Loading...
HomeMy WebLinkAboutMahoney Lake Hydro Project meetings notes 1995 April 5, 1995 Mr. Stan Sieczkowski Manager, Operations & Maintenance Alaska Energy Authority 480 West Tudor Anchorage, AK 99503 Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear Mr. Sieczkowski: In response to your request, HDR Engineering, Inc., on behalf of the City of Saxman and the Cape Fox Corporation, is pleased to provide you with the enclosed copy of Scoping Document 1 for the above-referenced project. This document was originally distributed to interested agencies and Native American groups on March 9, 1995. Please contact me or Jack Snyder if you have questions concerning the Mahoney Lake Hydroelectric Project. Sincerely, HDR ENGINEERING, INC. nthak V. Simae/, L{ Michael V. Stimac Manager, Licensing and Environmental Services cc. Doug Campbell, Cape Fox Jack Snyder, HDR HDR File, B.4.1 HDR Engineering, Inc. Suite 1200 Telephone 7 7 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 Mahoney Lake Hydroelectric Project FERC No. 11393 (MLHP): September 23, 1996 September 11, 1996 August 30, 1996 August 29, 1996 August 26, 1996 August 2, 1996 July 26, 1996 May 31, 1996 March 1, 1996 June 1, 1995 May 24, 1995 May 12, 1995 April 12, 1995 April 5, 1995 April 3, 1995 August 8, 1994 April 13, 1994 April 12, 1994 March 16, 1994 h:\all\sdean\fileguid.doc Ltr to Cashell frm SES Re: Upper Mahoney Lake Hydroelectric Project; FERC No. 11393-001 Ltr to SES frm Stimac Re: Post-Project Cumulative Degree Days Revised Tables Memo to SES frm Thrall Re: License Application Ltr to SES frm Stimac Re: Post-Project Cumulative Degree Days Ltr to Cashell frm Snell Re: Motion to Intervene Ltr to SES frm Stimac Re: Aquatic Resources Monitoring Plan Ltr to SES frm Stimac Re: FERC Acceptance of Application for License and Additional Info. Request Ltr to Cashell frm Stimac Re: FERC No. 11393-000 Ltr to SES frm Stimac Re: FERC No. 11393/AK 9504-08J Ltr to Stimac frm SES Re: Proposed Transmission Line Routing HDR Itr to SES frm Stimac Re: FERC #11393 HDR ltr to SES frm Stimac Re: FERC #11393 Ltr to Stimac frm Stevenson Re: FERC #11393 (KPU) Ltr to SES frm Stimac Re: FERC #11393 - Scoping Documents 1 (3/1/95) (attached) Memo to SES frm J. Thrall Re: Mahoney Lake Proj. (Locher) Ltr frm Stimac to WRS Re: Final Consultation Document (FCD) (HDR) w/enclosure Meeting Minutes frm HDR Re: NEPA Scoping Mtg. AM Session Meeting Minutes frm HDR Re: NEPA Scoping Mtg. PM Session Ltr frm Stimac to WRS Re: Initial Consultation Document (ICD) (HDR) w/enclosure MEETING MINUTES cs PROJECT: Mahoney Lake Hydroelectric Project, FERC No. 11393 SUBJECT: NEPA Scoping Meeting, Morning Session DATE: April 13, 1994 PLACE: Ketchikan, Alaska ATTENDEES: William Jones-City of Ketchikan; Melanie Fullman-Ketchikan Gateway Borough; Steve Brockman, Vicki Davis-USFWS; Jack Gustafson, Carol Denton-ADFG; Wendy Harkins-Sitka Electric Department; Jan Risla- Ketchikan Public Utilities; Craig Moore-State Parks Advisory Board; Tom Somrak, Jim DeHerrera, Teresa Trulock-USFS; Nan Allen, Vince Yearick-FERC; D. Campbell-Cape Fox Corporation; Wade Lindsay- Wilkenson, Knauer, Barker & Quinn; John Morsell-Northern Ecological Services; Mark Dalton, Mike Stimac, Jack Snyder, Lisa Fortney-HDR Engineering. The meeting began at 9:15 am. Doug Campbell welcomed everyone. He reminded everyone to sign in, especially if they were interested in testifying. This meeting is called as part of the National Environmental Policy Act (NEPA) process. It is a required step in the process. The meeting is being recorded. The minutes of the meeting will be issued to everyone signed in and to everyone on the mailing list. Scoping documents, agenda were made available to attendees. Doug asked them to please identify yourself, your name and who you are representing when commenting. Even though the intent of the meeting is to take testimony, Doug stated he would feel more comfortable and it would be more productive if this was more of an iffformal question and answer discussion on the issues. However, if anyone wishes to make a prepared statement, that is acceptable. The people are here to answer any questions and hopefully deal with any of the issues that may be raised. Mike Stimac reviewed the meeting agenda. Mike Stimac reviewed the project history to date from receiving the preliminary permit from the Federal Energy Regulatory Commission (FERC), which gave the City the exclusive right to study the project and to file a license application by the end of the term of the permit. This permit has a term of three years and was received in June 1993. By the end of May 1996, the City of Saxman has to file its license application for the project. He explained that this isn’t the first time developers have looked at the Mahoney Lake Project, previous studies date back to the Carter administration. Once the project looked feasible, the studies were scoped out and preliminary design work was done. On March 16, 1994, the Initial Consultation Document was issued, which contained a brief description of the project and its operation and discussed the study programs to be implemented to develop the environmental documentation. It sought input from the public and the agencies. The first-stage consultation meetings were held on April 26, 1994, same format as these NEPA scoping meetings, one meeting for the public and another for the resource agencies and a site visit was also held. The comment period lasted for 60 days following the meetings. That ended the first- ineering, Inc. Suite 1200 Telephone HOR Eng 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 stage of consultation and started the second stage. The Initial Consultation Document was then modified according to the agency letters that were received and the document was distributed as the Final Consultation Document on August 8, 1994. As a result of the comments that were received and the applicant’s understanding of the project, it appeared that the environmental impacts would not be too significant. In July of 1994, a meeting was held with the FERC to explore the possibility of developing an Applicant-prepared environmental assessment (EA). This was a procedure that was authorized by the National Energy Policy Act of 1992. How this differs from a normal licensing process is that the applicant in a normal situation would file the license application with the FERC. The FERC would then begin the NEPA process and write the EA. Under this new procedure, the NEPA process starts earlier in the process. It happens before the license application and the preliminary draft EA are filed with the FERC. When the Final Consultation Document was distributed, the letter that promulgated that document indicated that this was the approach that would be taken. That necessitated the development of the Memorandum of Agreement (MOA) between the City of Saxman, Cape Fox Corporation, U.S. Forest Service (USFS), and the FERC. The MOA sets forth the fact that an Applicant-prepared EA will be developed, a schedule of how the events might occur, and provided for a communications protocol between the parties. The MOA was signed on January 13, 1995. In February, the FERC issued a letter to all parties on the distribution list waiving certain regulations because the timing of those regulations do not apply with this EA process, and that the Applicant-prepared EA would be developed and the EA would be filed in place of Exhibit E of the license application. On March 9, 1995, the Scoping Document 1 (SD1) was sent out to everyone on the distribution list and indicated the scoping meetings would be held yesterday and today. Yesterday, a site visit was held in the afternoon and an evening meeting for the public. This morning’s meeting is oriented towards the resource agencies. Comments are due on issues and the project on May 15, 1995. Those comments should be addressed to me. My name, address, and phone number are all contained in the SD1. Looking ahead, if we need to modify the SD1 as a result of feedback that we receive, if we add or delete issues, then a SD2 will be issued in June 1995 while working towards finalizing the license application and the EA. In September 1995, we hope to send a draft of the EA and the license application to all parties for review. This will have a 90- day comment period. About two-thirds of the way through the 90-day comment period, a public and agency meeting will be held where information can be exchanged to make sure we understand what concerns there may still be and to answer any questions the resource agencies may have. At the end of the 90-day comment, formal comments will be submitted regarding the draft application and, because we are doing NEPA earlier, and under this modified procedure, those letters will also need to contain draft mandatory and recommended license terms and conditions and prescriptions. That will be tentatively in December 1995. Our hope would be to turn it around, modify the application and submit it to the FERC in January 1996. Three other dates on the chronology relate to what happens with the Draft EA and license application once FERC receives it. Vince Yearick of the FERC will talk about those procedures. Mike Stimac explained that the purpose of the scoping meetings is to identify issues, concerns and opportunities associated with the proposed action. According to NEPA, it should be conducted as soon as possible in the process. Normally, in a regular licensing proceeding, NEPA does not begin until the third stage of consultation. This is actually being done now as part of the second stage and having it completed sooner, before the application is filed with the FERC. 2 Mike Stimac explained that the participation of the federal, state, and local agencies, any Native American group and interested persons is requested to identify significant environmental and socioeconomic issues related to the proposed action, determine the depth of analysis and significance of issues to be addressed in the EA, identify how the project would or would not contribute to cumulative effects in the Mahoney Creek basin, identify reasonable alternatives that should be evaluated, eliminate from detailed study the issues and resources that do not require detailed analysis during review of the project, and to solicit additional study requests. This will be the last opportunity for resource agencies to request additional studies. If requests are submitted, they must conform to 18 CFR 4.32.b.7. You must describe the study, the basis for the request, who should participate and conduct the study, the methodology and the objective, whether the methodology is accepted by the scientific community, how the results will be used by the requesting agency, how long it might take to complete the study, and why the objectives cannot be achieved by using the existing data or study program. Mike Stimac requested additional information that would be beneficial to analyze the impacts of the project. Information, quantified data, or professional opinions that may contribute to defining the geographical and temporal scope of the analysis and identifying significant environmental issues; identification of, and information from any other environmental document or similar study (previous, on-going, or planned), relevant to the proposed Mahoney Lake Hydroelectric Project. Existing information and any quantified data that would help to describe the past and present actions and effects of the project and other developmental activities on environmental and socioeconomic resources; information that would help characterize existing environments and habitats; identification of any federal, state, or local resource plans, environmental impact statements, and future project proposals in the affected resource area, such as proposals to construct or operate water treatment facilities, recreation areas, water diversions, timber harvest activities, or fish management programs; documentation that would support a cgnclusion that the proposed project contributes to adverse or beneficial effects on resources, including but not limited to (a) how the project interacts with other hydropower projects and other development activities within the affected area, (b) results from studies, (c) resource management policies, and (d) reports from federal, state, and local agencies; and documentation showing why any resources should be excluded from further study or excluded from further consideration. Mike Stimac reiterated that all comment letters or additional study requests should be submitted to him by May 15, 1995. Vince Yearick introduced himself and Nan Allen, the fisheries biologist from the FERC. An applicant-prepared EA will be prepared that will be filed as part of the license application. That option came about from legislation as part of the Energy Policy Act of 1992. The intent of that was to shorten the length of time from when the FERC receives the license application to when they make a licensing decision on a project. The intent was to make the opportunity available to have an environmental document fairly complete when FERC receives it, so that FERC does not spend as much time on it internally reviewing and rewriting work that has already been done by the Applicant. In this case, it is a cooperative EA, which means that the USFS will also be using the document to support their decision on conditions that will go into their Special Use Permit for the project because the project occupies USFS land and FERC will use it to guide their decision whether or not to issue a license for the project. A couple of regulations were waived, or more accurately some things were pushed into different time frames. Some of the comment periods were moved to the pre-filing stages. Mike Stimac mentioned one of those and that is the time period to request additional studies on the project. Typically, that happens after FERC receives the application, it is noticed in the Federal Register, and there is opportunity for anyone to request additional studies. In this case, that time is now. This is the last time to request additional studies. Also, we are asking for more stringent and earlier review on the part of the agencies that are involved in the process. You will be receiving a copy of the preliminary draft EA for the Mahoney Lake Project. The applicant will be asking - for preliminary terms and conditions from the agencies, such as the Section (4)e conditions from USES, and the Alaska Department of Fish & Game (ADFG), what you think your final terms and conditions might look like for this project. The terms and conditions of the license are needed now in order to be analyzed in the EA before it is filed with FERC. If they are not included, FERC will have to rewrite the document which will lengthen the processing time and defeat the purpose of the applicant-prepared EA. More up-front work is required by the agencies so that less commitment is needed once the application is filed. So the preliminary terms and conditions will be requested in the comment period for the preliminary draft EA. Once FERC receives the application, some review will still be required. A check for adequacy that are required for license applications. Since FERC is working with the applicant, it is anticipated that the application will be acceptable because they will have reviewed and commented on it prior to filing. A public notice will be issued that FERC has accepted the application. Interventions on the project can be filed at this time. This is also the time to file final terms and conditions on the project. That information should be similar to the preliminary comments that FERC received from the draft. The FERC and USFS will make it their own document and issue it as a joint draft EA. Comments will be solicited on that document and a final EA will be issued. A license decision will then be made, and if the decision is to approve the license, what kind of measures should go in to the license. The USFS will also use this to issue their Special Use Permit. If all goes well, it will take approximately 1 year to issue a licensing decision from the time FERC receives the application. The Energy Policy Act did require FERC to develop regulations on how the process will work for applicant-prepared EA’s. Nothing official is expected for a while. Concentration is on processing the Class of 1993 relicensing applications. There is not a lot of attention being paid to developing new regulations. A draft schematic of how the modified process will work is available up here at the front. The applicant of a proposed project near Haines, Alaska is also utilizing this method of completing their own EA. It is a fairly popular idea and will be more popular if it works the first few times by obtaining a quick licensing decision. The intent is to speed things up and avoid duplication of efforts. However, it does require some more involvement up front. Questions? There were none. Jack Snyder described the proposed project. He described the project design and its location between Upper and Lower Mahoney Lakes. He presented a topographic map of the area and illustrated how the site will be accessed from the existing logging road near the Swan Lake transmission line near White River travels south towards the lower lake. The transmission line will be buried from the powerhouse to the existing logging road and then continue as an overhead line to the Swan Lake transmission line. TT Jack Snyder summarized how the proposed project would operate and the construction methods proposed. Jack Snyder explained that most of the project would be underground. An upper horizontal tunnel would be located about 80 ft. below the lake surface (lake tap) of Upper Mahoney Lake and would convey water 1,400 ft. to a vertical shaft. The water would drop 1,200 ft. and continue to a lower 3,500 ft. horizontal tunnel which would run to the powerhouse. The powerhouse location was chosen because of the impassable barrier to upstream migration of fish. Jack explained the normal operation of controlling the upper lake like a storage reservoir without the need to construct a dam. A videotape of aerial footage for the project area was shown which Jack Snyder narrated. Steve Brockman asked if there was a layout of construction camp facilities or staging area. Jack Snyder explained that construction proposed for this project is not labor-intensive. The tunnel operation would typically take 3-4 people to do the tunneling operation and maybe another 2-3 people involved in the excavation of the tunnel spoils. A total crew would be 6-8 people during construction of the main tunnel. The raised bore section needs a 2-man crew to run the drill rig above and another 2-man crew will excavate the spoils as it falls from above. That phase of construction would require a 4-man crew. Not a lot of construction personnel at the site during this part of construction. Jack Snyder showed the powerhouse site plan where the staging area is planned. This is where the contractor would place his job trailer and stockpile rebar and various construction materials. It is not anticipated that the construction crew would live at the site. With the access road, they could commute to the job site from Ketchikan. A small staging area would also be at the top of the vertical shaft where they would level off a pad to set up the drill rig. Jack pointed out anticipated spoils areas which would include 3,000 yards of shotrock and above approx. 1,200 yards of shotrock from the upper excavation. These areas‘will be identified in the erosion and sediment control plan. i Mark Dalton described the resource issues that have been raised to date in that the project has been studied since the 1970’s. The scoping document appendices include the study plans that were proposed last year and a brief summary of where the study plans are to date. Land disturbance issues - The applicant will prepare an Erosion and Sediment Control Plan as an appendix to the EA. In addition, a NPDES stormwater pollution prevention plan will be prepared. Botanical issues - Concern about USFS-designated sensitive plant species as well as threatened and endangered species that could be impacted. To date no threatened or endangered species have been identified. However, in consultation with USFS in Ketchikan and Mary Stensvold in the Sitka office, a survey was conducted last September of most of the project area starting with the terminus of the existing logging road, coming around to the powerhouse site and some work around the upper lake to try and characterize the plants that occur up there. That survey was conducted by HDR staff and Alaska Natural Heritage Program. A copy of that has been provided to the USFS (Mary Stensvold). A copy will also be given to Teresa Trulock at the end of the meeting. As a result of that work, a biological evaluation (BE) will be prepared. The USFS uses this as a management tool to assess what kind of impacts there might be to the sensitive plant species and whether or not management measures are appropriate to offset impacts. This will also be included as a technical appendix to the EA. This is a requirement 5 generated out of the need for a Special Use Permit because the project occupies USFS lands. The BE will be signed off by a USFS representative. Terrestrial resource issues that have been raised - What impacts construction of the project will have on species in the area, in particular, a population of mountain goats that were relocated by ADFG in 1991. Loss of habitat (wetlands) due to construction of the project. Identification of where wetlands are and relocate project features around wetlands where practical, primarily the access road. The overhead transmission line will utilize raptor-proof design to protect raptors and other birds from electrocution. To date, no threatened or endangered species have been identified. Field surveys occurred several times during the summer of 1994 which included a field assessment of wetlands and other habitats in the area, including a ground survey for nesting raptors (goshawks) in the project area. In addition, cooperatively with the U.S. Fish and Wildlife Service (USFWS) a bald eagle nest survey was conducted in June 1994. A wetlands functional assessment will be prepared and a wildlife species biological evaluation will be prepared in consultation with the USFS. Other issues include aesthetic resources - what impacts the project will have on the visual quality of the area. What impacts to potential recreation opportunities might occur as a result of construction and operation of the project. Socioeconomic issues-what can we anticipate happening to the local economy as a result of construction and operation of the project. Consultations are being held with the State Historic Preservation Office about any concerns of how project construction and operation will affect historical or archaeological resources in the area. Aquatic resource issues - impacts to fish in Mahoney Lake system, and Lower Mahoney Creek, spawning of sockeye salmon, temperature in gravels. At certain times of the year, Lower Mahoney Creek becomes impassable to certain species of salmon. The outlet of Upper Mahoney Creek where the delta is located has been identified as a spawning area for sockeye salmon. The concern is impacts to spawning habitat as well as maintaining the viability of that habitat for overwintering eggs and hatching in the spring. As a result, water quality data has been obtained. In the Upper Mahoney Lake, a temperature probe was placed at the proposed lake tap location and is continuously monitoring at depths of 20 ft. increments from surface to 100 ft to model water column temperatures. Because there has been so much snow at Upper Mahoney Lake, we have been unable to locate the temperature monitoring device for the last few months, even using a metal detector. At the tailrace, stream flow, water quality, and temperature data have been recorded. Two temperature probes were placed in Lower Mahoney Lake and an animal chewed on one of the cables. Some data were lost, but redundant recorders made sure we have sufficient data. The collection of data will continue through May 1995. John Morsell described the three field trips that occurred in 1994. The first visit was in mid-June and the intent was to get an idea of the resident fish living in Lower Mahoney Lake/Lower Mahoney Creek, South Creek which is a tributary to Lower Mahoney Lake, and the portion of Upper Mahoney Creek from the falls down to the lake. A variety of sampling and observational 6 techniques were used to get the information needed. A second field trip was made in late August which was timed to coincide with the maximum number of salmon in Lower Mahoney Creek and to get some observations of how many of those salmon were making into the lake and possibly to do some mapping of spawning areas in the lake. At that time, most of the sockeye salmon were stranded in Lower Mahoney Creek. A third field trip was scheduled for the third week of September. Following some heavy rains, the stream flows were substantially higher and most of the sockeye that were.in the lower creek had made it into the lake. John was successfully able to map the spawning areas in the lake. The field studies are essentially completed. The data analysis is mostly complete. The technical report will be included with the EA. The fish data will be integrated with the temperature data during preparation of the EA to try and attempt to model intergravel temperature post-project to predict what the impacts might be on salmon egg incubation. Vicki Davis asked about the studies for the USFS and if studies would be conducted for USFWS candidate species. Mark Dalton responded that no, usually there is an overlap of USFWS and USFS designated species. Vicki Davis asked if there were plants that may not overlap, if those were looked at too. Mark Dalton said he would have to review that again. Vicki Davis asked about surveying species other than those listed. Mark Dalton said he looked for sign or use, such as for goshawks. Vicki Davis asked Mark Dalton if he intends to look at candidate species. Mark responded no, not at this time. iv Mike Stimac asked if there were any other questions on anything covered so far, such as project design and operation, the licensing process, environmental studies or issues to be addressed. Jack Gustafson said that it was mentioned about fish migrating up from saltwater may encounter a barrier or partial barrier at certain stream flows, so that raises the question as to what the effect of discharge is from the hydroelectric project would be during those months that fish are migrating in the stream. That is something that should be looked at in more detail to actually quantify at what flow conditions fish passage is available under natural flows and try to enhance or replicate those flows during times when fish migrate so that it doesn’t create a more severe barrier. It needs additional work. Jack Snyder responded that the applicant hasn’t provided hydraulic data to the agencies to see how the operations will work. When the agencies receive that data, it will shed some light on that issue. The total drainage area for the lower lake outlet is 5 sq. miles. The upper lake drainage is 2.1 sq. miles so that equates to roughly 40% of what is going out the lower lake. The other 60% is from drainages downstream of the diversion area. If the project shuts down, the inflow will be reduced by 40%, a lot of other water is still coming into the lake. Jack Gustafson would like to know at what flows that threshold is reached where fish passage is available. Knowing that, there may not be a problem because under natural conditions, it is a problem sometimes. Only the Olympic swimmers make it up through that barrier. Jack Snyder 7 stated that we have an idea of where that threshold is. Some fish were getting through at low flows. Mark Dalton added that the sockeye were moving through the barrier. It was the pink salmon not making it. More field work is not anticipated at this time. Once you analyze the hydraulic information, it will give you a better idea. Nan Allen stated that under the aquatic section where it is asterisked for cumulative effects analysis as well as site-specific analysis. Those issues listed under the aquatic resources section look to be project effects as opposed to cumulative effects. I suggest moving those cumulative effects from aquatic resources into the recreational section and dropping the asterisks in the aquatics sections. Mike Stimac lead the discussion of agency/public comments on the project. Steve Brockman and Vicki Davis from USFWS had indicated on the sign-in sheet as wanting to make public testimony. Vicki Davis stated that as far as her comments, they have been addressed. Steve Brockman stated that he will save his comments for a letter. Mike Stimac asked if there was anything in particular he was concerned about. Steve Brockman asked for clarification if there were no fish in the upper lake. John Morsell responded that appears to be the case. Steve Brockman asked if that had been looked at. John Morsell stated that it was studied in the early 1980’s. Grayling had been stocked in the upper lake many years ago and follow-up showed the fish had disappeared. The last words was that there was no fish up there. Steve Brockman asked if the shoreline around the upper lake went straight down all the way around. Jack Snyder replied that there was a slide down at the far end where it is a little shallower but overall, it is very steep with little habitat and a very sterile environment. Steve Brockman asked about the effect of using the project tunnels to dewatering the upper creek, will it be diminished or dried up. Jack Snyder stated that flows in the upper creek would be diminished when the lake level drops below the outlet elevation. There is roughly a mile and a half of drainage area that feeds that section where springs, small tributaries coming down so there will be some inflow from drainage down to the lower lake. Steve Brockman asked if the lake level would be dropped by 75 ft. Jack Snyder stated that yes, the lake level will fluctuate from where it is full down to the lake tap. Steve Brockman stated that there will probably be a 80-90% depletion from the creek. Jack Snyder said that probably will be the case but it will vary seasonally. On the outflow of water from the tunnel, Steve Brockman wanted to know where is that in relation to where the creek currently is. Jack Snyder described how the creek comes out of the upper lake, goes through a little valley, turns and drops about 1,200 ft. down the waterfall, and at the bottom, there is one last waterfall and a pool, and the creek flows about 800 ft. through the woods in a braided channel into the lake. The powerhouse would be situated at the base of 8 that last waterfall. The water would be returned into that pool. There will be no loss of habitat in the lower creek from the falls down to the lake. In previous proposed arrangements for Mahoney Lake, the powerhouse was not situated there and would have caused the creek to be dried up in that section between the falls and the powerhouse. Steve Brockman asked about the spawning area near South Creek if there was an alluvial formation and if spawning habitat was potential or actual. John Morsell confirmed that there is currently spawning activities there, approximately 25% of the fish spawn there and the other 75% spawn at the delta from Upper Mahoney Creek. Steve Brockman asked how the access road will cross Lower Mahoney Creek and South Creek, if by free-span bridges or culverts. Jack Snyder replied that it would be free-span bridges. Steve Brockman stated that the timing of construction should be planned to be appropriate. Doug Campbell stated that this has been looked at closely in the field. Steve Brockman stated that when the snow is gone from Upper Mahoney Lake, he would like an opportunity to go up there. Jack Snyder said that he should coordinate with Doug Campbell. They will be going up in June to remove the temperature probe as soon as the ice is gone. Mark Dalton asked John Morsell if there were any fish in the 800 ft. stretch of Upper Mahoney Creek from the powerhouse location to the lower lake. John Morsell replied that he saw a few Dolly Varden. He stated that there are three log jams in this area and the creek dries up in low flows, so there are no fish in the middle section and some fish at the end. He stated it is poor fish habitat. ¥ 1 Mike Stimac asked if anyone had any more comments. Jack Gustafson asked if there were any steelhead in the system. John Morsell said he saw one juvenile rainbow trout/steelhead in the lake. Therefore, they must spawn in the lake. Steve Brockman stated