largely undeveloped and visually striking. Upper Mahoney Lake is surrounded by steep, rocky slopes, with bedrock exposures. Subalpine vegetation, including mountain hemlock and dense low shrub cover, exists where soil is deep and stable enough for vegetation to become established. Alder and salmonberry dominate areas that are unstable. unvege tated landslide chutes are present on the southeast side of the lake. Upper Mahoney Creek flows through steep slopes with a series of cascades and an approximate 100-foot scenic waterfall. At the base of the waterfall, the creek flattens and the adjacent landscape is surrounded by open deciduous alder trees and salmonberry shrubs. Further away from the creek channel, the landscape consists of a taller and more dense forest. The steep slopes above Lower Mahoney Lake and along the proposed road alignment support primarily dense old-growth forest. Lower elevation forests are more open and lighter in understory and dominated by western hemlock, Sitka spruce, western red cedar and a variety of understory species. The landscape to the south of Lower Mahoney Lake, where the transmission line corridor would be located, generally consists of dense hemlock and cedar forest. 79 Environmental Impacts and Recommendations: Construction Traffic, noise, dust, and exhaust emissions from construction machinery would be evident along public roads leading to and at the project site during project construction. For the access road, powerhouse, and construction staging area, Saxman would limit clearing to the extent possible. Measures to control erosion, such as soil erosion matting and mulches, and revegetation would be implemented during and after construction. This would help to minimize these short-term visual impacts. Operation Project Structures. Permanent, above-ground project features, including the lake tap air vent, valve house and upper shaft access building, semi-underground powerhouse, tailrace channel, new access road, and overhead transmission line would all, to some extent, intrude on the visual quality of the projec area. Since the entire pipeline would be underground in tunnels, and construction tunneling would occur underground, visual impacts during and following construction would be negligible. Permanent, above- ground features along the underground pipeline route, including a 300-square-foot concrete valve house and upper shaft access, would have minimal visual impacts. Because of the remoteness of the area, these structures would not be seen except by those who were able to access the site, or by air. The structures would be screened by the surrounding dense vegetation reducing the visual impacts. The powerhouse would be a semi-underground structure, which would reduce the ability to see this structure from the air or surrounding area. The awyeas cleared for the powerhouse staging area and tailrace channel would be visible from the air. The surrounding dense forest, however, would reduce the visual impacts from the air. Materials for above-ground project features would use natural colorings to blend to the extent possible with the natural surroundings. The powerhouse would be partially buried minimizing the visual impacts. The above-ground portion of the powerhouse and the valvehouse at the top of the vertical shaft would use construction materials that would blend with the surrounding area. Areas of disturbance would be kept to a minimum and revegetated to reduce the visual impact. The pipeline would be located within underground tunnels, also minimizing visual impacts. 80 Minor short-term impacts from construction of project structures would occur during clearing activities for the powerhouse, valve house, and upper shaft access and construction staging areas. Long-term impacts would be incurred from the above-ground structures themselves. Because of the remoteness of the project area and the dense vegetation that would screen the project structures from the surrounding area, the visual impacts would be minor. . The new access road would be seen from the air and by the few people who may visit the project area via boat from George Inlet, or from hiking down the existing logging road from the gate at the Cape Fox Corporation Boundary. Visual impacts, however, would be minimal. The dense vegetation in the area would help screen the road from the air and surrounding area. Rock sources for construction of the access road would be located off the mainline road system, if available. Short spur roads would provide access to the rock source. Cleanup of ground-disturbing activities would be continuous during construction activities. Tree removal would be minimized to the extent possible and stumps would be cut as low to the ground as possible. Transmission Line. Power generated from the project would be transmitted 4.6 miles over a combination of underground and overhead transmission lines. The line would be buried for about one mile from the powerhouse to the switchyard along the new access road. Burying the line in this area would help mitigate long-term visual impacts around Lower Mahoney Lake and should be required in any license that is issued. The overhead portion of the transmission line would require clearing the route of trees for a width of about 200 feet and a length of 3.1 miles. The overhead line would be visible from the air, but visual impacts from the surrounding area, such as from George Inlet, would be minimal due to the dense vegetation that would screen the clearing and transmission line from boat traffic in George Inlet. Operation Upper Mahoney Lake Drawdown. Drawdowns of Upper Mahoney Lake may change plant species over time and change the appearance of the shoreline. Changes in plant species, however, would probably only affect areas with elevations within a foot or two of the ordinary high lake surface elevation. Drawdown would occur from about November through July with maximum drawdown occurring in the middle of winter. Over time, new plant species would reestablish at the new drawdown elevation. Since Upper Mahoney Lake is difficult to access, few people visit the lake. Views of Upper Mahoney Lake from surrounding areas are also 81 limited due to the topography and terrain. Upper Mahoney Lake can only be viewed by those recreating along the alpine ridges above the lake and from the air. However, from the alpine ridges or air, the human eye would not likely be able to notice any changes in the lake level. The visual impacts from lake drawdown, therefore, would be minor. Short-term visual impacts from the drawdown of Upper Mahoney Lake would be minor, resulting from the drying of plant species along the shoreline and the associated change in appearance of the shoreline. Long-term impacts would be negligible, since new plant species are expected to reestablish along the shoreline. Upper Mahoney Creek Flows. The aesthetic quality of the project area would be affected by reduced streamflow in Upper Mahoney Creek. Most of the flows that form the waterfall at the outlet of Upper Mahoney Lake would be diverted for power generation. Upper Mahoney Creek from Upper Mahoney Lake to the tailrace would be partially dewatered each year from about November through July because there would generally be no outflow from the upper lake during that period. Flows in this bypassed reach, including the waterfall, would be only those from the natural drainage area that feeds the upper creek below the lake outlet. The waterfall currently can be seen from the air, from the east side of George Inlet, and from portions of the proposed powerhouse access road along the south side of Lower Mahoney Lake. These views of the waterfall would be diminished by the proposed project. However, this impact is not considered major because waterfalls are common in the area and because the falls can only be viewed from a few vantage points. Unavoidable Adverse Impacts: Short-Term Impacts. Minor short-term visual impacts would occur during clearing and construction of project structures, the access road, transmission line, and construction staging areas. Construction machinery and activities would produce short-term impacts by producing noise, dust, exhaust emissions, and additional traffic on existing roads. Long-Term Impacts. Project facilities would only have a minor adverse visual impact because of the buried project features, dense vegetation, and the remote location of the project area. Permanent clearing for the new access road would have long- term visual impacts. These impacts are expected to be minor due to the remoteness of the area and the surrounding dense vegetation that would help screen the new road from surrounding areas. 82 The overhead transmission line would have visual impacts by air. From the surrounding area, visual impacts would be minimal due to the dense vegetation that would screen the overhead line. Visual impacts would be incurred from reduced flows in the waterfall near the outlet of Upper Mahoney Lake. 6. Cultural Resources Affected Environment: Saxman conducted a cultural resources survey of the project (Campbell 1996). No archaeological or historic sites eligible for inclusion in the National Register of Historic Places were identified. The Mahoney Mine facilities date from the 1940s and have been extensively modified. All buildings are collapsed and deteriorated. Machinery associated with the mine has either been removed or significantly altered or vandalized. Environmental Impacts and Recommendations: Although no known National Register-eligible sites would be affected by the project, there is the possibility that undiscovered archaeological or historic sites may be present, such as buried archeological sites, that may be affected by project construction. Therefore, in the event sites are discovered during construction, Saxman has agreed to (1) consult with the SHPO; (2) prepare a cultural resources management plan (CRMP) and a schedule to evaluate the significance of any discovered sites and to avoid or mitigate any impacts to National Register- eligible sites; (3) base the plan on recommendations from the SHPO; (4) file the plan for Commission approval, together with the written comments of the SHPO; and (5) take steps necessary to protect the discovered archeological or historic sites from further impact until notified by the Commission that all of these requirements have been satisfied. Saxman has agreed to take the following precautions during project construction and operation to ensure the Mahoney Mine site and several other historic and archeological sites known in the general vicinity of the project would not be disturbed: (1) restrict knowledge and location of the sites to project personnel; (2) restrict shoreline access in the vicinity of the sites to project personnel; (3) monitor the sites during project construction and operation to assess whether disturbance is occurring; and (4) deposit rock or timber removed or dislodged during new road construction away from the Mahoney Mine site (Campbell, 1996; letter from Jimmy J. Herrera, District Ranger, Tongass National Forest, Ketchikan, Alaska, October 15, 1996; letter from Michael V. Stimac, Manager, Licensing and Environmental Services, HDR Engineering, Inc., Bellevue, Washington, October 17, 1996). Saxman should implement these protection measures, consult the SHPO and the FS if any disturbance is found, develop and implement a cultural resources 83 management plan based on the their recommendations as necessary to mitigate disturbances, after Commission approval. Unavoidable Adverse Impacts. None. 7. Recreation and other Land Uses Affected Environment: No developed recreation facilities are located near the project and access to the project area is fairly limited. A gravel road (Ward Lake Road) extends from Ketchikan through National Forest system lands, through lands owned by the Cape Fox Corporation toward Lower Mahoney Lake. The road is currently gated at the Cape Fox Corporation boundary, which is several miles from the proposed project site. From the gate, an existing timber access road extends another five miles south where it ends about one mile from Lower Mahoney Creek. Some recreationists park their cars at this gate and hike or bike to the mouth of the White River at George Inlet to fish or picnic. Hikers and snowmobilers are known to recreate on the alpine ridges above Upper Mahoney Lake. Alpine access to the upper Mahoney Basin is possible from the White River and the Silvis Lakes/John Mountain/Deer Mountain trail system. Most of these users, however, hike the trail system to Deer Mountain rather than the Upper Mahoney Basin. The trail to Upper Mahoney Basin is long, primitive, and difficult. The number of users of the Upper Mahoney Basin is small, estimated to be less than 50 people per year. Limited sport fishing (less than 50 people per year) also occurs at Lower Mahoney Lake via salt water access from George Inlet. Environmental Impacts and Recommendation: Ls : Construction During construction, machinery and construction-related activity would produce noise, dust, exhaust emissions, and additional traffic, affecting users of Ward Lake Road. These same impacts would detract from the overall recreation experience in the project area. However, these impacts would be minor due to the limited number of people who would be exposed to them and because their duration would be short. Operation Project operation would probably not have a measurable impact on existing or future recreational activities in the Mahoney Lake watershed. Visual impacts from reducing flows in the waterfall between Upper and Lower Mahoney Lakes would occur, but they would be minor since the waterfall can only be seen by air, from portions of the proposed project access road south of Lower Mahoney Lake, and from the east side of George Inlet. As we've said, impacts on fisheries resources, and, therefore, 84 recreational fishing, as a result of project operation are expected to be minor. Saxman proposes no recreational development or enhancements for the project. The existing timber access road that enters ° Cape Fox Corporation land via Ward Lake Road from the north is currently gated, and would remain so during project operation to avoid putting increased pressure on wildlife from increased human activity. As we've said in the terrestrial resources section, because we've received no comments on allowing public access to this area, we don’t object to gating the road as long as people can use the access road with permission from the licensee, and as long as people can still access the project area on foot or by boat. In addition, including ADFG fishing and hunting — regulations in worker standards should be an effective way of preventing fish and game violations during the construction period, but would be unnecessary during project operation since the project, once operational, would only employ, at the most, two people, and would be remotely controlled. Unavoidable Adverse Impacts: None. 8. Socioeconomics Affected Environment: Although Alaska is the largest state in the U.S. by land mass, it is the second smallest state by population. Southeast Alaska comprises 12 percent of the State's population and Ketchikan is Alaska's fourth largest city. The total population for Alaska in 1990 was 553,600 and is estimated to increase to 716,500 by the year 2000. As of February 1996, about 15,080 people lived in the Ketchikan area (Alaska Department of Labor, 1996). The annual growth rate for the state between 1990 and 2000 is anticipated to be about 2.57 percent, while the annual growth rate for Ketchikan is far below that at 0.87 percent (Alaska Department of Labor, 1992). Population trends are affected by employment opportunities. Natural resource-based industries have dominated southeast Alaska's economy in the past and present. They include forestry, fishing, and mining. The Louisiana-Pacific Corporation sawmill in Ketchikan has experienced some stability recently due to the closure of the Sitka mill. Even though the fishing industry has had record runs of fish, low prices are expected to keep employment growth down. The AJ and Greens Creek mines may open in the near future near Juneau, thereby, creating more jobs for southeast Alaska (Alaska Department of Labor, 1994). Recreation and tourism also have a strong effect on the economy. Services needed to keep the tourist industry growing are anticipated to increase. Areas where employment growth is expected to occur are mining, services, and wholesale/retail trade. Declines are forecasted for construction, seafood processing and government (Alaska Department of Labor, 1994). 