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HomeMy WebLinkAboutMahoney Lake Hydro Scoping 2 1995iv Ove _ fle September 27, 1995 Mr. Riley Snell Alaska Industrial Development Authority iW. Ta EGEIVE() Anchorage, AK 99503 SEP 29 1995 Subject: Mahoney Lake Hydroelectric Project FERC Project No. 11393/AK 9504-08JJ Alaska Industrial Development Scoping Document 2 and Export Authority Dear Mr. Snell: Enclosed is a copy of Scoping Document 2 (SD2) for the Mahoney Lake Hydroelectric Project. SD2 is based on Scoping Document 1 that was distributed via letter on March 9, 1995, incorporates the comments and requests for additional studies received during the NEPA scoping process, and contains copies of all consultation correspondence and responses developed in reply to concerns addressed in agency comment letters and identified at the scoping meetings held in Ketchikan on April 12 and 13, 1995. Please contact me if you have any questions regarding SD2 or the licensing process for the Mahoney Lake Hydroelectric Project. Sincerely, HDR ENGINEERING, INC. Michal V. Stic. LL Michael V. Stimac Manager, Licensing & Environmental Services Enclosure ce. Guy Galloway, City of Saxman Doug Campbell, Cape Fox Corporation Vince Yearick, FERC Jim DeHerrera, USFS John Braislin, Betts, Patterson & Mines Don Clarke, Wilkinson, Barker, Knauer & Quinn HDR Engineering, Inc. Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 x 500- 108th ee a Suite 1200 Scoping Document 2 TABLE OF CONTENTS Section Page 1.0 INTRODUCTION Mitel alla cartel | eal eel al] eda oT laMel al taal ad etal ali cy bern cal faa Vetoes 1 De ist OOP LIN Go “fife e te lets iets ae Tatts eis eed eh anna at eet sips Toco tn sate ara aT 4 20/1 DOSES: OF SCO ae ee eT ety 4 2.2 Mic SCOPIMB ACCES ote eats elerte loceer age Utell zug lade lial eae Teele Pal cai ale sta ee liaise 5 3:0 tI REQUEST: BOR INFORMATION dicot tar elie) slat ale taltetie lo felisl oltelis- ellel alla alii 6 4.0 PROPOSED ACTION AND ALTERNATIVES ................-000% 8 AoC ity. Of Saxian, s-Proposed Acton ae tete cel cietee falitts ote otietiae ise lia el alk 3 Ache ipProject DescrpiOmi: viata ie tale ile teate te oieie tics ele ieee 8 UE ZR TOIECE Ope anne eee ee ee a Me nL aaa 14 4.1.3 Proposed Protection and Mitigation ................... 18 4.2 Modifications to the City’s Proposed Project .................. 19 AD it st INORG et alle SIE UU a a le eM a a 19 5.0 SCOPE OF CUMULATIVE ANALYSIS AND RESOURCE ISSUES ....... 20 De Uses UNI ALLV © ETOCS Maia Helieke et olcot lo ier-ceel ie lletiel bee lee et stadia eel sth etre er elite Sit 20 5.1.1 Resources That Could Be Cumulatively Affected ........... 20 51:2 || Geographic: Scope fete ttt atten ere terete yeaa eet et ere foe eee ate eertba toe 20 SMS Lemporal Scope. (ici isi ect er tier UTM TS atm EI nn Sint aT 21 2 i] SOURCE ISSUES rataree stie ar etced ey el iae fe ated etal sels iets ie pestis dere aise al Ste se 21 5:21 Geology and (SOil Resources il sMau cia crm nr ean Tian ee Eg 21 2.2 AQUATIC RESOURCES fate: ei celle tic atletelei cael eet ciieiieaiietutecec aici cat 21 3.2.5) LOrneserial- ROGOUICES ster citeistttsetit teeta eectetven ere teea =e Hentai a netting 22 5.2.4 Threatened, Endangered, and Sensitive Species ............ 22 2-5) Aesthetic, Resources io) stata tciste rca tat eae tal art ba attic tai attain 22 5:2'6/ Recreation and, Land Use nea eel ella el eller eee lec ieleatte [tll 23 527 S0CLOSCOTO Nes ee ee Te ait 23 O22. Sil CUltUTAl RESOURCES Mics telsedtalctUalaa aut alta et tane at ale Me ae Ia ela sale 23 6:0 BAT PREPARATION SCHEDULER (cei. anita soe emis aise israel atl 24 7.0 DRAFT ENVIRONMENTAL ASSESSMENT (DEA) OUTLINE ......... 25 2 rR ALIN GEES Uren Tena Lee 27 Mahoney Lake Hydroelectric Project September 1995 i FERC No. 11393-000 Scoping Document 2 TABLE OF CONTENTS (Continued) Appendices A Study Plans for Additional Study Requests B Agency Correspondence GC Response to Agency Comments LIST OF FIGURES Figure Page 1 Project Location;and-Vicinity Maps (2°. - <0. <5. san 5 oe eo oi ere wie seme’ 3 2 Project Site Plan and Profile... 2.0... eee 10 3 Alternative Transmission Line Routes .... 0.0.0.0... 0 eee 15 LIST OF TABLES Table Page 1 Proposed_Principall Project. Features occ. cses se cases 0 este et ee es 11 2 Average Annual Energy Generation - Year 2000 ..................4.4. 16 5 Average Annual Energy Generation - Year 2005 and Beyond ............ 17 Mahoney Lake Hydroelectric Project FERC No. 11393-000 ii September 1995 Scoping Document 2 1.0 INTRODUCTION The Federal Energy Regulatory Commission (Commission) issued a Preliminary Permit (No. 11393-000) to the City of Saxman (City) in June 1993 to allow them to study the potential Mahoney Lake Hydroelectric Project. This permit expires in June 1996. Cape Fox Corporation, an Alaskan corporation established under the Alaska Native Claims Settlement Act as the village corporation for the Native village of Saxman, has been retained by the City as the development agent for the project. The City intends to file an application for a Major Unconstructed Project (18 Code of Federal Regulations [CFR] 4.41). The proposed Mahoney Lake Project would have an installed capacity of 9.6 megawatts (MW) and would be located on Upper Mahoney Creek, between Upper and Lower Mahoney Lakes, in southeast Alaska, approximately 5 air miles northeast of Ketchikan (see Figure 1). The project would be sited on National Forest System lands managed by the U.S. Forest Service (USFS) and lands owned by the Cape Fox Corporation. National Forest System lands impacted by the project include the area around Upper Mahoney Lake, the lake tap and upper tunnel and portions of the transmission line corridor. Two alternatives are being evaluated for routing the overhead transmission line; one to the north which would tie-in to the Swan Lake Hydroelectric Project (FERC No. 2911) transmission line near the White River (Northern Alternative) and one to the south, which would tie-in to the Beaver Falls Hydroelectric Project (FERC No. 1922) (Southern Alternative). The Northern Alternative would impact a short section of National Forest System lands along the project access road just north of Lower Mahoney Creek. The total amount of National Forest System lands impacted by project facilities including the Northern Alternative is approximately 85.6 acres. The analogous figure from the Southern Alternative is 115.1 acres. The Commission, under the authority of the Federal Power Act’ (FPA), may issue licenses for up to 50 years for the construction, operation, and maintenance of non-federal hydroelectric developments. The USFS must decide what limitations and conditions to include in a Special Use Permit if the Commission issues a license for the project. The Special Use Permit would authorize occupancy and use of National Forest System lands and would include those requirements necessary for comprehensive and compatible use of the natural resources, consistent with the purposes for which the national forests were established. Under the Commission’s regulations, issuing a license for the project first requires preparation of either an Environmental Assessment (EA) or Environmental Impact Statement (EIS), in accordance with the National Environmental Policy Act (NEPA) of 1969.* Pursuant to the ' U.S.C. Sect. 791(a)-825(r). 2 42 U.S.C. Sect. 4321 et seq. (1988) Mahoney Lake Hydroelectric Project September 1995 1 FERC No. 11393-000 Scoping Document 2 authority granted under Section 2403(b) of the Energy Policy Act of 1992°, the City, in coordination with the Commission staff and the USFS, will prepare a Draft Environmental Assessment (DEA) for the Mahoney Lake Project consistent with the requirements of NEPA and the Council on Environmental Quality’s guidelines, 40 CFR Part 1500. That document will include descriptions and evaluations of the effects of the City’s proposed action, including an assessment of the action’s cumulative effects and site-specific effects. The DEA will be submitted to the Commission, in lieu of the Environmental Report (Exhibit E), as part of the License Application. . The DEA will be circulated for review to all interested parties. The Commission staff will independently review the DEA and other application material for adequacy and will issue a staff DEA. The Commission staff will consider all comments filed on the DEA for the Final EA. The Staff will present conclusions and recommendations for the Commission to consider in reaching its final licensing decision. The USFS will use the EA to guide its decisions to issue mandatory license conditions pursuant to section 4(e) of the FPA and to issue a special use authorization under the Federal Land Policy and Management Act. 3 Pub.L. No. 102-486 Mahoney Lake Hydroelectric Project FERC No. 11393-000 2 September 1995 ARCTIC OCEAN UK x i yf REVILLAGIGEDO REVILLAGIGEDO LAY ISLAND : i o & LAKE PERSERVERANCE a KETCHIKAN oS LOWER SiLMS LAKE a a e % LOWER UPPER SILMS 3 ey KETCHIK / LAKE ! v aN o ee PACIFIC OCEAN % S p LOCATION MAP GRAVINA ISLAND aie “REVILLAGIGEDOCHANNEL MICINITY_MAP CITY OF SAXMAN, ALASKA APPLICATION FOR LICENSE | ——— fa MAHONEY LAKE HYDROELECTRIC PROJECT SCALE IN MILES FERC PROJECT NO. 11393 PROJECT LOCATION AND VICINITY MAPS Figure 1 HDR _ Engineering, Inc. Scoping Document 2 2.0 SCOPING Scoping is the process used to identify issues, concerns, and opportunities associated with a proposed action; the process, according to NEPA, should be conducted early in the planning stage of the project. In this case, scoping also provided the final opportunity for agencies and the public to request additional scientific studies. Requests for additional studies are normally solicited after the application is filed, but in this case, a DEA will be filed with the license application. 2.1. +‘ Purposes of Scoping Scoping Document 1 (SD1) for the proposed Mahoney Lake Hydroelectric Project was issued on March 8, 1995, to interested resource agencies, other organizations, and individuals. The purposes of SD1 were to: : Invite participation of federal, state, and local agencies, any Native American group, and other interested persons to identify significant environmental and socioeconomic issues related to the proposed action. a 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. 7 Eliminate from detailed study the issues and resources that do not require detailed analysis during review of the project. a Solicit additional study requests. Following the scoping meetings and comment period, all issues raised, along with any additional study requests, were reviewed. Consultation with the resource agencies was also conducted. This document, Scoping Document 2 (SD2), identifies the changes to SD1 (italicized and bold) and reflects comments received during the scoping meetings and comment period. The EA will also address comments and input received during the scoping process. Mahoney Lake Hydroelectric Project September 1995 4 FERC No. 11393-000 Scoping Document 2 2.2 Scoping Meetings In addition to written comments solicited by SD1, two scoping meetings were held in Ketchikan on April 12 and 13, 1995, to solicit any verbal comments and viewpoints concerning the project.* The times and location of the meetings were advertised in the Ketchikan Daily News. The scoping meetings were tape recorded, and all statements (verbal and written) are now a part of the public record for the project. Minutes from these meetings were distributed to the agencies on May 12, 1995. Interested parties who chose not to speak or who were unable to attend either scoping meetings were encouraged to provide written comments and information as described in Section 3.0 of SD1. A site visit was conducted the afternoon of April 12. Representatives from the Alaska Department of Fish and Game (ADFG), the Commission, USFS, Ketchikan Public Utilities (KPU), and the local media attended. 