that steelhead are as strong a swimmer as sockeye so it is possible to get past the barrier. John Morsell said that if steelhead are present, it is a small population. Vince Yearick stated that regarding cumulative effects of recreation/land use, if there was anything else going on between Upper and Lower Mahoney lakes such as logging activity and road construction. He wanted to know if there was much recreation utilization of the area. Based on the geographical scope of SD1, there may be no cumulative impacts on recreation/land use, but there might be if scope is expanded. Teresa Trulock stated there was some recreation that occurs near the project site. Jack Snyder asked Doug Campbell to explain how access to the site is managed. Doug Campbell stated that road access is limited to individuals. Access is mainly from saltwater, beaching the boat and hiking up the lower creek to the lake. Steve Brockman asked if the road will be gated. Doug Campbell said that it already is. Steve Brockman asked if it was on the Ward Lake Road. Doug Campbell confirmed that it was and said the gate is located approximately 7-8 miles from the end of the access road. Steve Brockman asked if people fish the White River. Doug Campbell said yes. Most of the recreation could be considered dispersed and is very minimal. Someone asked if the land would be opened up for recreation. Doug Campbell said it would not be encouraged because it is considered a liability to the Cape Fox Corporation. Craig Moore asked about FERC’s regulations on recreation. Vince Yearick said those regulations could be found in 18 CFR 2.7. Steve Brockman asked when does the lower creek dry up, if it was in late summer. John Morsell teplied yes. Jack Snyder said actually it infiltrates into the ground. Steve Brockman asked if this was constant. Jack Snyder said it gets lower in the summer. Vicki Davis asked if the upper creek dries up. Jack Snyder replied that it was the section from the last waterfall to the lake that the water infiltrates the alluvial materials. Vicki Davis asked if more water would be added to the system. Jack Snyder replied that new water could not be created but depending on the time of the year it would be above/below/at the baseline. Steve Brockman said that flows will be more uniform. Jack Snyder stated that generally that is true. Doug Campbell asked Jack Snyder to review the history of the hydraulic data. Jack Snyder stated that a gage had been at the lower creek for 12 years. A gage was located at the outlet of the upper lake for 6-7 years. So the gage data provides more precise data versus simulating data from another gaged creek nearby. ¥ Steve Brockman wanted to know the nature of the blockage on the lower creek. John Morsell stated that there are steep cascades, boulders, lined by rock walls and is gorge-like. The water is fast and turbulent at high flows. The worst blockage is about 100 ft. downstream from the lake outlet. Steve Brockman asked if there was room for improvement in the creek for fish passage as part of mitigation. Jack Snyder stated that you have to be careful because if you make it too easy, pink salmon will get into the lake. Pink salmon get into the lower creek, but they can’t get up to the lake. It adds a variable. Steve Brockman wanted to know about the effect of the drainage rate and lake elevation levels. Jack Snyder stated we don’t want to fool with the lake elevation. The project will stabilize the flows, the flows will be more consistent. Forty percent of the flow leaving the lower lake will be project related but the other 60% will be unaffected. The average will be taken for net flows. Jack Gustafson asked about supplementing flows during low flow times. Jack Snyder stated that since only 40% of lower lake outlet flows were project-related, supplementing flows should not be necessary. High rain fall events will continue to control lower lake outlet flows as is the case now. 10 Vicki Davis wanted to know what would happen in the event of a dry year, would contingencies be made to make water available. Jack Snyder stated that the applicant would have to make do with what is available. During a low water year, it usually shows its effects in fall/winter. The project would operate for a shorter period of time or at lower loads. Jack Gustafson asked if the drawdown would occur all the way to the lake tap. Jack Snyder said the lake would be drawn down to just above the lake tap because it would be undesirable to draw air into the pipe. At that point, it becomes a run-of-river project. When the lake starts to rise from increasing inflows, the project could increase its output. . Doug Campbell thanked everyone for attending. He encouraged attendees to contact team members if there any further questions or concerns. Jack Snyder reminded attendees that written comments are due by May 15, 1995. The meeting adjourned at 10:50 am. 11 MEETING MINUTES fc’ PROJECT: Mahoney Lake Hydroelectric Project, FERC No. 11393 SUBJECT: National Environmental Policy Act (NEPA) Scoping Meeting, Evening Session DATE: April 12, 1994 PLACE: Ketchikan, Alaska ATTENDEES: Wendy Harkins-Sitka Electric Department; Hank Newhouse; Rich Trimble-Ketchikan Public Utilities; Craig Moore-State Parks Advisory Board; Don Ranne, Teresa Trulock-USFS; Nan Allen, Vince Yearick- FERC; Wade Lindsay-Wilkenson, Knauer, Barker & Quinn; John Morsell-Northern Ecological Services; Mark Dalton, Mike Stimac, Jack Snyder, Lisa Fortney-HDR Engineering. The meeting began at 7:10 pm. An agenda (copy attached) and Scoping Document 1 (SD1) were available for attendees. Jack Snyder welcomed everyone, explained that Doug Campbell was unable to attend this meeting, explained the protocol for the meeting (e.g., sign in and indicate if wish to provide testimony, the meeting is being taped, identifying yourself before speaking, etc.), and he reviewed the agenda. Mike Stimac reviewed the project history to date from receiving the preliminary permit from the Federal Energy Regulatory Commission (FERC), which gave the City the exclusive right to study the project and to file a license application by the end of the term of the permit. This permit has a term of three years and was received in June 1993. By the end of May 1996, the City of Saxman has to file its license application for the project. Once the project looked feasible, the studies were scoped out and preliminary design work was done. On March 16, 1994, the Initial Consultation Document was issued, which contained a brief description of the project and its operation and discussed the study programs to be implemented to develop the environmental documentation. It sought input from the public and the agencies. The first-stage consultation meetings were held on April 26, 1994, same format as these NEPA scoping meetings, one meeting for the public and another for the resource agencies and a site visit was also held. The comment period lasted for 60 days following the meetings. That ended the first- stage of consultation and started the second stage. The Initial Consultation Document was then modified according to the agency letters that were received and the document was distributed as the Final Consultation Document on August 8, 1994. As a result of the comments that were received and the applicant’s understanding of the project, it appeared that the environmental impacts would not be too significant. In July of 1994, a meeting was held with the FERC to explore the possibility of developing an Applicant-prepared environmental assessment (EA). This was a procedure that was authorized by the National Energy Policy Act of 1992. How this i i Suite 1200 Telephone Tren ee 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 differs from a normal licensing process is that the applicant in a normal situation would file the license application with the FERC. The FERC would then begin the NEPA process and write the EA. Under this new procedure, the NEPA process starts earlier in the process. It happens before the license application and the preliminary draft EA are filed with the FERC. When the Final Consultation Document was distributed, the letter that promulgated that document indicated that this was the approach that would be taken. That necessitated the development of the Memorandum of Agreement (MOA) between the City of Saxman, Cape Fox Corporation, U.S. Forest Service (USFS), and the FERC. The MOA sets forth the fact that an Applicant-prepared EA will be developed, a schedule of how the events might occur, and provided for communications protocol between the parties. Tie MOA was signed on January 13, 1995. In February, the FERC issued a letter to all parties on the distribution list waiving certain regulations because the timing of those regulations do not apply with this EA process, and that the Applicant-prepared EA would be developed and the EA would be filed in place of Exhibit E of the license application. On March 9, 1995, the SD1 was sent out to everyone on the distribution list and indicated the scoping meetings would be held today and tomorrow. Mike Stimac stated that HDR needs to receive written comments from resource agencies and the = public by May. 19,1995. Depending on what kind of feedback is received, SD1 may be revised to include comments and distributed again as Scoping Document 2 (SD2). If little or no as significant comments are received, a second scoping document will not be issued, but instead a letter will be distributed informing parties of this. The preliminary draft EA and the draft license application are tentatively scheduled to be distributed by September 1995 for review and HK comment. The agencies and public will have a 90-day comment period. About two-thirds of the way through the comment period, a public/agency meeting will be held to discuss the results of the studies and respond to any questions and to clarify concerns about the project. This will help to refine the information that goes into the agencies comment letters. The comments of the draft license application and draft EA will be due, along with draft mandatory and recommended license terms and conditions or prescriptions in Pecember of 1995. The draft EA and the license application are scheduled to be filed with the C in January 1996. The last three items on the project chronology relate to what happens with the document and process once the application is filed. Vince Yearick of the FERC will talk about those when he’s up here. Mike Stimac explained that the purpose of the scoping meetings is to identify issues, concerns and opportunities associated with the proposed action. According to NEPA, it should conducted as soon as possible in the process. Normally, in a regular licensing proceeding, NEPA does not begin until the third stage of consultation. This is actually being done now as part of the second stage and having it completed sooner before the application is filed with the FERC. Mike Stimac explained that the participation of the federal, state, and local agencies, any Native American group and interested persons is requested to identify significant environmental and socioeconomic issues related to the proposed action, determine the depth of analysis and significance of issues to be addressed in the EA, identify how the project would or would not contribute to cumulative effects in the Mahoney Creek basin, identify reasonable alternatives that should be evaluated, eliminate from detailed study the issues and resources that do not require detailed analysis during review of the project, and to solicit additional study requests. This will be the last opportunity for resource agencies to request additional studies. If requests are submitted, they must conform to 18 CFR 4.32.b.7. You must describe the study, the basis for the request, who should participate and conduct the study, the methodology and the objective, whether the methodology 2 is accepted by the scientific community, how the results will be used by the requesting agency, how long it might take to complete the study, and why the objectives cannot be achieved by using the existing data or study program. Mike Stimac requested additional information that would be beneficial to analyze the impacts of the project. Information, quantified data, or professional opinions that may contribute to defining the geographical and temporal scope of the analysis and identifying significant environmental issues; identification of, and information from any other environmental document or similar study (previous, on-going, or planned), relevant to the proposed Mahoney Lake Hydroelectric Project. Existing information and any quantified data that would help to describe the past and present actions and effects of the project and other developmental activities on environmental and socioeconomic resources; information that would help characterize existing environments and habitats; identification of any federal, state, or local resource plans, environmental impact statements (EIS), and future project proposals in the affected resource area, such as proposals to construct or operate water treatment facilities, recreation areas, water diversions, timber harvest activities, or fish management programs; documentation that would support a conclusion that the proposed project contributes to adverse or beneficial effects on resources, including but not limited to (a) how the project_i development activities within the aff Ctivities v vithin the affect results from studies, (¢) resource mariag igement ~ policies, and (d) reports from federal, state, and local agencies; and documentation showing why ‘any resources should be excluded from further study or excluded from further consideration. Mike Stimac stated that all comment letters should be filed by May 15, 1995. He asked if there were any questions and there were none. Vince Yearick explained the NEPA process and how the USFS and the FERC need to complete NEPA to issue permit/license under their respective jurisdictions. The FERC issues licenses for non-federal hydropower projects, those projects developed by private individuals or utilities versus the Bureau of Reclamation or other federal agencies. The USFS issues Special Use Permits. For this project, because there are USFS lands involved, the environmental document, which FERC believes will be an EA, will serve as the NEPA background for their licensing decision and for the USFS to make their permitting decision. One thing that is different in this particular project is that the Applicant intends to prepare their own EA. This is an option that was brought about by the National Energy Policy Act of 1992. The intent is to speed up the licensing process, to allow the applicant to prepare their own environmental documents. If it’s an EA, they can do it themselves or they can hire someone to do it. If it will be an environmental impact statement, they can do another option which is Third Party Contracting. The FERC believes an EA would be needed because no new dam would be constructed and it would use existing impoundments, which minimizes some of the potential environmental impacts. Both the FERC and USFS are involved because of federal permits, which is what triggers NEPA. The intent of ‘the Applicant-prepared EA is to speed the licensing decision process. The application preparation work is being completed the same time the environmental analysis is being done. Typically, the application is prepared and filed with FERC and then the FERC begins their review of the project. FERC would begin scoping after the application is filed and would write the environmental document that leads to a licensing decision. For this project, the EA will be prepared along with the license application. One of those regulations that was waived is the requirement to file the Exhibit E, or the environmental report, with the 3 application. The EA will take the place of the Exhibit E in the application. The ultimate goal is for the EA to be as complete as possible when the FERC receives it, so little rewriting will have to be done at that time. Preliminary terms and conditions and recommendations will be requested when the preliminary draft EA is distributed. That way when the document is filed with the FERC, it will include an analysis of all of those recommendations, so major changes will not have to be made to the document once it is received. For those providing comments, it is important to submit your terms and conditions with the preliminary draft EA. The applicant can then incorporate your comments into the EA and the FERC will have a head’s up as to what to expect when the final comments come in. Once the application is filed, the FERC will review the application for adequacy, and assuming it is okay, the FERC will issue a public notice that the application has been filed and that it has been accepted (meaning there are no deficiencies in it). At that point, there will be a 60-day period for anyone to file interventions on the project. ere are two types of interventions, one is to become a party to the proceedings. This means anytine anyone sends any correspondence to the FERC, they have to send it to the intervenor also. If the intervenor sends any correspondence, they have to copy all the other parties. It also” provides an opportunity for opposing licensing of the project. This has some ramifications later on down the line for the FERC. It is termed a Commission action, where the project is voted on by the five commissioners. Final terms and conditions, which hopefully will be very similar to the preliminary terms and conditions, will be issued. A 60-day comment period will follow. The FERC will take all of the comments and make the EA their own document. The FERC will make any changes to the terms and conditions and issue a FERC draft EA. A public comment period will follow and after that the Final EA will be issued. Lastly, the FERC will issue its licensing decision. The time from when FERC receives the application to issuing a license could be about 1 year, unless major modifications to the EA are needed. Vince Yearick asked if there were any questions. He clarified that the environmental review was happening in the pre-filing stage. There were no questions. . 7 Rich Trimble asked Teresa Trulock of the USFS if this was the same as what the USFS does for a timber sale EA/EIS. Teresa said that it was a little different because it involves FERC. Rich Trimble asked if FERC was the lead agency the way the USFS is lead agency for a timber sale EIS. Teresa Trulock said yes, except FERC is requiring an EA or EIS whichever it ends up to be. Vince Yearick said that by doing a cooperative NEPA document, efforts are reduced because it avoids the USFS doing a separate EA from the one FERC does. It’s another way of consolidating the process by the applicant preparing the EA and involving the two federal agencies. Rich Trimble asked when the permits would be issued. Vince Yearick said that the application needs to be filed by June 1996 and a decision would take about a year minimum, so that would be June 1997. Mike Stimac said that the application would be filed by January 1996. Vince Yearick said that is probably ambitious and would be January 1997 given all the comment periods. He said it could be possibly be a shorter time period. Mark Dalton asked Teresa Trulock about the USFS action on the Special Use Permit, if that is the only action they take, if there is a FONSI or record of decision that the USFS will issue. 4 Teresa Trulock said that it would be FERC that makes the decision as lead agency. Vince Yearick said it was the Special Use Permit that triggers NEPA. Teresa Trulock said that since FERC is lead agency, FERC will be signing the document but USFS will review and approve it. Hank Newhouse said that for an example on the Black Bear Lake Hydroelectric Project, there was a NEPA document developed that was strictly for the Special Use Permit. Vince Yearick said that for the Black Bear Lake Project, FERC did do an EA on it. Jack Snyder reiterated that FERC did an EA but that Hank Newhouse was talking about the USFS. Hank Newhouse said the USFS portion of that did issue a decision notice as a result of categorical exclusion ... Teresa Trulock finished that it was a categorical exclusion beyond what FERC required. Jack Snyder stated that there was a lot more USFS land involved on that project. Hank Newhouse said there was a Special Use Permit for the cabin and trail. Teresa Trulock said the Black Bear Lake Project was a little bit more involved. Jack Snyder agreed. Jack Snyder described the proposed project. He described the project design and its location between Upper and Lower Mahoney Lakes. He explained that the natural topography of the area. He presented a topographic map of the area and pointed out the project features. He showed where the existing logging road is and how it will be extended south around the lower lake. The transmission line will be buried from the powerhouse to the existing logging road and then continue as an overhead line to the Swan Lake Intertie. avy ‘ SS Jack Snyder summarized how the proposed project would operate and how it would be constructed. Jack explained that most of the project would be underground. An upper tunnel would be located about 80 ft. below the lake surface (lake tap) of Upper Mahoney Lake and would convey water 1,400 ft. to a vertical shaft. The water would drop 1,200 ft. and continue to a lower tunnel which would run to the powerhouse. The powerhouse location was chosen because of the impassable barrier to upstream migration of fish. Jack explained the normal operation of the impulse turbines. Jack showed the powerhouse layout including where the staging area is planned. A videotape of aerial footage for the project area was shown to illustrate the existing site conditions, which Jack narrated. Vince Yearick asked what above-ground structures there would be at the project. Jack Snyder explained a small valvehouse will be situated at the top of the vertical shaft. He explained how a dam was considered for the upper lake but the avalanche danger would be too great to construct, operate and maintain a dam. He described the type of the rock found in the area and that it is metamorphic which is good for tunneling. He asked if there were any questions, there were none. Mark Dalton described the resource issues that have been raised to date. Initial consultation meetings were held about a year ago with ongoing agency consultation of the study plans. Land disturbance issues - an Erosion and Sediment Control Plan is being prepared as well as a NPDES stormwater pollution prevention plan. Botanical issues - sensitive, threatened and endangered species that could be impacted. To date, no threatened or endangered species have been identified. However, in consultation with USFS, a few sensitive plant species as designated by the USFS do occur within the project area. In response, a survey was conducted last September of the project area starting with the access road at the terminus of the existing logging road, coming around to the powerhouse site and some work around the upper lake to try and characterize the plants that do occur in the area. That survey was conducted by HDR’staff and the Alaska Natural Heritage Program. A copy of that report has been provided to the USFS (Mary Stensvold). Terrestrial issues - Concern for a population of mountain goats that were relocated by Fish & Game in 1991 to the area of the upper lake and to make sure the timing of project construction will not cause adverse impacts. Other concerns are loss of habitat (wetlands) due to construction of the project. Identification of where wetlands are and to relocate project features around wetlands where practical, primarily the access road. The overhead transmission line will be raptor-proof designed to protect raptors and other birds from electrocution. A field assessment of wetlands occurred in June 1994, along with a ground survey to locate raptor nest sites along the project access road, tailrace & powerhouse site. In addition, a bald eagle nest survey of the project area was conducted in cooperation with the U.S. Fish & Wildlife Service (USFWS). The survey also included areas up to the White River and across George Inlet. A wetlands functional assessment will be prepared and a limited discussion of the functions and values of wetlands that do occur in the area and a biological evaluation (BE) of wildlife species will be prepared in consultation with the USFS. A Plant BE will also be prepared with the USFS. Both of these reports will be contained as a technical appendix to the EA. Aesthetic resources - main concern is what will be the impact of construction and operation of the project on the visual quality of the area. The EA will characterize the existing visual quality and estimate what the potential changes might be from construction. Recreation issues - what impact the project will have on current recreation opportunities. Socioeconomic issues - the impact of project construction and operation on the local economy. Historical/Archaeological issues - concern about how project construction and operation will affect historical or archaeological resources in the area. Consultations are being held with State Historic Preservation Office. Aquatic issues - Impacts to fish in Mahoney Lake system, and Lower Mahoney Creek, spawning of sockeye salmon, temperature in gravels. Upper Mahoney Lake temperature profile continuously monitoring at depths of 20 ft. increments from the surface to 100 ft. to model water column temperatures. Stream flow,.water quality, and temperature data are being collected at the tailrace. The collection of raw data will continue through May 1995. Data collection began in June 1994 and some challenges have been incurred. The temperature device at Upper Mahoney Lake has not been located for the past few months because there is too much snow. Two temperature probes were placed in Lower Mahoney Lake. An animal chewed on one of the cables, so some data were lost, but redundant recorders made sure we have sufficient data. John Morsell described the three field trips that occurred in 1994. The first visit was in mid-June and the intent was to get an idea of the resident fish living in Lower Mahoney Lake/Lower Mahoney Creek and the portion of Upper Mahoney Creek from the falls down to the lake. A variety of sampling and observational techniques were used to get the information needed. Another field visit was made in late August, which was timed to coincide with the maximum number of salmon in Lower Mahoney Creek to get some idea of how many of those salmon were making into the lake and to possibly do some mapping of spawning areas in the lake. At that time, most of the sockeye salmon were still in the creek so a third field visit was made in the third week of September. At that time, flows were substantially higher due to heavy rains: and most of the sockeyes that were in the lower creek had made it into the lake. John was successfully able to map the spawning areas in the lake. The field studies are essentially completed. The data analysis is mostly complete. The fish information will be integrated with the temperature information during preparation of the EA to try and make some predictions on incubating salmon. Jack Snyder lead the discussion of agency/public comments on the project. Some people had identified themselves on the sign-in sheet as wanting to make public testimony. Don Ranne asked how the project fits in with the Swan Lake-Lake Tyee Intertie Project and the potential Lake Grace project. Will this project be able to replace any of those others? Jack Snyder responded that there are a variety of ways that those projects could interact with each other. Jack stated that average loads in the Ketchikan area exceed the capacity of the Ketchikan Public Utility (KPU) system, therefore, they have been running diesel generators from December to April. As the demand grows, the problem will worsen. There is demand that projects could be brought on-line. Mahoney Lake is one project, the intertie project is another and Grace Lake are additional new resources that could help meet this demand. Whether Mahoney Lake could replace any of these? According to the current projections of load growth, the Mahoney Lake Project could handle all of the additional growth in demand for the next 10 years. At that point, you begin to get into the need for diesel or another resource. How the intertie would meet those needs and how Grace Lake would meet those needs, Jack stated he was not qualified to respond to that. He stated he understood that Grace Lake is about the same size of Mahoney Lake and may have a little bit more storage, but it has other issues with it, such as located in Misty Fjords Park and would need a long transmission line. The intertie project could meet the needs of Ketchikan if there was power available at the right price. Rich Trimble asked if it would be economically feasible to put both the Mahoney Lake Project and the Swan Lake-Lake Tyee Intertie Project on-line at the same time. Jack Snyder said that according to his information from the economic analysis that was completed for the Mahoney Lake Project, it showed the intertie project is not economic. He was unable to tell if the intertie and Mahoney Lake at the same time would be economic because he doesn’t know what basis the intertie power would be. Jack said the analysis that was completed looked at different scenarios, depending on how the project was financed, where the money comes from, what the demand is, and how it grows over time. A few people on the sign-in sheet indicated that they would like to comment on the project. Request for comments or testimony was made at this time. ie Hank Newhouse asked if the Cape Fox Corporation was putting up funding for the project. Jack Snyder said that the City of Saxman is the project sponsor. The preliminary permit is in their name. The intent is that when construction financing begins, the City of Saxman will sell bonds to finance construction. The Capé Fox Corporation has an agreement to act as their development agent at this point in the project. Funding is coming from a variety of sources for these studies. One of the main sources is a Department of Energy grant that will give the project some federal monies. Hank Newhouse also added that some changes were needed to the distribution list, such as adding the Ketchikan Indian Corporation (Gerald Hope is President), Organized Village of Saxman (which is different than the City of Saxman-Joe Williams, President), and the Tongass Tribe’s new president is Bea Watson. Rich Trimble stated that as a utility to which the City of Saxman intends to sell the Mahoney Lake power, KPU has a very keen interest on how you go about the project and at what cost the power is sold. KPU is an intervenor in the project. This means that KPU’s interest is so deep that they made it formal. The City of Ketchikan has formally requested the City of Saxman to defer development of the project. It is true, Ketchikan is running out of power. Under those conditions, one would think that KPU would have an interest in any project that came along. Why would KPU voice concern about the Mahoney Lake Project and the reason is because it provides power but not when KPU needs it and at a cost that KPU should be expected to pay. KPU is responsible to find an alternative that will provide a long-term or even intermediate term solution to their shortage and anticipate at what cost they should be expected to pay for this. This is all in a letter that KPU will provide to HDR. KPU believes that scoping is premature because terms for power purchase by KPU have not been negotiated. There was a meeting where it was suggested that KPU purchase Mahoney Lake power in a preferential manner. KPU has their own economic and contractual constraints. KPU cannot simply purchase all the power in that kind of manner. There seems to be a conflict. On one hand, the City of Saxman needs to sell the power to make the project economically feasible. KPU has other power that they will use first and have to use first, specifically, KPU own hydroelectric projects at a very low cost to pay them off (Beaver Falls, Silvis, and Ketchikan Lakes). There is an existing contract where KPU has to purchase Swan Lake power after they use their own resources. It will not allow KPU to develop another project or purchase third party power under the same preferential treatment. They must purchase Swan Lake power until the lake level gets low. Only at that point can they consider running diesel generators or purchasing third party power. The economic analysis assumed that the City of Saxman could sell that power. KPU takes issue with that.,KPU must negotiate with the three other utilities in the four- dam pool to purchase power other. than Swan Lake. They would have to agree to that. That would decrease their revenues if KPU purchased Mahoney Lake power over Swan Lake power. They would not be able to purchase enough kilowatt-hours (kWh) of electricity over the intertie now and the short term to be able to market bonds for that project. You have indicated the Mahoney Lake Project could replace any of those other projects for the next 10 years. But the operating scenario you have shown indicates there is not enough demand in the year 2000. KPU will be running their diesels. I understand that Jack may not agree with everything I am saying, I am simply pointing out this is an issue. An If KPU is connected with Mahoney, there are some things they would like to see. First, they would like to have a dam built for extra storage capacity and to alleviate concerns of needing power. KPU would prefer to have the transmission lines go to the Beaver Falls Project 00 the south versus to the north to the Swan e tran sions. 