85 Most of these industries experience seasonal swings in employment, usually peaking in the summer months. Unemployment in the Ketchikan area for 1995 ranged from a high of 11.95 percent in January to a low of 3.7 percent in August. Environmental Impacts and Recommendations: * Construction: Project construction would require onsite employment of up to 50 workers. Up to two permanent full-time jobs would result from long-term project operation. Most construction personnel would be hired from Ketchikan. Some workers might ‘commute b ferry from other islands in southeast Alaska on a weekly basis and stay in motels or camp near the project site during the week and return home on weekends. Few, if any, workers are expected to relocate during the construction period. Because no in- migration of families with school-age children would occur, the Broce would not have a discernable impact on local government services. Short-term benefits to the Ketchikan economy would include reduced unemployment and more local spending by construction workers at retail and service establishments. In addition, the project contractor would undoubtedly purchase some equipment and material from local suppliers, thereby providing additional short-term benefits. Operation: The project would not displace any residences or business establishments. Once the proposed facilities are operational, the project would generate additional revenue for Saxman through the sale of power to KPU. Subsistence evaluation. Section 810 of the Alaska National Interest Lands Conservation Act of 1980 (ANILCA) requires an evaluation by the land-managing agency (in this case the FS) of effects on subsistence hunting, fishing, and gathering resources and the subsistence lifestyle for any project that uses federal lands. Because parts of the project would use federal lands, Saxman, in consultation with the FS, has prepared and filed a subsistence evaluation for the project. The evaluation concludes that constructing the project would not result in a significant restriction of subsistence resources because: (1) the project would have little effect on subsistence species; and (2) although unauthorized access to subsistence resources would be easier after the project access road is constructed, the number of additional people that would enter the area would probably not be enough to affect subsistence resources. The FS concurs with this assessment. 86 Because the project's socioeconomic impacts would be primarily beneficial, we don’t recommend any measures specifically addressing socioeconomics. Unavoidable Adverse Impacts: None. D.__No-Action Alternative Under the no-action alternative, the environmental resources of the area would not change. The license for the project would not be issued and the project would not be built. The energy that would have been produced by the project would not be available, and KPU and Revillagigedo Island would continue to have to rely on diesel generation to meet some of their energy needs. VI. DEVELOPMENTAL ANALYSIS As we've said, the purpose of the Mahoney Lake Project is to generate energy for sale to KPU for distribution in their power system and to offset the need to generate energy using KPU's diesel-fuel powered generators. As KPU's loads increase, the Mahoney Lake Project would produce its full potential of about 46.0 GWh of energy during an average water year and generate a maximum power output of 9.6 MW. Though the project's potential average year generation is 46.0 GWh, the project would provide less energy to KPU until about the year 2016, depending upon how KPU's loads increase. Also, the project would produce less energy in dry years and more in wet years, with the wet year generation limited based on how much energy is available to KPU from its other hydro resources. Taking into account these limits on useable generation from the project, we calculate the annual generation of the project would average about 39.6 GWh over the first 30 years of operation. For the proposed project to be economically beneficial, the estimated levelized cost of the project would have to be less than the current cost of alternative energy from any other sources available to KPU that can supply the regional energy needs. In analyzing the economic benefits of the project, the cost of production and the value of the project's power have been . considered. In 1998 dollars, the cost of the proposed project is $28,521,000. (See detailed construction cost estimate, Table D-1 87 of the Application for License.) 18/ Using our estimate of the average annual generation from the project, the 1998 levelized cost of energy production from the proposed project is $2,856,000 or $0.072 per kWh. To estimate the value of the project's power, we used KPU's estimated costs for diesel generation (Beaver Falls Relicense Application-FERC No. 1922). In 1998 dollars, the levelized cost of continued diesel generation is about $0.10 per kWh considering fuel, O&M, and fixed costs, which gives an annual value of the project's average annual energy generation of $3,900,000. Subtracting the cost of power from the power value shows the project would have an annual net benefit of $1,044,000 or $0.028 per kWh. Therefore, there is a clear economic benefit to the construction of the project. One potential alternative energy source for KPU would be the construction of an intertie transmission line to the Lake Tyee Hydroelectric Project (FERC No. 3015) located about 60 miles north of Ketchikan. Although KPU is still studying the feasibility of the intertie, Appendix H of the license application provides a preliminary comparison of the economics of using power from the intertie, diesel generators, or the Mahoney Lake Project. Using the same assumptions as used to analyze the Mahoney Lake energy costs and assuming a 1999 cost of purchased power over such an intertie of $0.065 (Appendix H, Page 3-4), the current cost of energy over an intertie would be about $0.115 per kWh (See Appendix H, Report Appendix B, Run 4). We conclude that the Mahoney Lake Project could be a more feasible long-term source of power than the intertie. Estimates have been made of the amount of diesel fuel necessary if diesel generation were used to generate the 46 million kWh (potential energy production of the proposed project). Estimates have also been made of the amounts of pollutants-oxides of nitrcg>n (NOx), carbon monoxide (CO), carbon dioxide (C02), and unburned hydrocarbon (UHC) that would be produced by burning diesel fuel. The diesel powerplants do not contain state-of-the-art emission control systems such as catalytic converters and low NOx, but are efficiently operated. Table 8 shows the results of the analysis. Carbon dioxide is considered to be a prime contributor to global warming, and the oxides of nitrogen and unburned 18/ O&M and financing assumptions are shown in Appendix H of the Application for License, Economic and Financial Feasibility Assessment of the Swan/Tyee Lakes Intertie Project, Appendix C, Lifetime Economic Summary. 88 hydrocarbons are considered to be prime contributors to the roduction of acid rain and photo-chemical smog. Carbon monoxide . s a poison. Construction and operation of the Mahoney Lake Project would benefit air quality and the environment because the need for fossil-fueled generation would be avoided or minimized. In previous sections of this EA, the environmental benefits of several resource mitigation measures proposed by Saxman and recommended by the agencies were assessed--such as meeting minimum flows below the project and providing flushing flows each year. Though these measures affect how Saxman must operate the project, they wouldn't have significant effects on the project's power value. In addition, the project as proposed by Saxman includes these measures. Therefore, we haven't separately analyzed the costs of these measures. Table 8. Estimated amounts of diesel fuel and resulting pollutants from equivalent amounts of generation from a diesel fired power plant, per year (Saxman, 1996). Fuel Required per year (gallons) 3,505,000 Diesel Fuel required per year (tons) 11,300 Oxides of Nitrogen (tons) 144 Carbon Monoxide (tons) 288 Carbon Dioxide (tons) 35,000 Unburned Hydrocarbons (tons) 54 Note: Emissions calculations based on the following estimated engine emissions: NOx-2.0 gr/BHP-hr., CO-4.0 gr./BHP-hr, CO,-3.09 lb/1b fuel, UHC-0.75 gr./BHP-hr. The project's use of the energy potential of the site has also been considered. It was found that at the hydraulic capacity of 78 cfs, inflows into Upper Mahoney Lake exceed project capacity about 16 percent of the time. However, due to the 4,000 acre-feet of storage in Upper Mahoney Lake used via the proposed lake tap intake arrangement, nearly all of the total available run-off could be used by the project in an average year. Based on the relationship of plant capacity to river flows and water utilization, the project is appropriately sized. 89 VII. COMPREHENSIVE DEVELOPMENT AND RECOMMENDED ALTERNATIVE Sections 4(e) and 10(a)(1) of the FPA require the Commission to give equal consideration to all uses of the waterway on which the project is located. When we review a proposed project, the recreational, fish and wildlife, and other nondevelopmental values of the involved waterway are considered equally with its electric energy and other developmental values. In determining whether, and under what conditions, to license a project, the Commission must weigh the various economic and environmental tradeoffs involved in the decision. As we've said, several of our recommended measures would affect how Saxman operates the project. However, in this case, none of these measures would significantly affect the project’s power value. In addition, the project as proposed by Saxman includes most of these measures. Therefore, in this case we haven't had to balance the costs versus benefits of these measures. Based on our independent review and evaluation of the proposed project, the proposed project with our additional recommended environmental measures, and the no-action alternative, we have selected the proposed project with some additional recommended environmental measures as the preferred option. Our preferred option includes Saxman's proposed measures and the agency) conditions that have been filed with some modifications. We discuss these measures below by resource area. We recommend that Saxman finalize and file for Commission approval, their proposed ESCP after consultation with the agencies. The final ESCP should include the conditions filed by the ADFG for monitoring and protecting South Creek spawning gravels (limiting road and bridge construction within 150 feet of the stream to the June 15-August 1 period). We also recommend that the limits on construction for South Creek be extended to construction activities that would directly involve Upper Mahoney Creek water to protect spawning gravels at the mouth of Upper Mahoney Creek. Elows Upper Mahoney Creek Flows. We recommend that Saxman implement the 13-cfs Upper Mahoney Creek minimum flow condition submitted by the FWS. We further recommend that the project be restricted to a maximum discharge of 50 cfs from August 1 until Upper Mahoney Lake fills, or October 31, whichever occurs first, to ensure that project operation does not prevent the lake from filing. In years when Upper Mahoney Lake cannot be completely refilled by November 1 because of low water conditions, the minimum flow in Upper Mahoney Creek below the tailrace, from November 1 through April 30, would be 13 cfs, or the instantaneous inflow to Upper Mahoney Lake, whichever is less. 90 Lower Mahoney Creek Pa ge Flows. We recommend that the project only be required to provide a minimum flow of 44 cfs, the project’s drainage area proportion of 120 cfs in Lower Mahoney Creek, or the natural inflow to Upper Mahoney Lake, whichever is less, during August and September to protect salmon passage. We also recommend that the project be operated such that, to the extent it is possible, a maximum of 200 cfs is maintained in Lower Mahoney Creek during August and September. Therefore, we are recommending that the project not be operated during August and September when flows in Lower Mahoney Creek exceed 200 cfs except under two conditions: (1) there are spill flows from Upper Mahoney Lake that would cause the flows in Lower Mahoney Creek to exceed 200 cfs whether the project were operating or not; or (2) flow releases by the project are necessary to maintain FWS's mandatory minimum flow requirement in Upper Mahoney Creek. We further adopt the modified condition by the ADFG that studies be performed prior, during, and after construction to better define the fish passage requirements for Lower Mahoney Creek. If the results of the recommended studies show that a different flow regime is required to maintain fish passage, the alternative flows would be implemented. Bypass Pipeline. We recommend that the capacity of the Proposed pipeline be adequate to maintain minimum flows up to 44 cfs, the project's drainage area Proportion of the minimum flows required for Lower Mahoney Creek during August and September. This would also accommodate the required minimum flows for Upper Mahoney Creek. Flushing Flows. We recommend adoption of the FWS’s condition for an annual flushing flow requiring a project release of 78 cfs over 48 hours, coinciding with a rainfall event. Non-compliance reporting. ADFG’s 12-hour non-compliance on flows reporting condition would require earlier reporting than commonly required by the Commission; however, considering the low minimum flow requirement, the unpredictability of project flows with an undefined operational mode (see Mode of operation), and the sensitivity of the early life stages to be protected by the flows, we recommend that Saxman be required to report any violations of required flows in Upper Mahoney Creek, if they occur, within 12 hours. We recommend that Saxman, in consultation with the USGS, the FS, the NMFS, the FWS, and the ADFG, prepare a plan to install streamflow monitoring equipment in Upper and Lower Mahoney Creeks as required by the ADFG. Existing equipment may be incorporated into the plan if the consulted agencies agree and the equipment meets the USGS’s standards. We agree with and 91 recommend adoption of the ADFG’s conditions regarding discharge data reporting. In addition to what Saxman is proposing for monitoring of salmon spawning in Mahoney Lake and passage through Lower Mahoney Creek, we recommend the following. hods for Upwelling Temperatures. We recommend that the met determining the pre-project upwelling temperature range and any adverse effects from post-project temperature conditions on sockeye salmon be defined prior to the start of project operation. We recommend monitoring intragravel temperatures at five locations and initiating biotic monitoring if temperature me monitoring shows potentially adverse project effects. If mee led, Saxman should prepare a biotic monitoring plan, in consultation with the FS, the NMFS, the FWS, and the ADFG, and file it with the Commission for approval. Salmon Emergence. We recommend that Saxman, in consultation with the FS, the NMFS, the FWS, and the ADFG, prepare a planter monitoring emergence timing in the spawning areas at the outlet of Upper Mahoney Creek and South Creek, and submit it to fe Commission for approval. Emergent monitoring should cont oe until data are available for returning adults that emerged after the project began operations or until the resource agencies agree that there are no significant project related temperature ; effects, whichever is longer. If the results of the monitor a indicate any adverse project effects, Saxman should consult wit! the FS, the NMFS, the FWS, and the ADFG to determine any _ appropriate actions to minimize any effects of the project on t! a Lower Mahoney Lake sockeye salmon. If agreed to by the cone Ee agencies, an alternative to emergence monitoring, such as smolt outmigration may be considered to monitor any early project effects on the salmon resource. ie. We recommend that the monitoring program Peaai reahiy th FG for salmon migration and spawning continue for 10 years following the start of operation, or until the FS, the NMFS, the FWS and the ADFG, are confident that the project's flow regime does not adversely affect adult salmon migration, whichever is longer. We recommend adoption of the FWS’s condition for a 3-year post-construction monitoring report describing salmon access to spawning habitat within Lower Mahoney Lake, fish population status, and making recommendations for improving salmon recruitment, or otherwise improving aquatic habitat conditions. We further recommend that the City, in consultation with the FS, the NMFS, the FWS, and the ADFG, prepare a plan for filing the report, including the methodologies to be used for making the 92 post-construction assessment, and submit it for Commission approval. We recommend that a terrestrial resource protection plan be developed to include: (1) Saxman's proposals for designing and constructing the transmission line to protect raptors, avoiding clearing of mountain goat winter habitat, avoiding sensitive plant species near the upper tunnel construction site, timing construction activities to avoid adverse effects on raptor nesting and mating, and safely storing refuse during construction to avoid human-bear encounters. (2) The FWS and ADFG conditions on avoiding mountain goat disturbance during project construction, the ADFG condition on mitigating bald eagle disturbances during the breeding season, and the ADFG condition on including ADFG fishing and hunting regulations in work standards and contracts for the project workers to avoid species exploitation. Visual Resources We recommend that Saxman's proposed measures for protecting visual resources be incorporated into.a visual resources protection plan to be filed with the Commission for approval after consultation with the agencies. These measures include: (1) using existing topographic and vegetative features in the final design of the transmission line to screen the line from George Inlet; (2) blending other above-ground project features with the surrounding landscape; (3) limiting clearing to the extent feasible; (4) locating rock sources for the new access road off of the main road system; and (5) including in construction plans the continual cleanup of ground- disturbing activities. We also recommend that Saxman's proposal to bury the project transmission line from the powerhouse to the switchyard be required in any license that is issued to protect the visual resources of Lower Mahoney Lake. Cultural Resources We recommend that the cultural resources management plan that Saxman is proposing for historic or archeological sites that may be discovered during project construction or operation include Saxman's proposed measures for protecting the Mahoney Mine site during project construction. Public Access We recommend that Saxman's proposal for allowing public access to the project area through a permit system be formalized through a plan that describes how potential users would be made aware of and obtain the permits. The plan mous still allow people to access the project area on foot or yy boat. We recommend this option because: (1) the 9.6-MW project would eliminate the need for an equivalent amount of fossil-fuel- derived energy and capacity, which helps to conserve these 93 nonrenewable resources and to limit atmospheric pollution; (2) the environmental impacts from the project would be relatively minor; and (3) the public benefits of the selected alternative would exceed those of the no-action alternative. VIII. CONSISTENCY WITH COMPREHENSIVE PLANS Section 10(a) (2) of the FPA requires the Commission to consider the extent to which a project is consistent with federal and state comprehensive plans for improving, developing, and conserving waterways affected by the project. Twenty-two plans are currently on the Commission list of comprehensive plans for the state of Alaska. Three of these plans address resources relevant to the Mahoney Lake Project, and are discussed below. 19/ Plan) The Forest Plan divides the forest into management areas through Land Use Designations (LUDs) and provides direction for managing activities in those areas. A hydroelectric project can, depending on its configuration, affect more than one management area. As we've said, Upper Mahoney Lake, the lake tap intake, the upper tunnel, most of the lower tunnel, and most of the project transmission line would be located on FS land, 114 total acres. These areas are designated as Semi-Remote Recreation and Timber Production. Semi-Remote Recreation Upper Mahoney Lake and Upper Mahoney Creek fall under this designation. The goals for this LUD are: (1) to provide predominantly natural-appearing settings for semi- primitive types of recreation and tourism, and (2) to provide opportunities for a moderate degree of independence, closeness to nature, and self-reliance in an environment requiring challenging forms of transportation - motorized or non-motorized. The setting should generally be unmodified, with the natural condition only minimally affected by past or current human uses or activity. Within this LUD, transportation and utility sites are permitted, but these uses must be consistent with semi-remote recreation objectives. These include limiting the number of social encounters, limiting facility and road development, and 19/ (1) Land and Resource Management Plan, Tongass National Forest, U.S. Forest Service, 1997, Ketchikan, Alaska (2) Alaska Outdoor Recreation Plan: 1981-1985, Alaska Department of Natural Resources, Division of Parks, 1981, Juneau, Alaska (3) North American Waterfowl Management Plan, U.S. Fish and Wildlife Service and Canadian Wildlife Service, 1986, Twin Cities, Minnesota. 94 designing activities to be visually subordinate to the characteristic landscape. Based on the analysis presented in this EA, construction and operation of the lake tap and project power tunnels would not significantly affect the recreation or visual resources in this LUD. Neither Upper Mahoney Lake nor Upper Mahoney Creek support recreational fisheries within the FS LUD. Upper Mahoney Creek does support a population of Dolly Varden near the proposed powerhouse site, but this area is on Cape Fox land, outside of the LUD. There would also be very little, if any, noticeable change in recreational access to the project area. People could still access the project area on foot, but the road into the site would remain gated as is the existing road. There would be some visual impacts during construction and from dewatering Upper Mahoney Creek and drawing down Upper Mahoney Lake during project operation, but these impacts would also be minor since they would, for the most part, only be visible from the air. Timber Production Most of the project’s approximately 3- mile-long, overhead transmission line would fall within this LUD. The goal for the LUD is to provide a continuous supply of wood to meet society's needs. In general, other activities within this LUD are subordinate to the purpose of timber production. Special use authorizations such as utility sites or corridors are permitted in this LUD, but those that require a natural setting are to be avoided. Best management practices are to be applied to all land-disturbing activities to protect beneficial uses of water. For visual resources, management activities may dominate the seen area, yet should be designed to borrow from the form and line found in the naturally-occurring landscape. Managed recreation activities are to be compatible with timber production objectives. Constructing the overhead portion of the project transmission line would be consistent with timber production objectives. Construction would only involve the clearing of about 77 acres of forest, and would be done within the requirements of an approved soil erosion and sedimentation plan to protect water quality. The line would be screened from most potential viewing areas by the dense surrounding vegetation. No managed recreation activities are anticipated. Because constructing and operating the project with our recommended measures would not significantly affect the environmental resources within the above LUD's, we conclude that the proposed project would be consistent with the Forest Plan. 95 North American Waterfowl Management Plan (NAWMP) The NAWMP sets goals for conserving North American waterfowl through cooperative planning and management. The plan provides the framework for a waterfowl conservation effort by describing population and habitat goals and suggesting recommendations to resolve problems of international concern through the year 2000. The plan’s intent is to set the stage for the development of national, flyway, provincial, territorial, and state plans that contain specific management measures for waterfowl conservation in the United States and Canada. The plan recognizes that habitat loss and degradation is the major waterfowl problem in North America and sets habitat conservation as a top priority. The only foreseeable impact that the Mahoney Lake Project could have on waterfowl would be temporarily displacing individuals due to noise and other human activity during the construction phase. However, this impact would be minor since the project lakes aren’t important habitat for waterfowl. aheretores we conclude that the project would be consistent with the NAWMP. : Alaska Outdoor Recreation Plan (AORP) Based on a survey of 2,865 residents, the AORP identifies citizen preferences and suggested actions to address outdoor recreation.issues in the state. The plan identifies the following issues: »The state needs to maintain its recreational land base. »The outdoor recreation needs of urban Alaskans must be met with sites near people's homes. »Cooperation among agencies is essential to successfully meeting state recreation needs. »Preserving and protecting Alaska’s culture and history is critical in maintaining the state’s distinct identity. *High quality outdoor recreation experiences must be perpetuated and enhanced. The Mahoney Lake Proj‘ct would have little, if any, noticeable affect on outdoor recreation. Current access opportunities wouldn’t change since the existing access road would remain gated. The new project access road could encourage some additional use of the project area, but the available information indicates that demand for using this area is low. No known cultural resources would be affected, and the project isn’t close enough to Ketchikan to meet the needs of urban Alaskans. Based on our assessment, then, we find the project would be consistent with the AORP. 96 IX. FINDING OF NO SIGNIFICANT IMPACT We prepared this EA for the Mahoney Lake Project in accordance with the National Environmental Policy Act of 1969. Constructing the proposed project would have some unavoidable adverse impacts; some temporary, some permanent. Temporary impacts would include short-term, localized erosion and sedimentation; increased traffic, noise, and dust which would temporarily displace wildlife, detract from the area's scenic quality, and detract from recreational use. Implementing the recommended soil erosion and sedimentation control plan should mitigate these impacts to minor levels. Permanent impacts would include: the loss of about 99 acres of old-growth coniferous forest habitat, an increase in the density of about 77 additional acres adjacent to cleared areas, the potential loss of about 140 choris bog orchids, and minor visual impacts from reduced streamflows, lake drawdowns, and Project features. These impacts are expected to be minor because sensitive habitats would be avoided, there is an abundance of similar habitat in the area, and the exposure of project features to public view is very limited. On the basis of this independent environmental analysis, issuance of a license for the project with our recommended environmental measures would not constitute a major federal action significantly affecting the quality of the human environment. Therefore, an environmental impact statement is not required. X. LITERATURE CITED Alaska Department of Fish and Game, U.S. Fish and Wildlife Service, National Marine Fisheries Service, Bureau of Land Management, U.S. Forest Service. 1994. Alaska's Threatened and Endangered Species. Juneau, Alaska. 29 Pp. Alaska Department of Labor, Administrative Services Division, Demographics Unit. Alaska Population Projections, 1990- 2010. November 1991, Second Printing March 1992. 105 pp. Alaska Department of Labor, Research and Analysis Section. 1994. Alaska Economic Trends, 1994-95 Forecast. Volume 14, Number 5. May 1994. 20 pp. Ambrose, R.E., R.J. Ritchie, C.M. White, P.F. Schempf, T. Swem, R. Dittrick. 1988. Changes in the status of peregrine falcon populations in Alaska. IN: Peregrine Falcon Populations-Their Management and Recovery, ed. T.J. Cade, J.H. Enderson, C.G. Thelander and C.M. White. The Peregrine Fund, Inc. Boise, Idaho. 97 i Alaska Armstrong, R.H. 1983. Guide to the Birds of Alaska. “me Rortiwest Publishing Company, Anchorage, Alaska. Michael L., Paul F. Springer and Nancy Dailey. 1980. apes Mortality at Man-made Structures: An_ Annotated Bibliography (Revised). U.S. Fish and Wildlife Service, National Power Plant team, FWS/OBS - 80/54. 152 pp. * . Suggested Power Line Interaction Committee (APLIC) 1996 Tr for raptor protection on power lines: the state of the art in 1996. Edison Electric Institute/Raptor Research Foundation. Washington, D.C. 125 pp. with appendices. Line Interaction Committee (APLIC). 1994. Avian teigating Bird Collisions with power lines: the state of the art in 1994. Edison Electric Institute, Washington, D.C. Item #06-94-33. 87 pp. with appendices. i Andrew R., Joseph J. Beatty, Deanna H. Olson, and Pea pres M. Storm. 7995. The biology of amphibians and reptiles in old-growth forests in the Pacific northwest. General Technical Report, PNW-GTR-337. Pacific Northwest Research Station, Corvallis, Oregon. 98 pp. , S. 1995. Biological Evaluation for Animals. Mahoney eee aeoo Hydroelectric Project, Ketchikan Ranger District, Tongass National Forest. HDR Engineering Inc. Anchorage, Alaska. November 21, 1995. 11 pp. Campbell, C.R. 1996. An archeological survey of Mahoney ae Hydroelectric Power Project, FERC Project No. 11393-000 for the City of Saxman, Alaska. C.R.C. Cultural Resource Consultant, Ketchikan, Alaska. 17 pp. ick, D.H. 1983. Mountain goat ecology-logging See or tasranise in Bunker Creek drainage of western Montana. M.S. Thesis. University of Montana, Missoula, Montana. 260 pp. i in - Mahoney City of Saxman. 1994. Final consultation document ase Lake Hydroelectric Project, FERC No. 11393. City of Saxman, Alaska. August 1994. a R it £ Saxman. 1995. Flow Regime Report Prepared by HD! ae miainesring® Bellevue, Washington for the City of Saxman, Alaska - Mahoney Lake Hydroelectric Project, FERC No. 11393. City of Saxman, Alaska. June 1995. City of Saxman. 1996. Application for license for major unconstructed project - Mahoney Lake Hydroelectric Project. No. 11393-001. City of Saxman, Alaska. May 1996. 98 Cole, G. A. 1983. Textbook of Limnology. Waveland Press, Inc., Prospect Heights, Illinois. Connor, R.C. and D.M. Peterson. 1994. The Lives of Whales and Dolphins. American Museum of Natural History. Henry Hot and Company. New York, New York. 233pp. Corps of Engineers. 1978. Proposed environmental impact statement-proposed Mahoney Lakes project. Department of the Army, Alaska District Corps of Engineers, Anchorage, Alaska. Corps of Engineers. 