4 Public meetings with respect to the proposed project were also held in Ketchikan on April 26, 1994, as part of the initial consultation required under FERC regulations. Mahoney Lake Hydroelectric Project FERC No. 11393-000 5 September 1995 Scoping Document 2 3.0 REQUEST FOR INFORMATION Federal, state, and local resource agencies, applicants, Native American groups, other entities, and individuals were requested to forward information that they believed would assist the City in conducting an accurate and thorough analysis of the site-specific as well as cumulative effects of licensing the Mahoney Lake Hydroelectric Project. Types of information requested included, but were not limited to the following: a 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. a 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; a Information that would help characterize existing environments and habitats; a 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; a 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 5 Documentation showing why any resources should be excluded from further study or excluded from further consideration. The requested information could have been submitted at the scoping meetings, or submitted in writing no later than May 15, 1995. This included any relevant copies of data, reports, or other documentation supporting positions taken. Mahoney Lake Hydroelectric Project September 1995 6 FERC No. 11393-000 Scoping Document 2 Additional study requests were received from the ADFG and the U.S. Fish and Wildlife Service (USFWS). The ADFG requested additional study of Lower Mahoney Creek when sockeye salmon were migrating upstream and the correlation of stream flows that allow their passage into Lower Mahoney Lake so that the effects of the project could be assessed. The USFWS requested nesting surveys for marbled murrelets and northern goshawks. Meetings were held with the USFS on June 21, 1995 and with the USFS, ADFG, and USFWS on June 22, 1995 to review the requests for additional studies. The agreed-to study plans and meeting notes are contained in Appendices A and B, respectively. The City previously sought input from interested parties during the Stage I consultation process in accordance with FERC regulations (18 CFR 4.38(b)). An Initial Consultation Document (ICD) was distributed on March 16, 1994, to interested agencies to provide a general overview of the proposed project design, operation, and potential impacts. Following distribution of the ICD, two agency/Native American/public meetings were held in Ketchikan on April 26, 1994, to discuss the proposed project and potential environmental impacts, and identify data to be obtained and studies to be conducted as part of the FERC consultation process. Written comments were due within 60 days following the joint meetings or by June 25, 1994. Comments received on the ICD were incorporated into a Final Consultation Document (FCD). The FCD, which was distributed on August 8, 1994, outlined the studies that are being performed during Stage II and contained copies of all consultation correspondence and responses that were developed in reply to concerns addressed in agency comment letters. Mahoney Lake Hydroelectric Project FERC No. 11393-000 7 September 1995 Scoping Document 2 4.0 PROPOSED ACTION AND ALTERNATIVES 4.1 City of Saxman’s Proposed Action 4.1.1 Project Description The proposed Mahoney Lake Project site is located in southeast Alaska approximately 5 air miles northeast of Ketchikan on Revillagigedo Island. Under current conditions, water from Upper Mahoney Lake, at approximate El. 1,959 feet mean sea level (fmsl), flows down a cascade (upper Mahoney Creek) to the lower lake (El. 85 fmsl) and then into George Inlet (sea level) by way of lower Mahoney Creek. The Mahoney Lake Project would consist of a lake tap diversion, reservoir (Upper Mahoney Lake), pipeline constructed inside tunnels and a vertical shaft, a bypass pipe, a powerhouse, a combination of underground and overhead transmission lines, and an access road. The proposed Project would use a "lake tap", which will tunnel into Upper Mahoney Lake about 75 feet below its surface. Water would be conveyed through an upper tunnel to a 1,370-ft. long, rock-lined vertical shaft. The water would continue to the powerhouse in a 3,350-ft. long lower tunnel (see Figure 2). The powerhouse would be located above Lower Mahoney Lake at the base of a large waterfall on upper Mahoney Creek. A dam would not be constructed for this project. Table | summarizes the proposed project features. The upper tunnel will be an 8-foot horseshoe-shaped tunnel, about 1,700 feet in length. Tunnel walls will be left unlined except in areas requiring additional support. Maximum velocity at full turbine flow will be 1.4 feet per second (fps) through the tunnel, which is well below accepted standards for safe velocities in unlined tunnels. The upstream end of the tunnel will pierce the submerged rock walls of Upper Mahoney Lake at a depth of about 75 feet. A lake tap deeper than this level would provide more drawdown capability, but hydrologic analysis shows that further drawdown may not allow the lake to be re-filled completely each year. The normal maximum water surface area of the upper lake is 72 acres. Preliminary surface investigations indicate the general rock quality in the vicinity to be competent for lake tap construction and tunneling. The upper tunnel will run from the lake tap downstream until it daylights at the ground surface in a flat area about 1,500 feet downstream of the upper lake. A concrete plug will be constructed at the downstream end of the lake tap diversion pressure tunnel. A 4-foot diameter pipe will be installed in the plug to convey water from the upper tunnel to the vertical shaft. A valve house will be constructed immediately downstream of the plug, containing two butterfly valves and a vent pipe. One valve will act as the primary intake shut-off valve and the other as an emergency shut-off. Both valves will be motor-operated and connected by power and communication lines to the powerhouse. Mahoney Lake Hydroelectric Project September 1995 8 FERC No. 11393-000 Scoping Document 2 Natural flows in Upper Mahoney Creek will be augmented through construction of a 12-inch diameter bypass pipe. The bypass pipe, located in the vicinity of the upper construction area, will be buried and end in a concrete box with an overflow weir on Upper Mahoney Creek. It is anticipated that the bypass pipe could contribute up to 10 cfs to the natural streamflow of the upper creek. The bypass pipe will be activated in the event that the hydroelectric facility stops operating during winter low flow periods. Bypass pipe flows will ensure that, if the Jfacility shuts down, water continues to flow into Upper Mahoney Creek, which will in turn contribute to upwelling at the Upper Mahoney Creek outlet delta. This upwelling is considered important for incubating salmon eggs. A 1,370-foot long rock-lined vertical shaft will be constructed leading from the upper tunnel to the lower tunnel. The lower tunnel will be a 3,350-foot long, 8-foot high by 8-foot wide horseshoe-shaped tunnel constructed from the powerhouse into the hillside. Portions of the tunnel will be lined with shotcrete, and supported by rock bolts and steel sets as required. The tunnel will provide permanent access to a 32-inch diameter welded steel pipe supported on concrete saddles within the tunnel. The tunnel invert will slope at a 10% grade to the powerhouse. The powerhouse will be a semi-underground concrete structure constructed at the portal entrance to the lower tunnel. The powerhouse structure will be approximately 40 ft. long by 40 ft. wide and 28 ft. high. The powerhouse site has been carefully selected to avoid potential impacts to fish using Lower Mahoney Lake. The cascades and waterfalls between the upper and lower lakes end at a deep pool surrounded by bedrock walls at approximate El. 140 fmsl, about 800 feet upstream of Lower Mahoney Lake. Fish cannot pass this point on Upper Mahoney Creek due to the waterfalls. The water discharged from the proposed turbine will re-enter Upper Mahoney Creek at this pool. The powerhouse will contain a single twin-jet horizontal Pelton turbine. Maximum rated discharge will be 78 cubic feet per second (cfs) and rated net head will be 1,730 feet. The synchronous generator will produce 13,200 volts of electricity and be rated 9,600 kilowatts (kW) continuous. Centerline of the turbine shaft will be at El. 150 fmsl. The turbine discharge will flow in a buried, concrete rectangular tailrace back to Upper Mahoney Creek. The pipeline will be approximately 5 ft. wide and 200 ft. in length. Open discharge of the tailrace will be into a naturally occurring solid rock deep pool at the base of the waterfall mentioned above. Mahoney Lake Hydroelectric Project FERC No. 11393-000 9 September 1995 +t z ; Ne ea a eet el ee + 8 H.S. TUNNEL ’ no i—< . at ; pee . aa / hi i Ae qReuTAn®,. — ee 8° HS. TUNNEL we oe us a aT — < es MAHONEY LAKE = WSEL 88.0 we UPPER MAHONEY LAKE WS.EL 1959.0 LAKE TAP Bone UPPER MAHONEY LAKE NORMAL WS.EL 1959.0 ACCESS ROAD ANO BURIED TRANSMISSION LINE 1800 1600 1400 1200 - we B a 3 1000 4 1000_= ne Ee 5 s G 200 ° 200 400 600 —800__ i ‘SCALE IN FEET B CITY OF SAXMAN, ALASKA APPLICATION FOR LICENSE MAHONEY LAKE HYDROELECTRIC PROJECT FERC PROJECT NO. 11393 B E PROJECT SITE PLAN AND PROFILE Figs 2 f B HDR Engineering, Inc. B 32+00 36+00 40+00 44400 48+00 52+00 PROFILE Scoping Document 2 TABLE 1 PROPOSED PRINCIPAL PROJECT FEATURES INumberiof; Generating; Unitser ieee eee ein renin een 1 prurbine shype: eres PUIG Ha MP eon ee Ho RC Hatteatt oat sito mbet ton bet ciate ot istiatte teeth Pelton Rated) Generator Output MWarra Weer wieder starch enon meron eet oms ten onene nomena 9.6 Maximum) Rated sTurbine Discharges cfs iar ae oreten eterna otro onan tenets 78 MinimumpRatedsLurpine Discharge aCisi-a ar ae ae ere ne ae a een ose erent 8 Turbine Runner, Centerline Rlevation sims) ieee et aie aerate stentatre 147 Average Annual/ nergy. (kW iced eter ot einer eon te etek den nat odene tren 42,080,000 Normal Maximum: Reservoir: Hlevation:: fish crs cry sree eter tere nist netron ett oite 1959 Dicusmnl Ditenieereets Thoma cnr vate: Tana ie aes an oe ae on 1890 GTOSS | Fea Pet eee Reta rer teatRattetiat ur ee ant Cate aera tar tC Ut an eA Tat tbe te toate tte anes 1809 INetsHeadiat)MaximumjRated»Discharpe i feetin-ut-u-u-n- tenon see ted -aeMieH mses ent to etolt. 1730 Upper Mahoney Lake DraimagerA rea sq amie eaten seen ei nono sien beste ier Meee aetenod tian 2.0 Surtace: Area ‘at: RISs 1 959 fmislacresirr sc csteereer cots et onic ottstr etree tnencanctreniors AD Active Storage Volume at El. 1959 fmsl, acre-ft .................. 3,760 Average Annual: Natural Outflow; acre-ft 7 ee 32,600 Averave: AnnualoNatural! Outflow: cfsiem iid tan tenets nnenetencnotsioienadet etait 44.4 ‘Approximate Depth at) Deepest: Pointsettiemeiensucieeie due ateee oer welie i 270 DIVETSION PL YDe ried ta erent eet eee aera aret ert .... Lake Tap at El. 1880 fmsl Upper Pressure Tunnel SRY Der reeset react eee ee rarest Partially Unlined Horseshoe SIZ Seer eStats 8-foot diameter Renown fect warn a deiner trate tber rite rarer ree erro ater atti 1700 Invest! Slope vertical :f/horizontal!: fears rse actor enon toner oie 0.002 \Velocityati/Maximum fl urbine) Discharge uipsimnsrsrussicionetsteicicneicieen inden 1.4 Bypass Pipe Size teiersieieicienersteteteieieneactercioteienot i ciedensiretene 12-inch steel diameter (buried) Operator srr seston test tot ote tote ot tenor ot ota etotetts 12-inch motor-operated valve LOCAhOn dgetne cust teronsyoten et etone Downstream of main penstock shutoff valves Operation tiie irsieioetreioh rete tets Remote controlled from powerhouse Mahoney Lake Hydroelectric Project September 1995 11 FERC No. 11393-000 Scoping Document 2 TABLE 1 PROPOSED PRINCIPAL PROJECT FEATURES (continued) Vertical Shaft TOV es ee cece eee eee eH teaete sterol otal elias ele Partially Lined Rectangular Ie etc ote hate att elon ot reat atne tele 5-foot by 7-foot unlined, 4-foot diameter lined Top of Shatt Blevation;: fish ease cine Hen tes at aoa orate 1850 Bottom: of Shatt Hlevations tis) sega eee eee ee ee eee 480 Velocity at Maximum Turbine Discharge, fps.............-2--2000-- 6.2 Meme OF Sait fe ee eee ee eset 1,370 Lower Access Tunnel PRY De rete teers eset otcta a tote teeter ania atte erudite settae lett otae tetas Partially Lined Horseshoe Sa ea erm tat a eee eC eta seagate dais te at 8-foot diameter MSCMBt OCU ee re ete eee rte oene e 3,350 Invert Slope; vertical fUhorizontal ft -.-. oe 0.10 Pipelitie (hype tee eet erecta Welded Steel on Saddles Pipeline Diameter, niches eer ore et ee teeta ttc ee beet tect 32 Pipeline Length; feet. <2. 2s cs eee ee eee ee ere eee aes 3,350 Velocity in Pipe at Maximum Turbine Discharge, fps ...........-...--- 14 Powerhouse SU ogee tea cele rg tat treat otal gee eet oate desea te Semi-underground Approximate Dimensions ............... 40-foot by 40-foot by 28-feet high Generator: Floor Hievation, fnisl- - ee 147 Tailrace CY Pe a eta alae ee etlgat a ota aa U Buried Concrete Rectangular Tenet, feet ese cee cect tet ole atetsie cele ceete teat et costs 200 Transmission Line (Northern Alternative) Length of Underground Construction, miles ....................0.0. Lz (Underground ‘Line!Voltage kev 1s) aed i ate ea 13:2 Lensth of Overhead Construction; miles: - 01): 232 S21. sto. see see 5.0 Overhead Tame Voltage Va are eee Oe ee eC 115 Transmission Line (Southern Alternative) Length of Underground Construction, miles ... 0... 000 cece eee eee 2 Underground Line Voliage, KV... 3 2. .- ovo « oe ss 0 so 00 si cs se oo 13.2 Length of Overhead Construction, miles... 1... 