1 Swan Lake dap one Y=) Mahoney Lake would drop off-line. If brought around to Beaver Falls and Swan Lake drops off- ; line, the downtown area of Ketchikan could remain with power, where it is unable to do now because there is too much load on that substation. Not only would it enhance KPU system teliability, it would enhance the revenue potential to keep it on-line. Another issue is the potential to wheel power to another market - Metlakatla. The EA should address potential markets. The: Mountain Point substation was built with capacity for interconnection to Metlakatla anticipating that an intertie would be established some day. The City of Metlakatla has identified they have a shortage of power. Hank Newhouse stated that he liked the Mahoney Lake Project because it has very low environmental impacts. Another reason is that it is being developed by the native community of Saxman. Unfortunately, KPU has not always been a good citizen in working with the native community. Also, with the current congressional climate, dollars are scarce - subsidized power for communities like Kake and other native villages is going to disappear. That will drive up their costs tremendously. Already they are paying approx. $0.25 kWh. If KPU takes the Swan Lake-Lake Tyee intertie project, that will leave communities like Kake out of the line and Kake would very much like to tie into the intertie. If Ketchikan pulls the power this way, it does not leave the option open for small communities like Kake. Kake has done much to diversify their economy. Their timber is gone, but they have their hatchery and fish processing plant. Options are cut off for other communities in southeast Alaska. I think the Mahoney Lake project is real good for the community of Ketchikan because it allows other communities to come on-line. Black Bear Lake Hydro will be coming on-line soon. I was talking to another party of the four- dam pool and the intent of the intertie project was not to come to Revilla Island but it would stay on the north side of Ernest Sound and go across to Thorne Bay on Prince of Wales Island, tie into the Black Bear Lake Hydro Project and go around and get Metlakatla to tie the grid that way. To tie into Beaver Falls does make sense. Eventually, tieing the grid together in the longer term makes more sense. In the short-term in a real tough dollar environment for the community of Ketchikan, the Mahoney Lake Project makes more economic sense. These other items can be negotiated and worked out and can be done with a lot less environmental impact to Revilla Island. The Swan Lake-Lake Tyee Intertie project will have a lot more environmental impact. Jack Snyder reminded the participants that comments are needed by May 15, 1995 and will be addressed in SD2. The meeting ended at 8:45 pm. r ALASKA INDUSTRIAL DEVELOPMENT AND EXPORT AUTHORITY / => ALASKA @@E™ =ENERGY AUTHORITY 480 WEST TUDOR ANCHORAGE, ALASKA 99503 907 / 269-3000 FAX 907 / 269-3044 September 23, 1996 Ms. Lois D. Cashell Secretary Federal Energy Regulatory Commission 888 First Street N. E. Washington, D. C. 20426 Subject: Upper Mahoney Lake Hydroelectric Project, FERC Number 11393-001 Dear Ms. Cashell: By means of this letter the Alaska Energy Authority (AEA) provides the following comments to the Commission concerning the subject project’s license application and applicant prepared Environmental Assessment (EA). Project Transmission Line Interconnection As indicated in our letter of June 1, 1995 to Mr. Michael Stimac of HDR Engineering Inc., the AEA had serious reservations concerning the use of the Swan Lake Transmission line to interconnect the proposed Mahoney Lake Project to the City of Ketchikan. We are pleased to see that the license documents now indicate that the preferred alternative is to interconnect the Mahoney Lake Project to Ketchikan via the Beaver Falls Project, rather than through the Swan Lake line. We agree that this is the best alternative as it will avoid conflicts between operation of the Swan Lake and Mahoney Lake transmission facilities and will provide increased reliability to the area’s power system. AEA strongly recommends that the Beaver Falls connection alternative, as presented in the Applicant’s license application and EA, be incorporated into the final project license. Resource Utilization As detailed in a letter from Ketchikan Public Utilities (KPU) to Mr. Stimac, dated April 12, 1996, KPU is contractually obligated by the Four Dam Pool Long Term Power Sales Agreement to purchase power from the Swan Lake Project second to use of their own hydroelectric resources. Although the applicant has recognized this fact in paragraph three on page B - 6 of Exhibit B, it is not clear to us how this assumption has been incorporated into the Exhibit B analyses. Ms. Lois D. Cashell September 23, 1996 Page 2 Paragraph three on page B - 6 of Exhibit B states, in part, that: ae by the year 1998, the year substantial completion of the project is anticipated to begin, KPU loads would exceed, by about 25,000,000 kWh, the average energy generation capability of all hydroelectric resources in its system. Because all of KPU’s hydroelectric resources will be fully utilized under these scenarios, KPU will have some flexibility to adjust operations of their various _ hydroelectric resources in order to maximize the benefits of the Mahoney Lake Project to the community.” The fact that KPU’s load would exceed its hydroelectric generation capability does not automatically translate into an ability to operate the system so as to “maximize the benefits of” the proposed Mahoney Lake Project. The KPU hydroelectric system, including Swan Lake, lacks substantial storage capacity and thus its operation is periodically constrained by lack of precipitation. Furthermore, because all of the existing projects are geographically proximate to one another, opportunities allowing KPU to operate one project at a higher capacity than the others, to offset lack of water in the other projects, rarely occur. Rather, lack of water commonly occurs in all projects at the same time, as all are located in the same general area and thus are subjected to very similar patterns of precipitation. The Mahoney Lake Project, also located in the same geographic area, will be similarly constrained in storage capacity, and thus may not necessarily be expected to provide KPU with a noticeable increase in flexibility of operation. The applicant should clarify how the Mahoney Lake Project could be operated to maximize its benefits to the community, given the limited storage capacity of the entire hydroelectric system combined with the contractual constraints placed on KPU for preferential utilization of Swan Lake power. Further to this issue, part of the analysis presented in Exhibit B appears to be based on basic assumptions that are not consistent. These inconsistencies may be significant, given the above mentioned constraints on storage in the KPU hydroelectric system. Specifically, tables B -2, B - 3, and B - 4 of Exhibit B provide an assessment of the amount of KPU’s un-met demand that could be met by the Mahoney Lake Project, under average, low and high water years. As would be expected, the total generation assumed to be available from the Mahoney Lake Project varies under these three conditions, ranging from 46,066 MWhrs for an average year and 29,640 MWhrs for a low water year to 52,414 MWhrs for a high water year. However, the values used for KPU’s existing hydro capability, and thus to compute KPU’s unmet demand for these different water years, does not vary, but rather is assumed to be constant at 147,650 MWhrs, regardless of the assumed hydrological conditions. Again, given the geographic proximity of all the existing hydro projects to the proposed Mahoney Lake site, it is highly probable that KPU’s hydro capability would be much higher than shown in a high water year and lower in a low water year. This, in turn, should result in significant changes in the Summary of Generation figures presented at the bottoms of tables B - 3 and B - 4. In a low water year, all Ms. Lois D. Cashell September 23, 1996 Page 3 hydro projects in the system would be constrained by lack of water and both KPU’s un-met demand and the percent of diesel generation required to operate the system would likely be significantly greater than the 67,350 MWhrs and 56% given in Table B- 3. Mahoney Lake generation would be as given, at 29,640 MWhrs, but the percent un-met demand this generation would represent would likely be less than the 44% given. Conversely, under a high water year conditions, it is likely that KPU’s un-met demand would be substantially less than shown, as all system hydro projects would have more water available. Thus, both the percent demand met by Mahoney Lake and the percent of diesel generation required would be lower than the 77.8% and 22.2% figures reported in Table B - 4. Additional Information For your information, in a review of the project drawings, trash racks were not evident. Trash removal with installed trash racks has been a significant operation and maintenance item at Swan Lake. The designers may wish to analyze the trash removal or clearing aspects of the design. Conclusion The applicant should revise tables B -2, B - 3, and B - 4 of Exhibit B to more accurately reflect the fact that all of KPU’s hydro projects are likely to be affected in the same way by yearly variations in precipitation and runoff. Further, the projections should show that Swan Lake must be fully utilized prior to purchase of power from Mahoney Lake. Contractual obligations to the Alaska Energy Authority and the four other purchasing utilities in the Four Dam Pool may inhibit or limit KPU’s use of Mahoney Lake. These considerations should be addressed in Exhibit B. Sincerely, LG Stan Sieczk 1 Manager, Maintenance and Operations SS/JHT/cjp Copy: William R. Snell, AEA Dennis V. McCrohan, AEA John Magyar, KPU James H. Thrall, Locher Interests, Ltd. File ~ September 11, 1996 SEP I$ 1996 (See Distribution List) Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Additional Information Request Post-Project Cumulative Degree Days Revised Tables The response to Item 3 of the AIR for the above-referenced project was sent to you for review and comment via my letter dated August 29, 1996. It was recently discovered that Tables B and D of the response contained some incorrect data entries. The corrected tables are enclosed to assist you in completing your review. As in our original request, please provide your comments to me by September 30, 1996. I hope this has not caused you any inconvenience. If you have any questions or require additional information, please let me know. Sincerely, HDR ENGINEERING, INC. ide ae Michael V. Stimac, Manager Licensing & Environmental Services Enclosure CG: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 MAHONEY LAKE HYDROELECTRIC PROJECT U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Mr. Andrew Grossman Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg USS. Fish & Wildlife Service 3000 Vintage Blvd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 Mr. Jim DeHerrera District Ranger U.S. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Mahoney Lake Hydroelectric Project Distribution List FERC NO. 11393 Distribution List Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main Street, Suite 905 Portland, OR 97204 Mr. Michael Strzelecki OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-70 Washington, DC 20426 Mr. Vince Yearick OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-73 Washington, D.C. 20426 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office 3601 C Street, #1200 Anchorage, AK 99503-5925 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 September 11, 1996 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project Distribution List Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 September 11, 1996 Mr. Tom Fitzgerald City Administrator City of Saxman Route 2, Box 1 Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen USS. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 Mahoney Lake Hydroelectric Project Distribution List Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, OR 97209 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20420 Mr. Jim Thrall Locher Interests, Ltd. 406 West Fireweed Lane, Suite 101 Anchorage, AK 99503 September 11, 1996 Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE B - Summed Accumulation October 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown Within 20 Feet of Intake Post - Project Gravel Temperatures Natural Gravel Temperatures Date _| Unmixed Mixed | Maximum Mixed | Minimum Mixed Averag 235 Maximum Oct 124 141 159 126 B13 169 Nov 244 247 310 , 202 388 590 169 Dec 368 342 437 289 431 740 169 Jan 492 419 563 366 471 878 169 Feb 604 501 684 436 522 1033 169 Mar 113 585 786 517 548 1128 169 Apr 788 660 879 572 620 1264 169 May 896 762 1006 642 719 1510 246 June 1016 905 1180 769 946 1867 398 Revised September 11, 1996 Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE D - Summed Accumulation October 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown > 20 Feet From Intake Post - Project Gravel Temperatures | Natural Gravel Temperatures Unmixed | Mixed |Maximum Mixed Minimum Mixed | Average [Average Maximum Average Minimum Oct 124 141 159 126 235 313 169 Nov 244 247 310 202 388 590 169 Dec 368 342 437 289 431 740 169 Jan 492 419 563 366 471 878 169 Feb 604 501 684 436 522 1033 169 Mar 728 596 798 528 548 1128 169 Apr 848 705 923 616 620 1264 169 May 972 816 1060 696 719 1510 246 June 1092 960 1234 823 946 1867 398 Revised September 11, 1996 LOCHER INTERESTS LTD. 406 WEST FIREWEED LANE, SUITE 101 ANCHORAGE, ALASKA 99503-2649 TELEPHONE (907) 258-2200 FAX (907) 258-5842 MEMORANDUM 9425-0097 TO: Stan Sieczkowski, Dan Beardsley, AEA. FROM: Jim Thrall, Locher Interests 0 ph DATE: August 30, 1996 REF: Mahoney Lake License Application. In addition to filing a Motion to Intervene on the subject project (done on August 26, 1996) AEA may wish to comment on the License Application and/or Preliminary Draft Environmental Assessment for this project. In June of 1995, AEA sent a comment letter on the project expressing concern for the planned tie-in of the Mahoney Lake transmission line with the Swan Lake line and recommending that an alternative route, to tie into the Beaver Falls project be used (see attached copy). KPU sent more extensive comments on the project. They also indicated that the Beaver Falls connection was preferred. In addition, KPU pointed out that they were contractually bound to purchase Swan Lake power second to their own hydroelectric resources and questioned whether the economic feasibility of Mahoney Lake is premised on an incorrect assumption of preferential use of Mahoney Lake power over Swan Lake. The License Application now proposes a transmission line to tie into Beaver Falls and appears to recognize that KPU is obligated to preferentially purchase Swan Lake power before Mahoney Lake power (although it is not readily evident that this was used as a basic assumption in their Exhibit B analyses). A comment letter from AEA recognizing that the Mahoney Lake project has now accepted these two points would be appropriate. In addition, | note that in the Exhibit B discussion the applicant has presented an analysis of the Mahoney Lake energy generation for average, wet and dry years that seems to me to rest on a questionable set of assumptions. Briefly, the analysis as presented, compares Mahoney Lake energy under these three scenarios to KPU un-met demand and displays the percent of this un-met demand that could be supplied by Mahoney. Although the energy produced by Mahoney Lake for each of the three hydrologic conditions varies considerably, the un-met demand value used for the other KPU hydro facilities is a long term average of some kind and stays the same. Given the close proximity of all these sites, it is probable that in a wet year at Mahoney the other projects also would produce more energy than the average and in a dry year they would produce less. What, if anything this means to the feasibility of the project is not clear to me, but it seems possible that it could be significant. AEA should raise this issue in its comment letter, requesting that the effect of adjusting the “other hydro” energy to reflect the assumed hydrologic conditions be evaluated. Finally, Remy Williams should review the License Application to see if any other issues appear to require comment. | will provide Remy with the license documents, and following his review we will draft a comment letter for your review and approval. JHT:cjp copy: R. Williams, Consultant File : ALASKA INDUSTRIAL DEVELOPMENT AND EXPORT AUTHORITY / = ALASKA @@m™ ENERGY AUTHORITY 480 WEST TUDOR ANCHORAGE, ALASKA 99503 907 / 561-8050 FAX 907 /561-8998 June 1, 1995 Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. Suite 1200 500 108th Avenue N. E. Bellevue, Washington 98004-5538 Subject: Mahoney Lake Hydroelectric Project; Proposed Transmission Line Routing Dear Mr. Stimac: The Alaska Energy Authority (AEA) has reviewed your May 24, 1995 correspondence concerning an alternate transmission line route for the subject project, connecting with the Beaver Falls Project rather than with the Swan Lake Transmission Line, as originally proposed. AEA, as owner of the Swan Lake Project and Swan Lake Transmission line has reservations concerning the interconnection of the proposed Mahoney Lake Project with the Swan Lake line. Potential conflicts between operation of the Mahoney Lake Project and operation of the Swan Lake Project transmission line, including AEA’s planning and implementation of scheduled outages of and maintenance of the line, are of significant concern. Further, a separate connection of the Mahoney Lake Project to the city of Ketchikan via the Beaver Falls Project, as stated in your letter of May 24, 1995, would improve Ketchikan Public Utilities ability to provide reliable service to that area. Improved reliability and increased flexibility in operation of the area’s power system are important issues which require consideration in the planning of this project. Therefore, the AEA recommends adoption of the South Route, as proposed in your letter, as the preferred alternative for this project. Sincerely, Stan Sieczkowski Manager, Maintenance and Operations SS/JHT/cjp Copy: D. Beardsley, AEA V. Yearick, FERC T. Waggoner, KPU J. Thrall, LIL * File August 29, 1996 ECE IVE D hy SEP - 3 199 F ‘Alaska Industrial Development (See Distribution List) and Export Authority Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Additional Information Request Post-Project Cumulative Degree Days In a letter dated July 22, 1996, the Federal Energy Regulatory Commission (FERC) issued an Additional Information Request (AIR) for the above-referenced project. A copy of the FERC letter and AIR (Schedule A) were forwarded to you via our letter dated July 26, 1996. In accordance with item 3 of the AIR, enclosed for your review is a copy of our response to items 3(A) through 3(C). Please provide any comments you may have to me by September 30, 1996. If we do not hear from you by this date, we will assume that you have no comments on the response. If you have any questions or require additional information, please call me at (206) 453-1523. Sincerely, HDR ENGINEERING, INC. FOU. Moree Michael V. Stimac, Manager Licensing & Environmental Services Enclosure cc: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 MAHONEY LAKE HYDROELECTRIC PROJECT U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Mr. Andrew Grossman Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg US. Fish & Wildlife Service 3000 Vintage Blvd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 Mr. Jim DeHerrera District Ranger U.S. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Mahoney Lake Hydroelectric Project Distribution List FERC NO. 11393 Distribution List Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main Street, Suite 905 Portland, OR 97204 Mr. Michael Strzelecki OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-70 Washington, DC 20426 Mr. Vince Yearick OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-73 Washington, D.C. 20426 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office 3601 C Street, #1200 Anchorage, AK 99503-5925 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 August 29, 1996 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project Distribution List Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 August 29, 1996 Mr. Tom Fitzgerald City Administrator City of Saxman Route 2, Box 1 Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen USS. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 Mahoney Lake Hydroelectric Project Distribution List Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, OR 97209 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20420 Mr. Jim Thrall Locher Interests, Ltd. 406 West Fireweed Lane, Suite 101 Anchorage, AK 99503 August 29, 1996 MAHONEY LAKE HYDROELECTRIC PROJECT FERC PROJECT NO. 11393 RESPONSE TO JULY 22, 1996, REQUEST FOR ADDITIONAL INFORMATION ITEM 3: POST-PROJECT CUMULATIVE DEGREE DAYS FERC Request: Your estimated post-project cumulative degree days during the sockeye incubation period are derived from estimated post-project temperatures that included assumptions about the mixing of Upper Mahoney Creek flows and ground water at the spawning site and the depth of the drawdowns in Upper Mahoney Lake. There are some discrepancies, however, in your application: e The post-project cumulative degree days in Table 3 (page 31) of the preliminary draft Environmental Assessment (EA) are different than the post-project cumulative degree days in Table 3 (page 7) of Appendix C of the application; e Figures 11 and 12 in Appendix C, graphic presentations of the cumulative degree days, do not correspond to the days enumerated in Table 3 of Appendix C, but appear to correspond with Table 3 of the preliminary draft EA; and e Figure 7 in the preliminary draft EA, a graphic presentation of Table 3 of the preliminary draft EA, does not correspond to the cumulative degree days in Table 3 of the preliminary draft EA or Table 3 of Appendix C. e The “minimum post-project mixed” values are not represented in Figure 11 of Appendix C. To help us understand your analysis, please: (A) explain the above discrepancies in cumulative degree days between the preliminary draft EA and Appendix C of the application; Response to (A): The Water Quality and Temperature Monitoring Report, which was issued in February 1996, was included as Appendix C of the Application for License (Application) to document the methodology that has been used to assess water quality and temperature effects due to the operation of the project. As described in the body of the Application and the Preliminary Draft Environmental Assessment (PDEA), the operation of the project is a function of the electrical demand placed on Ketchikan Public Utilities’ (KPU) system, the sequencing of all of KPU’s resources, and the availability of water. Since completion of the Appendix C report, a slightly different regional demand loading forecast was developed which resulted in a slightly different operational scenario for the project. To prepare the PDEA filed on May 31, 1996, the analysis Mahoney Lake Hydroelectric Project Page 1 FERC Project No. 11393 Response to Request for Additional Information Item 3 - Cumulative Degree Days described in Appendix C of the Application was updated using the most current operational information available. The results are presented in the tables and figures of the PDEA. The difference in the results presented in Appendix C and the PDEA is due to a change in the input parameters to the model for turbine flow and not a change in the methodology used to calculate cumulative degree days. As such, the results presented in the PDEA supersede the results presented in Appendix C. The specific values shown in the tables and figures of the EA are not representations of the results presented in Appendix C. Graphical Representations - Specific Comments Figures 11 and 12 of Appendix C are illustrative of values of Table 3 of Appendix C. As can be seen by comparing Table 3 of Appendix C to Table 3 of the PDEA, the change in the results due to the change in input parameters is small. Because of the scale and clarity of Figures 11 and 12, the differences in the two sets of results may not be readily apparent. Enclosed are better copies of Figures 11 and 12. Because the enclosed copy of Figure 11 is of better quality, the data series “minimum post-project mixed” is clear. Figure 7 of the PDEA is a graphic presentation of the maximum drawdown (>60 ft) results as compared to the natural gravel temperatures for the period September 1 to June 30 as shown in Table 3 of PDEA. FERC Request: (B) provide your best estimate of cumulative degree days; (1) from September I through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (2) from October | through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (3) from September I through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, and (4) from October 1 through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water. Mahoney Lake Hydroelectric Project Page 2 FERC Project No. 11393 Response to Request for Additional Information Item 3 - Cumulative Degree Days Response to (B): The enclosed tables show the cumulative degree day calculations for (1) September 1 through June 30 for drawdowns within 20 feet of the intake (Table A) with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water; (2) October 1 through June 30 for drawdowns within 20 feet of the intake (Table B) with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water; (3) September 1 through June 30 for drawdowns that do not come within 20 feet of the intake (Table C) with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water; and (4) October 1 through June 30 for drawdowns that do not come within 20 feet of the intake (Table D) with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water. FERC Request: (C) _ explain how the cumulative degree days in B(1) through B(4) were calculated. (Note: The cumulative degree day calculations in Appendix C appear to support Table 3 of Appendix C. If these calculations were changed by another analysis, please explain the basis for the changes.) Response to (C): The data listed for B (1) through B (4) above were derived by multiplying the average monthly temperature (a degree day is degrees over 0° C per day, the ground water is always 0° C or over) of the ground water, for each condition, by the number of days in the month. Each month was then summed to estimate a rate of accumulation of degree days. Ground water temperatures were derived by using the Mahoney Lake temperature monitoring data and Ketchikan air temperature data to establish relationships between Ketchikan air temperatures and Mahoney Lake air and water temperatures. Historic Ketchikan temperatures were used to estimate the natural range of temperatures that would be expected in surface and ground water. Mixing was based on normal average and estimated post-project flow regimes. The cumulative degree days were calculated using the flow regime shown in Table 4 of the PDEA. Mahoney Lake Hydroelectric Project Page 3 FERC Project No. 11393 Preliminary Draft Environmental Assessment 7 shows degree day accumulation for the period September 1 through June 30. The data indicate that degree day accumulation through early June under the pre- and post-project flow regimes would likely be very similar. Under the maximum drawdown scenario, post-project conditions would be somewhat cooler than existing conditions, especially for early spawners. Regardless of the drawdown scenario, post-project incubation conditions would fall well within the estimated range of pre-project conditions. TABLE 3 ESTIMATED CUMULATIVE DEGREE DAYS DURING SALMON INCUBATION ve | om | po fm afl aes Hustrated sn 64,7 Water temperature impacts to incubating salmon eggs and alevins within the Mahoney Lake upwelling areas would be small. During unusually warm years, development could be delayed compared to what would occur naturally, possibly causing intermittent adverse impact as a result of late emergence. However, the more stable temperature regime during project operation would probably be beneficial to salmon production in Mahoney Lake in the long term, since adverse impacts from natural climatic extremes would be less likely to occur. The applicant proposes to continue monitoring the temperature of the water in the selected upwelling area of the Upper Mahoney Creek delta in Lower Mahoney Lake in conjunction with temperature and stream flow at the proposed tailrace site on Upper Mahoney Creek. Monitoring would continue during project construction and for at least three years after operation begins, resulting in at least five more years of continuous data. Mahoney Lake Hydroelectric Project FERC No. 11393 31 May 1996 Mahoney Lake Hydroelectric Project Preliminary Draft Environmental Assessment FIGURE 7 Pre-Project and Post-Project Degree Day Accumulation 2300 2200 2100 1900 1800 1700 1600 1500 1400 1300 1100 Cumulative Degree Days 0 Sep Oct Nov Dec Jan Feb Mar Apr May ‘June —— Unmixed Post-Project = =—-------- Post-Project Mixed were Maximum Post-Project Mixed -———- Minimum Post-Project Mixed Natural Average ——— Natural Average Maximum = =—~—— Natural Average Minimum Pre-project and post-project ranges of degree day accumulation, for the period Septmeber 1 to June 30 and considering Upper Mahoney Lake drawdown. Preliminary Draft Environmental Assessment 3) Upwelling Water Volume. The successful development of salmon eggs and alevins also depends on an adequate exchange of water through their gravel environment to supply oxygen and to remove metabolic waste products. Water exchange in Lower Mahoney Lake salmon spawning areas is provided by upwelling ground water. The quantity of this upwelling water is likely determined in large part by the flow in Upper Mahoney Creek. The data collected to date seem to indicate that upwelling is a continuous process. Even at low flows (3 to 5 cfs measured in Upper Mahoney Creek), it appears water is flowing hyporheically through coarse channel substrate, according to the temperature variation seen between spawning gravel substrate and the water column in Lower Mahoney Lake. It is not known how much of the upwelling water volume comes from flows from Upper Mahoney Creek and how much might be from other groundwater sources. After the project is in operation, the flow in Upper Mahoney Creek downstream from the powerhouse would be the sum of the powerhouse discharge plus the contribution from the bypassed reach of the creek between the powerhouse and Upper Mahoney Lake. The bypassed portion of the watershed contributes about 24 percent of the flow in Upper Mahoney Creek below the powerhouse. Pre- and post-project flows in Upper Mahoney Creek (Table 4) are generally similar; post-project flow would be somewhat higher in December through April and lower in May through August. Assuming continuous project operation, no adverse impact to incubating salmon eggs would occur. There are natural changes in flow volume in Upper Mahoney Creek and presumably in upwelling due to storms and melt runoff. The alteration in TABLE 4 PRE- AND POST-PROJECT FLOWS IN UPPER MAHONEY CREEK = Pre-Project « Average Upper « Post-Project | Mahoney Creek Post-Project Average Upper Mahoney Creek | Flows Downstream of Average Turbine Flows (cfs) November December January February | March | April May June July August September Mahoney Lake Hydroelectric Project May 1996 34 FERC No. 11393 Mahoney Lake Hydroelectric Project Appendix C - Water Quality and Temperature Monitoring Report the intake. In that case the tailrace water temperature would correspond more closely to natural temperature fluctuations seen in Upper Mahoney Creek and the salmon spawning gravels. Water temperature variations at all sampling locations are driven by changes in air temperature (e.g. r=0.95, p<0.001 - stream water T vs. air T at the tailrace site) (Figure 7). Because water temperatures, both surface and groundwater, are strongly correlated to air temperatures, estimates of normal monthly average, average maximum, and average minimum temperatures were made based on Ketchikan air temperature data. Figure 8 illustrates the range of expected natural spawning gravel temperatures. To predict the range of possible temperatures in the spawning gravels after the project is in place, we assumed the actual groundwater temperature would fall between two conditions. In one scenario the project would overwhelm natural conditions and the ground water would be the same temperature as water at the intake in Upper Mahoney Lake. In the second scenario there would be mixing in the aquifer of post-project flows with runoff from the lower drainage basin in proportion to their volume. Figures 9 and 10 illustrate the range of temperatures expected in the spawning gravels after the project is operating based on these two conditions and the amount of drawdown in Upper Mahoney Lake. Critical to salmon egg development is the amount of heat to which they are exposed. This is calculated as cumulative degree days (CDD) or the number of degrees above 0°C per day per a designated time period. Estimates were made based on an average water temperature at the intake of 4°C and of 2° - 3°C during March and April in the case of drawdown in excess of 60 feet. Figures 11 and 12 illustrate these results. Table 3 lists estimates of natural, unmixed post- project and mixed post-project degree day accumulations TABLE 3 Estimated CDD in the Lower Mahoney Lake Spawning Gravels for the Incubation Period, September 1 - June 30 Estimated Natural Estimated Unmixed Estimated Mixed cDD cDD CDD Spring Drawdown 1266 (2260-637) © 1212 1172 css-1004 § Fugare \\ < 60 ft. Spring Drawdown 1266 (2260-637) 1112 983 sos. § Fi qn \X > 60 fi. ~@) Range Mahoney Lake Hydroelectric Project Appendix C - Water Quality and Temperature Monitoring Report Degree Day Accumulation During Salmon Incubation (Sept. 1 - June 30): Less than 60 Feet of Drawdown An WEY 12k 0 Sep Oct Nov Dec Jan Feb Mar Apr May June Month ——— Unmixed Post-Project sistaee: Post-Project Mixed “vores Maximum Post-Project Mixed nececeee Minimum Post-Project Mixed Natural Average Figure 11. Cumulative degree days in the spawning garvels for the period of salmon incubation, showing average natural conditions and post project conditions. Mahoney Lake Hydroelectric Project Appendix C - Water Quality and Temperature Monitoring Report Degree Day Accumulation During Salmon Incubation (Sept. 1 - June 30): More than 60 Feet of Drawdown 1400 FOS” JZGL 1200 we 1/42 - LT 1070 1000 = as = Pe a a a Eee ee a Fr # _ io = ee Seem - 200 0 0 Sep Oct Nov Dec Jan Feb Mar Apr May June Month = Unmixed Post-Project —— Post-Project Mixed ssw Maximum Post-Project Mixed we ceneee Minimum Post-Project Mixed Natural Avetage Figure 12. Cumulative degree days in the spawning gravels for the period of salmon incubation showing average natural conditions and post-project conditions. Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE A - Summed Accumulation September 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown Within 20 Feet of Intake Post - Project one Temperatu Natural Gravel a mperatures [Waaied [Mixed [ Mimo Med | Minimum Mined avenge Averge Maxim - 239 Sep Oct re rs 408 Nov 708 984 408 Dec 751 1133 408 Jan 791 1272 408 Feb 842 1427 408 Mar 868 1522 408 Apr 940 1657 408 May 1039 1903 484 June 1266 2260 637 Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE B - Summed Accumulation October 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown Within 20 Feet of Intake Post - Project Gravel Temperatures Natural Gravel Temperatures [Unmixed | Mixed | Maximum Mixed | Minimum Mixed | Average | Average Maximum | erage Average Minimum Oct 124 141 159 126 235 313 169 Nov 124 141 159 126 235 313 169 Dec 124 141 159 126 235 313 169 Jan 124 141 159 126 235 313 169 Feb 124 141 159 126 235 313 169 Mar 124 141 159 126 235 313 169 Apr 124 141 159 126 235 313 169 May 124 141 159 126 235 313 169 June 124 141 159 126 235 313 169 Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE C - Summed Accumulation September 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown > 20 Feet from Intake Post - Project Gravel Temperatures [Unmixed [Mixed [Maximum Mixed | Minimum Mixed | 120 182 208 154 - 239 244 323 367 280 408 Nov 364 429 518 356 708 984 408 Dec 488 524 645 443 751 1133 408 Jan 612 601 771 520 791 1272 408 Feb 724 683 892 590 842 1427 408 Mar 848 778 1006 682 868 1522 408 Apr 968 887 1131 770 940 1657 408 May 1092 998 1268 850 1039 1903 484 June 1212 1142 1442 9717 1266 2260 637 Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE D - Summed Accumulation October 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown > 20 Feet From Intake Post - Project Gravel Temperatures Natural Gravel Temperatures [Unmixed [Mixed [Maximum Mixed | Minimum Mixed | Average [Average Maximum _| Oct 124 141 159 126 235 313 Nov 124 141 159 126 235 313 169 Dec 124 141 159 126 235 313 169 Jan 124 141 159 126 235 313 169 Feb 124 141 159 126 235 313 169 Mar 124 141 159 126 235 313 169 Apr 124 141 159 126 235 313 169 May 124 141 159 126 235 313 169 June 124 141 159 126 235 313 169 : ALASKA INDUSTRIAL DEVELOPMENT AND EXPORT AUTHORITY /= ALASKA @E™ ENERGY AUTHORITY 480 WEST TUDOR ANCHORAGE, ALASKA 99503 907 / 269-3000 FAX 907 / 269-3044 August 26, 1996 Ms. Lois D. Cashell, Secretary Federal Energy Regulatory Commission 888 First Street, N. E. Washington, D.C. 20426 Subject: MOTION TO INTERVENE Project No. 11393-001, AK Mahoney Lake Hydroelectric Project Dear Ms. Cashell: Enclosed is our MOTION TO INTERVENE in the subject proceedings. The Alaska Energy Authority has interests not represented by other parties involved in these proceedings. William R. Sn Executive Director WRS:JHT:cjp Enclosure: As stated cc: Mr. Keith A Laufer, Assistant Attorney General, Dept. of Law, Anchorage (w/enclosure) Mr. J. Magyar, KPU (w/enclosure) Mr. S. Sieczkowski, AEA (w/o enclosure) Mr. D. Beardsley, AEA (w/o enclosure) Mr. J. Thrall, LIL (w/enclosure) Mr. Tom Fitzgerald (w/enclosure) Mr. Doug Campbell (w/enclosure) Mr. Michael V. Stimac (w/enclosure) Mr. John Braislin (w/enclosure) Mr. Donald H. Clarke (w/enclosure) File | UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION CITY OF SAXMAN, ALASKA PROJECT NO. 11393-001, AK Motion to Intervene of Alaska Energy Authority Pursuant to the Federal Energy Regulatory Commission's ("Commission") NOTICE OF APPLICATION AND APPLICANT PREPARED EA ACCEPTED FOR FILING; NOTICE REQUESTING INTERVENTIONS AND PROTESTS; AND NOTICE REQUESTING COMMENTS, FINAL TERMS AND CONDITIONS, RECOMMENDATIONS AND PRESCRIPTIONS, dated August 14, 1996, and the Commission's Rules of Practice and Procedure, the Alaska Energy Authority, ("Energy Authority") hereby moves to intervene in this proceeding. In support of its motion the Energy Authority states as follows: a The Alaska Energy Authority is a public corporation of the State of Alaska, having its principal office at 480 west Tudor Road, Anchorage, Alaska. Correspondence and communications with respect to this Motion should be addressed to: Mr. William R. Snell Executive Director Alaska Energy Authority Attention: Stanley E. Sieczkowski 480 West Tudor Road Anchorage, Alaska 99503 Mr. Keith A. Laufer Assistant Attorney General Department of Law General Civil Section 1031 West Fourth Avenue, Suite 200 Anchorage, Alaska 99501 The Energy Authority is a Public Corporation of the State of Alaska. The purpose of the Energy Authority is to promote, develop and advance the general prosperity and economic welfare of the people of the State by providing a means of financing and operating power projects and facilities that recover and use waste energy (§ Ch. 278 SLA 1976; am § 5 Ch 156 SLA 1978; am § 1 Ch 133 SLA 1982; am § 9 Ch 18 SLA 1993). The Energy Authority is supportive of projects resulting in sound energy development by entities other than itself and will make efforts to provide assistance as appropriate. Motion to Intervene, Alaska Energy Authority City of Saxman, Alaska Project No. 11393-001 Page 2 4. The Energy Authority is the Owner and FERC Licensee of the Swan Lake Hydroelectric Project, located near the subject project site. 5: The Swan Lake Project currently provides some of the power for the area to be served by the subject project. 6. Operation of the subject project may effect operation of the Swan Lake Hydroelectric Project. WHEREFORE, the Energy Authority moves that the Commission make and issue its Order permitting the Energy Authority to intervene in, and be made a party of, the above-entitled proceedings with a right to have notice of and appear at all hearings, to produce evidence and witnesses, to cross-examine witnesses, and be heard by counsel, and to submit briefs and participate in oral argument, if oral argument is granted. Dated this 2G day of August, 1996. Respectfully submitted, Magee Executive Director Alaska Energy Authority ALASKA INDUSTRIAL DEVELOPMENT AND EXPORT AUTHORITY /= = ALASKA @@™ =ENERGY AUTHORITY 480 WEST TUDOR ANCHORAGE, ALASKA 99503 907 / 269-3000 FAX 907 / 269-3044 August 26, 1996 Ms. Lois D. Cashell, Secretary Federal Energy Regulatory Commission 888 First Street, N. E. Washington, D.C. 20426 Subject: MOTION TO INTERVENE Project No. 11393-001, AK Mahoney Lake Hydroelectric Project Dear Ms. Cashell: Enclosed is our MOTION TO INTERVENE in the subject proceedings. The Alaska Energy Authority has interests not represented by other parties involved in these proceedings. Executive Director WRS:JHT:cjp Enclosure: As stated Cc: Mr. Keith A Laufer, Assistant Attorney General, Dept. of Law, Anchorage (w/enclosure) Mr. J. Magyar, KPU (w/enclosure) Mr. S. Sieczkowski, AEA (w/o enclosure) Mr. D. Beardsley, AEA (w/o enclosure) Mr. J. Thrall, LIL (w/enclosure) Mr. Tom Fitzgerald (w/enclosure) Mr. Doug Campbell (w/enclosure) Mr. Michael V. Stimac (w/enclosure) Mr. John Braislin (w/enclosure) Mr. Donald H. Clarke (w/enclosure) File UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION CITY OF SAXMAN, ALASKA PROJECT NO. 11393-001, AK Motion to Intervene of Alaska Energy Authority Pursuant to the Federal Energy Regulatory Commission's ("Commission") NOTICE OF APPLICATION AND APPLICANT PREPARED EA ACCEPTED FOR FILING; NOTICE REQUESTING INTERVENTIONS AND PROTESTS; AND NOTICE REQUESTING COMMENTS, FINAL TERMS AND CONDITIONS, RECOMMENDATIONS AND PRESCRIPTIONS, dated August 14, 1996, and the Commission's Rules of Practice and Procedure, the Alaska Energy Authority, ("Energy Authority") hereby moves to intervene in this proceeding. In support of its motion the Energy Authority states as follows: lp The Alaska Energy Authority is a public corporation of the State of Alaska, having its principal office at 480 west Tudor Road, Anchorage, Alaska. Correspondence and communications with respect to this Motion should be addressed to: Mr. William R. Snell Executive Director Alaska Energy Authority Attention: Stanley E. Sieczkowski 480 West Tudor Road Anchorage, Alaska 99503 Mr. Keith A. Laufer Assistant Attorney General Department of Law General Civil Section 1031 West Fourth Avenue, Suite 200 Anchorage, Alaska 99501 2: The Energy Authority is a Public Corporation of the State of Alaska. The purpose of the Energy Authority is to promote, develop and advance the general prosperity and economic welfare of the people of the State by providing a means of financing and operating power projects and facilities that recover and use waste energy (§ Ch. 278 SLA 1976; am § 5 Ch 156 SLA 1978; am § 1 Ch 133 SLA 1982; am § 9 Ch 18 SLA 1993). 3. The Energy Authority is supportive of projects resulting in sound energy development by entities other than itself and will make efforts to provide assistance as appropriate. Motion to Intervene, Alaska Energy Authority City of Saxman, Alaska Project No. 11393-001 Page 2 4. The Energy Authority is the Owner and FERC Licensee of the Swan Lake Hydroelectric Project, located near the subject project site. 5. The Swan Lake Project currently provides some of the power for the area to be served by the subject project. 6. Operation of the subject project may effect operation of the Swan Lake Hydroelectric Project. WHEREFORE, the Energy Authority moves that the Commission make and issue its Order permitting the Energy Authority to intervene in, and be made a party of, the above-entitled proceedings with a right to have notice of and appear at all hearings, to produce evidence and witnesses, to cross-examine witnesses, and be heard by counsel, and to submit briefs and participate in oral argument, if oral argument is granted. Dated this 2G day of August, 1996. Respectfully submitted, Executive Director Alaska Energy Authority August 2, 1996 rd, (See Distribution List) MIEN RE: Mahoney Lake Hydroelectric Project D FE (Ui E | VE I FERC Project No. 11393 \\ zi ub G5 G95 LL Alaska lcdusteial Additional Information Request Aquatic Resources Monitoring Plan Dave lonmant and Export Authority Ina letter dated July 22, 1996, the Federal Energy Regulatory Commission (FERC) issued an Additional Information Request (AIR) for the above-referenced project. A copy of the FERC letter and AIR (Schedule A) were forwarded to you via our letter dated July 26, 1996. In accordance with item 2 of the AIR, enclosed is a copy of the Aquatic Resources Monitoring Plan for your review. Please provide any comments you may have to me by September 3, 1996. If we do not hear from you by this date, we will assume that you have no comments on the plan. If you have any questions or require additional information, please call me at (206) 453-1523. Sincerely, HDR ENGINEERING, INC. A ea Michael V. Stimac, Manager Licensing & Environmental Services Enclosure Cc: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation h:\hyd\mahoney\app\air04.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 MAHONEY LAKE HYDROELECTRIC PROJECT U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Ms. Tamra Faris Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg US. Fish & Wildlife Service 3000 Vintage Blvd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 Mr. Jim DeHerrera District Ranger U.S. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project Distribution List FERC NO. 11393 Distribution List Mr. Steve Sams USS. Forest Service Federal Building Ketchikan, AK 99901 Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main St., Suite 905 Portland, OR 97204 Mr. Michael Strzelecki OHL/DPR Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 Mr. Vince Yearick OHL/DPR Federal Energy Regulatory Commission 810 First St. NE, Room 504 Washington, D.C. 20426 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 August 2, 1996 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office 3601 C St., #1200 Anchorage, AK 99503-5925 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mahoney Lake Hydroelectric Project Distribution List Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 August 2, 1996 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 Mr. Tom Fitzgerald City Administrator City of Saxman Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project Distribution List Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen US. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 August 2, 1996 Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, oR 97209 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20420 Mahoney Lake Hydroelectric Project Distribution List August 2, 1996 MAHONEY LAKE HYDROELECTRIC PROJECT AQUATIC RESOURCES MONITORING PLAN Introduction During the environmental review and licensing process for the proposed Mahoney Lake Hydroelectric Project various issues have been raised relative to protection of fish resources in the Mahoney Lake drainage. Studies and environmental monitoring programs conducted for the project Environmental Assessment have provided partial answers to these issues. However, study results and input from agencies during the licensing process have suggested that continuing study might be desirable in some areas, both during the remainder of the pre-construction period and for a time after construction of the project. The following plan suggests an approach to continued project monitoring to assure protection of fish resources with emphasis on anadromous species, especially sockeye salmon. Lower Mahoney Creek Fish Passage Studies conducted in 1994 and 1995 indicated that Lower Mahoney Creek contains cascades and falls that are natural barriers to fish movements. These barriers can only be passed by the strongest swimming fish species (adult sockeye and coho salmon) and only at intermediate flow levels. Prior observations have suggested a range of stream flows that will allow fish to pass but have not provided a good idea of threshold and optimal flow required by salmon to be able to pass the most formidable barrier and enter Lower Mahoney Lake. This information is considered desirable to determine whether the predicted post-project flow regime will affect fish passage and, if so, to determine appropriate possible mitigation measures. Lower Mahoney Creek Stream Gaging A continuously recording stream depth monitor (pressure transducer) was installed downstream from the most difficult fish barrier in July 1995 and _ hydrological measurements were conducted at the stream section to allow calculation of discharge. We propose that this gage continue to be maintained for the duration of the project, and that the hydrological model used to determine discharge be refined and updated as appropriate to assure accuracy. Monitoring of Fish Passage We propose that a study program similar to that which occurred in 1995 be implemented in 1996 and continued through the pre-construction period and for the first three years of Mahoney Lake Hydroelectric Project 1 Aquatic Resources Monitoring Plan project operation. This program would emphasize observation of the progress of salmon movement within Lower Mahoney Creek and the extent of use of Lower Mahoney Lake sockeye salmon spawning areas. The following methodology is suggested: beginning on August 1, a trained technician employed by the Cape Fox Corporation would observe Lower Mahoney Creek and Lower Mahoney Lake approximately every third day. The entire creek would be surveyed on foot and the lake spawning areas would be surveyed by boat. Observations would be documented and would include numbers of salmon of each species observed and the approximate location’ of fish in the stream or lake. When significant numbers of sockeye salmon are observed in upper portions of Lower Mahoney Creek, the technician would notify a biologist. The biologist would make a decision based on the fish observations, stream flow level, and weather information regarding whether to travel to the site and conduct more detailed observations regarding fish numbers, migratory behavior, success of passage, spawning condition, etc. The time spent on site would depend on the progress of fish movements. It might be desirable for the biologist to divide the field surveys into two time periods. It is expected that the biologist would spend up to 8 days on site. Routine observations by the technician would continue until the end of September. Salmon movement behavior and passage success would be compared with measured stream flows at the time of movement. Emphasis would be on determining threshold and optimum flow conditions for salmon passage in Lower Mahoney Creek. Spawning Area Incubation Conditions Another issue identified early in the planning process was the potential impact of altered Upper Mahoney Creek flow volume and water temperature on upwelling ground water within sockeye salmon spawning areas in Lower Mahoney Lake along the creek delta. Continuously recording water temperature monitoring stations were installed in 1994 within Upper Mahoney Creek near the proposed tailrace and at two locations in salmon spawning areas in Lower Mahoney Lake. The latter two stations included both intragravel water and above gravel water. This monitoring effort provided strong evidence that upwelling of stream water does in fact occur within areas chosen by salmon for spawning and that the temperature of upwelling water is correlated in part with the temperature of Upper Mahoney Creek water. The project environmental assessment concluded that, although pre-project and post-project temperature regimes may be somewhat different, the cumulative temperature units to which salmon eggs will be exposed will be similar and, thus, impact to incubating salmon eggs and fry will be minimal. Water Temperature Monitoring To confirm or reject the EA predictions it is recommended that the temperature monitoring program described above be continued during the pre-project period and for three years after the project is in operation. It is proposed that the Lower Mahoney Lake temperature monitoring stations be modified so that the two intragravel probes are both Mahoney Lake Hydroelectric Project 2 Aquatic Resources Monitoring Plan installed at the same location. This will provide redundancy in case one instrument fails and should increase the likelihood of a continuous record. Instrument temperature readings should be calibrated against an accurate hand thermometer at the time of installation. Water Quantity Monitoring There is no direct way to measure the quantity of upwelling water in the lake spawning areas. However, correlation of powerhouse release volume with intragravel water temperature on the Mahoney Creek delta may provide some insight into the relationship of flow release to upwelling water quantity. This possible relationship provides another reason for continued water temperature and flow monitoring at the proposed tailrace site on Upper Mahoney Creek and water temperature monitoring in Lower Mahoney Lake. Salmon Escapement Monitoring The most direct measure of project impact on fish resources is the actual health of the post-project fish populations. It is proposed that sockeye salmon be selected as a key indicator species and that the escapement of sockeye salmon be monitored with a minimal effort for at least 10 years after project operation. Since sockeye salmon spend 1-2 years in freshwater and 1-3 years in salt water, there is an average 3-4 year delay before the success of spawning in any given year can be determined through actual adult returns; consequently, any monitoring must continue for a substantial period of time in order to be meaningful. The monitoring program described above for Lower Mahoney Creek fish passage would provide sockeye salmon escapement information for the first three years of project operation. It is suggested that the information from these studies be used to develop a simplified index of salmon abundance that could be measured in subsequent years with minimal effort to acquire a long term record of sockeye salmon success in the Mahoney drainage. Such an index would involve a consistent combination of stream counts and lake spawning ground counts at selected optimal times. The observations could be obtained by a trained technician with minimal supervision by a fish biologist. Mahoney Lake Hydroelectric Project 3 Aquatic Resources Monitoring Plan CKe Malhrowey La Ke | MIM \ JUL 29 199 l 8 lus ! Deve ' lo, XPo Authority (See Attached Distribution List) Re: FERC Project No. 11393-000 FERC Acceptance of Application for License and Additional Information Request On behalf of the City of Saxman, Alaska, HDR Engineering, Inc. is providing a copy of the July 22, 1996, letter from the Federal Energy Regulatory Commission (FERC) accepting for filing the Application for License for the Mahoney Lake Hydroelectric Project and requesting additional information. Copies of this letter are being forwarded to only those agencies/entities receiving the Application for License that was filed with FERC on May 31, 1996. If you have any questions or require additional information, please let me know. Sincerely, HDR ENGINEERING, INC. PHM. hl Cran Michael V. Stimac, Manager Licensing and Environmental Services Enclosure cc: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation Don Clarke, Wilkinson, Barker, Knauer & Quinn h:\hyd\mahoney\app\air01.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 MAHONEY LAKE HYDROELECTRIC PROJECT U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Ms. Tamra Faris Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg USS. Fish & Wildlife Service 3000 Vintage Blvd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 Mr. Jim DeHerrera District Ranger U.S. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Steve Sams US. Forest Service Federal Building Ketchikan, AK 99901 FERC NO. 11393 Distribution List Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main St., Suite 905 Portland, OR 97204 Ms. Lois Cashell Federal Energy Regulatory Commission 888 First St. NE, Room A-1 Washington, DC 20426 Mr. Vince Yearick Federal Energy Regulatory Commission 810 First St. NE, Room 504 Washington, D.C. 20426 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office 3601 C St., #1200 Anchorage, AK 99503-5925 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 Mr. Tom Fitzgerald City Administrator City of Saxman Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen U.S. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, oR 97209 State Director Alaska State Office Bureau of Land Management Division fo Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20420 FEDERAL ENERGY REGULATORY COMMISSION v WASHINGTON, D. C. 20426 Pimeea || [asm 1996 Project No. 11393-001-AK IL 25 | Mahoney Lake Hydroelectric Project { City of Saxman, Alaska ‘HDR ENGINEERING, INC r Mr. Tom Fitzgerald City Administrator poe ead City of Saxman JR 22 1096 Route 2, Box 1 Ketchikan, Alaska 99901 Dear Mr. Fitzgerald: Your license application for the referenced project has been accepted by the Commission for filing as of May 31, 1996. A public notice for this project will be issued shortly indicating the above finding and soliciting interventions and protests on the application and your reply comments. The notice will also solicit final terms, conditions, and comments. Federal, state, and interstate resource agencies, and any Indian Tribe affected by this project, will be informed in the Commission’s public notice that a copy of the complete application may be obtained directly from you. Within 5 days after you receive this letter, if you haven’t already done so, send one copy of your license application to the following: the Commission’s Portland Regional Office; the Department of the Interior, Office of Environmental Affairs, the U.S. Army Corps of Engineers, North Pacific Office; and the Alaska State Director, Bureau of Land Management. A list of addresses is attached. Within 45 days from the date of this letter, you must file with the Commission’s Secretary an original and a duplicate set of aperture cards showing your exhibit drawings. Also, send a duplicate set of aperture cards to the Commission’s Portland Regional Office and the Alaska State Director, Bureau of Land Management. For the aperture cards showing your exhibit drawings: make an original and two Diazo-type duplicate sets of cards. To make the original set of cards, (1) take the exhibit sheets listed by FERC drawing numbers, (2) make microfilm copies of the sheets, and (3) mount them on type D aperture cards (3 1/4 by 7 3/8 inches). To make the duplicates, reproduce the original set on silver or gelatin 35-millimeter microfilm. For each microfilm drawing, show the FERC drawing number in the margin below the title block. On the top lines of the aperture cards, show (1) the appropriate FERC exhibit name, (2) the project number, (3) the drawing number, (4) the drawing title, and (5) the date of this letter. We also need additional information in order to complete our review and processing of your application. A listing of the information required is presented in the enclosed schedule A. Under section 4.32(g) of the Commission’s regulations, you have 90 days from the date of this letter to provide the additional information requested. If the requested information causes any other part of the application to be inaccurate, that part must also be revised and refiled by the due date. Within five days of receipt, provide a copy of this letter and the enclosed schedule to all entities that received a copy of your final application. Then, when you file the requested information with the Commission, you must also provide a complete copy of that information to each entity that received a copy of your final application. Documents to be filed with the Commission must be filed by providing an original and 8 copies as required by the Commission’s regulations to: Secretary, Federal Energy Regulatory Commission, 888 First Street, N.E., Washington, D.C. 20426. If you have any questions concerning this matter, please call Vince Yearick on (202) 219-3073. Sincerely, Sle CD TK John H. Clements Director, Division of Project Review Enclosures: List of Addresses FERC Drawing Numbers Schedule A ce; Mr. Doug Campbell Cape Fox Corporation 2851 S. Tongass P.O. Box 8558 Ketchikan, AK 99901 Mr. Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. 500-108th Avenue, NE Suite 1200 Bellevue, WA 98004 Mr. John Braislin Betts, Patterson, and Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Donald H. Clarke Wilkinson, Barker, Knauer, & Quinn 1735 New York Avenue, N.W. Washington, DC 20006 Addresses Federal Energy Regulatory Commission Portland Regional Office 101 S.W. Main Street, #905 Portland, OR 97204 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, DC 20240 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, OR 97209 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 FERC DRAWING NUMBERS Project No. 11393-001 Exhibit Drawing No. 11319- F F-0 through F-9 G G-1 through G-2 Project No. 11393 Schedule A ADDITIONAL INFORMATION 1. In your application your state that, by agreement between the Alaska Department of Environmental Conservation (ADEC) and the U.S. Army Corps of Engineers (COE), a dredge and fill application under Section 404 of the Clean Water Act may also serve as an application for a state water quality certification under Section 401 of the Clean Water Act. Your application includes a copy of a Section 404 application completed on May 20, 1996. However, there is no evidence that you sent the Section 404 application (or other request for water quality certification) to the ADEC, that the ADEC received the Section 404 application, or that the ADEC accepted the Section 404 application as a request for a Section 401 water quality certification. To establish that you have requested a Section 401 water quality certification please provide: (A) a copy of your certification request to the ADEC; and (B) proof that the ADEC received the request. Proof of receipt must be either: (1) a copy of a certified mail receipt showing the date the ADEC received the Section 401 request; or (2) a letter from the ADEC confirming the receipt date. If the ADEC has accepted the Section 404 application as a request for a Section 401 water quality certification, you must submit written confirmation of the acceptance from the ADEC, including confirmation of the date the ADEC received the Section 404 application. 2. According to Appendix K of your application, on May 9, 1996, you sent a proposed aquatic resources monitoring plan to the National Marine Fisheries Service (NMFS), the U.S. Fish and Wildlife Service (FWS), and the Alaska Department of Fish and Game (ADFG), and requested that the agencies send comments -.on the plan to you by May 17, 1996. You did not include a copy of your proposed aquatic resources monitoring plan, along with any agency comment letters, with your application. To help us evaluate your proposed monitoring of aquatic resources in the project area, please provide: (A) a copy of the proposed aquatic resources monitoring plan that you sent to the NMFS, the FWS, and the ADFG; and (B) copies of the comment letters, if any, that you received from the resource agencies. In addition, send a copy of the monitoring plan anda request for comments to each of the entities that received a copy of your final application, but have not received a copy of your monitoring plan, and allow them a minimum of 30 days to provide you with their comments. Include documentation of your request for comments and copies of the comments and recommendations, if any, in your response filed with the Commission. 