1983. Rivers and harbors in Alaska, draft interim feasibility report and environmental impact statement. Hydroelectric power for Sitka, Petersburg/Wrangell, and Ketchikan, Alaska. Department of che ACY: Alaska District Corps of Engineers, Anchorage, Alaska. Cowardin, Lewis M., Virginia Carter, Francis C. Golet, and Edward T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. U.S. Fish and Wildlife Service, Office of Biological Sciences. FWS/OBS-79/31. December: 1979. 131 pp. Crocker-Bedford, Coleman D. 1994. Conservation of the Queen Charlotte goshawk in southeast Alaska, appendix to: A proposed strategy for maintaining well-distributed, viable populations of wildlife associated with old growth forests in southeast Alaska. The Interagency Viable Population Committee for Tongass Land Management Planning. Crowley, David W. 1993. Breeding habitat of harlequin ducks in Prince William Sound, Alaska. Master of Science Thesis. Oregon State University, Corvalis, Oregon. December 9, 1993. 59 pp. with appendix. DeMeo, T., J. Martin, R.A. West. 1992. Forest Plant Association Management Guide, Ketchikan Area, Tongass National Forest. U.S. Department of Agriculture, Forest Service. Alaska Region R10-MB-210. Ketchikan, Alaska. December 1992. Duffy, M. 1994. The Mahoney Lakes Area of Revillagigedo Island, Southeastern Alaska: A Sensitive Species Survey. Alaska Natural Heritage Program, Environment and Natural Resources Institute, University of Alaska Anchorage. Anchorage, Alaska. Electric Power Research Institute. 1993. Proceedings: Avian Interaction With Utility Structures, International Workshop. Miami, Florida. EPRI TR-103268, Project 3041. September 13- 16, 1992. 99 Environmental Protection Agency. 1986. Quality criteria for water. U.S. Environmental Protection Agency, Office of Water Regulations and Standards, Washington, D.C. EPA 440/5-86-001. Fox, J.L., C.A. Smith, and J.W. Schoen. 1989. Relation between mountain goats and their habitat in southeastern Alaska. U.S. Department of Agriculture, Forest Service PNW-GTR-246. Groot, C. And L. Margolis, editors. 1991. Pacific salmon life histories. UBC Press, Vancouver, British Columbia, Canada. Hayes, M.P. and M. R. Jennings. 1986. Decline of ranid frog species in western North America: are bullfrogs (Rana catesbiana) responsible? J. Herpetology 20(4) :490-509. Jones, M.L., Swartz, S.L., and Leatherwood, S. (eds.). 1984. The Gray Whale Eschrichtius robustus. Academic Press, Orlando, Florida. Leggett, A. 1995. Biological Evaluation for Plants. Mahoney Lake Hydroelectric Project, Ketchikan Ranger District, Tongass National Forest. HDR Engineering Inc. Anchorage, Alaska. November 20, 1995. 13 pp. with appendices. Muller, M.C. 1991. Field Guide to Rare Vascular Plants of the National Forests in Alaska. USDA Forest Service, Alaska Region. R10-MB-128. Olendorff, R.R., A.D. Miller, and R.N. Lehman. 1981. Suggested practices for raptor protection on power lines: the state of the art in 1981. Raptor Research Foundation, Inc., Raptor Research Report No. 4. St. Paul, Minnesota. 111 pp. Olendorff, R.R. and R.N. Lehman. 1986. Raptor collisions with utility lines: an analysis using subjective field observations. Bureau of Land Management. Prepared for Pacific Gas and Electric Company. February 1986. 73 pp. Pacific Seabird Group. 1995. The Marbled Murrelet. A pamphlet of the Pacific Seabiftd Group. Seattle, Washington. August 1995. 4 pp. Standley, L.A. 1985. Systematics of the Acutae group of Carex (Cyperacea) in the Pacific Northwest. Systematic Botany Monographs, The American Society of Plant Taxonomists. Vol. 7. Steiglitz, W. 1994. Petition to list the Alexander Archipelago Wolf under provisions of the Endangered Species Act, ninety- day petition finding. U.S. Department of the Interior, Fish and Wildlife Service, Anchorage, Alaska. March 4, 1994. 100 Tennant, D.L. 1976. Instream flow regimens for fish, wildlife, recreation and related environmental resources. Fisheries 1(4) :6-10. U.S. Forest Service. 1991. Tongass Land Management Plan Revision-Supplement to the Draft Environmental Impact Statement. Parts 1 and 2. U.S. Department of Agriculture- Alaska Region. R10-MB-149, August 1991. 7 chapters with appendices. Viereck, L.A., C.T. Dyrness, A.R. Batten, and K.J. Wenzlick. 1992. The Alaska Vegetation Classification. U.S. Department of Agriculture, U.S. Forest Service. General .Technical Report PNW-GTR-286. July 1992. 278 pp. Wallmo, 0.C. and J.W. Schoen. 1980. Response of deer to secondary forest succession in southeast Alaska. Forest Sci. Vol. 26, No. 3, pp. 448-462. Waters, Dana L. 1992. Habitat associations, phenology, and biogeography of amphibians in the Stikine River basin and southeast Alaska. A report to the 1991 pilot project. U.S. Fish and Wildlife Service. Arcata, California. May 28, 1992. 61 pp. West, E. 1993. Rare vertebrate species of the Chugach and Tongass National Forests, Alaska. Alaska Natural Heritage Program, The Nature Conservancy, Anchorage, Alaska. XI. LIST OF PREPARERS Vince Yearick - Environmental Coordinator - Geology and Soils, Aesthetics, Recreation, Land Use, and Socioeconomics, FERC (Environmental Protection Specialist; B.S. Agricultural Economics, M.S. Recreation and Parks) Nan Allen - Aquatic Resources, FERC (Fisheries Biologist; M.S., Biology) Jim Fargo - Developmental Resources, FERC (Supervisory Civil Engineer; M.S., Civil Engineering) Carl J. Keller - Terrestrial Resources and Threatened and Bie ea len Species, FERC (Wildlife Biologist; M.S., Wildlife Biology Edwin Slatter - Cultural Resources, FERC (Archeologist; Ph.D. Anthropology) 101 XII. LIST OF REVIEWERS Teresa Trulock - Environmental Coordinator - Recreation and Land Use Resources, U.S. Forest Service (Resource Assistant; B.S., Forest Management) Bill Angelus - Aesthetic Resources, U.S. Forest Service (Landscape Architect; B.S., Landscape Architecture) Bill Baer - Aquatic and Wildlife Resources, U.S. Forest Service (Supervisory Biologist; B.S., Wildlife Management) 102 Appendix A Forest Service Section 4(e) Conditions I. GENERAL License articles contained in the Commission's Standard Form L-2 (revised October, 1975) issued by Order No. 540, dated October 31, 1975, cover general requirements that the Secretary of Agriculture, acting by and through the Forest Service, considers necessary for adequate protection and utilization of the land and resources of the Tongass National Forest For the purposes of section 4(e) of the Federal Power Act (16 U.S.C. 797 (e)), the purposes for which National Forest System land were created or acquired shall be the protection and utilization of those resources enumerated in the Organic Administration Act of 1897 (30 Stat. 11), the Multiple-Use Sustained Yield Act of 1960 (74 Stat. 215), the National Forest Management Act of 1976 (90 Stat. 2949), and any other law specifically establishing a unit of national Forest System or prescribing the management thereof (such as the Wilderness Act or Wild and Scenic Rivers Act), as such laws may be amended from time to time, and as implemented by regulations and approved Forest Plans prepared in accordance with the National Forest Management Act. Therefore, pursuant to said section 4(e)-of the Federal Power Act, the following conditions covering specific requirements for protection and utilization of National Forest System lands shall also be included in any license issued. II. STANDARD FOREST SERVICE PROVISIONS Condition No. 1 - Requirement to Obtain a Forest Service Special Use Authorization Within six months following the date of issuance of this license and before starting any activities the Forest Service determines to be of a land-disturbing nature, the Licensee shall obtain from the Forest Service a special-use authorization for the occupancy and use of National Forest System lands, and that authorization shall be filed with the Director, Office of Hydropower Licensing. The licensee may commence land-disturbing activities authorized by the license and special-use authorization 60 days following the filing date of such authorization, unless the Director, Office of Hydropower Licensing, prescribes a different commencement schedule. Notwithstanding the authorizations granted under the Federal Power Act, National Forest System lands within the project boundaries shall be managed by the Forest Service under the laws rules, and regulations applicable to the National Forest System. The terms and conditions of the Forest Service special use authorization are enforceable by the Forest Service under the laws, rules, and regulations applicable to the National Forest 103 System. The violation of such terms and conditions also shall be subject to applicable sanctions and enforcement procedures of the Commission at the request of the Forest Service. In the event there is a conflict between any provisions of the license and Forest Service special-use Authorization, the special-use authorization shall prevail on matters which the Forest Service deems to affect National Forest System resources. Condition No. 2 - Forest Service Approval of Final Design Before any construction of the project occurs on National Forest System land, the Licensee shall obtain the prior written approval of the Forest Service for all final design plans for project components which the Forest Service deems as affecting or potentially affecting National Forest System resources. The Licensee shall follow the schedules and procedures for design review and approval specified in the Forest Service special-use authorization. As part of such prior written approval, the Forest Service may require adjustments in final plans and facility locations to preclude or mitigate impacts and to ensure that the project is compatible with on-the-ground conditions. Should such necessary adjustments be deemed by the Forest Service, the Commission, or the Licensee to be a substantial change, the Licensee shall follow the procedures outlined in Article 2 of the license. Any changes to the license made for any reason pursuant to Article 2 or Article 3 shall be made subject to any new terms and conditions of the Secretary of Agriculture made pursuant to sections 4 (e) of the Federal Power Act. Condition No. 3 - Approval of Changes After Initial construction Notwithstanding any license authorization to make changes to the project, the Licensee shall get written approval from the Forest Service prior to making any changes in the location of any constructed project features or facilities, or in the uses of project lands and waters, or any departure from the requirements of any approved exhibits filed with the Commission. Following receipt of such approval from the Forest Service, and at least 60 days prior to initiating any such changes or departure, the Licensee shall file a report with the Commission describing the changes, the reason for the changes, and showing the approval of the Forest Service for such changes. The Licensee shall file an exact copy of this report with the Forest Service at the same time it is filed with the Commission. This article does not relieve the Licensee from the amendment of other requirements of Article 2 or Article 3 of this license. Condition No. 4 - Consultation Each year during the 60 days preceding the anniversary date of the license, the Licensee shall consult with the Forest Service with regard to measures needed to ensure protection and development of the natural resource values of the project area. 104 Within 60 days following such consultation, the Licensee shall file with the Commission evidence of the consultation with any recommendations made by the Forest Service. The Commission reserves the right, after notice and opportunity for hearing, to require changes in the project and its operation that may be necessary to accomplish natural resource protection. III, OPTIONAL FOREST SERVICE PROVISIONS Condition No. 5 - Cultural Resources If previously unidentified archeological or historic sites are discovered during project construction or operation, the licensee shall: (1) cease operations and consult with the Alaska State Historic Preservation Officer (SHPO) and the Forest Service, (2) prepare a cultural resources management plan and a schedule to evaluate the significance of the sites and to avoid or mitigate any impacts to any sites found eligible for inclusion in the National Register of Historic Places; (3) base the plan on the recommendations of the SHPO and the Secretary of the Interior's Guidelines for Archeology and Historic Preservation; (4) file the plan for. Commission approval, together with the written comments of the SHPO on the plan; and (5) take the necessary steps to protect the discovered sites from further impact until notified by ers CC that all of these requirements have been satisfied. The Commission may require a cultural resources survey and changes to the cultural resources management plan based on the filings. The Licensee shall not implement a cultural resources management plan or begin any land clearing or land disturbing activities ln the vicinity of any discovered sites until informed by the Commission that the requirements of this provision have been fulfilled. Condition No. 6 - Erosion Control Plan Within one year following the date of issuance of this license and before starting any activities the Forest Service determines to be of a land-disturbing nature on NFS land, the Licensee shall file with the Director, Office of Hydropower Licensing, a plan approved by the Forest Service for the control of erosion, and soil mass movement. The Licensee shall not commence activities the Forest Service determines to be affected by the plan until after 60 days following the filing date, unless the Director, Office of Bycropowey Licensing, prescribes a different commencement schedule. 105 Appendix B Fish and Wildlife Service Conditions The original conditions filed by letter dated November 4, 1996: (1) Helicopter flights shall be routed at least 1/4 mile from all active eagle nest trees and no construction within 660 feet, nor blasting within 1/2 mile, of active eagle nest trees shall be allowed between March 1 and August 31 (2) Flows of at least 30 cfs must be maintained in Upper Mahoney Creek immediately below the tailrace at all times between August 1 and July 15, to maintain water flow through salmon spawning area such flows may come from natural inflow to Upper Mahoney Creek, the proposed 12-inch bypass pipe, or through the turbine jets. (3) The applicant shall implement their proposed monitoring plan titled “Mahoney Lake Hydroelectric Project Aquatic Resources monitoring Plan,” transmitted to the Service on May 9, 1996. Any alternative to this plan must otherwise be specifically approved by the Service (4) The applicant shall provide a report to the Service after three years of post construction monitoring, describing salmon access to spawning habitat within Lower Mahoney Lake, and fish population status. This report shall make recommendations for improving salmon recruitment, or otherwise improving aquatic habitat conditions. The report shall be provided by January 15 following the third spawning season after project construction. Within one year of submission of this report, the applicant and the Service shall negotiate a remediation plan to correct any perceived problems, and the applicant shall implement the plan. The Alaska Department of Fish and Game and National Marine Fisheries shall be invited to participate in the discussions. The above conditions were modified by letter dated April 4, 1997, as follows and by letter dated August 12, 1997 (Appendix D): Instantaneous flows immediately below the powerhouse tailrace shall be maintained continuously at or above 13 cubic feet per second (cfs) year-round, except when the project is offline, when the average daily flow shall equal or exceed 13 cfs. Flushing flows of 78 cfs shall be provided in the tailrace for at least one period of 48 continuous hours, coinciding with a rainfall event, between May 1 and August 15 each year. Instantaneous flows between 5 and 13 cfs are allowed, for a maximum of 48 hours per calendar month, from November 1 through April 30 during or immediately following periods of low precipitation. These low flows may only occur during a maximum of one winter in any period of five consecutive winters. 