00 ee ee ee eee ee 3.8 Overhead Tine Voltage, RVs ce cc cee eset soos siete eee e-cie| seg a cr 34.5 Mahoney Lake Hydroelectric Project FERC No. 11393-000 12 September 1995 Scoping Document 2 TABLE 1 PROPOSED PRINCIPAL PROJECT FEATURES (continued) New Powerhouse Access Road MYO ie) oltre ol eae fel elec tal al del to fod ao)! elt fais Single-lane gravel surfacing with turnouts Length males | yeti tats fal fal a lal colon [at al lid [al cel dalla] ab Lalla alla ala Te ae isle aes] a 1.7 Mahoney Lake Hydroelectric Project September 1995 13 FERC No. 11393-000 Scoping Document 2 The access road will begin at the powerhouse and follow along the south and east sides of Mahoney Lake to connect to existing logging roads that run along George Inlet north to the White River area. A logging access road has recently been constructed by the Cape Fox Corporation that extends from near the mouth of White River south towards the project, ending near Lower Mahoney Creek. Approximately 1.7 miles of new road will be constructed from the existing logging access road to the powerhouse site. This road will be a single lane gravel surfaced road with turnouts. As previously discussed, two alternatives for routing the overhead transmission lines are being considered. Both alternatives (the Northern Alternative and the Southern Alternative-See Figure 3) will include 1.2 miles of 13.2 kilovolt (kV) buried transmission line from the powerhouse to the switchyard. The switchyard will be located in a low avalanche hazard area. A power transformer will be located in the switchyard to step up generation voltage from 13.2 kV to the transmission voltage of either 115 kV or 34.5 kV, depending on the selected alternative. The Northern Alternative will follow essentially the same route as the project access road for approximately 5 miles to the line’s interconnection point with the 115 kV Swan Lake Project (FERC No. 2911) transmission line near the mouth of the White River. The Southern Alternative will travel south for 3.8 miles along the 100-foot elevation contour from the switchyard to the Beaver Falls Project (FERC No. 1922). No access road is proposed to be constructed along this route. The overhead transmission lines will be raptor-proof designed to protect birds from electrocution. 4.1.2 Project Operation In the early years of operation, and during a normal water year, the project will be capable of fully displacing the projected diesel generation requirements for about eight months of the year, May through December. Upper Mahoney Lake will typically be drafted 69 feet to minimum pool level (El. 1,890 fmsl) by January each year, and remain at minimum pool through April. The project will generate power only from inflow to Upper Mahoney Lake, which averages 33.2 cfs during this four-month period. Projected monthly operation of the project for the first year of operation, Year 2000, and for Year 2005, are shown on Tables 2 and 3. The tables are based on average monthly flows, and assuming KPU’s hydro plants and the Swan Lake Project (FERC No. 2911) are generating at full capacity. The Mahoney Lake Project will operate at a 0.50 plant factor, typical for a storage project. For comparison, the Swan Lake Project (FERC No. 2911) operates at a 0.42 plant factor and the combined KPU-owned hydros operate at 0.63 plant factor. Mahoney Lake Hydroelectric Project FERC No. 11393-000 14 September 1995 . Pt SS S Dy’ PSS RW Interconnection Point to WE : Northern Alternative, 115 kV, : 26,282 feet long, \\_. follows existing road 2S 13.2 kV buried line from : c Southern Alternative, 34.5 kV 20,170 feet long, no existing road, is HF AM OE : CITY OF SAXMAN, ALASKA APPLICATION FOR LICENSE MAHONEY LAKE HYDROELECTRIC PROJECT FERC PROJECT NO. 11393 ALTERNATIVE TRANSMISSION LINE ROUTES HOR Engineering, inc. Figure 3 Scoping Document 2 Table 2 h:\hyd\mahoney\ea\tab2.sd1 CITY OF SAXMAN, ALASKA MAHONEY LAKE HYDROELECTRIC PROJECT Average Annual Energy Generation — Year 2000 Lake Tap Alternative Annual Demand 191196 MWhrs Minimum Pool Elev.: 1890 Storage KPU Summer 44339 MWhrs Pool Starting Elev.: 1959 3760 KPU Winter 103311 MWhrs Turbine Elev.: 150 ft Un-—met Summer 13020 MWhrs Assumed Head Loss: 80 ft Un—met Winter 30526 MWhrs Assumed Eff. 0.82 Inflow Avg Pool | Turbine Pool Monthly Inflow | —MIF |Demand} Start Flow Ending | Average Energy Month} _ (cfs) (ac—ft) | (MWh) Elev (cfs) Storage Elev Generation Oct 69.8 4169 4002 1959 44.8 3760 1959 4002 Nov 44.8 2547 4152 1959 48.1 3442 1957 4152 Dec 18.6 1021 4222 1954 47.9 1517 1938 4222 Jan 30.6 1759 3910 1921 45.1 504 1911 3910 Feb 24.4 1255 3645 1901 31.4 0 1896 2460 Mar 17.3 941 3773 1890 15.3 0 1890 1311 Apr 25.0 1369 3410 1890 23.0 0 1890 1907 May 61.1 3634| __3391 1890 39.3 1219 1903 3391 | June 82.4 4784 3125 1916 36.7 3749 1937 3125 July 61.2 3640 3129 1958 35.1 3760 1959 3129 Aug 44.6 2619 3151 1959 35.3 3760 1959 3151 Sept 52.7 3017 3629 1959 42.0 3760 1959 3629 Ending Pool Elevation 1959 Total Generation 38387 SUMMARY OF GENERATION Un—Met Summer Load Mahoney Summer Generation % Un—Met Summer Load Un—Met Winter Load Mahoney Winter Generation % Un—Met Winter Load September 1995 13020 13033 100% 30526 25354 83% MWhrs MWhrs Mahoney Lake Hydroelectric Project 16 FERC No. 11393-000 Scoping Document 2 Table 3 h:\hyd\mahoney\ea\tab3.sd1 CITY OF SAXMAN, ALASKA MAHONEY LAKE HYDROELECTRIC PROJECT Average Annual Energy Generation — Year 2005 and Beyond Lake Tap Alternative Annual Demand 198450 MWhrs Minimum Pool Elev.: 1890 Storage KPU Summer 44339 MWhrs Pool Starting Elev.: 1959 3760 KPU Winter 103311 MWhrs Turbine Elev.: 150 ft Un-metSummer 15196 MWhrs Assumed Head Loss: 80 ft Un—met Winter 35604 MWhrs Assumed Eff. 0.82 Inflow | Avg Pool ‘| Turbine Pool Monthly Inflow | —MIF |Demand| Start Flow Ending | Average Energy Month! _ (cfs) (ac—ft) | (MWh) Elev (cfs) __| Storage Elev Generation Oct 69.8 4169 4668 1959 523) 3760 1959 4668 Nov 44.8 2547 4842 1959 56.3 2957 1952 4842 Dec 18.6 1021 4924 1945 56.4 512 1923 4924 Jan 30.6 1759 4561 1901 36.9 0 1896 3175 Feb 24.4 1255 4251 1890 22.4 0 1890 1749 Mar 17S 941 4401 1890 15.3 0 1890 1311 Apr 25.0 1369 3977 1890 23.0 0 1890 1907 | May 61.1 3634 3956 1890 45.9 810 1899 3956 June 82. 4784 3647 1908 43.0 2948 1927 3647 July 61.2 3640 3652 1945 41.1 3760 1952 3652 Aug 44.6 2619 3677 1959 412 3760 1959 3677 Sept 52.7 3017 4235 1959 49.0 3760 1959 4235 Ending Pool Elevation 1959 Total Generation 41742 SUMMARY OF GENERATION Un—Met Summer Load 15196 MWhrs Mahoney Summer Generation 15211 % Un—Met Summer Load 100% Un—Met Winter Load 35604 MWhrs Mahoney Winter Generation 26531 % Un—Met Winter Load 75% Hoe eeenee eee eee eee esse eee ee ———_————————_— eee Mahoney Lake Hydroelectric Project FERC No. 11393-000 17 September 1995 Scoping Document 2 Low Water Year Operation Operation of the project will be coordinated with KPU’s other operating resources to best use each resource during normal and extreme hydrologic conditions. The general operating criteria will stipulate minimum and maximum pool levels with the objective of minimizing "spill" through the natural lake outlet. During a low water year, the minimum pool level will be sustained for a longer period of time, and the plant would operate more similar to a "run-of- river" project during that period. However, day-to-day operation could be fluctuated during these periods according to the energy needs of KPU to provide peaking power during high demand periods each day. High Water Year Operation During a high water year, inflow to Upper Mahoney Lake will exceed the turbine’s maximum hydraulic capacity resulting in some loss of runoff through the existing natural lake outlet. In this case, the project would be operated as either a base load or peaking facility depending on load and operating status of other generating resources in the system. 4.1.3 Proposed Protection and Mitigation The City proposes to construct and operate the project as described above, with the following protection and mitigation measures: * Avoid/minimize impacts to sockeye spawning grounds in Lower Mahoney Lake by constructing the powerhouse outlet 800 feet upstream of the lower lake and by providing year-round flows in Upper Mahoney Creek from the powerhouse to the lower lake. : Include construction of a bypass pipe to allow the release of water into Upper Mahoney Creek in the event that the hydroelectric facility stops operating during winter low flow periods. The additional water will help ensure continuation of upwelling in the sockeye spawning area of the Upper Mahoney Creek outlet delta. a Augment natural flows to improve upstream fish passage in Lower Mahoney Creek for brief periods, if needed, by increasing output from the hydroelectric facility. . Provide raptor protection along the overhead transmission line associated with the project regardless of the alternative route selected. 2 Provide erosion and sediment control measures during construction of the project. : Consult with appropriate agencies to develop a plan that will include mutually agreeable aesthetic treatments for above-ground facilities to reduce contrast of the project facilities with the surrounding natural environment. Mahoney Lake Hydroelectric Project September 1995 18 FERC No. 11393-000 Scoping Document 2 . Where feasible along the transmission line route, visual impacts will be mitigated through use of topographic and vegetative features. a Consult with the Cape Fox Corporation and other interested Native American groups, the USFS, and the Alaska State Historic Preservation Office to develop a plan regarding measures to be taken to mitigate any project produced adverse effects on cultural resources that may be found. 4.2 Modifications to the City’s Proposed Project Alternative project configurations, designs, and locations, including mitigation and enhancement measures not proposed by the City were considered. During the scoping process, KPU recommended the Southern Alternative for routing the overhead transmission line. The City investigated the potential of constructing the transmission line along this proposed route and considers it feasible from an engineering, environmental, and economic perspective. Therefore, the City has added this alternative for consideration. Agencies also expressed concern regarding the effect of altered streamflows in Upper Mahoney Creek on salmon redds in the creek’s outlet delta and the effect of project operation on upstream fish passage in Lower Mahoney Creek. In response, the City has added a bypass pipe to its proposal to release water into Upper Mahoney Creek and has agreed to augment natural flows by increasing the output from the hydroelectric facility. These actions will help ensure continuation of upwelling in the sockeye salmon spawning area of the Upper Mahoney Creek outlet delta and also allow, if needed, augmentation of natural stream flows in Lower Mahoney Creek to improve fish passage for upmigrating sockeye salmon. 4.3 No Action Under the no-action alternative, the project would not be constructed. No changes in the existing environment would take place. The no-action alternative is the baseline from which the proposed action and any action alternatives are compared. Mahoney Lake Hydroelectric Project FERC No. 11393-000 19 September 1995 Scoping Document 2 5.0 SCOPE OF CUMULATIVE ANALYSIS AND RESOURCE ISSUES 5.1 Cumulative Effects According to the Council on Environmental Quality’s Regulations for implementing NEPA (§1508.7), an action may cause cumulative impacts on the environment if its impacts overlap in space and/or time with the impacts of other past, present and reasonably foreseeable future actions, regardless of what agency or person undertakes such other actions. Cumulative effects can result from individually minor but collectively significant actions taking place over a period of time, including hydropower and other land and water development activities. Based on the initial consultation document and agency comments, we have outlined the geographic and temporal scope of cumulative effects for the resources that could be cumulatively affected by hydroelectric development and non-hydro activities in the Mahoney Creek drainage. These resources and cumulative effects will be addressed in the EA. 5.1.1 Resources That Could Be Cumulatively Affected Developmental activities in the vicinity of the Mahoney Creek basin are very limited. We have tentatively identified the following resources that have the potential to be cumulatively affected by the Mahoney Lake Project: aesthetic character of the Mahoney Creek basin, and recreational opportunities in the basin including any recreational sockeye salmon fishery. 