3. Your estimated post-project cumulative degree days during the sockeye incubation period are derived from estimated post-project temperatures that included assumptions about the mixing of Upper Mahoney Creek flows and ground water at the spawning site and the depth of the drawdowns in Upper Mahoney Lake. There are some discrepancies, however, in your application: e The post-project cumulative degree days in Table 3 (page 31) of the preliminary draft Environmental Assessment (EA) are different than the post-project cumulative degree days in Table 3 (page 7) of Appendix C of the application; . e Figures 11 and 12 in Appendix C, graphic presentations of the cumulative degree days, do not correspond to the days enumerated in Table 3 of Appendix C, but appear to correspond with Table 3 of the preliminary draft EA; and e Figure 7 in the preliminary draft EA, a graphic presentation of Table 3 of the preliminary draft EA, does not correspond to the cumulative degree days in Table 3 of the preliminary draft EA or Table 3 of Appendix C. e The "minimum post-project mixed" values are not represented in Figure 11 of Appendix C. To help us understand your analysis, please: (A) explain the above discrepancies in cumulative degree days between the preliminary draft EA and Appendix C of the application; (B) provide your best estimate of cumulative degree days; (1) from September 1 through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (2) from October 1 through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming 7 the ground water and with proportionate mixing between the streamflow and the ground water, (3) from September 1 through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (4) from October 1 through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, and (C) explain how the cumulative degree days in B(1) through B(4) were calculated. (Note: The cumulative degree day calculations in Appendix C appear to support Table 3 of Appendix C. If these calculations were changed by another analysis, please explain the basis for the changes.) You must provide the NMFS, the FWS, the ADFG, and each of the other entities that received a copy of your final application with copies of items 3(A) through 3(C), and allow them a minimum of 30 days to provide you with their comments. Include documentation of your request for comments and copies of the comments and recommendations, if any, in your response filed with the Commission. 4. We cannot evaluate the effect of the project on cultural resources without reviewing the report on the cultural resources survey of the project, and the comments of the Alaska State Historic Preservation Officer (SHPO) and the Forest Service (FS) archeologist on the adequacy of the report. Therefore, file the following: (1) 3 copies of the report; and (2) letters from the SHPO and the FS archeologist on the report. If the SHPO or the FS archeologist recommends additional survey, file a schedule for conducting the survey and filing a report with the Commission, or provide an explanation why such work is not necessary. Work needs to be completed by this year’s field season. If your survey shows that archeological or historic sites or traditional cultural properties of Native American tribes eligible for the National Register of Historic Places would be affected by the project, do the following: (1) File a cultural resources management plan--which you would implement after licensing--for avoiding or mitigating the effects on the sites. 8 (2) Base your plan on the recommendations of the SHPO and the FS archeologist, and include their comments on the plan in your filing. (3) If the SHPO and the FS archeologist recommends that you implement your plan through a memorandum of agreement (MOA), file an MOA, or explain why one is not needed. (4) If you prepare an MOA: (a) make the MOA among us, the SHPO, the FS, and the Advisory Council on Historic Preservation (Council); (b) include the comments of the SHPO and the FS on the MOA in your filing; and (c) revise the MOA as you determine appropriate to address the SHPO’s and the FS’s concerns. Conduct the survey and prepare the report and plan according to the Secretary of the Interior’s Standards and Guidelines for Archeology and Historic Preservation. You may obtain copies by telephoning the National Park Service at (202) 343-4101. In preparing an MOA, follow the Council’s guidelines, "Preparing Agreement Documents". You may get a copy of the guidelines by telephoning the Council at (202) 606-8505. To keep the locations of archeological sites confidential and to protect them from theft or vandalism, you should file three copies of the survey report and the plan or MOA directly with our cultural resources staff. Send this information--clearly marked "Confidential--Not for Public Disclosure"--to Dr. Edwin D. Slatter, Office of Hydropower Licensing, Federal Energy Regulatory Commission, 888 First St., NE, Room 5H-01, Washington, D.C. 20426. When you file this information with our staff, make a separate filing with the Secretary of the Commission that does the following: (1) Says you’ve made the filings with our staff. (2) Briefly describes the purpose and contents of the filing--without referring to site locations--so reviewing parties are informed about the general nature of archeological sites affected by the project. 5. Please provide one computer diskette copy of the complete hydrologic data set for the 35 years of record you used to analyze the Mahoney Lake Project. File the diskette with: Jim Fargo, Office of Hydropower Licensing, Federal Energy Regulatory Commission, 888 First St., NE, Room 52-77, Washington, D.C. 20426. May 31, 1996 Ms. Lois Cashell, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room A-1 Washington, D.C. 20426 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393-000 Application for License Dear Ms. Cashell: HDR Engineering, Inc., on behalf of the City of Saxman, Alaska, encloses for filing an original and eight copies of the Application for License for the above-referenced project. Also enclosed for filing are an original and eight copies of the City’s Preliminary Draft Environmental Assessment (PDEA). Consistent with the Commission’s February 13, 1995, order granting waiver of regulations, the PDEA is being submitted in lieu of the Exhibit E traditionally required as part of an Application for License. The Preliminary Supporting Design Report for the project is being filed simultaneously under separate cover. These documents are submitted pursuant to the Third Stage of Consultation under the Federal Energy Regulatory Commission regulations (18 CFR 4.38). The Cultural Resources Report (Appendix J to the Application for License) is not included in this filing, but will be submitted under separate cover at a future date. Copies of the Application for License and PDEA have been distributed to the parties on the attached service list that are shown in bold type. All others have received this letter only. Entities that would like to receive the documents or need additional copies should notify HDR Engineering. Please contact me if you have any questions concerning the Application for License or PDEA for the Mahoney Lake Hydroelectric Project. Sincerely, HDR ENGINEERING, INC. PAM. Mb erma Michael V. Stimac, Manager Licensing and Environmental Services Enclosures ce: Service List Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 CERTIFICATE OF SERVICE’ I hereby certify that I have this day served the Mahoney Lake Hydroelectric Project Application for License, including the Preliminary Draft Environmental Assessment, upon all persons listed below in bold type in accordance with the requirements of Section 385.2010(h) of the Rules of Practice and Procedure. U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Ms. Tamra Faris Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg U.S. Fish & Wildlife Service 3000 Vintage Bivd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 U.S. Forest Service Region 10: Alaska Region Box 21628 Juneau, AK 99802-1628 Mr. Jim DeHerrera District Ranger U.S. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Federal Emergency Management Agency Region 10: Bothell Federal Regional Center 130 228th Street, SW Bothell, WA 98021-9796 ' Entries on the Certificate of Service shown in bold type received copies of the Application for License and Preliminary Draft Environmental Assessment. Entries in regular type only received the letter of transmittal. Mahoney Lake Hydroelectric Project Certificate of Service 1 FERC No. 11393 Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main St., Suite 905 Portland, OR 97204 Ms. Lois Cashell Federal Energy Regulatory Commission 888 First St. NE, Room A-1 Washington, DC 20426 Mr. Vince Yearick Federal Energy Regulatory Commission 810 First St. NE, Room 504 Washington, D.C. 20426 Area Director Bureau of Indian Affairs P.O. Box 25520 Juneau, AK 99802-5520 Honorable Ted Stevens U.S. Senate Washington, DC 20510 Honorable Frank Murkowski US. Senate Washington, DC 20510 Honorable Don Young House of Representatives 2331 Rayburn Building House Office Boulevard Washington, D.C. 20515 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 District Manager Alaska Department of Environmental Conservation 540 Water Street, Suite 203 Ketchikan, AK 99901 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office P.O. Box 107001 Anchorage, AK 99510-7001 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Chris Westwood Alaska Department of Natural Resources Division of Forestry 2030 Sea Level Drive, #217 Ketchikan, AK 99901 Mr. Frank Rue, Commissioner Alaska Department of Fish and Game Habitat Division P.O. Box 25526 Juneau, AK 99802-5526 Certificate of Service Mahoney Lake Hydroelectric Project FERC No. 11393 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Mr. Glenn Freeman Alaska Department of Fish and Game Sport Fish Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Mr. Dennis Meiners State of Alaska Dept. of Community and Regional Affairs Division of Energy P.O. Box 112100 Juneau, AK 99811-2100 Mr. Riley Snell Alaska Industrial Development & Export Authority 480 W. Tudor Anchorage, AK 99503 Mr. Jim Thrall Locher Interests, Ltd. 406 West Fireweed Lane, Suite 101 Anchorage, AK 99503 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Director University of Alaska - Southeast Economic Development Center - UofASE 2600 - 7th Avenue Ketchikan, AK 99901 Mr. Robert Warner Librarian University of Alaska - Southeast 7th Avenue and Madison Ketchikan, AK 99901 Mr. Gary Freitag Southern SE Reg. Aquaculture Association 2721 Tongass Avenue Ketchikan, AK 99901 Mr. William J. Halloran Southern SE Reg. Aquaculture Association 2721 Tongass Avenue Ketchikan, AK 99901 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Certificate of Service Mahoney Lake Hydroelectric Project FERC No. 11393 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Jim Carlton Mayor Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 Mr. Mike Rody Borough Manager Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 Ms. Jennifer Carmen Coastal Coordinator Ketchikan Gateway Borough Planning Department 344 Front Street Ketchikan, AK 99901 Ms. Phyllis Yetka Assembly Member Ketchikan Gateway Borough Box 958 Ward Cove, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. Fred D. Monrean City of Ketchikan Department of Public Works 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. Rich Trimble Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Certificate of Service Mahoney Lake Hydroelectric Project FERC No. 11393 Mr. Lew Williams Publisher Ketchikan Daily News P.O. Box 7900 Ketchikan, AK 99901 Ms. Belinda Chase Ketchikan Daily News P.O. Box 7900 Ketchikan, AK 99901 Mr. Bob Konet News Director KTKN Radio 526 Stedman Street Ketchikan, AK 99901 Ms. Nancy Watt Greater Ketchikan Chamber of Commerce P.O. Box 5957 Ketchikan, AK 99901 Mr. Bob Martin, Director Tlingit-Haida Regional Electrification Authority P.O. Box 210149 Auke Bay, AK 99821 Mr. John Arriola President Tsimshian Tribal Association P.O. Box 7162 Ketchikan, AK 99901 Mr. Richard Jackson President Tongass Tribal Council P.O. Box 3380 Ketchikan, AK 99901 Certificate of Service Ms. Bea Watson, President Tongass Tribe Box 8634 Ketchikan, AK 99901 Ketchikan Indian Corporation 429 Deermount Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Honorable Harris Atkinson Mayor, City of Metlakatla Metlakatla Indian Comm. P.O. Box 8 Metlakatla, AK 99926 Mr. J. L. Bennett Ketchikan Pulp Company P.O. Box 6600 Ketchikan, AK 99901 Mr. O. J. Graham Ketchikan Pulp Company P.O. Box 6600 Ketchikan, AK 99901 Ms. Allis May Davis Tongass Conservation Society P.O. Box 1102 Ward Cove, AK 99928 Mr. Eric Hummel Tongass Conservation Society P.O. Box 3377 Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project FERC No. 11393 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Ms. Kate Tessar Alaska Services Group P.O. Box 22754 Juneau, AK 99802 Alaska Environmental Lobby P.O. Box 521 Haines, AK 99827-0521 Mr. Don Chenhall Chenhall Surveying P.O. Box 5860 Ketchikan, AK 99901 Mr. J. C. Conley Service Auto Parts, Inc. 3806 Tongass Avenue Ketchikan, AK 99901 Mr. David Kiffer 123 Stedman Ketchikan, AK 99901 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 Ms. June Robbins Legislative Information Office 352 Front Street Ketchikan, AK 99901 Ms. Sherrie Slick Alaska Congressional Delegation 109 Main Street Ketchikan, AK 99901 Certificate of Service Ms. Tena Williams 755 Grant Street Ketchikan, AK 99901 Ms. Mary Klugherz McDowell Group 320 Dock St., #201 Ketchikan, AK 99901 Mr. Hank Newhouse P.O. Box 9508 Ketchikan, AK 99901 Mr. Randall Ruaro Keene & Currall 540 Water Street, Suite 302 Ketchikan, AK 99901 Mr. Des Moore 8175 Sehome Road Blaine, WA 98230-9564 Mr. and Mrs. Forrest DeWitt Box 5252 Ketchikan, AK 99901 Mr. Tom Fitzgerald City Administrator City of Saxman Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. Michael V. Stimac, Manager Licensing & Environmental Services HDR Engineering, Inc. 500 - 108th Ave. NE, Suite 1200 Bellevue, WA 98004 Mahoney Lake Hydroelectric Project FERC No. 11393 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen U.S. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 Dated at Bellevue, Washington, this 31st day of May 1996. Gam Lindner Certificate of Service Mahoney Lake Hydroelectric Project FERC No. 11393 March 1, 1996 E C E | MAR 4199 (See attached list) Alaska Industrial vet en and Export Authority Re: City of Saxman, Alaska Mahoney Lake Hydroelectric Project FERC No. 11393/AK 9504-08) HDR Engineering, Inc. (HDR), on behalf of the City of Saxman, Alaska, is pleased to provide you with the enclosed Draft License Application and Preliminary Draft Environmental Assessment (PDEA) for the above-referenced project. These documents are being distributed pursuant to Stage II of the consultation process under Federai Energy Reguiaiory Commission (FERC) reguiations (18 CFR $4.38). Please review the Draft License Application and PDEA and provide HDR with your written comments no later than May 30, 1996. To facilitate incorporating your comments into a Final License Application and EA before they are filed with the FERC, we encourage you to provide your written comments before May 30. In addition to comments regarding the Draft License Application and PDEA, preliminary license terms and conditions, and recommendations on the PDEA are also being requested at this time. All comments should bear the heading “Preliminary Comments", "Preliminary Recommendations", "Preliminary Terms & Conditions", or "Preliminary Prescriptions". The Draft License Application and PDEA have been distributed to the entries on the attached distribution list that are shown in bold type. All others have received this letter only. If you would like to receive the documents or need additional copies, please let me know. Please do not hesitate to call me should you have questions concerning the Draft License Application or the PDEA for the Mahoney Lake Hydroelectric Project. We appreciate your interest in the project and look forward to receiving your comments. Sincerely, HDR ENGINEERING, INC. LA Michael V. Stimac Manager, Licensing and Environmental Services ce. Doug Campbell, Cape Fox Corporation HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington 98004-5538 DRAFT LICENSE APPLICATION & PDEA DISTRIBUTION LIST' U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Ms. Tamra Faris Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg U.S. Fish & Wildlife Service 3000 Vintage Blvd. Suite 201 Juneau, AK 99801 Mr. Steve Brockman U.S. Fish & Wildlife Service P.O. Box 23193 Ketchikan, AK 99901 Ms. Vicki Davis U.S. Fish & Wildlife Service P.O. Box 23193 Ketchikan, AK 99901 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 U.S. Forest Service Region 10: Alaska Region Box 21628 Juneau, AK 99802-1628 Mr. Jim DeHerrera District Ranger U.S. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Federal Emergency Management Agency Region 10: Bothell Federal Regional Center 130 228th Street, SW Bothell, WA 98021-9796 Mr. Arthur Martin Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main St., Suite 905 Portland, OR 97204 Ms. Lois Cashell Federal Energy Regulatory Commission 888 First St. NE, Room A-1 Washington, DC 20426 Mr. Vince Yearick Federal Energy Regulatory Commission 810 First St. NE, Room 504 Washington, DC 20426 Area Director Bureau of Indian Affairs P.O. Box 3-8000 Juneau, AK 99802 1 Entries shown in bold type received copies of the Draft License Application and Preliminary Draft Environmental Assessment. Entries in regular type only received the letter of transmittal. Honorable Ted Stevens U.S. Senate Washington, DC 20510 Honorable Frank Murkowski U.S. Senate Washington, DC 20510 Honorable Don Young House of Representatives 2331 Rayburn House Office Boulevard Washington, D.C. 20515 Ms. Lorraine Marshall Alaska Division of Governmentai Coordination P.O. Box 110030 Juneau, AK 99811-0030 Ms. Joan Hughes Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 District Manager Alaska Department of Environmental Conservation 540 Water Street, Suite 203 Ketchikan, AK 99901 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office P.O. Box 107001 Anchorage, AK 99510-7001 Mr. John Dunker Alaska Department of Natural Resources/Water 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Chris Westwood Alaska Department of Natural Resources Division of Forestry 2030 Sea Level Drive, #217 Ketchikan, AK 99901 Mr. Frank Rue, Commissioner Alaska Department of Fish and Game Habitat Division P.O. Box 25526 Juneau, AK 99802-5526 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2036 Sea Levei Drive, #205 Ketchikan, AK 99901 Mr. Steve Hoffman Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive Room 207 Ketchikan, AK 99901 Mr. Mike Haddix Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Mr. Glenn Freeman Alaska Department of Fish and Game Sport Fish Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Mr. Paul Novak Alaska Department of Fish and Game 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Mr. Doug Larsen Wildlife Biologist Alaska Department of Fish and Game 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mr. Dick Emerman Division of Energy Department of Community and Regional Affairs 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Mr. Dennis Meiners State of Alaska Dept. of Community and Regional Affairs Division of Energy P.O. Box 112100 Juneau, AK 99811-2100 Mr. Riley Snell Alaska Industrial Development & Export Authority 480 W. Tudor Anchorage, AK 99503 Mr. Stan Sieczkowski Manager, Operations & Maintenance Alaska Energy Authority 480 West Tudor Anchorage, AK 99563 Mr. Jim Thrall Locher Interests, Ltd. 406 West Fireweed Lane, Suite 101 Anchorage, AK 99503 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Director University of Alaska - Southeast Economic Development Center - UofASE 2600 - 7th Avenue Ketchikan, AK 99901 Mr. Robert Warner Librarian University of Alaska - Southeast 7th Avenue and Madison Ketchikan, AK 99901 Mr. Gary Freitag Southern SE Reg. Aquaculture Association 2721 Tongass Avenue Ketchikan, AK 99901 Mr. William J. Halloran Southern SE Reg. Aquaculture Association 2721 Tongass Avenue Ketchikan, AK 99901 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Jim Carlton Mayor Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 Mr. Mike Rody Borough Manager Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 Coastal Coordinator Ketchikan Gateway Borough Planning Department 344 Front Street Ketchikan, AK 99901 Ms. Phyllis Yetka Assembly Member Ketchikan Gateway Borough Box 958 Ward Cove, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. Fred D. Monrean City of Ketchikan Department of Public Works 334 Front Street Ketchikan, AK 99901 Mr. John Magyar Acting General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. Rich Trimble Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen’s Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Lew Williams Publisher Ketchikan Daily News P.O. Box 7900 Ketchikan, AK 99901 Ms. Belinda Chase Ketchikan Daily News P.O. Box 7900 Ketchikan, AK 99901 Mr. Bob Konet News Director KTKN Radio 526 Stedman Street Ketchikan, AK 99901 Ms. Nancy Watt Greater Ketchikan Chamber of Commerce P.O. Box 5957 Ketchikan, AK 99901 Mr. Bob Martin, Director Tlingit-Haida Regional Electrification Authority P.O. Box 210149 Auke Bay, AK 99821 Mr. John Arriola President Tsimshian Tribal Association P.O. Box 7162 Ketchikan, AK 99901 Mr. Richard Jackson President Tongass Tribal Council P.O. Box 3380 Ketchikan, AK 99901 Ms. Bea Watson, President Tongass Tribe Box 8634 Ketchikan, AK 99901 Ketchikan Indian Corporation 429 Deermount Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Honorabie Harris Atkinson Mayor, City of Metlakatla Metlakatla Indian Comm. P.O. Box 8 Metlakatla, AK 99926 Mr. J. L. Bennett Ketchikan Pulp Company P.O. Box 6600 Ketchikan, AK 99901 Mr. O. J. Graham Ketchikan Pulp Company P.O. Box 6600 Ketchikan, AK 99901 Ms. Allis May Davis Tongass Conservation Society P.O. Box 1102 Ward Cove, AK 99928 Mr. Eric Hummel Tongass Conservation Society P.O. Box 3377 Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Ms. Kate Tessar Alaska Services Group P.O. Box 22754 Juneau, AK 99802 Alaska Environmental Lobby P.O. Box 521 Haines, AK 99827-0521 Mr. Don Chenhall Chenhall Surveying P.O. Box 5860 Ketchikan, AK 99901 Mr. J. C. Conley Service Auto Parts, Inc. 3806 Tongass Avenue Ketchikan, AK 99901 Mr. David Kiffer i23 Stedman Ketchikan, AK 99901 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 Ms. June Robbins Legislative Information Office 352 Front Street Ketchikan, AK 99901 Ms. Sherrie Slick Alaska Congressional Delegation 109 Main Street Ketchikan, AK 99901 Ms. Tena Williams 755 Grant Street Ketchikan, AK 99901 Ms. Mary Klugherz McDowell Group 320 Dock St., #201 Ketchikan, AK 99901 Mr. Hank Newhouse P.O. Box 9508 Ketchikan, AK 99901 Mr. Randall Ruaro Keene & Currall 540 Water Street, Suite 302 Ketchikan, AK 99901 Mr. Des Moore 8175 Sehome Road Blaine, WA 98230-9564 Mr. and Mrs. Forrest DeWitt Box 5252 Ketchikan, AK 99901 Mr. Tom Fitzgerald City Administrator City of Saxman Route 2, Box 1 Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. Jack Snyder Western Regional Manager Northrop, Devine & Tarbell, Inc. 22118-20th Ave. SE, Suite 205 Bothell, WA 98021 Mr. Michael V. Stimac Manager, Licensing & Environmental Services HDR Engineering, Inc. 500 - 108th Avenue NE, Suite 1200 Bellevue, WA 98004-5538 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Donald H. Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Q ALASKA INDUSTRIAL DEVELOPMENT AND EXPORT AUTHORITY /= ALASKA @e_ =ENERGY AUTHORITY 480 WEST TUDOR ANCHORAGE, ALASKA 99503 907 / 561-8050 FAX 907 /561-8998 June 1, 1995 Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. Suite 1200 500 108th Avenue N. E. Bellevue, Washington 98004-5538 Subject: Mahoney Lake Hydroelectric Project; Proposed Transmission Line Routing Dear Mr. Stimac: The Alaska Energy Authority (AEA) has reviewed your May 24, 1995 correspondence concerning an alternate transmission line route for the subject project, connecting with the Beaver Falls Project rather than with the Swan Lake Transmission Line, as originally proposed. AEA, as owner of the Swan Lake Project and Swan Lake Transmission line has reservations concerning the interconnection of the proposed Mahoney Lake Project with the Swan Lake line. Potential conflicts between operation of the Mahoney Lake Project and operation of the Swan Lake Project transmission line, including AEA’s planning and implementation of scheduled outages of and maintenance of the line, are of significant concern. Further, a separate connection of the Mahoney Lake Project to the city of Ketchikan via the Beaver Falls Project, as stated in your letter of May 24, 1995, would improve Ketchikan Public Utilities ability to provide reliable service to that area. Improved reliability and increased flexibility in operation of the area’s power system are important issues which require consideration in the planning of this project. Therefore, the AEA recommends adoption of the South Route, as proposed in your letter, as the preferred alternative for this project. Sincerely, Stan Sieczkowski Manager, Maintenance and Operations SS/JHT/cjp Copy: Bl Beardsley) AEA” V. Yearick, FERC T. Waggoner, KPU J. Thrall, LIL File ALASKA INDUSTRIAL DEVELOPMENT AND EXPORT AUTHORITY / => ALASKA @@—— ENERGY AUTHORITY 480 WEST TUDOR ANCHORAGE, ALASKA 99503 907 / 561-8050 FAX 907 /561-8998 June 1, 1995 Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. Suite 1200 500 108th Avenue N. E. Bellevue, Washington 98004-5538 Subject: Mahoney Lake Hydroelectric Project; Proposed Transmission Line Routing Dear Mr. Stimac: The Alaska Energy Authority (AEA) has reviewed your May 24, 1995 correspondence concerning an alternate transmission line route for the subject project, connecting with the Beaver Falls Project rather than with the Swan Lake Transmission Line, as originally proposed. AEA, as owner of the Swan Lake Project and Swan Lake Transmission line has reservations concerning the interconnection of the proposed Mahoney Lake Project with the Swan Lake line. Potential conflicts between operation of the Mahoney Lake Project and operation of the Swan Lake Project transmission line, including AEA’s planning and implementation of scheduled outages of and maintenance of the line, are of significant concern. Further, a separate connection of the Mahoney Lake Project to the city of Ketchikan via the Beaver Falls Project, as stated in your letter of May 24, 1995, would improve Ketchikan Public Utilities ability to provide reliable service to that area. Improved reliability and increased flexibility in operation of the area’s power system are important issues which require consideration in the planning of this project. Therefore, the AEA recommends adoption of the South Route, as proposed in your letter, as the preferred alternative for this project. Sincerely, Manager, e and Operations SS/JHT/cjp Copy: D. Beardsley, AEA V. Yearick, FERC T. Waggoner, KPU J. Thrall, LIL File : ALASKA INDUSTRIAL DEVELOPMENT AND EXPORT AUTHORITY f= ALASKA @m™ ENERGY AUTHORITY 480 WEST TUDOR ANCHORAGE, ALASKA 99503 907 / 561-8050 FAX 907 /561-8998 June 1, 1995 Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. Suite 1200 500 108th Avenue N. E. Bellevue, Washington 98004-5538 Subject: Mahoney Lake Hydroelectric Project; Proposed Transmission Line Routing Dear Mr. Stimac: The Alaska Energy Authority (AEA) has reviewed your May 24, 1995 correspondence concerning an alternate transmission line route for the subject project, connecting with the Beaver Falls Project rather than with the Swan Lake Transmission Line, as originally proposed. AEA, as owner of the Swan Lake Project and Swan Lake Transmission line has reservations concerning the interconnection of the proposed Mahoney Lake Project with the Swan Lake line. Potential conflicts between operation of the Mahoney Lake Project and operation of the Swan Lake Project transmission line, including AEA’s planning and implementation of scheduled outages of and maintenance of the line, are of significant concern. Further, a separate connection of the Mahoney Lake Project to the city of Ketchikan via the Beaver Falls Project, as stated in your letter of May 24, 1995, would improve Ketchikan Public Utilities ability to provide reliable service to that area. Improved reliability and increased flexibility in operation of the area’s power system are important issues which require consideration in the planning of this project. Therefore, the AEA recommends adoption of the South Route, as proposed in your letter, as the preferred alternative for this project. Sincerely, Stan Sieczkowski Manager, Maintenance and Operations SS/JHT/cjp Copy: D. Beardsley, AEA V. Yearick, FERC T. Waggoner, KPU J. Thrall, LIL File May 24, 1995 D EGEIVE - 7 IWR Mr. Stan Sieczkowski MAY 30 1995 Manager, Operations & Maintenance Alaska Industrial Development Alaska Energy Authority : 480 West Tudor and Export Authority Anchorage, AK 99503 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Dear Mr. Sieczkowski: As a result of the scoping meetings held on April 12 and 13, 1995, an alternative transmission line route is being investigated for the Mahoney Lake Hydroelectric Project. The original proposal (North Alternative) entailed routing the electrical transmission line northward from Lower Mahoney Lake to the White River area, where it would connect to the Swan Lake Transmission Line. The new alternative (South Alternative) to be evaluated is to route the overhead transmission line southward from Lower Mahoney Lake to connect with the existing transmission line at Beaver Falls. A new access road would still be constructed northward from the powerhouse to connect with the existing forest road a mile north of Lower Mahoney Creek. The two alternatives are shown on the attached figure. The South Alternative resulted from a specific request made by Ketchikan Public Utilities (KPU). The transmission line running from Mahoney Lake to Beaver Falls would provide a direct connection into the existing system that provides electricity to the downtown area of Ketchikan, and would enhance KPU’s ability to continue to provide electrical service to that area in the event of temporary failure of the Swan Lake system. One quarter of the length of the transmission line route leading southward is located on land owned by the Cape Fox Corporation; the remainder is on land presently managed by the U.S. Forest Service. The South Alternative is over one mile shorter than the North Alternative, but will be somewhat more expensive to construct. Construction of the transmission line between Lower Mahoney Lake and Beaver Falls would require clearing the route of trees for a width of approximately 100 feet and a length of 20,170 feet from the site of the step-up transformer located at the east end of Lower Mahoney Lake. The land along this route is presently undisturbed and is primarily steep forested slopes. The cut trees will be removed from the route using helicopters. The poles supporting the electrical line will also be set by helicopter. No access road will be constructed southward from Lower Mahoney Lake and ground disturbance will be limited to that necessary for tree removal and pole placement. Access for line maintenance will be by helicopter, boat, and on foot. The South Alternative is 6,100 feet shorter than that of the North Alternative, and will allow the clearing necessary for the North Alternative to be avoided. i i Suite 1200 Telephone i 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 May 24, 1995 Page 2 We would appreciate hearing your questions and potential concerns about this new transmission line alignment by June 26, 1995. We plan to incorporate information you provide into the Scoping Document 2. Your input will help us determine what type of additional issues we may need to address and whether additional field studies will be necessary. If you wish, you may reference comments you provided previously and state how your questions or concerns about the new alignment differ from those you previously expressed. Thank you for your interest in this project. If you have any questions, please call me at (206) 453-1523. Sincerely, HDR ENGINEERING, INC. Michael V. Stimac Manager, Licensing and Environmental Services Enclosure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Jack Snyder, ND&T Mark Dalton, HDR Don Clarke, WKBQ HDR File, B.4.1 GOENUN 2h Interconnection Point to LY 4 Ze ce —S= Ov ny ECEIVE/) oe ZA MAY 3 0 1995 Alaska Industrial Development and Export Authority May 24, 1995 ra, Db Mr. Riley Snell Alaska Industrial Development Authority 480 W. Tudor Anchorage, AK 99503 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Dear Mr. Snell: As a result of the scoping meetings held on April 12 and 13, 1995, an alternative transmission line route is being investigated for the Mahoney Lake Hydroelectric Project. The original proposal (North Alternative) entailed routing the electrical transmission line northward from Lower Mahoney Lake to the White River area, where it would connect to the Swan Lake Transmission Line. The new alternative (South Alternative) to be evaluated is to route the overhead transmission line southward from Lower Mahoney Lake to connect with the existing transmission line at Beaver Falls. A new access road would still be constructed northward from the powerhouse to connect with the existing forest road a mile north of Lower Mahoney Creek. The two alternatives are shown on the attached figure. The South Alternative resulted from a specific request made by Ketchikan Public Utilities (KPU). The transmission line running from Mahoney Lake to Beaver Falls would provide a direct connection into the existing system that provides electricity to the downtown area of Ketchikan, and would enhance KPU’s ability to continue to provide electrical service to that area in the event of temporary failure of the Swan Lake system. One quarter of the length of the transmission line route leading southward is located on land owned by the Cape Fox Corporation; the remainder is on land presently managed by the U.S. Forest Service. The South Alternative is over one mile shorter than the North Alternative, but will be somewhat more expensive to construct. Construction of the transmission line between Lower Mahoney Lake and Beaver Falls would require clearing the route of trees for a width of approximately 100 feet and a length of 20,170 feet from the site of the step-up transformer located at the east end of Lower Mahoney Lake. The land along this route is presently undisturbed and is primarily steep forested slopes. The cut trees will be removed from the route using helicopters. The poles supporting the electrical line will also be set by helicopter. No access road will be constructed southward from Lower Mahoney Lake and ground disturbance will be limited to that necessary for tree removal and pole placement. Access for line maintenance will be by helicopter, boat, and on foot. The South Alternative is 6,100 feet shorter than that of the North Alternative, and will allow the clearing necessary for the North Alternative to be avoided. i ing, Inc. Suite 1200 Telephone HOR Engineering 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 May 24, 1995 Page 2 We would appreciate hearing your questions and potential concerns about this new transmission line alignment by June 26, 1995. We plan to incorporate information you provide into the Scoping Document 2. Your input will help us determine what type of additional issues we may need to address and whether additional field studies will be necessary. If you wish, you may reference comments you provided previously and state how your questions or concerns about the new alignment differ from those you previously expressed. Thank you for your interest in this project. If you have any questions, please call me at (206) 453-1523. Sincerely, HDR ENGINEERING, INC. Michael V. Stimac Manager, Licensing and Environmental Services Enclosure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Jack Snyder, ND&T Mark Dalton, HDR ‘ Don Clarke, WKBQ HDR File, B.4.1 2 (Cabal) aS A rea GS Ny ers / 4 WOE eae WAR, Ns. - <> Rs. .. l flrs, KER Sa P ne DOSS SS\ / acs. AS A oS Pe i, 138 KV buried ine from SHA, ae 5 , A). Bill, powerhouse to step-up \N ‘2 Ra! 2 J FE & VANE Alternative, 34.5 k x, 2S t AS Sees §: | May 12, 1995 Va Mr. Stan Sieczkowski Manager, Operations & Maintenance Alaska Energy Authority 480 West Tudor Anchorage, AK 99503 Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear Mr. Sieczkowski: Enclosed are the minutes from the April 12 and 13, 1995, National Environmental Policy Act (NEPA) scoping meetings for the above-referenced project. As a reminder, written comments regarding Scoping Document 1 are due on May 15, 1995. We look forward to your continued participation in this project. Sincerely, HDR ENGINEERING, INC. Guchat V Seriae fla Michael V. Stimac Manager, Licensing & Environmental Services Enclosure ce: Vince Yearick, FERC { Doug Campbell, Cape Fox Corporation C 5 ¢ F | V FE : Jack Snyder, NDT LI Don Clarke, Wilkinson, Barker, Knauer, & Quinn MAY 15 i9¢ Alaska Industrial D2. HDR File, B.4.1 and Export Auth Dlivy i i Suite 1200 Telephone BD Engrnearena, ec. 