106 Appendix C Alaska Department of Fish and Game Conditions The original conditions filed by letter dated November 26, 1996: The ADFG offers the following terms and conditions for construction and operation of the Mahoney Lake Hydroelectric Project, in the event that a license is issued for this project. It is our understanding the applicant, the City of Saxman, seeks benefits under Section 210 of the Public Utility Regulatory Policy Act of 1978 (PURPA), and the ADFG is provided mandatory conditioning authority under the procedures provided per Section 30(c) of the Federal Power Act. Page 26 of the PDEA references a U.S. Fish and Wildlife Service citation (USF&WS 1978) although it was not included in the Literature Cited section. Referring to the citation, the PDEA states that there is no evidence of Arctic grayling in Upper Mahoney Lake. This reference does not state the type or duration of sampling conducted to reach this conclusion. If the 1978 Fish and Wildlife Service information is incorrect and grayling or other species are present in Upper Mahoney Lake, the proposed drawdown will be detrimental to the fish resources. Therefore, the applicant should perform appropriate onsite investigations to verify and describe fish distribution by species and life phase for this and all waters potentially affected by this project. Our staff would also like to review the procedures and schedule that will be used for this investigation. We would also appreciate being provided the option to participate in onsite sampling. CONSTRUCTION Construction and blasting activities could be detrimental to parturient mountain goat nannies and newborn kids. Therefore, surface blasting shall not occur between May 15 and June 30. Subsurface blasting may occur between May 15 and June 30 unless and until detrimental effects on parturient mountain goat nannies or newborn kids are determined by the ADFG to be occurring. Air traffic, particularly rotor wing, can cause detrimental effects on mountain goats of both genders during all life stages. Therefore, project air traffic shall be restricted to a 0.5 mile-wide corridor centered on Lower Mahoney Lake, Upper Mahoney Lake, and Ketchikan Lakes, including the two-lake basin upstream of Upper Mahoney Lake. In particular, the mountain goat habitats on Mahoney Mountain, John Mountain, and Fish Mountain, exclusive of the two-lake basin upstream of Upper Mahoney Lake, shall be avoided at all times by project-associated aircraft. As indicated in the PDEA and Appendix B of the Application, construction activities associated with excavation of overburden soils for the powerhouse, staging area, tailrace, and powerhouse access road may increase sediment to Upper Mahoney Creek and the 107 spawning gravel within Lower Mahoney Lake. The effectiveness of the erosion and sediment control measures shall be determined through water quality sampling. From the initiation of construction and continuing for 60 days following the removal of all temporary erosion control structures, water samples shall be taken daily from Upper penoney, Creek upstream and downstream of all construction activities, including all overland flow that crosses construction areas, but above the inlet to Lower Mahoney Lake, and analyzed for turbidity. Measurements may be taken using a portable turbidimeter if such can be shown to have the appropriate resolving power. If turbidity below the construction area measures greater than 5 nephelometric turbidity units (NTU higher than the values obtained above the construction area, then all construction activities shall cease, sediment sources shall be located, and appropriate sediment control measures shall be implemented. Daily turbidity data shall be submitted to the ADFG Division of Habitat and Restoration office in Ketchikan weekly. To reduce the introduction of sediment to spawning gravel at the outlet of South Creek, road and bridge construction within 150 feet of South Creek shall acetl occur between June 15 and August 1. Exceptions to this condition (such as clearing, grubbing, and road construction between 150 and 50 feet from South Creek, or bridge installation without activities within the limits of ordinary high water) may be granted in writing by the ADFG in response to detailed, site specific proposals from the applicant. A 12-inch diameter bypass pipeline from the Upper Mahoney Lake valve house to Upper Mahoney Creek is currently proposed to allow the continuance of flows in Upper Mahoney Creek in the event of a shutdown or other action that stops the flow of water into Upper Mahoney Creek from the tailrace. Based on our analyses of required instream flows noted in the operation section, this may be inadequate. OPERATION From August 1 through September 30, storage and release of water from Upper Mahoney Lake shall be conducted based on maintaining Lower Mahoney Creek flows ranging between 120 and 200 cubic feet per second (cfs) for adult salmon migration. The rate of flow from Lower Mahoney Lake shall be continuously monitored throughout the year to identify operational schemes to achieve these mandatory flows. Project design and operation shall incorporate fail-safe and redundant backup provisions to insure that flows will be provided during routine maintenance periods and during emergency project shut downs. It does not appear that the proposed 12-inch diameter bypass line as currently configured will meet this criterion. Project design and operations should include remote monitoring and operation of all project components. 108 MONITORING AND ENFORCEMENT All discharge measurements must comply with standards established by the U.S. Geological Survey (USGS). Instantaneous discharge shall be measured in Upper Mahoney Creek on a continuous basis at a location between the tailrace and 75 feet downstream of the tailrace. Mean daily and continuous discharge data shall be submitted monthly to the ADFG Division of Habitat and Restoration office in Ketchikan, the ADFG Statewide Instream Flow Coordinator, and other interested parties, in documented electronic format for the first year of operation, and annually after that. If a rating curve or any other regression relationship is used to calculate discharge then the data used to build this regression relationship also must be submitted annually. Intragravel water temperature shall be measured from a minimum of five locations throughout the spawning area in Lower Mahoney Lake at the mouth of Upper Mahoney Creek. These data shall be submitted monthly to the ADFG Division of Habitat and Restoration office in Ketchikan, the ADFG Statewide Instream Flow Coordinator, and other interested parties, in documented electronic format for the first year of operation, and annually after that. Instantaneous discharge shall be measured continuously in Lower Mahoney Creek. Mean daily and continuous discharge data shall be submitted monthly to the ADFG Division of Habitat and Restoration office in Ketchikan, the ADFG Statewide Instream Flow Coordinator, and other interested parties, in documented electronic format for the first year of operation, and annually after that. If a rating curve or early other regression relationship is used to calculate discharge then the data used to build this regression relationship also must be submitted annually. If during project operation discharge and/or water temperature in Lower Mahoney Creek varies from the range of measured pre-project values and is determined by ADF&!G to pose a potential negative effect on the spawning, incubation, and/or rearing of sockeye salmon in Lower Mahoney Lake, an ADFG-approved biotic monitoring plan shall be formulated and implemented by the applicant to address any or all of these potential effects. Whenever required flows are not achieved, the ADFG, the FERC and other interested parties must be notified orally and in writing within 12-hours of the beginning of the noncompliance event. From August I through September 30, sockeye salmon fish counts shall be conducted throughout Lower Mahoney Creek and the spawning areas at the mouths of South Creek and Upper Mahoney Creek every three days. Reports shall be submitted to the ADFG 109 Division of Habitat and Restoration Ketchikan office annually. Monitoring shall continue until the ADFG is confident that project operation under the with-project flow regime, does not have negative effects on adult salmon migration. The developer shall provide sufficient resources for an onsite representative of the ADFG to monitor project during construction and for an ADFG representative to inspect the project once per month when the project is on line. EILSHING AND HUNTING The Developer shall cooperate with the ADFG by incorporating ADFG fishing and hunting regulations into employee/employer work standards and contracts for all employees, contractors, and subcontractors of the developer to prevent exploitation of species resulting from improved access to the project area. Penalties for violation should include termination of employment. The above conditions were modified by letter dated August 11, 1997 (Appendix D). 110 APPENDIX D Comments on the Draft Environmental Assessment, and staff responses. Name Letter Date Alaska Department of Fish and Game 08-11-97 U.S. Fish and Wildlife Service 08-12-97 HDR Engineering, Inc. 08-12-97 Alaska Department of Natural Resources 08-21-97 Ketchikan Public Utilities 08-29-97 U.S. Army Corps of Engineers 09-02-97 HDR Engineering, Inc. 10-23-97 The comment letters and staff responses are shown on the pages that follow. 111 Copy STAVE OF ALASIA wens 933 RASPBERRY ROAD DEPARTMENT OF FISH AND GAME ANCHORAGE, ALASKA 99518 PHONE: (907) 267-2369 DIVISION OF SPORT FISH EAN: (007) 37-2462) 2 a ° on $5 aA oz Zp. <r en 240 3 August 11, 1997 Transmitted by Email S SHEL SS F O21 A9Ua Ms. Lois D. Cashell, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room A-1 Washington, D.C. 20426 NOISSIWWO AUVLIUS3} Re: Mahoney Lake Hydroelectric Project, FERC No. 11393-001, Response to July 11, 1997 Comments from Kevin Madden, Acting Director, FERC, Terms and Conditio: nd Prescriptions . Dear Ms. Cashell: The Alaska Department of Fish and Game is submitting the following comments in response to the July 11, 1997 comments from Kevin Madden, Acting Director, Hydropower and Licensing, Federal Energy Regulatory Commission (FERC), regarding the Mahoney Lakes hydroelectric project. These comments are being submitted on behalf of Jack Gustafson, lead permitter for the Alaska Department of Fish and Game for the Mahoney Lakes project, and are limited to only those concerns relating to instream flow issues. Comments 1. Flow range in Lower Mahoney Creek during adult salmon migration. FERC has recommended a flow release of no less than 44 cfs from the project or the natural inflow to Upper Mahoney Lake, whichever is less. ADFG-1 The Alaska Department of Fish and Game (ADF&G) understands your rationale for this suggested flow release. However, it should be emphasized that the amount of water discharged from Lower Mahoney Lake must be adequate for ensuring continued adult salmon immigration. The original flow 112 Ms. Lois Cashell August 11, 1997 recommendations requested a flow release from Lower Mahoney Lake based on observations of fish p ¢ by the applicant's consultant. We specified the original conditions using that limited information. Based on your rationale, we can agree to your recommended language revisions for operations with the understanding that sufficient studies will be performed prior, during, and post construction to better define fish passage requirements for this system. Should these studies indicate a different flow regime is required to maintain fish passage (which is different from your recommended modification to our original request), the alternative flow regime (established by the studies) must instead be implemented. Evaluating the project's effect on sockeye salmon in lower Mahoney Lake. You requested clarification where to perform the studies and made suggestions for designing studies. The monitoring conditions requested by the ADF&G refer to the requirement to perform studies in the sockeye salmon passage (immigration and outmigration), spawning/incubation, and rearing areas. These areas include, but are not limited to Lower Mahoney Lake, the inflow and outflow areas to and from Lower Mahoney Lake, and any other portions of the watershed impacted by the project that influences the preproject production and habitat conditions for sockeye salmon passage, spawning, incubation, and rearing in this system. We concur with your suggestion to establish a multi-agency and project owner work group to define monitoring study methods. This group should meet on a scheduled basis (at least once per year) to review study results and identify courses of actions required based on those results. Ideally, funding for these studies will be placed in an escrow account similar to that established for other projects in Alaska. If you have any questions or require additional information, please do not hesitate to contact Jack Gustafson at our Ketchikan office, (907)-225-2027. Sincerely, Chudighn foto Christopher Estes Statewide Instream Flow Coordinator 907-267-2142 ce: Jack Gustafson, ADF&G, Ketchikan ADFG-2 ADFG-3 113 We appreciate your willingness to reconsider this condition, and have incorporated this modification into the FEA. We appreciate your willingness to reconsider this condition, and have incorporated this modification into the FEA. Saxman would be required to submit a plan for funding the studies, see section V.C.2. of the final EA. United States Department of the Interior FISH AND WILDLIFE SERVICE orrce oF Alene 1011 B. Todor Rd. STAG 22 PH S12 me" COPY EM BS, AS 12 pata te, Ms. Lois D. Cashell Federal Energy Regulatory Commission Attention’ Mr. Vince Yearick £88 First Street, NE. Washington, D.C. 20426 Re: Mahoney Lake Hydroelectric Project FERC No. 11393-001 Dear Ms. Cashell: The U;S. Fish and Wildlife Service has reviewed a July 11, 1997, letter from Mr. Kevin P. Madden of your staff, requesting modifications of two conditions provided by the Service for incorporation into a license sought for the Mahoney Lake Hydropower Project. One of the recommended modifications would change our proposed year-round, 13-cubic feet per second minimum flow requirement in Upper Mahoney Creek. The FERC’s proposal would require minimum flows for Upper Mahoney Creek from November | through April 30 to be FWS-1 We agree with your modification of this flow 13-cf3 or the instantaneous inflow to Upper Mahoney Lake, whichever is less, in years when condition and have modified the EA to reflect the Upper Mahoney Lake cannot be completely refilled by November 1 because of low water change. We have considered this proposal, and do not object, in principle, to the concept. meee ensure, however, that the project is not operated in a manner that would intentionally precude filing Upper Mahoney Lake by November 1 during years that might otherwise have been filled. Such project operation would free the operator from the 13-cfs flow ae Ree ee ee A ee eee eg es elo To help conserve water in Upper Mahoney Lake for release during the winter, while providing flows that appear to be necessary for migration of adult salmon into Lower Mahoney Lake, we Tecommend that the project be restricted to releasing a maximum of $0-cfs from August | until either Upper Mahoney Lake fills, or until October 31, whichever occurs first. Preliminary studies by the applicant suggest that passage of adult salmon to Lower Mahoney Lake occurs at flows between 120- and 200-cfs at the outlet of Lower Mahoney Lake. The Alaska Department of Fish and Game provided a condition requiring the operator to maintain such flows 114 during August and September. Ina July 11, 1997, letter to Mr. Durst of ADF&G, the FERC recommended that the condition be modified to require only up to 44-cfs or natural inflow to Upper Mahoney Lake, whichever is less, during low water years. A flow of 44-cfs represents 36.8 percent of 120-cfs, proportionally equivalent to Upper