5.1.2 Geographic Scope Our geographic scope of analysis for cumulatively affected resources is defined by the physical limits or boundaries of (1) the proposed action’s effect on the resources, and (2) contributing effects from other hydropower and non-hydropower activities within the Mahoney Creek basin. No hydropower development currently exists and the only non-hydro activity potentially affecting resources in the Mahoney Creek basin that we have identified is recreation. Water from Upper Mahoney Lake, at approximate El. 1959 fmsl, flows down a cascade (Upper Mahoney Creek) to Lower Mahoney Lake (El. 85 fmsl) and then into George Inlet by way of Lower Mahoney Creek. The proposed project will affect flows in Upper Mahoney Creek as well as into and out of Lower Mahoney Lake. The reduced flows in Upper Mahoney Creek due to project operations and the existence of project facilities have the potential to affect the aesthetic character of the area. Thus, we have defined the geographic scope of the cumulative analysis as the Mahoney Creek basin consisting of Lower Mahoney Lake and the upper portion of Lower Mahoney Creek. Mahoney Lake Hydroelectric Project September 1995 20 FERC No. 11393-000 Scoping Document 2 5.1.3 Temporal Scope The temporal scope of our cumulative analysis in the EA will include past, present, and future actions and their effects on each resource that could be cumulatively affected. For purposes of our analysis, the temporal scope will look 30 years into the future, concentrating on the effect on the resources from reasonably foreseeable future actions. The historical discussion will, by necessity, be limited to the amount of available information for each resource. We have identified the present resource conditions based on the initial consultation document and studies conducted to date and we will also document these in the EA. 5.2 Resource Issues A list of resource issues and concerns that have been identified for analysis in the BA is presented below. Those issues identified by an asterisk (*) will be analyzed as both a cumulative impact and from a site-specific effect. This list is not intended to be exhaustive or final, but is an initial listing of potential issues that have been identified. For convenience, the issues have been listed in categories related to technical disciplines. 5.2.1 Geology and Soil Resources a What measures would be needed to prevent erosion and sedimentation of Upper and Lower Mahoney Creek and Lower Mahoney Lake during land-disturbing activities associated with project construction. 5.2.2 Aquatic Resources s Whether project effects on the surface levels of Lower Mahoney Lake would affect spawning for sockeye salmon. . Whether flow fluctuations into Lower Mahoney Lake would affect spawning for sockeye salmon. . Whether altered flow volumes to Lower Mahoney Lake would affect sockeye salmon spawning or over-wintering on the Upper Mahoney Creek outlet delta and along the adjacent shoreline. - Whether colder inflows into Lower Mahoney Lake would affect sockeye salmon spawning or eggs on the Upper Mahoney Creek delta. . Whether project effects on the outflows of Lower Mahoney Lake into Lower Mahoney Creek would affect spawning for pink and chum salmon and block access of sockeye salmon that spawn in Lower Mahoney Lake. Mahoney Lake Hydroelectric Project FERC No. 11393-000 21 September 1995 Scoping Document 2 5.2.3 Terrestrial Resources Whether project operations would affect riparian habitats in the bypass reach. Whether blasting and other construction activities would affect wildlife distribution in the project area. Whether project construction, including the proposed 1.7 mile-long access road, would permanently affect vegetation and wildlife. Whether wetlands would be adversely affected from the project construction along the access road. Whether the proposed transmission line design and location would be a possible electrocution or collision hazard to large birds, such as bald eagles, golden eagles, ospreys, and swans, and whether mitigative measures would be needed. Whether fifteen mountain goats, that were transplanted into the alpine area around Mahoney Lake in 1991, would be directly and indirectly affected by project construction. 5.2.4 Threatened, Endangered and Sensitive Species Whether project construction and operation would affect federally listed candidate threatened, endangered, or sensitive species, such as the Marbled murrelet, Northern goshawk, Spotted frog, American peregrine falcon, Alexander Archipelago wolf, Thurber’s reedgrass (Calamagrostis, spp.), Choris bog orchid (Platanthera chorisiana) and an unnamed sedge (Carex lenticularis var. dolia), and whether the impacts need to be avoided, minimized, or mitigated. 5.2.5 Aesthetic Resources *e *e The degree that flows associated with project operations would affect aesthetic resources in the bypass reach, and whether alternative flows are needed. The degree that construction and operation of project facilities would adversely impact the visual quality of the area. September 1995 Mahoney Lake Hydroelectric Project 22 FERC No. 11393-000 Scoping Document 2 5.2.6 Recreation and Land Use *e Whether project construction and operation would impact recreational opportunities in the Upper and Lower Mahoney Lake area and what those impacts would be. 5.2.7 Socioeconomics . Whether construction and operation of the project would result in socioeconomic impacts and what those impacts would be. 5.2.8 Cultural Resources a Whether project construction would adversely impact cultural resources that may exist in the area. Mahoney Lake Hydroelectric Project FERC No. 11393-000 23 September 1995 Scoping Document 2 6.0 EA PREPARATION SCHEDULE The preliminary schedule for preparing the Mahoney Lake Hydroelectric Project DEA and license application is presented below: Scoping Document 1 - March 1995 Scoping Meetings - April 1995 Scoping Document 2 - September 1995 Preliminary DEA and Draft License Application - late October or early November 1995 DEA and License Application - February 1996 Mahoney Lake Hydroelectric Project September 1995 24 FERC No. 11393-000 Scoping Document 2 7.0 DRAFT ENVIRONMENTAL ASSESSMENT (DEA) OUTLINE The tentative outline for the Mahoney Lake Hydroelectric Project EA is as follows: SUMMARY i APPLICATION I. PURPOSE AND NEED FOR ACTION A. Purpose of Action B. Need for Power IIL. PROPOSED ACTION AND ALTERNATIVES A. City of Saxman’s Proposal VE Project Facilities and Operations Zs Proposed Environmental Measures a. Construction b. Operation J: Mandatory Requirements a. Section 4(e) Conditions b. Section 18 Fishway Prescription a Water Quality Certificate Conditions d. Coastal Zone Management Act Consistency ce Section 30(c) Fish and Wildlife Conditions B. Modification of City’s Proposal Cc. No-Action Alternative D. Alternatives Considered but Eliminated from Detailed Study IV. CONSULTATION AND COMPLIANCE A. Agency Consultation B. Interventions (es Scoping D. Subsistence Evaluation and Finding V. ENVIRONMENTAL ANALYSIS A. General Description of the Mahoney Creek Basin B. Scope of Cumulative Effect Analysis (CEA) I: Geographic Scope of CEA Resources 2. Temporal Scope of Analysis Cc. Proposed Action and Other Recommended Environmental Measures iD Geology and Soil Resources 2 Aquatic Resources a5 Terrestrial Resources 4. Threatened, Endangered, and Sensitive Species 5. Aesthetic Resources 6. Cultural Resources qs Recreation and Other Land Uses 8. Socioeconomic Resources D. No-Action Alternative Mahoney Lake Hydroelectric Project FERC No. 11393-000 25 September 1995 Scoping Document 2 Vi. DEVELOPMENTAL ANALYSIS Vi. COMPREHENSIVE DEVELOPMENT AND RECOMMENDED ALTERNATIVE VIII. CONSISTENCY WITH COMPREHENSIVE PLANS Ix. RECOMMENDATIONS OF FISH AND WILDLIFE AGENCIES x FINDING OF [ or NO] SIGNIFICANT IMPACT XI. LITERATURE CITED Xl. LIST OF PREPARERS XIII. MAILING LIST Mahoney Lake Hydroelectric Project September 1995 26 FERC No. 11393-000 Scoping Document 2 8.0 MAILING 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 Regional Office Federal Energy Regulatory Commission 1120 SW Sth Avenue, Suite 1340 Portland, OR 97204 Ms. Lois Cashell Federal Energy Regulatory Commission 825 N. Capitol St. NE Washington, DC 20426 Mahoney Lake Hydroelectric Project FERC No. 11393-000 27 September 1995 Area Director Bureau of Indian Affairs P.O. Box 3-8000 Juneau, AK 99802 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, DC 20515 Ms. Christine Valentine Alaska Division of Governmental 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 Mr. Barry Hogarty Alaska Department of Environmental Conservation DEQ/SE Region DEC 540 Water Street, Suite 203 Ketchikan, AK 99901 Scoping Document 2 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 2030 Sea Level 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 September 1995 Mahoney Lake Hydroelectric Project FERC No. 11393-000 Scoping Document 2 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 Mahoney Lake Hydroelectric Project FERC No. 11393-000 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 Authority 480 W. Tudor Anchorage, AK 99503 Mr. Stan Sieczkowski Manager, Operations & Maintenance Alaska Energy Authority 480 West 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 Mr. C. L. Cheshire, Director University of Alaska - Southeast Economic Development Center - UofASE 7th Avenue and Madison Ketchikan, AK 99901 Mr. Robert Warner Librarian University of Alaska - Southeast 7th Avenue and Madison Ketchikan, AK 99901 September 1995 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 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 Ms. Melanie Fullman Ketchikan Gateway Borough Planning Department 344 Front Street Ketchikan, AK 99901 Mr. Jim Voetberg Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 Scoping Document 2 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. William Jones Acting 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. Jan Risla Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project September 1995 30 FERC No. 11393-000 Scoping Document 2 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 J President Tongass Tribal Council P.O. Box 3380 i 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 Mahoney Lake Hydroelectric Project FERC No. 11393-000 September 1995 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 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 Scoping Document 2 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 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 September 1995 Mahoney Lake Hydroelectric Project FERC No. 11393-000 Scoping Document 2 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. Guy Galloway 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 HDR Engineering, Inc. P.O. Box 91201 Bellevue, WA 98009 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mahoney Lake Hydroelectric Project FERC No. 11393-000 33 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 September 1995 APPENDIX A STUDY PLANS FOR ADDITIONAL STUDY REQUESTS Study Plans for Additional Study Requests APPENDIX A STUDY PLANS FOR ADDITIONAL STUDY REQUESTS Plants A survey for sensitive plants was conducted on the National Forest System lands near Upper Mahoney Lake and northeast of Lower Mahoney Lake in September 1994. Since then, an additional transmission line route has been identified that is located on National Forest System lands south of Lower Mahoney Lake to the Beaver Falls Project (FERC No. 1922). Because that route includes habitat types that may support sensitive plant species and those plants could be affected by the project, a survey was conducted. The City walked the southern transmission line route during mid-July 1995, seeking sensitive plant taxa and taxa proposed for designation as sensitive (see draft Biological Evaluation for Plants). A survey of intensity level 4 (“general”) was completed, as defined in draft survey protocol information provided by USFS Regional Botanist Mary Stensvold. Attention was focused on any unique habitats that might be more likely to support one or more of the sensitive plants. A list will be made of all species identified, and all plants observed will be identified to a level sufficient to determine whether they are or are not one of the sensitive taxa. Any plants that cannot be determined to not be one of the sensitive plants will be collected if an adequate population is found. If any sensitive plants are located, information will be collected on the location, habitat type, and approximate population size. Survey results will be documented using USFS-provided forms and in a short memorandum. The City also conducted additional surveys for a previously identified USFS sensitive plant species (choris bog orchid). The purpose of these surveys was to attempt to clarify the status of the populations found around Upper Mahoney Lake last year and to identify additional populations of this orchid in the Ketchikan and Mahoney area that will not be affected by facility construction or operation. The results of this additional work will be included in the biological evaluation for plants prepared for the USFS. Animals The City conducted a survey for the Queen Charlotte goshawk (Accipiter gentilis laingi). The areas surveyed included National Forest System lands northeast of Lower Mahoney Lake affected by the access road and Northern Alternative transmission line route and National Forest System lands along the Southern Alternative transmission line route between Lower Mahoney Lake and the Beaver Falls Project (FERC No. 1922). The survey was conducted in mid-July 1995. Cape Fox Corporation personnel flagged the proposed Southern Alternative transmission line route across National Forest System lands in advance of the survey. The goshawk survey followed the USFS Alaska Region Goshawk Inventory Protocol for 1992. Point samples were taken 150 meters