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 ek EGEIVE|)) hr May 12, 1995 MAY 15 4995 Alaska Industrial Development Alaska Industri and Export Authority eee ot ene ne 480 W. Tudor Anchorage, AK 99503 Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear Mr. Snell: Enclosed are the minutes from the April 12 and 13, 1995, National Environmental Policy Act (NEPA) scoping meetings for the above-referenced project. As a reminder, written comments regarding Scoping Document | are due on May 15, 1995. We look forward to your continued participation in this project. Sincerely, HDR ENGINEERING, INC. Michael V. Stimac Manager, Licensing & Environmental Services Enclosure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Corporation Jack Snyder, NDT Don Clarke, Wilkinson, Barker, Knauer, & Quinn HDR File, B.4.1 HDR Engineering, Inc. Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 MEETING MINUTES ra, PROJECT: Mahoney Lake Hydroelectric Project, FERC No. 11393 SUBJECT: National Environmental Policy Act (NEPA) Scoping Meeting, Evening Session DATE: April 12, 1994 PLACE: Ketchikan, Alaska ATTENDEES: Wendy Harkins-Sitka Electric Department; Hank Newhouse; Rich Trimble-Ketchikan Public Utilities; Craig Moore-State Parks Advisory Board; Don Ranne, Teresa Trulock-USFS; Nan Allen, Vince Yearick- FERC; Wade Lindsay-Wilkenson, Knauer, Barker & Quinn; John Morsell-Northern Ecological Services; Mark Dalton, Mike Stimac, Jack Snyder, Lisa Fortney-HDR Engineering. The meeting began at 7:10 pm. An agenda (copy attached) and Scoping Document 1 (SD1) were available for attendees. Jack Snyder welcomed everyone, explained that Doug Campbell was unable to attend this meeting, explained the protocol for the meeting (e.g., sign in and indicate if wish to provide testimony, the meeting is being taped, identifying yourself before speaking, etc.), and he reviewed the agenda. Mike Stimac reviewed the project history to date from receiving the preliminary permit from the Federal Energy Regulatory Commission (FERC), which gave the City the exclusive right to study the project and to file a license application by the end of the term of the permit. This permit has a term of three years and was received in June 1993. By the end of May 1996, the City of Saxman has to file its license application for the project. Once the project looked feasible, the studies were scoped out and preliminary design work was done. On March 16, 1994, the Initial Consultation Document was issued, which contained a brief description of the project and its operation and discussed the study programs to be implemented to develop the environmental documentation. It sought input from the public and the agencies. The first-stage consultation meetings were held on April 26, 1994, same format as these NEPA scoping meetings, one meeting for the public and another for the resource agencies and a site visit was also held. The comment period lasted for 60 days following the meetings. That ended the first- stage of consultation and started the second stage. The Initial Consultation Document was then modified according to the agency letters that were received and the document was distributed as the Final Consultation Document on August 8, 1994. As a result of the comments that were received and the applicant’s understanding of the project, it appeared that the environmental impacts would not be too significant. In July of 1994, a meeting was held with the FERC to explore the possibility of developing an Applicant-prepared environmental assessment (EA). This was a procedure that was authorized by the National Energy Policy Act of 1992. How this ii ‘ing, Inc. Suite 1200 Telephone i eee 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 differs from a normal licensing process is that the applicant in a normal situation would file the license application with the FERC. The FERC would then begin the NEPA process and write the EA. Under this new procedure, the NEPA process starts earlier in the process. It happens before the license application and the preliminary draft EA are filed with the FERC. When the Final Consultation Document was distributed, the letter that promulgated that document indicated that this was the approach that would be taken. That necessitated the development of the Memorandum of Agreement (MOA) between the City of Saxman, Cape Fox Corporation, U.S. Forest Service (USFS), and the FERC. The MOA sets forth the fact that an Applicant-prepared EA will be developed, a schedule of how the events might occur, and provided for communications protocol between the parties. The MOA was signed on January 13, 1995. In February, the FERC issued a letter to all parties on the distribution list waiving certain regulations because the timing of those regulations do not apply with this EA process, and that the Applicant-prepared EA would be developed and the EA would be filed in place of Exhibit E of the license application. On March 9, 1995, the SD1 was sent out to everyone on the distribution list and indicated the scoping meetings would be held today and tomorrow. Mike Stimac stated that HDR needs to receive written comments from resource agencies and the public by May 15, 1995. Depending on what kind of feedback is received, SD1 may be revised to include comments and distributed again as Scoping Document 2 (SD2). If little or no significant comments are received, a second scoping document will not be issued, but instead a letter will be distributed informing parties of this. The preliminary draft EA and the draft license application are tentatively scheduled to be distributed by September 1995 for review and comment. The agencies and public will have a 90-day comment period. About two-thirds of the way through the comment period, a public/agency meeting will be held to discuss the results of the studies and respond to any questions and to clarify concerns about the project. This will help to refine the information that goes into the agencies comment letters. The comments of the draft license application and draft EA will be due, along with draft mandatory and recommended license terms and conditions or prescriptions in December of 1995. The draft EA and the license application are scheduled to be filed with the FERC in January 1996. The last three items on the project chronology relate to what happens with the document and process once the application is filed. Vince Yearick of the FERC will talk about those when he’s up here. Mike Stimac explained that the purpose of the scoping meetings is to identify issues, concerns and opportunities associated with the proposed action. According to NEPA, it should conducted as soon as possible in the process. Normally, in a regular licensing proceeding, NEPA does not begin until the third stage of consultation. This is actually being done now as part of the second stage and having it completed sooner before the application is filed with the FERC. Mike Stimac explained that the participation of the federal, state, and local agencies, any Native American group and interested persons is requested to identify significant environmental and socioeconomic issues related to the proposed action, determine the depth of analysis and significance of issues to be addressed in the EA, identify how the project would or would not contribute to cumulative effects in the Mahoney Creek basin, identify reasonable alternatives that should be evaluated, eliminate from detailed study the issues and resources that do not require detailed analysis during review of the project, and to solicit additional study requests. This will be the last opportunity for resource agencies to request additional studies. If requests are submitted, they must conform to 18 CFR 4.32.b.7. You must describe the study, the basis for the request, who should participate and conduct the study, the methodology and the objective, whether the methodology 2 is accepted by the scientific community, how the results will be used by the requesting agency, how long it might take to complete the study, and why the objectives cannot be achieved by using the existing data or study program. Mike Stimac requested additional information that would be beneficial to analyze the impacts of the project. Information, quantified data, or professional opinions that may contribute to defining the geographical and temporal scope of the analysis and identifying significant environmental issues; identification of, and information from any other environmental document or similar study (previous, on-going, or planned), relevant to the proposed Mahoney Lake Hydroelectric Project. Existing information and any quantified data that would help to describe the past and present actions and effects of the project and other developmental activities on environmental and socioeconomic resources; information that would help characterize existing environments and habitats; identification of any federal, state, or local resource plans, environmental impact statements (EIS), and future project proposals in the affected resource area, such as proposals to construct or operate water treatment facilities, recreation areas, water diversions, timber harvest activities, or fish management programs; documentation that would support a conclusion that the proposed project contributes to adverse or beneficial effects on resources, including but not limited to (a) how the project interacts with other hydropower projects and other development activities within the affected area, (b) results from studies, (c) resource management policies, and (d) reports from federal, state, and local agencies; and documentation showing why any resources should be excluded from further study or excluded from further consideration. Mike Stimac stated that all comment letters should be filed by May 15, 1995. He asked if there were any questions and there were none. Vince Yearick explained the NEPA process and how the USFS and the FERC need to complete NEPA to issue permit/license under their respective jurisdictions. The FERC issues licenses for non-federal hydropower projects, those projects developed by private individuals or utilities versus the Bureau of Reclamation or other federal agencies. The USFS issues Special Use Permits. For this project, because there are USFS lands involved, the environmental document, which FERC believes will be an EA, will serve as the NEPA background for their licensing decision and for the USFS to make their permitting decision. One thing that is different in this particular project is that the Applicant intends to prepare their own EA. This is an option that was brought about by the National Energy Policy Act of 1992. The intent is to speed up the licensing process, to allow the applicant to prepare their own environmental documents. If it’s an EA, they can do it themselves or they can hire someone to do it. If it will be an environmental impact statement, they can do another option which is Third Party Contracting. The FERC believes an EA would be needed because no new dam would be constructed and it would use existing impoundments, which minimizes some of the potential environmental impacts. Both the FERC and USFS are involved because of federal permits, which is what triggers NEPA. The intent of ‘the Applicant-prepared EA is to speed the licensing decision process. The application preparation work is being completed the same time the environmental analysis is being done. Typically, the application is prepared and filed with FERC and then the FERC begins their review of the project. FERC would begin scoping after the application is filed and would write the environmental document that leads to a licensing decision. For this project, the EA will be prepared along with the license application. One of those regulations that was waived is the requirement to file the Exhibit E, or the environmental report, with the 3 application. The EA will take the place of the Exhibit E in the application. The ultimate goal is for the EA to be as complete as possible when the FERC receives it, so little rewriting will have to be done at that time. Preliminary terms and conditions and recommendations will be requested when the preliminary draft EA is distributed. That way when the document is filed with the FERC, it will include an analysis of all of those recommendations, so major changes will not have to be made to the document once it is received. For those providing comments, it is important to submit your terms and conditions with the preliminary draft EA. The applicant can then incorporate your comments into the EA and the FERC will have a head’s up as to what to expect when the final comments come in. Once the application is filed, the FERC will review the application for adequacy, and assuming it is okay, the FERC will issue a public notice that the application has been filed and that it has been accepted (meaning there are no deficiencies in it). At that point, there will be a 60-day period for anyone to file interventions on the project. There are two types of interventions, one is to become a party to the proceedings. This means anytime anyone sends any correspondence to the FERC, they have to send it to the intervenor also. If the intervenor sends any correspondence, they have to copy all the other parties. It also provides an opportunity for opposing licensing of the project. This has some ramifications later on down the line for the FERC. It is termed a Commission action, where the project is voted on by the five commissioners. Final terms and conditions, which hopefully will be very similar to the preliminary terms and conditions, will be issued. A 60-day comment period will follow. The FERC will take all of the comments and make the EA their own document. The FERC will make any changes to the terms and conditions and issue a FERC draft EA. A public comment period will follow and after that the Final EA will be issued. Lastly, the FERC will issue its licensing decision. The time from when FERC receives the application to issuing a license could be about 1 year, unless major modifications to the EA are needed. Vince Yearick asked if there were any questions. He clarified that the environmental review was happening in the pre-filing stage. There were no questions. Rich Trimble asked Teresa Trulock of the USFS if this was the same as what the USFS does for a timber sale EA/EIS. Teresa said that it was a little different because it involves FERC. Rich Trimble asked if FERC was the lead agency the way the USFS is lead agency for a timber sale EIS. Teresa Trulock said yes, except FERC is requiring an EA or EIS whichever it ends up to be. Vince Yearick said that by doing a cooperative NEPA document, efforts are reduced because it avoids the USFS doing a separate EA from the one FERC does. It’s another way of consolidating the process by the applicant preparing the EA and involving the two federal agencies. Rich Trimble asked when the permits would be issued. Vince Yearick said that the application needs to be filed by June 1996 and a decision would take about a year minimum, so that would be June 1997. Mike Stimac said that the application would be filed by January 1996. Vince Yearick said that is probably ambitious and would be January 1997 given all the comment periods. He said it could be possibly be a shorter time period. Mark Dalton asked Teresa Trulock about the USFS action on the Special Use Permit, if that is the only action they take, if there is a FONSI or record of decision that the USFS will issue. 4 Teresa Trulock said that it would be FERC that makes the decision as lead agency. Vince Yearick said it was the Special Use Permit that triggers NEPA. Teresa Trulock said that since FERC is lead agency, FERC will be signing the document but USFS will review and approve it. Hank Newhouse said that for an example on the Black Bear Lake Hydroelectric Project, there was a NEPA document developed that was strictly for the Special Use Permit. Vince Yearick said that for the Black Bear Lake Project, FERC did do an EA on it. Jack Snyder reiterated that FERC did an EA but that Hank Newhouse was talking about the USFS. Hank Newhouse said. the USFS portion of that did issue a decision notice as a result of categorical exclusion ... Teresa Trulock finished that it was a categorical exclusion beyond what FERC required. Jack Snyder stated that there was a lot more USFS land involved on that project. Hank Newhouse said there was a Special Use Permit for the cabin and trail. Teresa Trulock said the Black Bear Lake Project was a little bit more involved. Jack Snyder agreed. Jack Snyder described the proposed project. He described the project design and its location between Upper and Lower Mahoney Lakes. He explained that the natural topography of the area. He presented a topographic map of the area and pointed out the project features. He showed where the existing logging road is and how it will be extended south around the lower lake. The transmission line will be buried from the powerhouse to the existing logging road and then continue as an overhead line to the Swan Lake Intertie. Jack Snyder summarized how the proposed project would operate and how it would be constructed. Jack explained that most of the project would be underground. An upper tunnel would be located about 80 ft. below the lake surface (lake tap) of Upper Mahoney Lake and would convey water 1,400 ft. to a vertical shaft. The water would drop 1,200 ft. and continue to a lower tunnel which would run to the powerhouse. The powerhouse location was chosen because of the impassable barrier to upstream migration of fish. Jack explained the normal operation of the impulse turbines. Jack showed the powerhouse layout including where the staging area is planned. A videotape of aerial footage for the project area was shown to illustrate the existing site conditions, which Jack narrated. Vince Yearick asked what above-ground structures there would be at the project. Jack Snyder explained a small valvehouse will be situated at the top of the vertical shaft. He explained how a dam was considered for the upper lake but the avalanche danger would be too great to construct, operate and maintain a dam. He described the type of the rock found in the area and that it is metamorphic which is good for tunneling. He asked if there were any questions, there were none. Mark Dalton described the resource issues that have been raised to date. Initial consultation meetings were held about a year ago with ongoing agency consultation of the study plans. Land disturbance issues - an Erosion and Sediment Control Plan is being prepared as well as a NPDES stormwater pollution prevention plan. Botanical issues - sensitive, threatened and endangered species that could be impacted. To date, no threatened or endangered species have been identified. However, in consultation with USFS, a few sensitive plant species as designated by the USFS do occur within the project area. In response, a survey was conducted last September of the project area starting with the access road at the terminus of the existing logging road, coming around to the powerhouse site and some work around the upper lake to try and characterize the plants that do occur in the area. That survey was conducted by HDR ‘staff and the Alaska Natural Heritage Program. A copy of that report has been provided to the USFS (Mary Stensvold). Terrestrial issues - Concern for a population of mountain goats that were relocated by Fish & Game in 1991 to the area of the upper lake and to make sure the timing of project construction will not cause adverse impacts. Other concerns are loss of habitat (wetlands) due to construction of the project. Identification of where wetlands are and to relocate project features around wetlands where practical, primarily the access road. The overhead transmission line will be raptor-proof designed to protect raptors and other birds from electrocution. A field assessment of wetlands occurred in June 1994, along with a ground survey to locate raptor nest sites along the project access road, tailrace & powerhouse site. In addition, a bald eagle nest survey of the project area was conducted in cooperation with the U.S. Fish & Wildlife Service (USFWS). The survey also included areas up to the White River and across George Inlet. A wetlands functional assessment will be prepared and a limited discussion of the functions and values of wetlands that do occur in the area and a biological evaluation (BE) of wildlife species will be prepared in consultation with the USFS. A Plant BE will also be prepared with the USFS. Both of these reports will be contained as a technical appendix to the EA. Aesthetic resources - main concern is what will be the impact of construction and operation of the project on the visual quality of the area. The EA will characterize the existing visual quality and estimate what the potential changes might be from construction. Recreation issues - what impact the project will have on current recreation opportunities. Socioeconomic issues - the impact of project construction and operation on the local economy. Historical/Archaeological issues - concern about how project construction and operation will affect historical or archaeological resources in the area. Consultations are being held with State Historic Preservation Office. Aquatic issues - Impacts to fish in Mahoney Lake system, and Lower Mahoney Creek, spawning of sockeye salmon, temperature in gravels. Upper Mahoney Lake temperature profile continuously monitoring at depths of 20 ft. increments from the surface to 100 ft. to model water column temperatures. Stream flow,. water quality, and temperature data are being collected at the tailrace. The collection of raw. data will continue through May 1995. Data collection began in June 1994 and some challenges have been incurred. The temperature device at Upper Mahoney Lake has not been located for the past few months because there is too much snow. Two temperature probes were placed in Lower Mahoney Lake. An animal chewed on one of the cables, so some data were lost, but redundant recorders made sure we have sufficient data. John Morsell described the three field trips that occurred in 1994. The first visit was in mid-June and the intent was to get an idea of the resident fish living in Lower Mahoney Lake/Lower Mahoney Creek and the portion of Upper Mahoney Creek from the falls down to the lake. A variety of sampling and observational techniques were used to get the information needed. Another field visit was made in late August, which was timed to coincide with the maximum number of salmon in Lower Mahoney Creek to get some idea of how many of those salmon were making into the lake and to possibly do some mapping of spawning areas in the lake. At that time, most of the sockeye salmon were still in the creek so a third field visit was made in the third week of September. At that time, flows were substantially higher due to heavy rains and most of the sockeyes that were in the lower creek had made it into the lake. John was successfully able to map the spawning areas in the lake. The field studies are essentially completed. The data analysis is mostly complete. The fish information will be integrated with the temperature information during preparation of the EA to try and make some predictions on incubating salmon. Jack Snyder lead the discussion of agency/public comments on the project. Some people had identified themselves on the sign-in sheet as wanting to make public testimony. Don Ranne asked how the project fits in with the Swan Lake-Lake Tyee Intertie Project and the potential Lake Grace project. Will this project be able to replace any of those others? Jack Snyder responded that there are a variety of ways that those projects could interact with each other. Jack stated that average loads in the Ketchikan area exceed the capacity of the Ketchikan Public Utility (KPU) system, therefore, they have been running diesel generators from December to April. As the demand grows, the problem will worsen. There is demand that projects could be brought on-line. Mahoney Lake is one project, the intertie project is another and Grace Lake are additional new resources that could help meet this demand. Whether Mahoney Lake could replace any of these? According to the current projections of load growth, the Mahoney Lake Project could handle all of the additional growth in demand for the next 10 years. At that point, you begin to get into the need for diesel or another resource. How the intertie would meet those needs and how Grace Lake would meet those needs, Jack stated he was not qualified to respond to that. He stated he understood that Grace Lake is about the same size of Mahoney Lake and may have a little bit more storage, but it has other issues with it, such as located in Misty Fjords Park and would need a long transmission line. The intertie project could meet the needs of Ketchikan if there was power available at the right price. Rich Trimble asked if it would be economically feasible to put both the Mahoney Lake Project and the Swan Lake-Lake Tyee Intertie Project on-line at the same time. Jack Snyder said that according to his information from the economic analysis that was completed for the Mahoney Lake Project, it showed the intertie project is not economic. He was unable to tell if the intertie and Mahoney Lake at the same time would be economic because he doesn’t know what basis the intertie power would be. Jack said the analysis that was completed looked at different scenarios, depending on how the project was financed, where the money comes from, what the demand is, and how it grows over time. A few people on the sign-in sheet indicated that they would like to comment on the project. Request for comments or testimony was made at this time. Hank Newhouse asked if the Cape Fox Corporation was putting up funding for the project. Jack Snyder said that the City of Saxman is the project sponsor. The preliminary permit is in their name. The intent is that when construction financing begins, the City of Saxman will sell bonds to finance construction. The Capé Fox Corporation has an agreement to act as their development agent at this point in the project. Funding is coming from a variety of sources for these studies. One of the main sources is a Department of Energy grant that will give the project some federal monies. Hank Newhouse also added that some changes were needed to the distribution list, such as adding the Ketchikan Indian Corporation (Gerald Hope is President), Organized Village of Saxman (which is different than the City of Saxman-Joe Williams, President), and the Tongass Tribe’s new president is Bea Watson. Rich Trimble stated that as a utility to which the City of Saxman intends to sell the Mahoney Lake power, KPU has a very keen interest on how you go about the project and at what cost the power is sold. KPU is an intervenor in the project. This means that KPU’s interest is so deep that they made it formal. The City of Ketchikan has formally requested the City of Saxman to defer development of the project. It is true, Ketchikan is running out of power. Under those conditions, one would think that KPU would have an interest in any project that came along. Why would KPU voice concern about the Mahoney Lake Project and the reason is because it provides power but not when KPU needs it and at a cost that KPU should be expected to pay. KPU is responsible to find an alternative that will provide a long-term or even intermediate term solution to their shortage and anticipate at what cost they should be expected to pay for this. This is all in a letter that KPU will provide to HDR. KPU believes that scoping is premature because terms for power purchase by KPU have not been negotiated. There was a meeting where it was suggested that KPU purchase Mahoney Lake power in a preferential manner. KPU has their own economic and