Mahoney Lake’s contribution to Leer Mahoney Creek's flow based on drainage area. Our suggestion to limit flows to a maximum of $0-cfs from August | until Upper Mahoney Lake fills will allow the operator to meet the proposed 44-cfs minimum. The additional 6-cfs allowed by our condition is intended to provide 2 degree of operational flexibility. The 50-cfs maximum also approximates the average natural inflow to Upper Mahoney Lake for August and September (45- and 53-cfi, respectively), suggesting that this range of flows is biologically acceptable. Tf additional monitoring, as proposed by the applicant, indicates that adult salmon migration into Lower Mahoney Lake depends on flows other than 120- to 200-cfi, the Service will reconsider the flow regimes required of the operator. The second modification of the Service's conditions recommended by FERC concems the monitoring plan proposed by the applicant. In our letter of November 4, 1996, the Service required the applicant to implement their proposed plan as submitted on May 9, 1996, unless an alternative plan is specifically approved by the Service. The FERC proposes that the monitoring plan be modified to require onsite monitoring every 3 days throughout August and September for the first 10 years of operation, or until the Forest Service, National Marine Fisheries Service, ADF&G, and the Fish and Wildlife Service are confident that the project’s flow regime does not adversely affect adult sockeye salmon migration. Our original proposal would have done such monitoring only for the first 3 years of operation, followed by calculation of a simplified index of abundance to predict the most likely times when sockeye salmon would be present in Lower Mahoney Creek. For the next 7 years, onsite monitoring would have been limited to times when the index predicted salmon would be abundant. We agree with FERC, and approve the modification of dropping the requirement for calculation and use of an abundance index, and requiring onsite monitoring every 3 days during August and September during the first 10 years of operation. ‘Thank you for your attention to these matters. If you have any questions please contact Steve Brockmann at (907) 225-9691. Sincerely, Me Janet E. 6 ‘Acting Field Supervisor 115 FWS-2 We appreciate your willingness to reconsider the monitoring plan condition, and have modified the EA to reflect the change. OFFICE OF THe Sconetany STAUG 13 PH 3:45 AL ENERGY ReveATORY COMMISSION Ms. Lois D. Cashell, Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room A-1 Washington, D.C. 20426 Re: Mahoney Lake Hydrocectrie Project FERC Project No. 11393 —(()/ Dear Ms. Cashell: On behalf of the City of Saxman, we enclose for filing an original and eight copies of the City’s comments on the FERC Draft Environmental Assessment issued on July 14, 1997, for the above- referenced project. If you have any questions regarding these comments, please let me know. Sincerely, HDR ENGINEERING, INC. PU Mbewa Michael V. Stimac, P.B. ‘Manager, Licensing and Environmental Services Enclosures cc: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation Service List 116 MAHONEY LAKE HYDROELECTRIC PROJECT FERC PROJECT NO. 11393 City of Saxman (Applicant) Comments on FERC Draft Eaviroamental Assessment Issued July 14, 1997 1. p. 25: In the second full paragraph, third line from the bottom, water temperature information to estithate the range of intragravel temperatures was from Upper Mahoney Creek, not from the Upper Mahoney Lake as stated. pp. 31-32: Freezing of eggs and crowding of spawners are discussed as possible consequences of low flow. Freezing is not a problem in Lower Mahoney Lake and crowding is unlikely unless fish populations increase drastically. All of the Applicant’s studies suggest that spawning at the Upper Mahoney Creek outlet delta takes place well below the extreme lake level fluctuations that have be observed during the past three years. Freezing has never been postulated as a problem. . pp. 33, 87: The concept of flushing flows is not applicable to the Lower Mahoney Lake Situation where spawning is occurring at depth in the lake. The velocity of any flushing flows Lake. Any residual surface velocities will do little to flush sediments from the lake gravels. Further, the gentle upwelling currents on the lake bottom probably are not adequate in any event to prevent deposition. Thus, the use of flushing flows in Upper Mahoney Creek may actually transport more sediment at an increased concentration to the spawning gravels in the lake than would have naturally occurred. Under normal circumstances, there are almost no suspended solids in the lake water to be deposited. . p. 34: Alternative monitoring methods, such as bioacoustics, should be allowed as options to the monitoring proposal contained in the current aquatic resources monitoring plan. . pp. 35-37, 87: Several additional factors should be considered when evaluating the flow regime in Lower Mahoney Creek: ¢ Flow in Lower Mahoney Creek is controlled by the elevation in Lower Mahoney Lake. Due to the attenuation of flows that will occur in Lower Mahoney Lake, Lower Mahoney Creek will not see the full effect of a change in project flow until 24-36 hours after the flow is implemented. From an operational perspective, this translates to regulation for “today” being based on the events of “yesterday” and producing results which won’t be seen until “tomorrow”. When the project is operating, the flow in Lower Mahoney Creek will be the summation of naturally occurring flow from the unregulated portion of the basin (63% of total) plus the regulated project flow. During low flow periods, the project may Applicant's Comments on FERC DEA ae Mahoney Lake Hydroelectric Project FERC Project No. 11393 HDR-1 HDR-1 HDR-2 117 We made this correction is the final EA. We agree that eggs and alevins in the intragravel area would not be exposed to freezing air temperatures. They would, however, be exposed to water temperatures approaching 0° C. The size of the existing upwelling area and the size of the post- project upwelling area haven't been determined, so we aren't able to predict crowding effects. Freezing and crowding effects, if any, would be identified through the recommended monitoring programs for discharge, water temperature, and salmon resources. After releasing the flushing flow, if Saxman finds that it has no effect or adversely affects spawning conditions, then Saxman, after consulting with the fisheries agencies, should forward the documentation to the Commission and request that the flushing flow be modified or eliminated. The salmon monitoring program we recommend was developed from the mandatory conditions of the U.S. Fish and Wildlife Service (FWS) and the Alaska Department of Fish and Game (ADFG). Alternatives to the required monitoring program could be developed with the agreement of these agencies and submitted to the Commission for approval. already be providing enhancement flows, During high flow periods, water will be stored. ¢ Flows within the target range of 120-200 cfs in Lower Mahoney Creek occur naturally only 14% of the time during the months of August and September. © The range of target flows does not have a tested biological basis. © Recent observations by the Applicant do not support the existence of a trough in Lower Mahoney Creek that may allow fish to pass at higher flows. The manner and timing of fish passage is still being investigated. ‘These factors, when combined with the conditions and modifications suggested, will create a situation for which the Applicant will be unable to provide complete compliance and also has the potential to work against the desired objective of enhancing fish passage. Upper Mahoney Lake's storage capacity can neither provide the amount of enhancement flow nor capture excessive runoff in the amounts necessary to completely satisfy ADFG’s condition. The Applicant also believes that normal operation of the project will tend to enhance the flow situation in Lower Mahoney Creek by helping to moderate the extreme variations in flow. In light of these facts, the Applicant believes that a flow constraint on Lower Mahoney Creek is not warranted and is premature at this time. |. pp. 37, 38, 40: It should be recognized when developing plans to assess project effects, that demonstrating any adverse (or beneficial) effect may be very difficult because of the naturally high variability in this system. ‘This should be acknowledged during the planning process. . p. 44: Table 6 is based on questionable assumptions. . p. 45: A shift in the number of average degree days during the incubation period will not necessarily cause a proportional shift in emergence time because of compensatory mechanisms. HDR-5 HDR-6 |HDR-7 |HDR-8 . p. 88: Re: Salmon Emergence. It is suggested that the use of smolt outmigration studies be | HDR-9 allowed as a substitute for emergence studies. Mahoney Lake Hydroelectric Project FERC Project No. 11393 HDR-5 118 Post-project flow attenuation in Lower Mahoney Lake would remain the same as the pre-project attenuation. We agree that project operation would moderate the existing seasonal flow extremes. See section V.C.2. of the FEA for a detailed discussion of the flow recommendations for Lower Mahoney Creek. The on-going monitoring we recommend would better define the range of flows needed for salmon passage in Lower Mahoney Creek. We agree that on-going monitoring results may support modification of this flow requirement. The ADFG has agreed to modify their condition to allow a minimum flow equal to the instantaneous inflow to Upper Mahoney Lake when it is lower than 44 cfs, the project's drainage area proportion of Lower Mahoney Creek passage flows. The hydrologic record confirms that flows in the Upper and Lower Mahoney watersheds are highly variable. Table 6 is calculated from data provided by the applicant in Table 5. Because Tables 5 and 6 represent only estimates of incubation times, we recommend monitoring to determine any post-project effects from the altered temperature regime. We agree that compensatory mechanisms would work to moderate shifts in incubation periods, as discusse in the EA. Emergence monitoring is recommended as a method for early detection of any potential project-related affects on salmon because the adult salmon monitoring program wouldn't assess the effects on eggs incubated during project operations for up to 5 or 6 years after hatching. Outmigration of smolts may not occur for 2 years after hatching. Any early detection monitoring plan would be prepared in consultation HDR-9 with the fisheries agencies, however, and the ORIGINAL Commission would consider smolt outmigration as an alternative to emergence monitoring if the consulted ‘TONY KNOWLES, GOVERNOR STATE OF ALASKA 108 Along y hem, a os agencies agree that it would adequately evaluate any roe omassee project effects. FAX (ON) G00-2086 DEPARTMENT OF NATURAL RESOURCES DIVISION OF MINING AND WATER MANAGEMENT 21 August 1967 Lola D, Cashell, Secretary Federal Energy Raguistory Commission 088 First Street, NE Weshington, D.C. 20428 NOISSIWHOS A x0, AQUSNF eae Re: Project No. 11903-001 Comments on Draft Environmentel Assessment ‘The following comments on the Mahoney Lake Hydro Project Draft Environmental Assessment are otered fos PUPA a cneaberaian: DNR-1 The operational feasibility of the agency conditions, = Section Vi, particutarly the lest paragraph of thie section on p. 865, addresses the sizing of since they are primarily fisheries-related, is pete teachin ganar nae clone oh ve ay orn ror discussed in the Aquatic Resources section of the foesibity of operating under conditions proposed by ADF 4G, or the feasibilty of an alternative DNR-1 DEA. In addition, we stated in the Developmental Tantatipiaseinmneeinaeeiomacea Resources section of the DEA that we didn't figuring in the fisheries values effected. Thie le unfortunate, since the project's imitations in delivering separately analyze the cost of these measures Sindee cteanentar teen lortaentemm bation se, because, although they would affect how Saxman of the appropriete sizing of inetalied capacity, bul the sppropriate sizing of reservoir storage, from the operates the project, they wouldn't significantly wer caiemtegtiomamaiaetoen int affect the project's power value. resource mitigation flows, and since the Application for Licenee staies thet, “W additonal storage DNR-2 nd ansanieabietdaieiaenre tein en DNR-2 A small dam near the outlet of Upper Mahoney Lake was no project features be bull that might prectude esi emell dem or other Infrastructure or operational one of several alternative project configurations Ree Tear al eee iaiaeencnesnstion oie dteanieedetetibe with dams that were considered by Saxman. caxmany “only be required to provide a minimum flow of 44 cfs, the project's drainage area proportion of 120 didn't pursue these options because of the rockslide nou idaen oaemeerenee ee DNR-3 risk in this area. In addition, no entity suggested, (his perticuter flow smount, we disagree with the implication thet such a minimum flow requirement when scoping alternatives for this project, that such pr patpenag Sect termite «or armn der mera a project configuration be included in the NEPA analysis. There is nothing, however, that we are ‘some of that storage be used to release flows thet may exceed drainage area proportion, lnnhed periods of time. Gimterty, cherien values may justly reservolr eperetion rues tat aware of in the proposed project, that would preclude “Develop, Conserve end Enhance Natural Resources for Prevent and Future , . adding a small dam in the future. Such a proposal ; os would, at that time, be subject to a separate NEPA analysis. 