apart along the Southern Alternative transmission line route and the part of the Northern Alternative route that passes through National Forest System lands. The clearing for Mahoney Lake Hydroelectric Project September 1995 A-1l FERC No. 11393-000 Study Plans for Additional Study Requests the transmission line will be 30 meters wide so one transect along the route provided adequate coverage for the survey (transects are recommended to be 260 meters apart). Survey results will be documented in the animal biological evaluation. The spotted frog (Rana pretiosa) has been expanding its range into coastal areas of southeast Alaska. It is a Category 2 species that may be listed as sensitive by the USFS in the near future. The City investigated potential frog habitat in the project area in conjunction with other wildlife and botanical field surveys. Potentially suitable habitat has been identified in the shallow shoreline waters along the southern edge of Lower Mahoney Lake. The project is not, however, expected to impact this area of Lower Mahoney Lake. Also, this area is not National Forest System land. This area was surveyed to provide information to the USFS and the USFWS about the species’ status. The survey placed two or three baited minnow traps in each suitable location. Three locations were surveyed. The traps were allowed to remain at each site for a minimum of two days before they were removed. Any frogs caught will be identified using Amphibians of the Western United States by Stebbins. The results will be reported in the animal biological evaluation prepared for the USFS. The marbled murrelet (Brachyramphus marmoratus) is a Category 2 species for which there is increasing concern because of its close association with old growth forests throughout its range. Surveys for marbled murrelets were conducted in habitat (predominantly old growth timber stands) likely to support nesting and roosting within the vicinity of the project. The City conducted dawn watch surveys consistent with USFS protocol. Efforts were made to detect individual birds returning to the nest but not necessarily the location of individual nest trees. The results will be reported in the animal biological evaluation prepared for the USFS. Fish The City has been observing Lower Mahoney Creek for salmon presence approximately every third day starting on August 1. Creek observations include as much of the creek as possible, with emphasis on the lower intertidal area (where fish can be easily observed) and the area between the proposed road crossing and Lower Mahoney Lake. Observers record date, time of observation, species of fish (if known), number of fish, and general location within the stream. Fish locations will be plotted on maps of the stream. When significant numbers of salmon are observed in Lower Mahoney Creek, the project fish biologist will be notified. The fish biologist will travel to Lower Mahoney Creek when preliminary observations suggest that sockeye salmon may be ready to move into Lower Mahoney Lake. Visual observations will be made of salmon distribution, movements, and behavior. Emphasis will be placed on determining when, and under what flow conditions, sockeye salmon move past barrier sections of the stream and into the lake. Sockeye salmon movements will be compared with measured stream discharge at the time of their movement. Results of this work will be reported as a technical memorandum to be appended to the existing fish report prepared in December 1994. Mahoney Lake Hydroelectric Project FERC No. 11393-000 A-2 September 1995 Study Plans for Additional Study Requests To date, flows have been too low in Lower Mahoney Creek for the fish to migrate into Lower Mahoney Lake. Hydrology The City established a stream flow gaging station on Lower Mahoney Creek in July. The gage is located in the approximate location of the former gage established by the U.S. Geological Survey. Mahoney Lake Hydroelectric Project September 1995 A-3 FERC No. 11393-000 APPENDIX B AGENCY CORRESPONDENCE APPENDIX B Agency Correspondence AGENCY CORRESPONDENCE Listed below in chronological order is the agency correspondence associated with scoping for the Mahoney Lake Hydroelectric Project. All of the referenced letters, documents, and meeting notes are attached. Date From To Subject 3-9-95 HDR Agencies/NAG/Public | Scoping Document 1 (SD1) distributed 4-5-95 ADGC HDR Comments re: SD1 | 4-12-95 KPU HDR Comments re: SD1 | 4-25-95 HDR Meeting Attendees Draft 4/12-4/13/95 Scoping Meeting | Minutes 5-9-95 HDR USFWS Sensitive, Threatened and Endangered | Species 5-11-95 ADFG HDR Comments re: SD1 5-12-95 HDR Agencies/NAG/Public | Final 4/12-4/13/95 Scoping Meeting Minutes 5-14-95 KASPAB HDR Comments re: SD1 5-19-95 USFWS HDR Comments re: SD1 5-19-95 ADGC HDR Comments re: SD1 5-24-95 HDR Agencies/NAG/Public | Request for Comments on Southern Alternative Transmission Line Route Undated ADGC HDR Comments re: Southern Alternative 6-1-95 AIDA HDR Comments re: Southern Alternative 6-7-95 Sen. Robin L. Taylor HDR Comments re: Southern Alternative 6-15-95 HDR USFS/ADFG/USFWS | 6/21-6/22/95 Meeting Confirmation 6-20-95 ADFG HDR Mountain Goats 6-21-95 USFS HDR Comments re: Southern Alternative 6-21-95 FERC HDR Comments re: Southern Alternative 6-23-95 GKCC HDR Comments re: Southern Alternative 6-27-95 ADFG HDR Comments re: Southern Alternative HDR USFS/ADFG/USFWS | 6/21-6/22/95 Meeting Minutes USFWS HDR Comments re: Southern Alternative Mahoney Lake Hydroelectric Project September 1995 B-1 FERC No. 11393-000 Agency Correspondence From To Subject Acronym Definitions: ADFG Alaska Department of Fish and Game ADGC Alaska Division of Governmental Coordination AIDA Alaska Industrial Development and Export Authority FERC Federal Energy Regulatory Commission GKCC Greater Ketchikan Chamber of Commerce HDR HDR Engineering, Inc. KASPAB Ketchikan Area State Parks Advisory Board KPU Ketchikan Public Utilities NAG Native American Groups USFS U.S. Forest Service USFWS U.S. Fish & Wildlife Service Mahoney Lake Hydroelectric Project FERC No. 11393-000 B-2 September 1995 March 9, 1995 (See Distribution List) Subject: Mahoney Lake Hydroelectric Project FERC Project No.11393 Scoping Document 1 Dear : The City of Saxman (City), Alaska, is proposing to construct a small hydroelectric generating plant near Mahoney Lake, about 5 miles northwest of Ketchikan. The project must be licensed by the Federal Energy Regulatory Commission (FERC) before construction can begin. Previously, the City sought input from interested parties during the Stage I consultation process in accordance with FERC regulations (18 CFR 4.38(b)). An Initial Consultation Document (ICD) was distributed on March 16, 1994, to interested agencies to provide a general overview of the proposed project design, operation, and potential impacts. Following distribution of the ICD, two agency/Native American/public meetings were. held in Ketchikan on April 26, 1994, to discuss the proposed project and potential environmental impacts, and identify data to be obtained and studies to be conducted as part of the FERC consultation process. Written comments were due within 60 days following the joint meetings or by June 25, 1994. Comments received on the ICD were incorporated into a Final Consultation Document (FCD). The FCD, which was distributed on August 8, 1994, outlined the studies that are currently being performed during the Stage I consultation process and contained copies of all consultation correspondence and responses that were developed in reply to concerns addressed in agency comment letters. Consistent with the authority granted under Section 2403(b) of the Energy Policy Act of 1992, the City will prepare an Environmental Assessment (EA) for the Project and will file that as part of its license application to the FERC in lieu of preparation of Exhibit E, the environmental exhibit traditionally prepared as part of a license application. To that end, the City has entered into a Memorandum of Agreement (MOA) with the FERC and the U.S. Forest Service establishing cooperative procedures for the preparation of the EA. Under this MOA, FERC and the Forest Service have agreed to advise the City in the preparation of the EA to assist the City in developing a document that complies with the National Environmental Policy Act (NEPA) . with respect to analysis of the potential environmental impacts of the project. The details of this cooperative procedure were set forth in the February 13, 1995 letter from FERC to the individuals and entities currently on the project distribution list. HDR Engineering, Inc. Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 March 9, 1995 Page 2 To support and assist the environmental review of the project, the scoping process is being initiated to ensure that all pertinent issues are identified and analyzed, and that the EA is thorough and balanced. The attached Scoping Document 1 (SD1) is being circulated to solicit written comments from federal, state, and local agencies, Native American groups, and all other interested parties. The specific request for your written comments is identified in Chapter 3.0 of the SD1. In addition to written comments, two scoping meetings are planned to solicit any verbal input and comments you wish to offer on the scope of the EA. Both meetings will be held at the Westmark-Cape Fox Hotel, 800 Venetia Way, Ketchikan, Alaska. The first meeting will be at 7:00 PM on Wednesday, April 12, and will be oriented toward the public. The second meeting will be oriented toward the resource agencies and will begin at 9:00 AM on Thursday, April 13. The public and agencies may attend either or both meetings, however. Written and verbal comments will be treated equally. A site visit is tentatively planned for the afternoon of April 12. Those who would like to visit the site should contact Mr. Doug Campbell at the Cape Fox Corporation, (907) 225-5163 prior to April 1. Those attending the site visit should plan to meet in the lobby of the Westmark- Cape Fox Hotel at 1:00 PM. You may direct any further questions or concerns to me at (206) 453-1523, or Mr. Vince Yearick, Office of Hydropower Licensing, Federal Energy Regulatory Commission, Washington, D.C., (202) 219-3073, or Mr. Linn Shipley, Acting District Ranger, U.S. Forest Service, Ketchikan, AK, (907) 225-2148. We invite your participation in the scoping of the Mahoney Lake Hydroelectric Project. Sincerely, HDR ENGINEERING, INC. Mithal Vv. timac Ley Michael V. Stimac Manager, Licensing & Environmental Services cc: Guy Galloway - City of Saxman Doug Campbell - Cape Fox Corporation John Braislin - Betts, Patterson, & Mines Don Clarke - Wilkinson, Barker, Knauer, & Quinn Jack Snyder - HDR Engineering 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 Nevin Holmberg U.S. Fish & Wildlife Service 3000 Vintage Blvd. Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gamble 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. Linn Shipley Acting District Ranger U.S. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. David Rittenhouse U. S. Forest Service Federal Building Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 Mr. Don Ranne 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 Regional Office Federal Energy Regulatory Commission 1120 SW Sth Avenue, Suite 1340 Portland, OR 97204 Ms. Lois Cashell Federal Energy Regulatory Commission 825 N. Capitol St. NE Washington, DC 20426 Area Director Bureau of Indian Affairs P.O. Box 3-8000 Juneau, AK 99802 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 Kerry Howard, Acting Director Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 Ms. Lisa Weissler Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811 Ms. Susan Viteri Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99801 Ms. Joan Hughes Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Mr. Barry Hogarty Alaska Department of Environmental Conservation DEQ/SE Region DEC 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 Geary 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, Director 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 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Mr. Steve Hoffman Alaska Department of Fish and Game Habitat Division 2030 Sealevel 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 Agency 480 W. Tudor Anchorage, AK 99503 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Mr. C. L. Cheshire, Director University of Alaska - Southeast Economic Development Center - UofASE 7th Avenue and Madison 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 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 Borough Planner Ketchikan Borough Planning 344 Front Street Ketchikan, AK 99901 Mr. Jim Boetberg Ketchikan Gateway Borough 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. William Jones Acting 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. Thomas Stevenson 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. Ester Shea Tongass Tribe 835 E. Seasame Street 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 