contractual constraints. KPU cannot simply purchase all the power in that kind of manner. There seems to be a conflict. On one hand, the City of Saxman needs to sell the power to make the project economically feasible. KPU has other power that they will use first and have to use first, specifically, KPU own hydroelectric projects at a very low cost to pay them off (Beaver Falls, Silvis, and Ketchikan Lakes). There is an existing contract where KPU has to purchase Swan Lake power after they use their own resources. It will not allow KPU to develop another project or purchase third party power under the same preferential treatment. They must purchase Swan Lake power until the lake level gets low. Only at that point can they consider running diesel generators or purchasing third party power. The economic analysis assumed that the City of Saxman could sell that power. KPU takes issue with that.,.KPU must negotiate with the three other utilities in the four- dam pool to purchase power other. than Swan Lake. They would have to agree to that. That would decrease their revenues if KPU purchased Mahoney Lake power over Swan Lake power. They would not be able to purchase enough kilowatt-hours (kWh) of electricity over the intertie now and the short term to be able to market bonds for that project. You have indicated the Mahoney Lake Project could replace any of those other projects for the next 10 years. But the operating scenario you have shown indicates there is not enough demand in the year 2000. KPU will be running their diesels. I understand that Jack may not agree with everything I am saying, I am simply pointing out this is an issue. If KPU is connected with Mahoney, there are some things they would like to see. First, they would like to have a dam built for extra storage capacity and to alleviate concerns of needing power. KPU would prefer to have the transmission lines go to the Beaver Falls Project to the south versus to the north to the Swan Lake transmission lines. If Swan Lake drops off-line, Mahoney Lake would drop off-line. If brought around to Beaver Falls and Swan Lake drops off- line, the downtown area of Ketchikan could remain with power, where it is unable to do now because there is too much load on that substation. Not only would it enhance KPU system reliability, it would enhance the revenue potential to keep it on-line. Another issue is the potential to wheel power to another market - Metlakatla. The EA should address potential markets. Tke: Mountain Point substation was built with capacity for interconnection to Metlakatla anticipating that an intertie would be established some day. The City of Metlakatla has identified they have a shortage of power. Hank Newhouse stated that he liked the Mahoney Lake Project because it has very low environmental impacts. Another reason is that it is being developed by the native community of Saxman. Unfortunately, KPU has not always been a good citizen in working with the native community. Also, with the current congressional climate, dollars are scarce - subsidized power for communities like Kake and other native villages is going to disappear. That will drive up their costs tremendously. Already they are paying approx. $0.25 kWh. If KPU takes the Swan Lake-Lake Tyee intertie project, that will leave communities like Kake out of the line and Kake would very much like to tie into the intertie. If Ketchikan pulls the power this way, it does not leave the option open for small communities like Kake. Kake has done much to diversify their economy. Their timber is gone, but they have their hatchery and fish processing plant. Options are cut off for other communities in southeast Alaska. I think the Mahoney Lake project is real good for the community of Ketchikan because it allows other communities to come on-line. Black Bear Lake Hydro will be coming on-line soon. I was talking to another party of the four- dam pool and the intent of the intertie project was not to come to Revilla Island but it would stay on the north side of Ernest Sound and go across to Thorne Bay on Prince of Wales Island, tie into the Black Bear Lake Hydro Project and go around and get Metlakatla to tie the grid that way. To tie into Beaver Falls does make sense. Eventually, tieing the grid together in the longer term makes more sense. In the short-term in a real. tough dollar environment for the community of Ketchikan, the Mahoney Lake Project makes more economic sense. These other items can be negotiated and worked out and can be done with a lot less environmental impact to Revilla Island. The Swan Lake-Lake Tyee Intertie project will have a lot more environmental impact. Jack Snyder reminded the participants that comments are needed by May 15, 1995 and will be addressed in SD2. The meeting ended at 8:45 pm. MEETING MINUTES ra, PROJECT: Mahoney Lake Hydroelectric Project, FERC No. 11393 SUBJECT: NEPA Scoping Meeting, Morning Session DATE: April 13, 1994 PLACE: Ketchikan, Alaska ATTENDEES: William Jones-City of Ketchikan; Melanie Fullman-Ketchikan Gateway Borough; Steve Brockman, Vicki Davis-USFWS; Jack Gustafson, Carol Denton-ADFG; Wendy Harkins-Sitka Electric Department; Jan Risla- Ketchikan Public Utilities; Craig Moore-State Parks Advisory Board; Tom Somrak, Jim DeHerrera, Teresa Trulock-USFS; Nan Allen, Vince Yearick-FERC; D. Campbell-Cape Fox Corporation; Wade Lindsay- Wilkenson, Knauer, Barker & Quinn; John Morsell-Northern Ecological Services; Mark Dalton, Mike Stimac, Jack Snyder, Lisa Fortney-HDR Engineering. The meeting began at 9:15 am. Doug Campbell welcomed everyone. He reminded everyone to sign in, especially if they were interested in testifying. This meeting is called as part of the National Environmental Policy Act (NEPA) process. It is a required step in the process. The meeting is being recorded. The minutes of the meeting will be issued to everyone signed in and to everyone on the mailing list. Scoping documents, agenda were made available to attendees. Doug asked them to please identify yourself, your name and who you are representing when commenting. Even though the intent of the meeting is to take testimony, Doug stated he would feel more comfortable and it would be more productive if this was more of an informal question and answer discussion on the issues. However, if anyone wishes to make a prepared statement, that is acceptable. The people are here to answer any questions and hopefully deal with any of the issues that may be raised. Mike Stimac reviewed the meeting agenda. Mike Stimac reviewed the project history to date from receiving the preliminary permit from the Federal Energy Regulatory Commission (FERC), which gave the City the exclusive right to study the project and to file a license application by the end of the term of the permit. This permit has a term of three years and was received in June 1993. By the end of May 1996, the City of Saxman has to file its license application for the project. He explained that this isn’t the first time developers have looked at the Mahoney Lake Project, previous studies date back to the Carter administration. Once the project looked feasible, the studies were scoped out and preliminary design work was done. On March 16, 1994, the Initial Consultation Document was issued, which contained a brief description of the project and its operation and discussed the study programs to be implemented to develop the environmental documentation. It sought input from the public and the agencies. The first-stage consultation meetings were held on April 26, 1994, same format as these NEPA scoping meetings, one meeting for the public and another for the resource agencies and a site visit was also held. The comment period lasted for 60 days following the meetings. That ended the first- i ‘ing, Inc. Suite 1200 Telephone Se te 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 stage of consultation and started the second stage. The Initial Consultation Document was then modified according to the agency letters that were received and the document was distributed as the Final Consultation Document on August 8, 1994. As a result of the comments that were received and the applicant’s understanding of the project, it appeared that the environmental impacts would not be too significant. In July of 1994, a meeting was held with the FERC to explore the possibility of developing an Applicant-prepared environmental assessment (EA). This was a procedure that was authorized by the National Energy Policy Act of 1992. How this differs from a normal licensing process is that the applicant in a normal situation would file the license application with the FERC. The FERC would then begin the NEPA process and write the EA. Under this new procedure, the NEPA process starts earlier in the process. It happens before the license application and the preliminary draft EA are filed with the FERC. When the Final Consultation Document was distributed, the letter that promulgated that document indicated that this was the approach that would be taken. That necessitated the development of the Memorandum of Agreement (MOA) between the City of Saxman, Cape Fox Corporation, U.S. Forest Service (USFS), and the FERC. The MOA sets forth the fact that an Applicant-prepared EA will be developed, a schedule of how the events might occur, and provided for a communications protocol between the parties. The MOA was signed on January 13, 1995. In February, the FERC issued a letter to all parties on the distribution list waiving certain regulations because the timing of those regulations do not apply with this EA process, and that the Applicant-prepared EA would be developed and the EA would be filed in place of Exhibit E of the license application. On March 9, 1995, the Scoping Document 1 (SD1) was sent out to everyone on the distribution list and indicated the scoping meetings would be held yesterday and today. Yesterday, a site visit was held in the afternoon and an evening meeting for the public. This morning’s meeting is oriented towards the resource agencies. Comments are due on issues and the project on May 15, 1995. Those comments should be addressed to me. My name, address, and phone number are all contained in the SD1. Looking ahead, if we need to modify the SD1 as a result of feedback that we receive, if we add or delete issues, then a SD2 will be issued in June 1995 while working towards finalizing the license application and the EA. In September 1995, we hope to send a draft of the EA and the license application to all parties for review. This will have a 90- day comment period. About two-thirds of the way through the 90-day comment period, a public and agency meeting will be held where information can be exchanged to make sure we understand what concerns there may still be and to answer any questions the resource agencies may have. At the end of the 90-day comment, formal comments will be submitted regarding the draft application and, because we are doing NEPA earlier, and under this modified procedure, those letters will also need to contain draft mandatory and recommended license terms and conditions and prescriptions. That will be tentatively in December 1995. Our hope would be to turn it around, modify the application and submit it to the FERC in January 1996. Three other dates on the chronology relate to what happens with the Draft EA and license application once FERC receives it. Vince Yearick of the FERC will talk about those procedures. Mike Stimac explained that the purpose of the scoping meetings is to identify issues, concerns and opportunities associated with the proposed action. According to NEPA, it should be conducted as soon as possible in the process. Normally, in a regular licensing proceeding, NEPA does not begin until the third stage of consultation. This is actually being done now as part of the second stage and having it completed sooner, before the application is filed with the FERC. 2 Mike Stimac explained that the participation of the federal, state, and local agencies, any Native American group and interested persons is requested to identify significant environmental and socioeconomic issues related to the proposed action, determine the depth of analysis and significance of issues to be addressed in the EA, identify how the project would or would not contribute to cumulative effects in the Mahoney Creek basin, identify reasonable alternatives that should be evaluated, eliminate from detailed study the issues and resources that do not require detailed analysis during review of the project, and to solicit additional study requests. This will be the last opportunity for resource agencies to request additional studies. If requests are submitted, they must conform to 18 CFR 4.32.b.7. You must describe the study, the basis for the request, who should participate and conduct the study, the methodology and the objective, whether the methodology is accepted by the scientific community, how the results will be used by the requesting agency, how long it might take to complete the study, and why the objectives cannot be achieved by using the existing data or study program. Mike Stimac requested additional information that would be beneficial to analyze the impacts of the project. Information, quantified data, or professional opinions that may contribute to defining the geographical and temporal scope of the analysis and identifying significant environmental issues; identification of, and information from any other environmental document or similar study (previous, on-going, or planned), relevant to the proposed Mahoney Lake Hydroelectric Project. Existing information and any quantified data that would help to describe the past and present actions and effects of the project and other developmental activities on environmental and socioeconomic resources; information that would help characterize existing environments and habitats; identification of any federal, state, or local resource plans, environmental impact statements, and future project proposals in the affected resource area, such as proposals to construct or operate water treatment facilities, recreation areas, water diversions, timber harvest activities, or fish management programs; documentation that would support a conclusion that the proposed project contributes to adverse or beneficial effects on resources, including but not limited to (a) how the project interacts with other hydropower projects and other development activities within the affected area, (b) results from studies, (c) resource management policies, and (d) reports from federal, state, and local agencies; and documentation showing why any resources should be excluded from further study or excluded from further consideration. Mike Stimac reiterated that all comment letters or additional study requests should be submitted to him by May 15, 1995. Vince Yearick introduced himself and Nan Allen, the fisheries biologist from the FERC. An applicant-prepared EA will be prepared that will be filed as part of the license application. That option came about from legislation as part of the Energy Policy Act of 1992. The intent of that was to shorten the length of time from when the FERC receives the license application to when they make a licensing decision on a project. The intent was to make the opportunity available to have an environmental document fairly complete when FERC receives it, so that FERC does not spend as much time on it internally reviewing and rewriting work that has already been done by the Applicant. In this case, it is a cooperative EA, which means that the USFS will also be using the document to support their decision on conditions that will go into their Special Use Permit for the project because the project occupies USFS land and FERC will use it to guide their decision whether or not to issue a license for the project. A couple of regulations were waived, or more accurately some things were pushed into different time frames. Some of the comment periods were moved to the pre-filing stages. Mike Stimac mentioned one of those and that is the time period to request additional studies on the project. Typically, that happens after FERC receives the application, it is noticed in the Federal Register, and there is opportunity for anyone to request additional studies. In this case, that time is now. This is the last time to request additional studies. Also, we are asking for more stringent and earlier review on the part of the agencies that are involved in the process. You will be receiving a copy of the preliminary draft EA for the Mahoney Lake Project. The applicant will be asking ' for preliminary terms and conditions from the agencies, such as the Section (4)e conditions from USES, and the Alaska Department of Fish & Game (ADFG), what you think your final terms and conditions might look like for this project. The terms and conditions of the license are needed now in order to be analyzed in the EA before it is filed with FERC. If they are not included, FERC will have to rewrite the document which will lengthen the processing time and defeat the purpose of the applicant-prepared EA. More up-front work is required by the agencies so that less commitment is needed once the application is filed. So the preliminary terms and conditions will be requested in the comment period for the preliminary draft EA. Once FERC receives the application, some review will still be required. A check for adequacy that are required for license applications. Since FERC is working with the applicant, it is anticipated that the application will be acceptable because they will have reviewed and commented on it prior to filing. A public notice will be issued that FERC has accepted the application. Interventions on the project can be filed at this time. This is also the time to file final terms and conditions on the project. That information should be similar to the preliminary comments that FERC received from the draft. The FERC and USFS will make it their own document and issue it as a joint draft EA. Comments will be solicited on that document and a final EA will be issued. A license decision will then be made, and if the decision is to approve the license, what kind of measures should go in to the license. The USFS will also use this to issue their Special Use Permit. If all goes well, it will take approximately 1 year to issue a licensing decision from the time FERC receives the application. The Energy Policy Act did require FERC to develop regulations on how the process will work for applicant-prepared EA’s. Nothing official is expected for a while. Concentration is on processing the Class of 1993 relicensing applications. There is not a lot of attention being paid to developing new regulations. A draft schematic of how the modified process will work is available up here at the front. The applicant of a proposed project near Haines, Alaska is also utilizing this method of completing their own EA. It is a fairly popular idea and will be more popular if it works the first few times by obtaining a quick licensing decision. The intent is to speed things up and avoid duplication of efforts. However, it does require some more involvement up front. Questions? There were none. Jack Snyder described the proposed project. He described the project design and its location between Upper and Lower Mahoney Lakes. He presented a topographic map of the area and illustrated how the site will be accessed from the existing logging road near the Swan Lake transmission line near White River travels south towards the lower lake. The transmission line will be buried from the powerhouse to the existing logging road and then continue as an overhead line to the Swan Lake transmission line. 4 Jack Snyder summarized how the proposed project would operate and the construction methods proposed. Jack Snyder explained that most of the project would be underground. An upper horizontal tunnel would be located about 80 ft. below the lake surface (lake tap) of Upper Mahoney Lake and would convey water 1,400 ft. to a vertical shaft. The water would drop 1,200 ft. and continue to a lower 3,500 ft. horizontal tunnel which would run to the powerhouse. The powerhouse location was chosen because of the impassable barrier to upstream migration of fish. Jack explained the normal operation of controlling the upper lake like a storage reservoir without the need to construct a dam. A videotape of aerial footage for the project area was shown which Jack Snyder narrated. Steve Brockman asked if there was a layout of construction camp facilities or staging area. Jack Snyder explained that construction proposed for this project is not labor-intensive. The tunnel operation would typically. take 3-4 people to do the tunneling operation and maybe another 2-3 people involved in the excavation of the tunnel spoils. A total crew would be 6-8 people during construction of the main tunnel. The raised bore section needs a 2-man crew to run the drill rig above and another 2-man crew will excavate the spoils as it falls from above. That phase of construction would require a 4-man crew. Not a lot of construction personnel at the site during this part of construction. Jack Snyder showed the powerhouse site plan where the staging area is planned. This is where the contractor would place his job trailer and stockpile rebar and various construction materials. It is not anticipated that the construction crew would live at the site. With the access road, they could commute to the job site from Ketchikan. A small staging area would also be at the top of the vertical shaft where they would level off a pad to set up the drill rig. Jack pointed out anticipated spoils areas which would include 3,000 yards of shotrock and above approx. 1,200 yards of shotrock from the upper excavation. These areas’ will be identified in the erosion and sediment control plan. rm Mark Dalton described the resource issues that have been raised to date in that the project has been studied since the 1970’s. The scoping document appendices include the study plans that were proposed last year and a brief summary of where the study plans are to date. Land disturbance issues - The applicant will prepare an Erosion and Sediment Control Plan as an appendix to the EA. In addition, a NPDES stormwater pollution prevention plan will be prepared. Botanical issues - Concern about USFS-designated sensitive plant species as well as threatened and endangered species that could be impacted. To date no threatened or endangered species have been identified. However, in consultation with USFS in Ketchikan and Mary Stensvold in the Sitka office, a survey was conducted last September of most of the project area starting with the terminus of the existing logging road, coming around to the powerhouse site and some work around the upper lake to try and characterize the plants that occur up there. That survey was conducted by HDR staff and Alaska Natural Heritage Program. A copy of that has been provided to the USFS (Mary Stensvold). A copy will also be given to Teresa Trulock at the end of the meeting. As a result of that work, a biological evaluation (BE) will be prepared. The USFS uses this as a management tool to assess what kind of impacts there might be to the sensitive plant species and whether or not management measures are appropriate to offset impacts. This will also be included as a technical appendix to the EA. This is a requirement > generated out of the need for a Special Use Permit because the project occupies USFS lands. The BE will be signed off by a USFS representative. Terrestrial resource issues that have been raised - What impacts construction of the project will have on species in the area, in particular, a population of mountain goats that were relocated by ADFG in 1991. Loss of habitat (wetlands) due to construction of the project. Identification of where wetlands are and relocate project features around wetlands where practical, primarily the access road. The overhead transmission line will utilize raptor-proof design to protect raptors and other birds from electrocution. To date, no threatened or endangered species have been identified. Field surveys occurred several times during the summer of 1994 which included a field assessment of wetlands and other habitats in the area, including a ground survey for nesting raptors (goshawks) in the project area. In addition, cooperatively with the U.S. Fish and Wildlife Service (USFWS) a bald eagle nest survey was conducted in June 1994. A wetlands functional assessment will be prepared and a wildlife species biological evaluation will be prepared in consultation with the USFS. Other issues include aesthetic resources - what impacts the project will have on the visual quality of the area. What impacts to potential recreation opportunities might occur as a result of construction and operation of the project. Socioeconomic issues-what can we anticipate happening to the local economy as a result of construction and operation of the project. Consultations are being held with the State Historic Preservation Office about any concerns of how project construction and operation will affect historical or archaeological resources in the area. Aquatic resource issues - impacts to fish in Mahoney Lake system, and Lower Mahoney Creek, spawning of sockeye salmon, temperature in gravels. At certain times of the year, Lower Mahoney Creek becomes impassable to certain species of salmon. The outlet of Upper Mahoney Creek where the delta is located has been identified as a spawning area for sockeye salmon. The concern is impacts to spawning habitat as well as maintaining the viability of that habitat for overwintering eggs and hatching in the spring. As a result, water quality data has been obtained. In the Upper Mahoney Lake, a temperature probe was placed at the proposed lake tap location and is continuously monitoring at depths of 20 ft. increments from surface to 100 ft to model water column temperatures. Because there has been so much snow at Upper Mahoney Lake, we have been unable to locate the temperature monitoring device for the last few months, even using a metal detector. At the tailrace, stream flow, water quality, and temperature data have been recorded. Two temperature probes were placed in Lower Mahoney Lake and an animal chewed on one of the cables. Some data were lost, but redundant recorders made sure we have sufficient data. The collection of data will continue through May 1995. John Morsell described the three field trips that occurred in 1994. The first visit was in mid-June and the intent was to get an idea of the resident fish living in Lower Mahoney Lake/Lower Mahoney Creek, South Creek which is a tributary to Lower Mahoney Lake, and the portion of Upper Mahoney Creek from the falls down to the lake. A variety of sampling and observational 6 techniques were used to get the information needed. A second field trip was made in late August which was timed to coincide with the maximum number of salmon in Lower Mahoney Creek and to get some observations of how many of those salmon were making into the lake and possibly to do some mapping of spawning areas in the lake. At that time, most of the sockeye salmon were stranded in Lower Mahoney Creek. A third field trip was scheduled for the third week of September. Following some heavy rains, the stream flows were substantially higher and most of the sockeye that were.in the lower creek had made it into the lake. John was successfully able to map the spawning areas in the lake. The field studies are essentially completed. The data analysis is mostly complete. The technical report will be included with the EA. The fish data will be integrated with the temperature data during preparation of the EA to try and attempt to model intergravel temperature post-project to predict what the impacts might be on salmon egg incubation. Vicki Davis asked about the studies for the USFS and if studies would be conducted for USFWS candidate species. Mark Dalton responded that no, usually there is an overlap of USFWS and USFS designated species. Vicki Davis asked if there were plants that may not overlap, if those were looked at too. Mark Dalton said he would have to review that again. Vicki Davis asked about surveying species other than those listed. Mark Dalton said he looked for sign or use, such as for goshawks. Vicki Davis asked Mark Dalton if he intends to look at candidate species. Mark responded no, not at this time. v Mike Stimac asked if there were any other questions on anything covered so far, such as project design and operation, the licensing process, environmental studies or issues to be addressed. Jack Gustafson said that it was mentioned about fish migrating up from saltwater may encounter a barrier or partial barrier at certain stream flows, so that raises the question as to what the effect of discharge is from the hydroelectric project would be during those months that fish are migrating in the stream. That is something that should be looked at in more detail to actually quantify at what flow conditions fish passage is available under natural flows and try to enhance or replicate those flows during times when fish migrate so that it doesn’t create a more severe barrier. It needs additional work. Jack Snyder responded that the applicant hasn’t provided hydraulic data to the agencies to see how the operations will work. When the agencies receive that data, it will shed some light on that issue. The total drainage area for the lower lake outlet is 5 sq. miles. The upper lake drainage is 2.1 sq. miles so that equates to roughly 40% of what is going out the lower lake. The other 60% is from drainages downstream of the diversion area. If the project shuts down, the inflow will be reduced by 40%, a lot of other water is still coming into the lake. Jack Gustafson would like to know at what flows that threshold is reached where fish passage is available. Knowing that, there may not be a problem because under natural conditions, it is a problem sometimes. Only the Olympic swimmers make it up through that barrier. Jack Snyder 7 stated that we have an idea of where that threshold is. Some fish were getting through at low flows. Mark Dalton added that the sockeye were moving through the barrier. It was the pink salmon not making it. More field work is not anticipated at this time. Once you analyze the hydraulic information, it will give you a better idea. Nan Allen stated that under the aquatic section where it is asterisked for cumulative effects analysis as well as site-specific analysis. Those issues listed under the aquatic resources section look to be project effects as opposed to cumulative effects. I suggest moving those cumulative effects from aquatic resources into the recreational section and dropping the asterisks in the aquatics sections. Mike Stimac lead the discussion of agency/public comments on the project. Steve Brockman and Vicki Davis from USFWS had indicated on the sign-in sheet as wanting to make public testimony. Vicki Davis stated that as far as her comments, they have been addressed. Steve Brockman stated that he will save his comments for a letter. Mike Stimac asked if there was anything in particular he was concerned about. Steve Brockman asked for clarification if there were no fish in the upper lake. John Morsell responded that appears to be the case. Steve Brockman asked if that had been looked at. John Morsell stated that it was studied in the early 1980’s. Grayling had been stocked in the upper lake many years ago and follow-up showed the fish had disappeared. The last nos was that there was no fish up there. Steve Brockman asked if the shoreline around the upper lake went straight down all the way around. Jack Snyder replied that there was a slide down at the far end where it is a little shallower but overall, it is very steep with little habitat and a very sterile environment. Steve Brockman asked about the effect of using the project tunnels to dewatering the upper creek, will it be diminished or dried up. Jack Snyder stated that flows in the upper creek would be diminished when the lake level drops below the outlet elevation. There is roughly a mile and a half of drainage area that feeds.that section where springs, small tributaries coming down so there will be some inflow from drainage down to the lower lake. Steve Brockman asked if the lake level would be dropped by 75 ft. Jack Snyder stated that yes, the lake level will fluctuate from where it is full down to the lake tap. Steve Brockman stated that there will probably be a 80-90% depletion from the creek. Jack Snyder said that probably will be the case but it will vary seasonally. On the outflow of water from the tunnel, Steve Brockman wanted to know where is that in relation to where the creek currently is. Jack Snyder described how the creek comes out of the upper lake, goes through a little valley, turns and drops about 1,200 ft. down the waterfall, and at the bottom, there is one last waterfall and a pool, and the creek flows about 800 ft. through the woods in a braided channel into the lake. The powerhouse would be situated at the base of 8 that last waterfall. The water would be returned into that pool. There will be no loss of habitat in the lower creek from the falls down to the lake. In previous proposed arrangements for Mahoney Lake, the powerhouse was not situated there and would have caused the creek to be dried up in that section between the falls and the powerhouse. Steve Brockman asked about the spawning area near South Creek if there was an alluvial formation and if spawning habitat was potential or actual. John Morsell confirmed that there is currently spawning activities there, approximately 25% of the fish spawn there and the other 75% spawn at the delta from Upper Mahoney Creek. Steve Brockman asked how the access road will cross Lower Mahoney Creek and South Creek, if by free-span bridges or culverts. Jack Snyder replied that it would be free-span bridges. Steve Brockman stated that the timing of construction should be planned to be appropriate. Doug Campbell stated that this has been looked at closely in the field. Steve Brockman stated that when the snow is gone from Upper Mahoney Lake, he would like an opportunity to go up there. Jack Snyder said that he should coordinate with Doug Campbell. They will be going up in June to remove the temperature probe as soon as the ice is gone. Mark Dalton asked John Morsell if there were any fish in the 800 ft. stretch of Upper Mahoney Creek from the powerhouse location to the lower lake. John Morsell replied that he saw a few Dolly Varden. He stated that there are three log jams in this area and the creek dries up in low flows, so there are no fish in the middle section and some fish at the end. He stated it is poor fish habitat. ; 1 Mike Stimac asked if anyone had any more comments. Jack Gustafson asked if there were any steelhead in the system. John Morsell said he saw one juvenile rainbow trout/steelhead in the lake. Therefore, they must spawn in the lake. Steve Brockman stated that steelhead are as strong a swimmer as sockeye so it is possible to get past the barrier. John Morsell said that if steelhead are present, it-is a small population. Vince Yearick stated that regarding cumulative effects of recreation/land use, if there was anything else going on between Upper and Lower Mahoney lakes such as logging activity and road construction. He wanted to know if there was much recreation utilization of the area. Based on the geographical scope of SD1, there may be no cumulative impacts on recreation/land use, but there might be if scope is expanded. Teresa Trulock stated there was some recreation that occurs near the project site. Jack Snyder asked Doug Campbell to explain how access to the site is managed. Doug Campbell stated that road access is limited to individuals. Access is mainly from saltwater, beaching the boat and hiking up the lower creek to the lake. Steve Brockman asked if the road will be gated. Doug Campbell said that it already is. Steve Brockman asked if it was on the Ward Lake Road. Doug Campbell confirmed that it was and said the gate is located approximately 7-8 miles from the end of the access road. Steve Brockman asked if people fish the White River. Doug Campbell said yes. Most of the recreation could be considered dispersed and is very minimal. Someone asked if the land would be opened up for recreation. Doug Campbell said it would not be encouraged because it is considered a liability to the Cape Fox Corporation. Craig Moore asked about FERC’s regulations on recreation. Vince Yearick said those regulations could be found in 18 CFR 2.7. Steve Brockman asked when does the lower creek dry up, if it was in late summer. John Morsell replied yes. Jack Snyder said actually it infiltrates into the ground. Steve Brockman asked if this was constant. Jack Snyder said it gets lower in the summer. Vicki Davis asked if the upper creek dries up. Jack Snyder replied that it was the section from the last waterfall to the lake that the water infiltrates the alluvial materials. Vicki Davis asked if more water would be added to the system. Jack Snyder replied that new water could not be created but depending on the time of the year it would be above/below/at the baseline. Steve Brockman said that flows will be more uniform. Jack Snyder stated that generally that is true. Doug Campbell asked Jack Snyder to review the history of the hydraulic data. Jack Snyder stated that a gage had been at the lower creek for 12 years. A gage was located at the outlet of the upper lake for 6-7 years. So the gage data provides more precise data versus simulating data from another gaged creek nearby. 