119 Te eee oT eriig TREN paneege a Senet, ly fey eo increseed capecty. «fei ls cesadate i requ flown hn Lower Mahoney Creek nthe sounds recommended by ADF&G during sil of August and Geptember, FERC should enalyze the pre-project hydrologic record to determine the probebilties of this range cf flows for those months, and should recommend operetional conditions that, et minimum. do not diminish those probabilities or the periods of time over which those flows would occur, and which previded the windows of opportunity for sockeye salmon spawning passage into Lower Mehoney Lake. During project shut-downe, f the reservoir is not epiling, flows into Upper Mahoney Creek wil be fimited to the 44 cfs capacity of the bypees pipeline, There should be requirements for enough project operation during this period et maximum flow (78 oft) along with the 44 cle bypees flow end/or Upper Mahoney Lake spillage to provide periods of sockeye peseage Bows In Lower Mahoney Creek thet are undiminished from historic, flows, in flow rate, frequency, and duration. = The DEA's Cumulative Effects Section (Section V, B, pp. 17-18) needs to be updated to include the Whitman Lake, Connell Lake, and Carienna Lakes projects on Revilagigedo island. While 8 footnote explains thet FERC dose not typically include projects for which ony a preliminasy permit has been lseved because 6 smsii percentege of theee historically are ever developed, this seems an ‘ec¥ficial diatinetion. Moreover, the ebove tres projects ere developed water supply projects wih ‘edeting Impacts, that would be altered to furnieh hydroelectric energy. ‘We have @ concer that the diminishing number of watersheds In. | DNR-6 DNR-4 DNR-5 the arse, along with the peucity of strearnfiow gages, could be causing difficuities in the utility of tegional hydrologic deta for analysis of water resources and ite development. We recommend that FERC consult with USGS to determine If this is the case, and consider requiring this project and future projects to provide or sseiet in providing streamfiow gages thal heve valve in building the regional hydrologic date baee. DNR-3 DNR-4 DNR-5 DNR-6 120 Our EA evaluates the flows for salmon migration that would be available as Saxman has proposed to design the project. Should an amendment for increased storage be proposed in the future, we would evaluate the flows according to the proposed amendment. In the FEA we reevaluate our recommendations for flows and conclude that migration flow requirements based on drainage area proportions are appropriate. See section V.C.2. of the final EA. The hydrologic record shows that salmon passage flows during August and September are unpredictable. See our detailed discussion in section V.C.2. of the final EA. We will note the presence of these developments in the text only, since they are already shown on the figure. If this project is licensed as we recommend, there are mandatory agency conditions and license conditions that would require streamflow gaging. Lois D. Cashell, Secretary Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426 Subject: FERC Project No. 11393-001 Alaska Comments on Draft Environmental Assessment Dear Ms. Cashel: Ketchikan Public Utilities (KPU) has completed its review of the FERC environmental assessment (EA) prepared for the subject project proposed by the City of Saxman. We offer the following comments for your consideration in preparing the final EA for this project. We note that many of the concerns expressed in our comments on the license application itself (see our letter to you dated November 7, 1996) are not addressed in this EA. Primary among our concerns is the fact that the value for the project's potential average year generation is still given as 46.0 GWh despite our detailed explanation of why this value may overestimate actual production. In that explanation we indicate that our estimate of 35,090 MWh more accurately reflects the actual conditions that will prevail with the Mahoney Lake Project on line. We pointed out that project feasibility must be determined using generation estimates based on long-term sequential daily or monthly power studies. These studies should properly account for hydrologic variability and similarity in concurrent water year conditions among KPU hydroelectric projects, Swan Lake and Mahoney Lake. The generation estimate should also account for usability of generation in an isolated system, the priority of generation usage among the resources, and the effects of various load levels on usable generation. We do not believe the estimate of 46.0 GWh reflects a thorough consideration of these factors. Consequently, we view the Developmental Analysis presented on page 83 of the EA to be seriously flawed. We note that, despite our cautionary warning about maintenance of underground cables, the EA indicates that 1.5 miles of transmission line will be buried, apparently to avoid disturbing an unoccupied eagle nest. We urge the FERC to reexamine the need to bury this portion of the transmission line. Maintenance of a buried line in a remote area can be quite difficult and costly. We cited possible alternatives and reasons for their consideration in our comments on the license application and refer you to those alternatives for your further consideration. ‘h:\aserAtronee \wiswrord\data\090-< I cor KPU-2 121 KPU-1 As we say on page 82 of the DEA, though the potential average year generation is 46.0 GWh, the project would provide less energy to KPU until about the year 2016, depending upon how KPU's loads increase. We also say that the project would produce less energy in dry years and more in wet years, with the wet year generation being limited by how much energy is available to KPU from other sources. When we take these factors into account we calculate that the annual generation of the project would average 39.6 GWh over the first 30 years of operation. We reviewed both your comments on design issues and Saxman's response to those comments. Besides commenting on how Saxman calculates the potential average generation of the project, which we discuss above, you also raise concerns about several details of Saxman's design and cost estimate. At this preliminary stage of design, we think Saxman's description of the proposed project in the license application is adequate and their cost estimate, when considered together with their contingency allowance, is reasonable enough for us to compare the proposed project to other alternatives. If the Commission issues a license for the project, and Saxman decides to build it, Saxman will start the final design process for the project. At that time, Saxman would have a chance to reevaluate any of the preliminary design features as they learn more about the conditions at the site from further site investigation. The Commission reviews the final design of projects and the project's plans and specifications before a project is built. Lois Casbell Adgust 29, 1997 Page Two We strongly urge the FERC to revisit our earlier comments on the license application itself to ensure thorough consideration of our concerns expressed on both design issues and those aspects of the proposed project either directly or indirectly affecting the environment. Please address any questions you may have regarding these comments and our earlier review of the application to me at (907) 225-1000. ‘Thank you for your careful consideration of our comments on this EA. Sincerely, ae fF Acting John A. Magyar General Manager KPU-3 122 We are, however, recommending that Saxman's proposal to bury part of the transmission line be included in the project's final design to avoid and/or mitigate impacts on wildlife and visual resources. KPU-3 We've considered your earlier comments and Saxman's response in our response above. DEPARTMENT OF THE ARMY NORTHAVESTEAN DIVISION, CORPS OF ENGINEERS PO. BOK 2870 PORTLAND, OREGON 87208-8570 =P 2 noe Le ot Water Management Division Mrs. Lois Cashell, Secretary ral Energy Regulatory Commission Pirest Street NE Washington, D.C. 20426 Dear Mrs. Cashell: We have reviewed the Draft Environmental dasgement (BA) for the Mahoney Lake Project, FERC Project No. 11393/ a paolo Proposed by the City of Saxton and Cape Fox Corporation. The only comments we have to offer are of a regulatory nature. These comments were provided by the U.8. Army Corps of Engineers, Alaska District (CBPOA-EN-CW-PF) on August 26, 1997. The Alaska District, Regulatory Branch has completed its Section 404 pore review of this peoiere: On January 14, 1997 thie office issued a provisional permit pending a consistency determination on Coastal Zone Management and Section 401 Water Quality Certification and/or waiver by the State of Alaska. It is our understanding that the State of Alaska is not prepared to finalize their actions at this time. c The Corps’ point of contact regarding the review of the Draft Environmental Assessment is John R. Klutz, Project Manager, Regulatory Branch at the Corps' Alaska District Office. His phone number is (907) 753-2720. "i B. Velehradsky, P.2, rector of Engineering Technical Services Thank you for the update. 123 ORIcn's orrice othe Stenctaey 9700127 PHU: 37 FEGERAL Ent His 9 Tema ISSIO! Ms, Lois D. Casbell, Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room A-1 Washington, D.C. 20426 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 — OO! Dear Ms. Cashel: On behalf of the City of Swxman (Applicant), we enclose for filing an original and eight copies of the Applicant's response to the comments contained in Ketchikan Public Utilities’ letters dated November 7, 1996, and August 29, 1997. This information is being submitted at the request of FERC staff member, Vince Yearick. Your comments have been noted and considered in our preparation of the FEA. 124 City of Saxman (Applicant) response to comments contained in Ketchikan Public Utilities’ letters dated November 7, 1996, and August 29, 1997. KPU's letters follow this response and have been annotated by placing comment letiers/mumbers in the margins of the letters. The below listed responses are provided by comment letier/number. Comments A/12/3 The Applicant believes that the energy generation potential of the project presented in the Application for License is reliable and accurate. The Applicant has also developed a sequential daily flow model that uses the 35 years of simulated daily flow as input. This model has been used to evaluate the various scenarios that are possible for the project which are too numerous to all be presented in the Application. Accounting for the most recent minimum instream flow Tequirements proposed by the agencies for Upper Mahoney Creek, the energy potential for the Project is estimated to be 44.0 GWhiyr. ‘To met over-estimate the benefits of the project, the Applicant has presented the project as a “last-in, first-out” resource. However, this is clearly not the way to maximize the use of this resource and create the greatest benefits for the ratepayers of Ketchikan By utilizing all of this resource and integrating the operation of the project with the other generating resources on the electrical system, additional benefits are achievable. Under the terms of which the license is being ‘sought, and the conditions of the Swan Lake Power Sales Agreement, full utilization of Mahoney Lake energy is possible. This will provide the most benefits to the ratepayers, and is the prudent action to take. Comment 4 Tables B-2, B-3, and B-4 indicate that, for an un-met system load of 67,350 MWh, Mahoney Lake would be able to produce 46,066 MWh, 29,640 MWh, and 52,414 MWh during average, low, and high water years, respectively. Thus, the Mahoney Lake Project is consistent with the observations stated that hydro projects are normally capable of producing more energy during wet years and less during dry years. Comments $/6/7/8/9 The Swan Lake Power Sales Agreement contains a provision that allows KPU to purchase power from qualified facilities, such as Mahoney Lake, prior to purchasing Swan Lake power. Accordingly, output from Mahoney Lake is “water” limited rather than “load” limited. As such, the annual energy is estimated to be 44.0 GWh as described above. While KPU's comments may be aimed at discounting the capability of the project, the need and desire to have an additional hydroelectric resource are apparent. ‘As stated by KPU, “...we have seen significant growth in electrical demand over the past decade. In recent years, we have not been able to meet demand with hydroelectricity. We have been Sorced to rely on the more expensive and less dependable power provided by our aging diesel Applicant's Response to b ‘Mahoney Lake Hydroelectric Project KPU Comment Letters FERC Project No. 11393 125 plant and surplus power from the Ketchikan Pulp Company (KPC)."' In 1996 and 1995, KPU used diesel generators to produce 26,000 MWh and 35,300 MWh, respectively, to meet an annual Joad of approximately 156,500 MWh. In addition, in 1996 KPC closed its operations in Ketchikan and this resource is no longer available. When referring to the new diesel generators planned to be on-line in 1998, KPU states “...it isn't cheap to operate compared to our hydroelectric projects. In order to keep your electric rates as low as possible, we need to develop other, lower cost resources."* The Mahoney Lake project is that resource. Comments 10/11/12 Figures ere appropriate and are in context with the material presented in the documentation. Comment 13 Monitoring activities have included, and currently do inchide, temperature measurements. Comment 14 Comments noted. Comment 15 ‘The Applicant is willing to consider the use of fiber optics in place of telephone lines. Comments B/16 Comment noted. The performance characteristics of underground cable can be a flunction of the quality of the cable installed. This may have been an important factor in the establishment KPU's underground cable experience. Regardless, the Applicant is willing to consider the use of overhead transmission lines where underground is now proposed, consistent with the need to Comment 17 The underground transmission line from the powerhouse to the switchyard will follow the access toad, but will not necessarily be buried beneath it. Differential settling of the road, should it ‘occur, should not affect the underground line. Comments noted. " Forward to the Initial Draft of the Power Sapply Planning Stody, December 27, 1996, Joha A. Magyar, KPU Mahoney Lake Hydroelectric Project FERC Project No, 11398 126 Comment noted. Again, cable performance can be a function of product quality and care of installation. Use of conduit will be considered, as appropriate, depending on conditions encountered in the field. Comment 21 ‘This suggestion seems to contradict previous comments regarding the use of transmission lines with other than overhead construction. Further, routing a submarine cable through Lower Mahoney Lake would introduce other complications such as potential impacts to spawning areas. The agencies have heightened concen regarding the pristine nature of Lower Mahoney Lake. Comment 22 Comment noted. The Applicant does not believe this would be a significant consideration. Comment 23 ‘The Applicant is willing to investigate alternate transmission routes during final design. Comment 24 Comment noted. The Applicant is willing to work with KPU during the final design phase to address such matters. ‘The Applicant is unaware of any geotechnical reports that may have been used to draw this conchusion. However, the Applicant would agree that accumulation of natural materials at the site has caused a lake to form. This type of formulation would be consistent with countless of other lakes and, in that regard, Upper Mahoney Lake could be considered a typical lake. While the exact date at which Upper Mahoney Lake was formed is not known, it is safe to assume that the outlet has seen continuous spilling of varying degrees and has survived the test of time. Removal of « functioning natural plug in favor of installing a man-made plug would unjustly add to the project's cost. Comments 2728/29 Comments noted. However, design details will be addressed during final design. Applicant's Response to Mahoney Lake Hydroelectric Project KPU Comment Letters FERC Project No, 11393 127 ‘Comment 30 ‘The means and methods of constructing the project is contractor specific and, therefore, ‘Speculation on the manner and length of commute time by the Applicant is not warranted. By Alaskan standards, a project that is within 5 air miles of & major community that has scheduled air and berge service and has a road to the site capable of carrying any construction-related loads would normally be considered a hnaury rather than a hardship. Regarding operational reliability, the road conditions associated with Mahoney Lake should be ‘simailar to those experienced at other hydroelectric facilities in the area. Comment 31 Comments noted. However, design details will be addressed during final design. Comments 32 throurh 38 ‘When creating cost estimates using the conceptual design of the project, it is common practice within the industry to inchade contingency amounts to account for incidental costs that have not yet been designed or estimated. Between the direct contingency amounts stated, and the ‘estimates for tunnel and shaft linings and rock support systems which represent additional contingency in the underground excavation, the cost estimate included in Exhibit D of the Application for License contains approximately $8 million dollars of contingency. This should be sufficient to cover such incidentals as culverts in the access road that may not have been Tepresented with a line item estimate. Applicant's Response to + Mahoney Lake Hydroelectric Project KPU Comment Letters FERC Profect No. 11393 128 Lola D. Cashel, Secretary Federal Energy Regulatory Commission 488 First Strest NE . Washington, DC 20426 Subject: FERC Project Mo. 11393-001 Alaska Comments oa Desf Bavironments) Assesermest Dear Ms. Casall: Ketchikan Public Utilities (KPU) bas compleud ks mview of the FERC enviroamenul tumsument (BA) prepared for the subject project proposed by the City of Saxman. We offer the following comment: for your consideration ia preparing the final BA for this project. We note that many of the concerns expressed la our comments on the license applicatio itself (ene our letter to you dased November 7, 1996) aze not addressed in this EA. Primary among our concerns is the fact that the value for the project's poteatial average year generation is still given 