Mr. Mike Moyer Tongass Conservation Society 501 Front-B 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 123 Stedman Ketchikan, AK 99901 Mr. Jack Lee Tongass Sportfishing Association P.O. Box 5898 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. and Mrs. Forrest DeWitt Box 5252 Ketchikan, AK 99901 Mr. Guy Galloway Administrator City of Saxman Route 2, Box 1 Ketchikan, AK 99901 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 Mr. Mike Moyer Tongass Conservation Society 501 Front-B 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 123 Stedman Ketchikan, AK 99901 Mr. Jack Lee Tongass Sportfishing Association P.O. Box 5898 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. and Mrs. Forrest DeWitt Box 5252 Ketchikan, AK 99901 cs | TONY KNOWLES, GOVERNOR OFFICE OF THE GOVERNOR OFFICE OF MANAGEMENT AND BUDGET DIVISION OF GOVERNMENTAL COORDINATION C soutHCENTRAL REGIONAL OFFICE Ucn OFFICE oO PIPELINE COORDINATOR’S OFFICE 3601 “C* STREET, SUITE 370 P.O. BOX 110030 411 WEST 4TH AVENUE, SUITE 2C ANCHORAGE, ALASKA 99503-5930 JUNEAU, ALASKA 99811-0300 ANCHORAGE, ALASKA 99501-2343 PH: (907) 561-6131/FAX: (907) 561-6134 PH: (907) 465-3562/FAX: (907) 465-3075 PH: (907) 278-8594/F AX: (907) 272-0690 April 5, 1995 Mr. Micheal Stimac HDR Engineering, Inc. Suite 1200 500 108th Avenue, NE Bellevue, WA 98004-5538 Dear Mr. Stimac: SUBJECT: MAHONEY LAKE HYDROELECTRIC PROJECT STATE ID #AK9504-08JJ - FERC PROJECT NO. 11393 SCOPING DOCUMENT 1/STAGE II CONSULTATION Thank you for submitting copies of the Scoping/Stage II Consultation document for the Mahoney Lake Hydroelectric project proposed near Ketchikan to the State of Alaska. The document and your correspondence explain the special review procedures approved by the Federal Energy Regulatory Commission (FERC) for the Mahoney Lake project. The State strongly supports the consolidation of review under the National Environmental Policy Act (NEPA) with FERC preapplication consultation review. Bringing NEPA requirements to the front of the process allows assessment of issues at an early stage prior to State coastal consistency review and filing of the final license application. The State encourages FERC to consolidate review stages for other applicable hydroelectric projects within Alaska. The Division of Governmental Coordination (DGC) serves as the primary contact within the Governor’s Office for coastal zone management issues and coastal project reviews. We note that HDR submitted documents to both our office and to the Governor’s Office. Please be advised that DGC is responsible for addressing coastal zone management issues during project reviews. While you are welcome to send copies to the Governor’s Office, the Southeast Consistency Review Section of DGC must receive copies of project documents and correspondence to process project reviews. For Mahoney Lake, please send all correspondence to Ms. Christine Valentine of the Southeast Consistency Review Section, and please remove Ms. Diane Mayer, Ms. Lisa Weissler, and Ms. Susan Viteri from your distribution list. The enclosed project information sheet includes a State Identification # (#AK9504-08JJ). Please refer to this number along with the FERC project # in all future correspondence to this office regarding this review. We thank HDR Engineering for directly distributing the Scoping/Stage II Consultation document to review participants. By a copy of this letter and the enclosed project information sheet, we are reminding review participants that final Scoping/Stage II Consultation comments are due to HDR Engineering by May 15, 1995. The comment deadline is set in accordance with FERC procedures. We are also reminding review participants of the dates for upcoming meetings and a site visit. As the process for obtaining a FERC license requires extensive preapplication assistance, this review is informational in nature. The purpose of this review is for the reviewers to provide you with information about pertinent environmental and socioeconomic issues, identify reasonable alternatives to the proposed action, suggest additional studies, and identify permits which will be necessary. The information provided during this review should assist you in developing the FERC license application. A consistency review per the Alaska Coastal Management Program ordinarily occurs when all permit applications and public notices required for the project are received. When FERC officially accepts the hydroelectric application, a public notice will by issued by that agency. DGC will consult with FERC to discuss the appropriate timeframe for the pending coastal consistency review. Please call me at 465-3177 if you have any questions or comments. Sincerely Christine Valentine Project Review Coordinator cc: Jackie Brown, Governor’s Office, Juneau Linn Shipley, USFS, Ketchikan Vince Yearick, FERC/Office of Hydropower Licensing, Washington D.C. a] PACKET DISTRIBUTION LIST Joan Hughes, DEC, Juneau Lana Shea, DFG, Juneau Jack Gustafson, DFG, Ketchikan Elizaveta Shadura, DNR, Juneau John Dunker, DNR/DOW, Juneau Bill Garry, DNR/DPOR, Juneau Judith Bittner, DNR/SHPO, Anchorage Bill Ballard, DOT/PF, Juneau Mike McKinnon, DOT/PF, Juneau Melanie Fullman, Coastal Coordinator, Ketchikan Gateway Borough The Honorable Alaire Stanton, Mayor, Ketchikan The Honorable Jim Carlton, Mayor, KGB Charles Denny, President, Cape Fox Corporation, Ketchikan Louis Thompson, Kavilco Inc., Ketchikan Rick Harris, Sealaska Corporation, Juneau Ron Wolfe, Klukwan, Inc., Juneau NOTE: If you did not receive a copy of the Mahoney Lake Hydroelectric Project Scoping Document 1, you may request one from Michael Stimac, HDR Engineering, Inc. (phone 206-453-1523). i SVAME OF ALASICA) | persone aro OFFICE OF THE GOVERNOR CENTRAL OFFICE OFFICE OF MANAGEMENT AND BUDGET CONSISTENCY REVIEW UNIT DIVISION OF GOVERNMENTAL COORDINATION 240 MAIN STREET, SUITEE C CONTACTS P.O. Box 110030 JUNEAU, AK 99811 DEC Joan Hughes............ 465-5345 Fax: 465-5362 DFG Jack Gustafson .......... 225-2027 228-2676 DNR John Dunker............ 465-2533 586-2954 ketAhikan Melanie. Fe man 2Z6-64/0 242-3437 PROJECT INFORMATION SHEET PROJECT TITLE: Mahoney Lake Hydro Project 2nd Consultation-Scoping STATE I.D. NUMBER: AK 9504-08JJ ; DGC CONTACT: Christine Valentine Phone: 465-3177 Fax: 465-3075 APPLICANT/PROPONENT: Saxman, City of i AGENT: Michael Stimac Phone: 206-453-1523 Fax: DIRECT FEDERAL ACTION: No REVIEW TYPE: NEPA-SCOPING i ACTIVITY TYPE: HYDROELECTRIC PROJECT LOCATION: ! i Nearest Coastal District: KETCHIKAN GATEWAY BOROUGH Project is INSIDE the District Boundary District Plan Approved: Yes REVIEW SCHEDULE: 50 DAYS REVIEW MILESTONES: Days ea erect ee rice cic Stier 04/05/95 *First Scoping Meeting (7:00pm-public oriented)......... 04/12/95 Pete VISIR yd neeslatekelaeanl etal lela oly Hellen al Mande ellel ted 04/12/95 *Second Scoping Meeting (9:00am-resource agency oriented) . 04/13/95 Comments Due To HDR with copy to DGC: ........... 05/15/95 *Scoping meetings will be held at the Westmark-Cape Fox Hotel in Ketchikan, Alaska. **If you plan to participate in the site visit, you should contact Mr. Doug Campbell at the Cape Fox Corporation, (907) 225-5163 prior to April |. PROJECT PREVIOUSLY REVIEWED UNDER STATE I.D. NO. AK 9403-33JJ (First consultation) ae APPROVALS (AGENCY, APPROVAL TYPE AND NUMBER): one FEDERAL APPROVALS (AGENCY, APPROVAL TYPE AND NUMBER): None CLOSEOUT INFORMATION EXTENSION GRANTED FOR: SOS SONS CLOCK STOPS: Stopped On: Reason #: REQUESTOR FOR EXTENSION: ELEVATION TO: __ Director ___ Commissioner ELEVATION BY: ACTION AT CLOSEOUT: Closeout Date: District Comments Received: ___ Yes ____ No For Conclusive Consistency Determinations: For Other Reviews: Comments Submitted: ___ Yes ____ No ADDITIONAL COMMENTS: Closeout entered into computer: Formal Information Request Project in Unorganized Borough DNR Disposal of Land Miscellaneous Applicant Request Proposed Finding En Route Public Hearing Held Field Review SMCRA Unusually Complex Project Restarted On: Consistent Consistent with Stipulations Inconsistent Withdrawn KETCHIKAN PUBLIC UTILITIES 2930 TONGASS AVENUE KETCHIKAN, ALASKA 99901 TELEPHONE 907-225-1000 FAX 907-225-1888 April 12, 1995 pf cm ev E| | MUNICIPALLY OWNED 1! APR 13 1995 SLECTRIC TELEPHONE WATER Return Receipt Requested HDG 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) i 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 i 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 would 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 buiit 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\INANCYL\WPI\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 on a 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 Falls. 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 service 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 Falls 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\NANCYLIWPIDATA\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 JOEL Z= pig Thomas W. Stevenson General Manager TWS:nil Attachment cc: 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 wit of | 1eicninan July 28, 1$84 Mr. Forrest DeWitt, Mayor City of Saxmen Saxman City Hail Saxman, Alaska $SS01 Dear Mayer DeWitt The City Council of the City of Ketchikan has asked me to write ‘o you regarding the Mahoney L2ke Hycroelecric projec: that you are currently reviewing for sossibdle deveicoment The City Council recently came to the City of Saxman ‘o Oe Onefed by your consuitemts and Cape Fox staif and we ecoreciate very mucn your sharing the gcais you Aave-jor develcoment of she Mehcney L2ke Projecz. After discussion end review of the sifeccs of the Mahoney L2eke Project on the deveicpment of the Intertie Projecz, it is cleer thet we cannot oreceed with the Intertie if the Mahcney Lake Prciecz is Cuiit iirst That means the long range planning icr the Imerte wiil have ceen lost end we will have to refund monies spent to date that have ceen ecvancsd on the Imterte. The community wiil iose this Sé0 million dollar grant. Through the joint effcrts ot the City of Saxman, the City of Ketchikan and the Ketchikan Gateway 8crough, the Lsgisiative Liaiscn has teen succsssiul in promoting and in obtaining the initial funding for this croject which has teen a sriority project ‘or cur whole area for many years. From a presentation (which is attached) irom Ketchiken Public Utilities, it is clear that the timing of your project will create the termination of the Swan Lake and Tyee Lake Intertie. The City Council has asked that the City of Saxman delay deveicoment of the Mahoney Lake Project so that it will come on line aiter the Intertie Project comes on line. The City Caunci is in a position such that it cannot endorse or emer imta negotiations with the City of Saxman for the Mahoney L2ke Project because if your project comes on line pricr to the Imertie Project, the Intertie Project wiil Se lost forever with the junding scurce as legislated through Senate Bill 106/125, Eighteenth Lecisiature-First Session. Thereicre, emtering imto a Surcnase power agreement on Mahcney wil 2tfecavely terminate the projec: the community has said jor many years is its ccal—‘o Ouild she Interte. The Council and | sincerely appreciate the fact that the Manoney Lake Prcject is an imcenant sccncmic development orciec: ‘cr the City of Saxman. We succor ycu in :hat regard. Unfortunately, the iming of the projec: olaces us in the unccmicrable ¢csiticn of Mr. Forrest DeWrt Juty 28, 1994 Page 2 killing a project we need as a utility in order to best oravide a long term power source for all our Customers and which we promoted and obtained funding for through the State. Mayor, this is obviously a very imcortant issue to all parties and if you feel you cannot delay the Mahoney lake Project, let's get together and discuss where we go from here. ls = fj fe a Of et eS Alaire Stanten, Mayor City of Ketchikan Attachments co Ketchikan City Counciimembers KPU General Manager MEMORANDUM TO : Maver Alaire Stanton and City Counc: FROM : Thomas W. Stevenson, KPU General Manage \/ =~ iMP4CT_OF THE SSOCPOSED MAHONEY LAKE SYOROELESTRIC FACILITY CF THE CITY OF SAXMAN/CAPE £3DXK CORPORATION SUBJECT: ECCNOMICS OF THE PSOPOSED SWAN/TYS= INTERTIE AND THE | have inciceted to the Councd that the imcec: ot the Méhcney Lee orciect causes séricus ercciems ‘cr the icng range clenning thet the Utility sec cone :n tts cuest to cot2in the jinéncing end uitimate constucicn of he Swen/Tyee Intere. Snetiv, che Utility nes pursued the cconstucicn of the Swen/Tyes Interce ‘cr cver 3 years. For che pencd since 1SS0 when | came io the Utility, anc in f@cz cunng the imerviewing crecess, it wes mMemticned to me that he mest imecrerm !onc rence 2cuvity chat the community ‘wanted wes ‘0 nave its Icng ‘erm Scwer scurce in ia@cs vié wis interde. The last four yeers we have had the Swen/Tyee Imtertie 2s the ‘co “Scienal cnenity for Southeast Alesk2....Secziaeimtertie anc Read Camider. =very lecisiaicr nat hes served this 2rea since iSSO hes mace this Interde 2 cricnty. The communntty iecisiatve iiziscn nes ned us make oresentations to cbtain the iunding ‘or this crcjecz The Utility could nave ouiit he Mancney Leke Projecc it wes ‘est excicred in the mid i$€0’s and hes nad no less than three erctessional reviews icr jessiciiftv. Tne Swan L2ke/Leke Tyee Intertie facility wes chosen icr the fcilawing reesans: Ue It provides us with én additional 20,CC0,000 kWH’s at elecmicity. (We will use about 163,600,CCO kWH's in iS). 