4 Steve Brockman wanted to know the nature of the blockage on the lower creek. John Morsell stated that there are steep cascades, boulders, lined by rock walls and is gorge-like. The water is fast and turbulent at high flows. The worst blockage is about 100 ft. downstream from the lake outlet. Steve Brockman asked if there was room for improvement in the creek for fish passage as part of mitigation. Jack Snyder stated that you have to be careful because if you make it too easy, pink salmon will get into the lake. Pink salmon get into the lower creek, but they can’t get up to the lake. It adds a variable. Steve Brockman wanted to know about the effect of the drainage rate and lake elevation levels. Jack Snyder stated we don’t want to fool with the lake elevation. The project will stabilize the flows, the flows will be more consistent. Forty percent of the flow leaving the lower lake will be project related but the other 60% will be unaffected. The average will be taken for net flows. Jack Gustafson asked about supplementing flows during low flow times. Jack Snyder stated that since only 40% of lower lake outlet flows were project-related, supplementing flows should not be necessary. High rain fall events will continue to control lower lake outlet flows as is the case now. 10 Vicki Davis wanted to know what would happen in the event of a dry year, would contingencies be made to make water available. Jack Snyder stated that the applicant would have to make do with what is available. During a low water year, it usually shows its effects in fall/winter. The project would operate for a shorter period of time or at lower loads. Jack Gustafson asked if the drawdown would occur all the way to the lake tap. Jack Snyder said the lake would be drawn down to just above the lake tap because it would be undesirable to draw air into the pipe. At that point, it becomes a run-of-river project. When the lake starts to rise from increasing inflows, the project could increase its output. . Doug Campbell thanked everyone for attending. He encouraged attendees to contact team members if there any further questions or concerns. Jack Snyder reminded attendees that written comments are due by May 15, 1995. The meeting adjourned at 10:50 am. 11 KETCHIKAN PUBLIC UTILITIES KETCHIKAN, ALASKA 99901 TELEPHONE 907-225-1000 FAX 907-225-1888 2930 TONGASS AVENUE April vo 1995 ce: _ Four Dam Pool Members Mayor and City Council of Wrangell Clay Keene, Attorney at Law MUNICIPALLY OWNED Ron Saxton, Attorney at Law ELECTRIC TELEPHONE WATER Senator Robin Taylor Representative Bill Williams Return Receipt Requested Mr. Michael V. Stimac Manager, Licensing & Environmental Services HDR Engineering, Inc. 500 - 108th Avenue NE, Suite 1200 Bellevue, WA 98004 Subject: MAHONEY LAKE HYDROELECTRIC PROJECT (FERC No. 11393) Dear Mr. Stimac: Please accept this as our comment of record for the Mahoney Lake Environmental Assessment. As an Intervener in this project, and the only utility with a Certificate of Need and Necessity to provide power to this community, we have very a strong interest and concerns in the proposal to add the Mahoney Lake project to our power system. Therefore we ask that you very carefully consider our comments and concerns regarding this project and its impact to this power system. If the Mahoney Lake project were the cost effective and reliable solution to our power needs, we would to welcome it. However, our previous studies and the study recently done by HDR lead us to the conclusion that the Mahoney Lake project simply will not meet Ketchikan’s needs at this time. For that reason, the Ketchikan City Council asked last year that the City of Saxman defer development of the Mahoney Lake Project since we are committed to developing another power resource (see attached). On the surface, one might think that the 42,000 MWH maximum potential offered by Mahoney would be a valuable resource during our critical periods. If, however, you refer to tables 2 and 3 in your scoping document, you will see that we wouid still have been running our diesels over the past few months even if Mahoney were on line today! We recognize that these tables only reflect one operating scenario, but the fact remains that the project proposed has very limited storage and would be of little value during our critical low water, high demand months. Mahoney Lake is in the same vicinity as our other local hydroelectric projects. It stands to reason that if Ketchikan Lakes and Upper and Lower Silvis are critically low during the first part of the year, then so will Upper Mahoney Lake which is only a couple of miles north of Silvis. The Mahoney project does not offer power, when we need it most. In order for the Mahoney project to be financially feasible, it needs to be operated when water is available. Since the project as presently planned has little storage H:\USER\NANCYL\WP\DATA\007-A6.COR Mr. Michael V. Stimac April 12, 1995 Page 2 capacity, the only way to achieve financial feasibility would require KPU to curtail its lower cost embedded hydro facilities to use the Mahoney hydro power during certain periods of the year. Since the Mahoney drainage is in the same weather pattern as KPU’s current hydros, we may be at a spill condition at the same time Mahoney would be. Our major hydro resource (Swan Lake) has contract provisions which do not allow injection of new. resources at any time power is available from the Swan Lake facility. The scoping for this project appears to be premature. It would seem that FERC would expect there to be at least tentative terms negotiated for the sale of power to be produced by the project before proceeding with scoping. The only discussion held to date with KPU on the issue of rates was in April, 1994 where we were asked to consider terms that would favor the purchase of Mahoney Lake power over our other resources. While this may be the only way to make the project economically feasible, we are not willing to sign a “take or pay” contract or otherwise accept preferential use of Mahoney Lake power, because we do not accept the proposed operating scenarios, nor has the cost been established. Approximately one half of our hydroelectric power comes from hydroelectric resources owned by KPU. Because these facilities were built many years ago, our embedded costs allow these hydros to produce very inexpensive power for our community, as low as one or two cents per KWH. Power purchased from the Mahoney Lake project may cost us many times that amount. Considering the difference in cost, it would be most imprudent for us to purchase power from Mahoney in lieu of producing power from our own resources preferentially. The other half of our hydroelectric power comes from Swan Lake. This is power we are contractually obligated to purchase second to our own hydroelectric resources. Once Swan Lake has been essentially exhausted, we are free to use our diesel power or purchase other power. This means that if Mahoney were on line, our existing contract requires that we exhaust Swan Lake before purchasing Mahoney Lake power. Considering the current wholesale power rate of 6.6 cents per KWH, it appears likely that economics alone would dictate that KPU purchase Swan Lake power before Mahoney. The economic feasibility of the Mahoney Lake project appears to be based on the preferential use of Mahoney Lake power by KPU, which is simply not an acceptable option for the ratepayers of KPU who would be forced to pay extraordinary amounts for the use of Mahoney Lake power over the cost of operating KPU’s own hydros. Since April of 1994, there have been no further negotiations with KPU to establish the terms of a more acceptable power sales agreement or even define the avoided power cost. Further, there have been no discussions regarding other significant economic issues such as overall management of the project, operation and maintenance and H:\USER\NANCYL\WP\DATA\007-A6.COR Mr. Michael V. Stimac April 12, 1995 Page 3 potential wheeling of power to Metlakatla. Since even tentative terms for the purchase of power have not been established, there can be no meaningful investigation of the economic viability of this project. Under the only terms proposed thus far for purchased power, the Mahoney Lake project does not appear to be cost effective by any means, at least for the Ketchikan area ratepayers. KPU has investigated this project three times over 20 years and on each occasion opted for more economically feasible projects. Further, we are concerned about relying ona future power resource from an agency that has not been in the power business, nor has any operating expertise. We are concerned with the ability of a small community of 400 people to secure funding for a $25-40 million power plant. Finally, we have technical concerns regarding the design of the project. For the project to be a meaningful addition to the Ketchikan area power system, it should include a dam for additional storage. A dam might allow the additional storage we would need to have a truly flexible power resource. With additional storage, we could dispatch our resources so that we can have more power “in the bank” when we need it. As it is, Mahoney appears viable only if we use the water when it is raining the most (and immediately available to us). Unfortunately, that is when we need it the least. As it is, Mahoney is essentially a run-of-river project. Further, the interconnection of the Mahoney Lake transmission line to the Ketchikan system should be moved to Beaver Fails. This would significantly enhance our system reliability. During a system failure, the Ketchikan Substation North breaker must often open. If the Beaver Falls and Upper Silvis powerhouses could support the load from the Ketchikan Substation, we would often be able to keep downtown Ketchikan in service. Unfortunately, the load is too great for them to serve so the downtown area suffers blackout. If another resource were added to the south end of our system, we could often keep our center of population in servicé even if Swan Lake or Bailey tripped off line. In addition to losing some system reliability, tying in Mahoney at the Swan Lake transmission line adds another layer of vulnerability to that resource. Specifically, if Swan Lake trips off line, Mahoney would also. Having Mahoney interconnected at Beaver Falls would be a vital component of our ability to successfully use it as a resource. There is another compelling reason for tying in Mahoney at Beaver Falls rather than the Swan Lake transmission line. The community of Metlakatla has identified a need for additional hydroelectric power. With the City of Saxman and Cape Fox seeking a market for Mahoney Lake power, there seems to be good potential to negotiate the terms of a power sale to Metlakatla with KPU wheeling the power from Beaver Fails to Mountain Point. Wheeling the power this shorter distance would be more efficient than bringing it through the Swan Lake transmission line. For reasons noted above it would also be more reliable. The economic analysis of this project would be H:\USER\NANCYL\WP\DATA\007-A6.COR Mr. Michael V. Stimac April 12, 1995 Page 4 incomplete without pursuing the market potential of Mahoney Lake power in Metlakatla. We remain supportive of the economic development efforts of the City of Saxman. At some point, the Mahoney Lake project may well offer a valuable source of power for an interconnected Southern Southeast Alaska, as well as a source of revenue for the City of Saxman. In the near term however, the Mahoney Lake project does not meet the electrical needs of the Ketchikan area when considering economic feasibility. That’s why we never built the project ourselves. Further, it is even less economically feasible when you add an anticipated mark-up for the power for the benefit of the City of Saxman, who would obviously expect a return on their investment, if they use their own funds. These issues should be addressed before a permit for the Mahoney Lakes Hydroelectric Project is issued. Sincerely, KETCHIKAN PUBLIC UTILITIES ZZ fea Thomas W. Stevenson General Manager TWS:nil Attachment cm Ketchikan City Council KPU Advisory Board Doug Campbell, Cape Fox Corp. Forrest DeWitt, Mayor, City of Saxman Jim Scudero, Mayor of Metlakatla Jim Deherrera, Ketchikan District Ranger, USFS Vince Yearick, Office of Hydropower Licensing, FERC H:\USER\NANCYL\WP\DATA\007-A6.COR ~ aa 3 3+ : ‘ ari ne wit> of ssrorwcr, As Qe on i eiciiinan July 28, 1934 ae Mr. Forrest DeWitt, Mayor City of Saxmen Saxman City Hail Saxman, Alaska SSS01 Dear Mayor DeWitt: The City Council of the City of Ketchikan has asked me ‘o write to you regarding the Mahoney Lake Hydroelectric project thet you are currently reviewing ior possible deveicoment. The City Council recently came to the City of Saxman ‘o Ce oriefed by your consuitants and Cape Fox staif and we appreciate very much vour sharing the gcais you have jor deveicoment of the Mahoney Lake Project. Aiter discussion and review of the etfeczs of the Mahoney Lake Project cn the develcoment of the Intertie Projecz, it is clear that we cannot proceed with the Intertie if the Mahoney Lake Project is buiit irs. That means the long range planning ‘cr the Intertie will have been last and we will have to refund monies spent to date that have been acvanced on the Intertie. The community wiil lose this $60 miilion dollar grant. Through the joint efforts of the City of Saxman, the City of Ketchikan and the Ketchikan Gateway Borough, the Legisiative Liaison nas been successiui in promoting and in obtaining the initial funding for this project wnich has been a priority project for our wnole area for many years. From a oresentation (which is attached) irom Ketchikan Public Utilities, it is clear that the timing of your project wiil create the termination of the Swan Lake and Tyee Lake Intertie. The City Council has asked that the City of Saxman delay development of the Mahoney Lake Project so that it will come on line after the Intertie Project comes on line. The City Caunci is in a position such that it cannot endorse or enter into negotiations with the City of Saxman for the Mahoney Lake Project because if your project comes on line pricr to the Imtertie Project, the Intertie Project wiil be lost forever with the funding source as legisiated througn Senate 8ill 106/125, Eighteenth Lecisiature-First Session. Therefore, entering into a purchase power agreement on Mahoney wiil effectively terminate the orojec: the community has said for many yeers is its geal—to ouiid the Intertie. The Councii and | sincerely appreciate the fact that the Mahoney Lake Project is an imccrant econcmic development project for the City of Saxman. We succort you in that regard. Unfortunately, the timing of the projec: places us in the uncomicrabie positicn of 007-F3.1 Mr. Forrest DeWitt Juty 28, 1994 Page 2 killing a project we need as a utility in order to best provide a long term power source for ail our customers and which we promoted and obtained funding for through the State. Mayor, this is obviously a very important issue to ail parties and if you feel you cannat celay the Mahoney lake Project, let's get together and discuss where we go from here. Sincerely, Alaire Stanton, Mayor City of Ketchikan Attachments on Ketchikan City Councidmembers KPU Generali Manager 007-F3.2 oO July 21, i c Sa MEMORANDUM TO : Mayer Alaire Stanton and City Councii FROM : Thomas W. Stevenson, KPU General Menangle / — SUBJECT: ECONOMICS OF THE PROPOSED SWAN/TYES INTSRTIE AND THE iMPACT OF THE PSQPOSED MAHCNEY LAKE SYDROELSCTRIC FACILITY CF THE CITY OF SAXMAN/CAPS FOX CORPORATION nave indicated to the Ccouncii that the imcact cf the Mehcney L2ke orciect causes séricus orobiems icr the long rence clenning thet the Utiity hac ccne in ‘ts cuest to ectain the financing and uitimate constuczicn of the Swen/Tyee Interde. Sriefly, the Utility nas pursued the ccnsuccicn of the Swen/Tyee Imterte icr cver $ years. For the pericd since 1SS0 wnen | came ‘o the Utiiity, and in fect, during the interviewing creesss, it wes mentioned to me that te mest imocramt !ong rence 2civity that the cmmunity wanted wes ‘o Nave its !cng ‘erm ocwer source in oiacs via this interde. The last four years we have had the Swen/Tyee intertie és the ico -scioneal cricrity for Southeast Alaska....Slecriecimtertie and Read Carmdor. Svery legisietcr that has served this area since 1SS0 has mace this Interte 2 cnemty. The community lecisiative liaiscn has ned us make presentations io obtain the juncing ior this srcjecz. The Utility could nave oulit he Mancney Leke Project. It wes last excicred in the mid 1$80’s and has nad no less than three erctessional reviews jor ieesittiity. The Swan L2ke/Lake Tyee Intertie facility was chosen itr the foilowing reasons: te It provides us with an ecaitiona! 80,CC0,CO0 kWH's of electricity. (We wiil use about 163,000,000 kWH's in 1994). 2. It will maintain or reduce the cost of energy irom our Oarticipaticn in the Four Oam Pool because we can spread our overhead costs over adciticnal KWH sales since we will start using energy that is literally “water over the dam* 2t Tyee and unused at oresent. it will provide us with the ability to Tansier siecaicty back 2nd icorth oetween Petersburg, Wrangeil and Ketcnikan in emergencies. G 4, It will provide for joint dispatch and icint operations ot aur two major hydrceleczic facilities. a ‘oO It will cravide us with the access to ail additional hydroelecrc sites cCetween Ketcnikan and the end of the line at Petersdurg wnen consicsring future cower suocly sources. The Tyee Project aireacy has a third bay installed within the ocwerncuse anc it wiil onty require $3-3 miilicn to instail a generatcr cepabie of sraduc:ng oetwesn 10-15 MW’s of ceaking power. availabie to ail Southeast Alaska utilities will Ce an invaluacie ‘cel in crevicing energy options for the future with the adciticn of this intertie link. The Intertie itseif may crovide an cotion jor the Mahoney Lake croject and orcjects like it for sales opportunities to other Southeast utilities in the iuture. The Intertie provides an income sireem to pay for the Interte and therefore the cost to Ketchikan resicents is nii and the orice of the energy thet goes across the transmission line is a known quantity. (Currently, 6.6 cents cer Kwn). WHAT HAPPENS IF THE MAHONEY LAKE PROJECT ENERGY IS USED BEFORE THE INTEATIE POWER? ., ile oo The intertie will not be ouiit as the energy irom the [ntertie would not start being used by KPU ratepayers until the year 2007. A. | would not recommend to the Counci that we buiid a Tensmission line that wouid not be used for 9 years other than jor surpius sales to the cuip miil. B. We wouid not be abie to repay or justify economically a rensmissiqn line that would not be used jor 9 years. The State Legisiature will stop annual allocations towards this croject since it wiil be economicaily infeasibie to continue. We wiil lose a longer term energy source with ifs oulit in cperational Oenents (inclucing the fact that the State has aporoved the funcing sources for the Intertie through its legisiature), for a short term ix that provices none of the operational options. We subsiitute a project that wiil interconnect hydro sites that have different cimates for projects that lie in the same hycro area. i.e. wnen we are in crought in cur own hydros, Mahoney wiil be in drought aiso. This past year wnen we were running our dieseis due ‘to insufficient raintail, Tyee was in a spiil condition. Therefore, we wiil lose some of that soiil in climates to balance our resource nescs. Memorandum - Mayor and Cty Counc Juty 21, 1994 Page $ 3. To do otherwise will mean the eccncmic jeesidility and enc to the Swen/Tyee Intertie. DOES THE MANAGEMENT OF KPU SUPPORT THE ODEVELCPMENT OF THE MAHONEY LAKE PROJECT? 1 Yes, with the concerns accressed 2Ocve cut of he way. Yes, T we can 2cree to have the ccwer erter into she XFU system on our 34.5 kV transmissicn ‘ine. 19 if we can Se 2 camner in essunng that the quality conte! anc ne constuczcn will crovice icr ccerating efiiciency 4nd keeo crereticns anc Maintenances to a minimum. ro) 4. We can 2cree ‘Oo maximizes the cutout with the cost of the ‘facility. WHY DIDN’T KPYU SUILD MAHONEY LAKE AFTER STUDYING IT THREES DIFFERENT TIMES? 1. The ijirst ime we dicn’t culid t wes Secause we ccted to Oulid Swan Lake. 2s The seccnd ime we cicn’t culid it wes cecausé we wamted ‘Oo optimize our Particication in the Four Dam Feci 2nd cuiid the interte. WHY ISN’T USE OF MAHONEY LAKE POWER CHEAPER THAN RUNNING THE BAILEY DIESELS? 1. It isn’t Cecause the avoided cost cf running Séiiey is simnty the cost of ‘uel and the wear on the generators. All other costs are aireacy Ceing incurred at the cresent time. as if we leave the Gailey generators dawn, and use Mahoney Power, we suill incur ail arent costs of running Saiiey, so we pay wnat ever the cost 's determined to be and mayce that cost is established at a level higner then our cual avoided costs. WHAT OTHER CONCERNS DOES THE MANAGEMENT OF KPU HAVE ABOUT THE MAHONEY LAKE PROJECT? ile That it is being constucted outsice the score and controi ot the Utility which wiil have to rely on its cutout yet we Nave no Management cversi¢nt or comme! on how it gets conswucczed or where it enters imto cur system fcr he Dest use or the Utility. Memorandum - Mayor and City Councd Juty 21, 1994 Page 6 2 TWS: nil That KPU is 4 not 4 for-oromt municicaily owned utility that cetermined that the Mahoney Lake orojec: was not ihe orcijec: it ‘eit was in the Cest interest ct the ratepayers and the community it serves inciucing the City of Saxman, at 2 orice less than we would now expect the sroject wil cost us CY accing cromts to the City ot Saxman and Cape Fox Corperation. Attacnments 7 ai C ( Memcrandum - Mayor and City Counc Juty 21, 1994 Page 3 We wiil suOsatute the Four Oam ®coi rate of snergy icr 3 nigher Mancney Lake cower rate. We have concems 2s to whether the Méencney Leke =rciject will consistentty erecucs up io + MW's ct jirm cower, uncer ite scenaric srcccsec. And we are Cesircus cf having she snercy come inte the KFU system Sy imterccnnecing with cur 34.5 «V Tansmissicn line ‘0 crevices icr saietv in cesé scmetming Neccens io the 11S kV Swen ske Tansmissicn ine. (An cctcn we 2re Tying ‘o inccrcorate into the Swan/Tyes interie.) o We wiil Ics 2il surtius cower saies veiiadie <o use frcucn cur agreement with the Four Cam Pcci. = CAN THE INTERTIE AND THE MAHONEY LAKE PROJECT 8& BUILT SiMULTANEDUSLY? 1. Yes. Sut either will be cost effective and neither -miil crovice 2 return on the invesument ‘Oo che Suiicers cf she crcjeccs. So wniie the answer is yes the reaiity is that they wiil nct ce ouiit simuitenecusiy. HOW SHOULD THE Two PROJECTS 3& 3UlLT? te From the srcscecive of the community and its subiicy owned utlity, we nave determined ircugh our long range sianning ‘% orccsed with Ne intertie sroject because cf its crerational jexibility and its greater KWH availability and because of the favcrebie cost consiceraticns througn use of Siete iuncing that we ere unlikely to ever recsive again itr this ercjece. As the communities stated goai of oeing the numter cne regicnai cricrty ‘cr the lest several years (@ memter ct that team was Mayor CeWitt) we olacsd it on our lecisiative ononity list as something we wanted 4s a community. S) From the crospecive of the City of Saxman and Care Fox, it crovices an economic deveicoment opecrunity wich will orcvide 2 xeacy and permanent income seam if: A. They 2re able to obtain a sermanert sales eqreement with KPU for 2 set orice jor purchase ct the cower. 8. A somewhat higher risk invoives selling the power to us under PURPA (Pubiic Utility Reguiatcry Policies Act cf 1878) wnicn mandates thet KPU ourchase the power at the avoiced cost of the next source of siecaical generaticn we wouid use if the Mahoney L2ke orcjecz were net avaiianie. co7--3.3 Memorandum - Mayor and Cty Counc duly 21, 1994 Page 4 C. This means that Manoney wauid suppiant, at sresent, the cower we generate cut of our Baiiey Diese! Generators if they cen get the ‘ectity oulit before the Intertie is ouiit. (That avoiced cost would have to Se determined). 1). if the intertie lenquace requires us io purchase ‘he cower Tom the Interte regarcless, then the avoiced cost would Se whatever the prevailing Four Oam #coi: cost wouic Oe. if the Imterte is constucted jirst, then the avciced casi is the Four Dam Pool orevailing cost. ho Soe SO WHAT DO WE DO? + I ao ’ if the City Council agrees to enter into 2 long term cower sales ecreememt with the City of Saxman jor power out ct Mahoney Lake, you are sifectively «iiling the Intertie project. if the City of Saxman builds the Mehcney Leke croject before we nave the Intertie built, we are killing the Interte projecz lf we don’t crovice a guarantee cf energy at 2 set crics to the City of Saxman, it may make their project more difficuit to develop. Since Saxman participated in the Legisiative Liaiscn with the other governments cn this lsiand, and since the Mahoney L2ke project was not one of those projects, it would seem that in the interests of working together ior the iuture of the Isiand, they weuid agree to delay the development of Manoney L2kes to be the “next" generating source to come on line for the community aiter the Intertie wnich they helped to promote. It is clear that one cr both of these orojects will fail if we ty to bulid them concurrently, so we should stick to our original plans. To do otherwise is gaing to create havec, hard feelings and the loss of economic opportunities for ail, fF not in the short run, but then in the future. SHOULD THE COUNCIL ENDORSE THE MAHONEY LAKE PROJECT? 4 1 nN ' Yes, crovided that it is agreed that it will come on line ater the Interte is constructed. Otherwise, we snouid resceccuily dectine to emter into any comrac: with Saxman for Mahoney Lake power, AND, Yes, once the City of Saxman’s financial parmer, the Cape Fox Carperaticn and KPU have settled the Seaver Fails lend disoute. yore et ts. Tp en tt or Uy tt ey on ou ' a mn ty 1 Om La) —focd.- tayo Tce ty are) Coe sx of Cs on wat wy en ey wee ey erp ten cet can) ” La ") 0 ” a ™ ( on moe) my a) ay ") aa) on ' ta] W) t y m4) nm oy yy “ny 1) "“) o w ") an te ol Mm tao cy tp ore eyo ry det eve al qe a GE of cud ehed al Coy CD cic a chores a a7 Te i a Yep od rire oboe now at / 7 ft Ute Gb oad , . (—0— 9, f-s (= \ ; W 7] tl wy mr UW ct . ml! ny} an Vv u . : . an . . Ne , t~ t- it Vey ted uw) tee tee fof wy om 1 ) wu 7 a Ste s | Cp ort uw Wore xe te fo tor bs. w toed es my eryoey oie w ' uy w i i. tobe wo) anc lee ‘) wwuw e- V S GIG Gh tao " at : chebet tot )) Lay) WO Or wn ey OD UN) tO MOE h Od r= 10 UP OU LY th ee OF OD cs iy u! Shon Ow 0 9) UlW & 19 0) 0 . Vote: cota Mr Ow w/w Ww oO lh - Of OF aro tet § 8 of ~ ooo 4 al al WO larg +t xt xt cy) ot +f I~ ~ ~ a upu © = - - 0) 67-6) ab ab eb ek xb at <b xt I" uy a wring gggwvVIoIg oOVoOVo UT yO”9O \\ VOW OVUUVIEVGVUIIVUIVUVGVIUIONOYVIIIODUYAE UV z ero aovwvaanoao0ggeaoaegodu ge Gg ‘ Q a -W Or vIW orOoraAaA A aA AANA aA A © Ww -t = t~ 09 ng I~ oo 80 cy oO) oy CU CU CO OD CO OF) CO OD CF O&O OU WD | iF WwW) ( WwW wo aay Ww , if ' OO MM wWwOMMeE RRR RRR RR ERR RK EK I u Ww) Woe co sf Oth tata to to ta te to to te to to to, to wo to to to vw) ZOrer tree R Ree RR RE RRR RR RK + QO FUrKAOIhA Ata tkaAtatt ata ttt At Zz OM wh w tow wow Ww Ww 1 WO tO WD WO Ww lO 00 10 W& WO 10 | ty) A a ) vu) eee maa } . y vo) ul an 1 Uv - Q VW 4 | Irae Me IH - WO Ok —eooMm Ade KR 4 ov OMaIMr~ VYVIOr OM IDM MY tg AWK Wee re Ww) ~ Z1091 EF OCD Wr b tf I9 to XO te & 9) to to fb oF oD 6)) ILYNNOMNNE MW WMA MOM OOF) WW) ALO 0 mS OF : 0. Gi aoehto td www woh mer rE & woo Ww wow YH UD? OD {J Mw Pt tt Bt tte te te at Ww n on 1 Ww 4 -G) Ly Vv QD — O10) sb too be ao ee Of Od =f ty mt co uw te w “1 Mp Momo sn oaugwaug wy S - W) > Ww UVUUUUUNUHUWAIagawowvwoudwouuod W f »- ot tte te ree ee AAA A at ataral al & al a