2s 46,0 GWh despite our detailed explanation of why this value may overestimate actual) production. In that explanation we indicate thet our estimate ef 35,050 MWh more accuratly reflects the actual conditions that will prevail with the Mahoney Lake Project on Ene. We pointed out that project feasibility mest be determined using geocration estimates based on long-term sequential daily or monthly power studies. Thess studies should property account for hydrologic variability and similarity in concurreat water year conditions among KPU hydroelectric projects, Swan Lake and Mahoaey Lake. The generation estimate should also account for vaabllixy of generation in an isolated system, the priority of generation usage among the resources, and the effects of various loed levels on usable generation. We do not believe the estimate of 46.0 GWh refiects a thorough consideration of these factors. Consequently, we view the Developmental Analysis presested on page &3 of the EA to be seriously fixwed, a: ‘We note that, despite our cautionary wamiag about mainmoance of uaderground cables, the HA indicates thar 1.5 miles of transmission fine will bs buried, apparently t0 svold disturbing 0 129 ‘We strongly urge the FERC to revisit oar earlier comments on the license application itself to ensure thorough consideration of our concems expressed oa both desiga inaues and those ‘aspects of the proposed project elther directly or iadirectly affecting the exvironment. ‘Picase address any questions you may bave regarding these comments and our earlier review f the application to me ut (907) 225-1000. ‘Thank you for your careful consideration of oer comments on this BA. 130 Mz. Lois D. Cashel Federal Energy Raguisory Comenievion ‘323 Few Swest NE, Loom A-i Washingmn, DC 2006 ‘Dear Ma, Cashelt Suge Comments, Teal Terms and Conditions, Recseumendasieas med Preseripticas (a Miabeney Lake Licamae A ppiiancier, . FERC Project No. 11383-400 ‘Konchiken Public Uilldes (KPU) hes o sumber of commens w the License Application of the above ‘Project, The comments generady fil isms the blowing cansgaries: |) exergy geoerarion, 2) operational reliability and 3) conguroction and operaiion com Each of hese inom are of 3 cancers w KPU because ‘the Applicant iemnds 10 all KPU power renerased by the Project fir se within owr rym. ENERGY GENERATION 7 A ‘The analyst prosesnd in Exton Bis imadequay © demnmine te ereruge mnsuel wary prodoctoa thom Mahoney Lake. The average ansual nergy production for Mahoney Lake pressed in Exhiba B 2 SMNOCY saa ae peer dang ae rN Anan ibsd astoliog b enasey (() 1 reliably desanmane te average argue! energy production. DLagarding power scady machodology, we cw recommpenderions (rec boc: the Amaricsn Society of Civ] Engineecs wed the Corps of Engineers, As prevented fn tho Cid Beghwortng Guidelinee for Plawing and Designing Hydreciecri: Deralopmace, by ton marcas Soctery of Chel Englert, ded LI: . jataaing to worey pm prince wid pow serge (or naigsropind csargy pemadal of rea-cf-civer projeces, and it con be done securamly enly ating the sequertal srenmiow routing method.” AS preseaned in Hydropower, Engineering end Design, by ta US. Anay Corps of Engineers, desed December 31, 1983; “SSR (sequenial sreamiiow ‘ the only vieble mached for walang morgs ee ena ance “Where 3 projen is aparaned a5 8 part of « eymem, SSR mabyeis is required © property model the ienpact of syemnen eperacion 08 that projent’s power oun.” i31 Ma, Lote D. Canal Nevember 7, 1996 Page 3 _ pumeraion on a momthly, weekly, deity, or hourly te increment for peried of at lest 30 years. The APU pyeiem with Swan Lake and the pomerial addition of Mahaney Laks monst be evaluated a « fynam with power songs, As erimam of te werag sonal merty predusion is requred in » FERC license application ts Section 4.0 of Mahoney Lake Rxhibis B, tided Average Annual Energy end Dependable Capacity, it is Saned thet curing a werage war your, the Project would be able © pmerms ox mverige of 46,000,000 kh. Ths prin wet ws ri oni wi fom Lan peeraies, (3) har KPU hydro project generation, and Geel power peneraticn te meet 1 KPU load of 215,000 ‘MWh (Teble 3-2), Apperendy, this animate reprises the project's eerage exmal energy producnoa, We consider this generation valos 1 be an over-cetimacioa of the we ible genereson for tba Sollowing reasoes. Tobles 3-2, B-}, and 3-4, which presse: monthly energy gmeration ding worngs, lew, ond high ‘water yours, all show the KPU hycke capubiliey o be « constant 147,650 MWh par year, regarciess of hydrologic condisions. This is 6 grout simplification of what sctunlly eccurs with KPU's hydropower resources. Bi is cormally expected, ead confirmed by KPU records, that lyrdroelecric projeces heve ths Copebiliy wm puncrams mote energy in wet yours wd long enaryy in Gy your. ‘The Mahoney Leice grmeretion wnalycin should be modified w riiect the weisten of XPU bydro generation wih Tytologic ound ‘As we have indicated ia provisut lowes, KPU ig comracmaally cbliguied to purch oc Swan Lake power Second t eur own lydroslectic resources. Became of lgcdrolagy, the ioolened aamare of the KPU symen, 1d ectractanl obligaions regarding wage o! Swen Lake pmereten, fong-arm erenge usable guneracoa froma Mahoney Lake will be laos thea te esable penerenies mi rvernge weer yum. ‘Because of the geographic praciemsy of the ecsting KPU bydrodectric pryecs: and Mahosey Lake, the concurrent occurrence of water then merge and drier then perege conditions is normally expected, During dry war years, gmermion Som Mahony Lake would be les ten during os everngn cute year de & hytrologs wvelabiity. During wet water yout, emble pumeratcn fom ‘Mahoney Lake would by leat than during sn serage weer year dus © increased puserssien from the KPU hydro projects and Swan Lake The leng-arm everage usable peneruion ther KFU would be bla w purchase ould bas be leas thun during m average waner year, Axa check of the Excubic 8 gonererion velons, a KPU consuinat has developed « profmunery wxtineto ol Mahoney Lake werage wereal generuson Mahoney Laks overage ssmvel josriios wes found 1 very wih KPU lead Although this mudy dd ust we the demiled soqumtel sruumfiow rovtag swebodology, & Gd acenam thr the veriesion of KPU byte rescerces and Swen Laks generation ering we, dy, 2nd orwrags won yours, This sudy renated a wo eodrwend woable overnge mnmual caagy for Mahosay Loks af 25,090 MWh corresponding 0 KPU lead of 211,060 MWh, We consider das subsunmially Gffereat extiness be more accorne ten the Exkaby: B ertimeted everage gwd enarty of 46,000 Wh for Mehonay Lake enrrenpending w a KPU leed of 215,000 MWh. Bowever, we recomunend thar 3 eacibdity-level estxnasn of paneraten for |(ehomey Lake m be, indie a Ent Bsa snd oq resto rug modiogybchtg tn 4) ecisting KPU hydro resourves tnd Sen Lae. Orhan comenerce wating to MghoWey Lome apres a facie Wigeres 3-7 20d 3-10; Thess mombly pore-proyect Sows appear ty mune bose landing, however KPU would not operas tis plant for bess leading, As Gocused shove, KPU's ecining kydro 132 Ma Laie D. Conbell November 1, 1996 Page resources and Swen Lake Hydro should be valized Grat wo their optimal capablily belbre Mahoey ‘Laka Project generation would be valized Mahoney Laks Project output woukd be utilized 06 the fl) wcesct posible befor ramming our Gesel gunerstors ot our Badkey plore. Also, because Mahoney Lake Poet open wil very wih KPU lend, he igus shodd uso sam the exrepenting KPUC(E) Reservoir Water Tomperatere: Wah the small lke reparvoir end occasional snail nxbine flows, KPU la concerned about « rise is water temperatures, which might edvervely affect spewning fich A study should be conducted mensare the elfecs on warr ianiperumre and DO. ‘Table 3-11: This table comains various minor errors which should be correcend as thliows: 1, The Town Bight Gasel hes bean decommissioned aad should be removed froma this table. 2 tased capacity is KW but dus wad PU a onecaea 1. Sinan the actomation of Denver Fall, walk 61 is eporutonaily lenieed to 1,000 KW (rather han bes rated capacity of 1,200 KW) which lowers the tral plant capacity t 5,400 kW. OPERATIONAL RELIABLLITY Page A-6 (2.10) The application mefecs t mmnove monimcing wing “wlephone lines.” Now thet PU correndy has a ongoing programs iemtall Sher opis for SCADA ccugol ad aoaimring. We carry beve Biber aplias fer SCADA contol end monimrisg. We curready have Bber opeics Aerween Lake Silvis nad the Mourcaia Poa pubetatic:. nd would require ther Sher optict ecnad tee Mahoney propect 1s wad m inure sysmam relbabiiey. Page A-6 (2.9 KPU srongly opposes the proposed underground buried wensmission ryvmm. KU Has cigallone pedo wih be ealenaeen ent nibblly of ceterpensl slams bs Sa Keun (7) area. hh face, KPU hes sbendoned severed oreas of wderground conmrestion in fiver of evechead tor tellabiligy and ease of maismenca, ln tis remom ores, mamnainabiliey wil be eves more crucial. Aa wddeiceal concer that te aw arms rad log tha 1.0 ede of 13.2 XV wil dere 8 carnin((7) scocurt of Gierecial seclement poruntially srtesing the buried taremission As for burying the 0.5 mile of 34 5-L1 trmnersnion w evord impact 2 he ines eagle Wee, we suggest thet there may be cater eagle vee found ding nurvey ox ese cometcion sad tt bcs ode mom predecs ‘itigadon mensure PU hes significant experiance ceneeecing snrial planm and oven pubemccas achecant 1 eagle (reer in eccerdance wih approved repwor promcion yusdeiner. Numerous mearures can be taken w misyae egy Garupecn during sesting senscn down tea comms FERC ((4) requires buried (ranemunsion tor any significant lang, we otter the folowing considerscioas: 1. We assume the buried syewm would be conduit end vault (er covered concrets tench) youn os opposed to Erect burial, The relsbliy and manminablxy record of direct burial ia this eres i¢ extrenely poor. This is typically because qualiny backfill muserial is wcpeasive in this zen and poorw quaby becifll with more reck ia often subrieuted. This remut in sich ond mechanical delbrmadon af tee cable, ypically reducing the service bts of tea cable. 1. The abn of ring he 132 LV adver teoegh Lover Mahaney Labs to te rwachyard deuld bo Gareughy comida por @ Scag by FERC (his would be _ finde RPV Lover Lie Siva dogg) 133 ‘Ma Leis D, Cashel November 7, 1996 ras ‘2. Tha buried lengch proposed will edd capacimece load Glow analyeia prior t9 Bemsing by FERC. Echibits FS esd Gd: KPU is concerned shout te trmnidating near station T 40+00. ‘which sheald be troreuphty addrased in a seqpnats of the sida shpe tong the Wensmission Ine routing hom Besser Falls sation T 120+00. This muse will be subject w land sides und will be diBicut and expansive 0 constrect sod mainteht. Since helicopter construction is proposed for we wxywey, KPU reccanmends thet on upland route be considered along a ridge beginning a masion T 120+00 wp te s planes at about the |,000Ahot comnur then descending aid Lxhibit F-8: Typical ranemission srucnare depiciad here i simailer w Swen Lake, The existing E- fraeme srructures cf the Swen Laks fs mee thee wood pos grovend nade ¢ eel com mourned t 5 pile focengs. Replacement of poles is made wcremaly éMicut because of the proved connesicn. ‘Becaune of our mamtenence dfficatios wih tis design, KPU recommends ferent swvcures be conedared bec: far cot und cnet of caintunebizy. W the Wtame srucre is wed 1 ferent Inethod wal bev: s be ned tbr iene they ore po) Gua age Page A-6 (10s At Swan Lake, KPU tes hed malesonance diffcukies with power med comenutecotions sibles in condust adjecest hs seocrme bed ransal wmadie from to ceoboare 1 the powerhougs due to accersive mepagn We arn in the process of replacing this system with an ceverheed syemen. The proposed desea for Mehosey peeer sad comemoracs#a: to ths vatva hose will carnncdy suffer sisnilar Sxibares bet cannot be a5 easly replaced or repaired. KPU recommends design sheenztives be invertigned ha bem promct the power end communications cables thes tet demcribed bere Mabeney Lake Outlet: One fhanwe omined from the design, which wus inahuded in the 1977 RW. ‘Beck Project conenpt is 0 esetrel srruceurs at Upper Mahaney Lake. The cathe: te the ini is overiain «by tabs in the prem channel, bis reescuable we expect a deep arrow gorge ot this size similor we tho ‘Upper Savis spillway site, 1 is ns ey war te met mde on neck wk ¢ (2) required exensive ramedial construction measured during project robabliunion’', The RW. Beck concept mcheded « contre! strucmare w ensure mabiiey of he stream chumel a the lake euciet and to. maintain the existing reservoir storage. This erucesrs would also serve as 2 spillway te pass the design Boor. The cunesion of thie feature requires 1 carefl assesment bebore procesding. Lower Tusnel Concrete Plugs The Project contains 6 concrete plug in the lower uxmél to coal he leakage from ths shaft to the lower tunnel. The plug it w be 100 ther in length; the hydraniis head ie 1440 fast at that location. The plug length amy need be incensed t reduce enmashle senpege or proundwemr buddup around he wained tener rowel a the ond of the plug. Alss lacking is 2 growt seal bn the sock, weer bet expressas concen thet tis dag, »dl neque recommends (he 21 aberneshve decige bs omneed= nc, "Lemar to Me, 2. L. Teague, Cy Manager of Kashiuon. bom Deanid Bowes, BW. Bact and Assciotas, ‘enchiet: “Prepuund Moneony [tes Hytreciauzia Prajo(” bowoorber 219) Eehidit F-4; KPU recommends crane rail eaand welt well w0 allow rigging out of mia valve. Pages B-31 through 5-32: KPU conswy with the susenent regarding the warbine unit's “datlecex” (request meinmecece'replacement and 134 Ms, Loin D. Casall Movember 7, 1996 Pops CONSTRUCTION AND OPERATING COSTS Page D-1 (1.2): The work site will not have mtzively good reed accest and commmute time us stated, Furthermore, the sonsinection cost estimates appear t9 ba based on an cary wark free commen to the Project sine from the Cay of Ketchikan. KPU recommends that the consurvction cost be amended te show fubstandel coewrute teens and dfSeuk winter acces. One of the kay alemenes to minimis the cust of constructing the Project is t provide aceets Som Ketchikan w climninase the need of « construction camp for the labor crew, Sin wea is dae sacugh is Katana come w (59) commute daily, however, daring possible winter shesdowe of the overiand red route, KPU balleves ‘that aicher project worl will need tp be suspended (which would extend the period fbr constructing the reject) or a conswucton carng for the wimer canssrection period wil need to be set up. Finally, mow wil further complica overland sceens to tha siea, which is an operational reliability concern of KPU. Powerkeuse Dacign: ‘The seni-undergreund powerhouse to be cur into the hilside will likely need more support then Indicamed in Exhibis F-4, We recermmend that the cavern be axcovesed at its crows © provide arch support. ls alse likely thet the powerhouse walls and root will need to be ined with a . Concree ouppert aymem reher than the vhotcreta 19 provide more permanent wemer-tight support fbr the turbine-geceramx equipment. During final design investigations, k may be hows thet he powerhouses would be beter located well inte the hill where rock quality is [aly boner end supports and lirang cold be reduced, Table D-1: KPU disagrees with the following clamenes of the cost extimate. 1. Tarn cot incl fh ere, which or eporonce has bon ively ich (64>) 2. Cant of concrete is undecomed, @ “3, An emarguncy Gesal generator is shown in the one-fne diagram, bet is net inched ia the cond extent, @® 4 Com of renemissien ine end reachyerd is waderrased, S. The wait pricing for the upper name! is shown w be the sume os fr the lower tunnel, which is met becenge of the incrnnsed Giicutty in getting people, manerials and eqaipment wp te the upper poral area, Consequently, the cost of uccaveting the upper wunnel is waderstated, The unit cost for rock examveien of the powerhouse coven is shown we be enly $50 par oubie yard, This is quite « comrast 0 the $240 par cubis yerd excavation of the eunnal and, conse quendy, i waderreuzed. 1, Tha cmt cnecing wo Wid fr xcam a Prost peowon ia mdecramd. (59) Secerely, Ong tee A Mager Gener) Manager 135