2s it will maintain cr reduce the cost of eneray Tom cur oarictoaticn in the Four Oam Pcol because we can spread our overnead costs over 4cciticné! x<WH séles since we wiil Stert using enercy ‘that is literally “water over the dam* = Tyee end unused at oresent ‘t will orovide us with the ability tio Tansver aiecricsty Séck 2nc icmh cerween ?etersourg, Wrengeil and Ketcniken in emergenciss. ro) 4. it wiil crovide for joint cispatcn anc ioimt coeretions ct our wo maicr hyarcelecnc (~ C Memorandum - Mayor and City Councd Juty 21, 1994 Page 2 aw o It will provide us with the access ‘to all additional hydrcelecnc sites cetween Ketcnikan and the end of the line at Petersturg when consicenng iuture power supply sources. Tne Tyee Project aireaay has a third tay installed within the ocwernouse and it wiil only require 33-9 miilicn to inscail a generatcr cecebie of sroducing betwesn 10-15 MW'Ss of ceaking power. availacie to all Southeast Alasxa utilities will Ce an invaluacie ‘oci in orovicing energy octons for the future wih the acciticn of this intertie link. The Intertie itseif may srovide an ceticn jor the Ménoney Lake croject and projeccs like it for sales opportunities to other Scutheast utilities in the ‘uture. The Interte orovides 2n income seam io fay ior the Interte 2nd therefcre the cost to Ketchikan resicents is nil and the once of the energy ther goes across the transmissicn line is a known quamtty. (Currently, 6.6 cents cer Kwh). WHAT HAPPENS IF THE MAHONEY LAKE PROJECT ENERGY IS USED BEFORE THE INTERTIE POWER? 1. re) oa7-S2 The inmterte will not be buiit as the energy irom the Interte weuld not start being used by KPU ratepayers until the year 2007. A. | would not recommend to the Counci that we ouild a Tensmission line that would not be used fer 9 years other ‘han ior surplus sales to the puip miil. 8. We would not be able to repay ar justiy economically a trensmission line that would not be used for 9 years. The State Legisiature will stop annual allccations towards this sroject since it will be economically inteasidie to continue. We wiil lose a longer term energy source with its oulit in coerational oenefrits (inctucing the fact that the State has aporoved the funcing sources for the Intertie througn its legisiature), ior a short term ik that provices none ct the operational optcns. We supsutute a projec: hat wiil interconnecz hydro sites that nave different climates for projects that lie in the same hycro area. i.e. wnen we are in crought in our own nydres, Manoney wil be in drougnt also. This past year ‘wnen we were running our dieseis due *o insutfic:ent raintail, Tyee was in a soiil ccnciticn. Therefore, we wiil lose some ct that soiil in Cimates ‘0 Calénce cur rescurce nescs. C C Memorandum - Mayor and Cty Csunci Juty 21, 1994 Page 3 5. We wiil suOscatute the Four Oam Pccl rate ct anergy icr 2 nigner Mancney Lake oower rate. We have concems 2s to whether ne Mencrey Leke =rcject will consistently erecuce up to + MW'S cf Jirm Sower, uncer ihe scenanc crcccsed. And we zre desircus ct naving the anercy come irtc she KPU sysiem Sy interconnecing with cur 24.3 kV yansmissicn ‘ine :o crevices icr saiery in cesé ScmMeming neccens io the 175 kV Swen Leke Tensmissicn ‘ine. (An cptcn we 2rs Tying to inccrcorate imto she Swan/7yee Interie.) o tis We wiil cse 2il surcius power saies avaliable co use Shrcucn cur agreement with the Four Cam Pca. CAN THE INTeRTIE AND THE MAHONEY LAKE PROJECT BE BUILT SiMULTANEODUSLY? i Yes. Sut refther will Oe cost stfecave 2nd neither wiil crcvice 2 return on the invesanert :o we Suiicers ct he <rcjecs. So wniie the answer ‘s ves ‘he reality is that hey will nct ce Culit simuitanecusiy. HOW SHOULD THE TWO PROJECTS 3E SUILT? Te From the srcscecive of the communry and és cuclicty cwned utlity, we nave Cetermined trcugh cur !ong range sienning ‘0 crceceed ‘mith ‘he interte orojecz because ct its ocerationa! jexbility and iS Greater KWH 2vaiieniiity and because cf the iavcrecie cost consicereticns througn use of State ‘uncing that we are unlikely ‘O ver recsive agéin itr this crojecu As the communities stated coal ct deing the numcer cne regicnal cricnty ‘tr the last several years (@ memter of that team wes Maycr CeWitt) we olaced it cn our lecisiative onomty list as something we wamed as 2 community. Fram ‘the srosoecave of the City ct Saanan and Cece Fax, it orovices an econemic ceveicomemt opecrunity wnicn wil srcvide 3 St@ecy and cermanemt income steam if- Vy A. They 2re adie to obtain a sermanert sales eqreememt with KFU jor 2 set arice jor curcnase ct the cower. 8. A scmewnert higher nsx invcives selling the ecwer to us uncer PURPA (Puolic Utility Reguiatcry Policies Acc ct 1£78) wnicn mencates het KPU ourchese the pcwer at the avoiced cost ct he next scurc2 ct ecmica! Generaticn we wouid use 7 the Manoney Leke prcjecz were not avaiieoie. Cc C Memorandum - Mayor and Cty Counci Juty 21, 1994 Page 4 C. This meens that Menoney would sucplent, at cresent, the sower we Generate out cf cur @aiiey Diese! Generaters if they cen get the feccity oulit Secre the Imerde is Suiit (That avoiced cost wculd have to be determined). 1). if the interie language requires us ‘Oo ourchase she cower itcm the Imerde regardless, then the avoiced cost wculd de whatever the prevailing Four Oam Pool cost would oe. 2) If the Imterde is constucced jrst, then the avoiced cost is ihe Four Dam Pool prevailing cost. SO WHAT DO WE DO? te {v ov If the City Council agrees to enter into a long term ocwer sales ecreement with the City of Saxmen ior pewer out of Manoney Lake, you are stfecavely kiiling the Interte projec. If the City of Saxman ouilds the Mehcney L2ke croject before we nave the Imertie built, we are killing the Interte projecu If we cont crovice 4 guarantee ct energy =t a set erics to the City of Saxman, it may make their projec: more Giificuit to develop. Since Saxman participated in the Legisiative Liaison with the other governments cn this Isiend, and since the Mahoney L2ke eroject was net one of those orojecss, it would seem that in the interests of working together ior the iuture of the Isiand, they would agree to delay the development of Mahoney Lekes to be the “next generating source to come cn line for the community ater the Intertie wnich they helped © promote. It is clear that one cr both of these crojects wiil fail if we try to build them concurrently, so we should stick to our onginal olens. To do otherwise is gaing to create navoc, nard feelings and the loss of economic opportunities for all, if nat in the shert run, but then in the iuture. SHOULD THE COUNCIL ENDORSE THE MAHONEY LAKE PROJECT? ls Yes, crovided that it is agreed that it will come on line ater the Interte is constucced. Otherwise, we snouid respeccuily dectine to emter imto any commec: with Saxman jor Mancney Leke cower, AND, Yes, ance the City ct Sexman’s jinencal sermer, the Cape Fox Carperatcn and KPU have settled the Beaver Fails land cisoute. HII We Memorandum - Mayor and Cty Counci Juty 21, 1994 Page S a To do otherwise wiil mean the sccncmic ieesibility and enc :o the Swan/Tyee Interte. DOES THE MANAGEMENT OF KPU SUPPORT THE DEVELOPMENT OF THE MAHONEY LAKE PROJECT? 1. Yes, with the concems 2ccressed 2ocve cut ot he way. st Yes. 7 we <an 2cres ‘Oo have the ccwer enter imo he XFU system on cur 34.5 kV tTansmission ‘ine. 1y if we can ce 2 carmer in essunng thet che cuaiity comme! enc ne constucicn wiil crovice icr ccerating ificiency énd keeo cceretions anc maintenance io 2 minimum. re) 4. We can 2cree co maximize the cutout with he cost of the ‘accity. WHY DIDN’T KPU 3UILD MAHONEY LAKE AFTER STUDYING IT THREE DIFFERENT TIMES? ne The jrst ime we diGn’t culid t wes Secause we ccted to buiid Swan Lake. 2 Tne seccnd ime we cicn’t culld t wes oecsuse we wanted ‘Oo cptimize our Qaricicaticn in the Four Oam Pccl 2nd tutid che imerte. WHY ISN’T USE OF MAHONEY LAKE POWER CHEAPER THAN RUNNING THE BAILSY DIESELS? 1 It isn’t Secause the evciced cost at running Gatiey is simoty the cost of ‘ue! and the weer on the genereticrs. All other costs are aireecy Oeing incurred at the oresent ume. 2s If we leave the Gailey generators ccwn, énd use Mencney Power, we sill incur ail current costs ct running Saliey, 30 we cay wert sver the cost 's determined to be and mayce that cost is estaniisned 2 2 levei nicner than our éccual avcided cssvs. WHAT OTHER CONCERNS DOES THE MANAGEMENT OF KPU HAVE ABOUT THE MAHONEY LAKE PROJECT? ie That it is being consmucced cutsice he scoce 2nd ccnmci of he Utility wnicn will Nave ‘o rely cn its cutout yet we Teve no Manecememt cversicm or comme! on Acw it sets conswucced or wnere it mers into Cur system ‘cr che Sest use cr the Utility. C C Memorandum - Mayor and Cty Caunci Juty 21, 1994 Page 6 2 That KPU is a not a jor-promt municcoally owned utlity that cetermined ‘hat the Mahcney L2ke orcjec: was not the croject it ‘eit was in the Cest interest ct the ratepayers and the ccommunnty it serves inciucing the City of Saxman, @ 2 once less than we would now expect the crojec will cost us by adcing cromis to the City ot Saxman and Care Fox Ccrporation. TWS:nil Attachments coors a Le crtu . i , . ty U to pba ep nap COP Mr eee Op age ate oe er} tf § Gere sob Ot est tt tet ed he cl "" gy mT} 2 wt A tp. (2). t- wl ; rep oop {4 Ik. 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A & | -t Mn HH fy ) a oO th ry iy) 71) }» < iD 7 a (a w n a | oO \ a+ (Oo in iy re, April 25, 1995 (See Attached List) Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear : Enclosed are the draft minutes from the National Environmental Policy Act (NEPA) Scoping Meetings that were held on April 12 and 13, 1995, for the above-referenced project. Please review the minutes and forward any changes or comments you may have by May 9, 1995. We appreciated your attendance at the meetings and look forward to your participation in this project. Sincerely, HDR ENGINEERING, INC. Mihak Vo Sime HE Michael V. Stimac Manager, Licensing & Environmental Services Enclosure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Jack Snyder, HDR Mark Dalton, HDR Lisa Fortney, HDR John Morsell, NES Wade Lindsay, WBKQ HDR File, B.4.1 Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 HDR Engineering, Inc. DISTRIBUTION LIST Ms. Teresa Trulock Ketchikan Ranger District U. S. Forest Service 3031 Tongass Ave. Ketchikan, AK 99901 Mr. Don Ranne Ketchikan Ranger District U.S. Forest Service Federal Building Ketchikan, AK 99901 Mr. Jim DeHerrera U.S. Forest Service 3031 N. Tongass Avenue Ketchikan, AK 99901 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 Ms. Nan Allen Federal Energy Regulatory Commission 810 First St., NE, Room 1004 Washington, DC 20426 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, Room 205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game 2030 Sea Level Drive, Room 205 Ketchikan; AK 99901 ~ Mr. Rich Trimble Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. Jan Risla Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Ms. Melanie Fullman Ketchikan Gateway Borough 344 Front St. Ketchikan, AK 99901 Mr. William Jones City of Ketchikan 334 Front St. Ketchikan, AK 99901 Ms. Wendy Harkins Sitka Electric Department 1306 Halibut Point Road Sitka, AK 99835 Mr. Hank Newhouse P.O. Box 9508 Ketchikan, AK 99901 Mr. Craig Moore State Parks Advisory Board P.O. Box 5776 Ketchikan, AK 99901 pRAF MEETING MINUTES ‘de, 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 Teviewed 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 HDR Engineering, Inc. Suite 1200 Telephone 25 500 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, ina 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 agency. 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 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 application. The 3 BA 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 is 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 a 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, 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. 5 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 asa 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 b2 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 Cape 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. 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 saiNiaaila ey 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 Emest 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. DRAFT MEETING MINUTES cs PROJECT: Mahoney. Lake Hydroelectric Project, FERC No. 11393 SUBJECT: NEPA Scoping Meeting, Moming 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- HDR Engineering, Inc. Suite 1200 Telephone fe. 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 tum 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 mun 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. 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. — alii . 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 BA. The fish data will be integrated with the temperature data during preparation of the BA to try and attempt to model intergravel temperature post-project to predict what the impacts might be on salnion egg incubation. Vicki Davis asked about the studies for the USFS and if studies would be conducted for USFWS candidate species. Mark Dalton sesponded 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. 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. 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 word 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, tums 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 that last waterfall. The water would be returned into that pool. There will be no loss of habitat 8 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. 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. 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 doés 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. 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. 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. 10 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. il May 9. 1995 Vicki Davis Ecological Services - U.S. Fish and Wildlife Service P.O. Box 23193 Ketchikan, AK 99901 ~ Subject: Mahoney Hydroelectric Project Dear Ms. Davis: I enjoved meeting with you and Steve Brockman of your office at the Mahoney Hydroelectric agency scoping meeting in Ketchikan last week. I thought the meeting went well and I appreciated all the agency comments that were offered at that meeting. In response to your comments, I am providing you with information related to the project that should address some of the issues you raised. First. I have enclosed a copy of the sensitive plant species survey conducted by staff of the Alaska Natural Heritage Program. This document presents the results of the field survey of the Mahoney project area on U.S. Forest Service lands conducted by ANHP and HDR staff. Please don’t hesitate to call Anne Leggett of our staff about the specifics of the survey. I have also researched our records of previous consultation with U. S. Fish and Wildlife Service staff about the project and the need to consider other species such as category 2 candidate species. Enclosed is a letter from John Lindell which discusses certain species of concern that may occur in the vicinity of the project. including two subspecies of peregrine falcon. the Alexander Archipelago wolf. and three category 2 animal species. One subspecies of peregrine falcon (Falco peregrinus tundrius) has been delisted and the wolf has been placed in category 2 candidate status since our written correspondence with Mr. Lindell. We conducted ground surveys of the project area for other species of concern in June, 1994. John Lindell also mentioned in his letter two category 2 plant species. One of these (Carex /enticularis var. dolia) was sought (and found) on U.S. Forest Service lands during the sensitive plant survey. The other (Calamagrostis crassiglumis) was not been sought during the plant survey. Please note that no mention was made in that letter of the spotted frog being a species of concern. We conducted our field surveys based on the input from agencies such as the U. S. Forest Service and the U.S. Fish and Wildlife Service. While our surveys did not reveal the presence of spotted frogs in the area. we were not specifically looking for them. I would appreciate additional guidance from you if we are to consider the spotted frog further in our environmental assessment. Thank you for vour assistance with this project. I look forward to working with you on this important project for the community of Ketchikan. Sincerely. HDR ENGINEERING. INC. 7 ‘ AT Sao Mark Dalton Director of Environmental Services Enclosure ce: Mike Stimac. HDR Bellevue Doug Campbell. Cape Fox Corporation HDR Engineering, Inc. 2525 C Street Telephone Suite 305 907 274-2000 Anchorage, Alaska Fax 99503-2689 907 274-2022 11-K84LH S TAYE (i F | fi LL AS mK nN SE eseeta seats DEPARTMENT OF FISH AND GAME Merc Axe 90500" PI ‘: (907, 5S - '7 DIVISION OF HABITAT AND RESTORATION FAX (G07) 282676 May 11, 1995 Mr. Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. 4 500-108th Avenue NE, Suite 1200 Bellevue, Washington 98004 Re: Mahoney Lake Hydroelectric Project Scoping FERC Project No. 11393 Dear Mr. Stimac: J We have the following comments regarding this current phase of the Mahoney Lake Hydroelectric project and our review of the "Scoping Document 1" prepared. by HDR Engineering, Inc: fi Lower Mahoney Creek. Concerns need to be addressed in more detail regarding flow- dependent impediments to migrating fish in lower Mahoney Creek. We agree with the draft Fisheries and Aquatic Resources Studies report of December 1994 that a potential issue of concern is the blockage of lake access to migrating sockeye salmon during some flow conditions in Lower Mahoney Creek. This report states that, "Very low flows prevent access and, presumably, extremely high flows would also create blockage conditions due to high velocity." It is important to know under what flow conditions adult sockeye salmon currently access Lower Mahoney Lake. Although the project can probably be designed and operated to accommodate the flow conditions which provide passage for migratory fish under natural conditions, the information presented thus far does not clearly show that this is the case. Consequently, the applicant must assure that post-construction operational flows will be such that they do not cause more of a blockage to migratory fish at the time of spawning than occurs under natural conditions. If the information currently available is not sufficient to determine this, then additional study should be accomplished to address this concern. aonrerycled paper b ct Mr. Michael V. Stimac 2 May 11, 1995 Although gage data may be available, or at least estimated at the location of the partial barrier, no data appears to be available to correlate this with the timing of fish movements into the lake. Consequently, it appears that at least one season of on- site field data needs to be collected at the location of the boulder barrier during the time of the spawning run. This data is necessary to verify that the predicted fish movements actually can and do occur at specific estimated flow parameters. We recommend that the applicant hire a qualified contractor to collect the following data during, at least, the 1995 sockeye spawning run. A. Velocity and discharge data on Lower Mahoney Creek. Data collection devices should probably be located where they could also be used and maintained after the hydroelectric project is constructed. Locations. to be evaluated should probably include consideration of placing gaging instrumentation at the present partial boulder barrier, even if a gage is located elsewhere on Lower Mahoney Creek. This may be particularly helpful if the physical configuration of the barrier experiences change over time. B. Visual or electronic verification of the timing of blockages to fish passage and the thresholds where flow levels permit fish passage. This data is needed so that it can be correlated with the flow data that is collected. The results of this data collection will be used to assure that adequate fish passage will be provided during the operation of this hydroelectric facility. We feel that the regulation of flows to replicate natural conditions during the spawning run is the best way to achieve fish passage and do not recommend barrier modification in Lower Mahoney Creek. Maintenance of Groundwater Upwelling Flows and Incubating Eggs. It is unclear what hydrological effects might occur in spawning redds if the hydroelectric plant is shut down for extended periods of time during September-May to allow for the recharge of Upper Mahoney Lake. This impact should be modeled to assure that sockeye salmon redds will not become dewatered or experience mortality from the manipulation of stream flows. The Necessity of Post-construction Monitoring. The applicant needs to plan and implement a post-construction fisheries monitoring program to assure the operation of this hydroelectric facility maintains natural fish productivities. Included in this should be plans to continue to monitor intragravel temperatures in sockeye spawning areas until the project is complete and for at least 5 years after operation begins. Data collection needs to be sufficient to determine Mr. Michael V. Stimac 3 May 11, 1995 cause and effect relationships to fisheries and recommend remedial actions in the event this becomes necessary. Request for Preliminary Stipulations at this Scoping Phase. At the meeting on April 13, 1995, it was requested that the agencies provide detailed preliminary stipulations at this stage of the project. Stipulations for fish habitat permits at stream crossings will be developed when applications are processed by DGC for state-review. Other requests for stipulations by ADF&G will be based primarily upon the above referenced topics and informational needs. An operating constraint for ADF&G is that past and current budget cuts are causing the Habitat and Restoration Division of the Department of Fish and Game to have insufficient staffing. Additionally, in the future, this situation may cause ADF&G to ask project applicants to seek fish and wildlife information from the Federal agencies, or result in our deferring the development of final stipulations to the U.S. Fish and Wildlife Service, or National Marine Fisheries Service. The Mahoney Lake hydroelectric project, though, must be designed and operated so as not to degrade the naturally-occurring aquatic productivity of this system. We hope our comments thus far will help to accomplish this objective. More detailed stipulations will be forthcoming or deferred to an alternative source once all of the information has been collected and the final review is initiated. We hope this response is sufficient to provide the input necessary for assisting in moving to the next phase of this project. We appreciate the opportunity to comment. Sincerely, a ack Gustafson ea Habitat Biologist cc: Lana Shea, ADF&G, Douglas Christine Valentine, DGC, Juneau Joan Hughes, ADEC, Juneau John Dunker, ADNR, Juneau Guy Galloway, City of Saxman Nevin Holmberg, USFWS, Juneau Steven Pennoyer, NMFS, Juneau May 12, 1995 (See attached list) Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear : 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 Enclasure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Corporation Jack Snyder, NDT Don Clarke, Wilkinson, Barker, Knauer, & Quinn HDR File, B.4.1 Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 HDR Engineering, Inc. 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 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 MAILING LIST Mr. David Rittenhouse U. S. Forest Service Federal Building Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 Mr. Don Ranne 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 Regional Office Federal Energy Regulatory Commission 1120 SW Sth Avenue, Suite 1340 Portland, OR 97204 Ms. Lois Cashell Federal Energy Regulatory Commission 825 N. Capitol St. NE Washington, DC 20426 Area Director Bureau of Indian Affairs P.O. Box 3-8000 Juneau, AK 99802 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. Christine Valentine Alaska Division of Governmental 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 . Mr. Barry Hogarty Alaska Department of Environmental Conservation DEQ/SE Region DEC 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 2030 Sea Level 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 Authority 480 W. Tudor Anchorage, AK 99503 Mr. Stan Sieczkowski Manager, Operations & Maintenance Alaska Energy Authority 480 West 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 Mr. C. L. Cheshire, Director University of Alaska - Southeast Economic Development Center - UofASE 7th Avenue and Madison 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 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 Ms. Melanie Fullman Ketchikan Gateway Borough Planning Department 344 Front Street Ketchikan, AK 99901 Mr. Jim Voetberg ; Ketchikan Gateway Borough 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. William Jones Acting 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. Thomas Stevenson Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. Rich Trimble Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. Jan Risla 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 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 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. Jack Lee Tongass Sportfishing Association P.O. Box 5898 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. and Mrs. Forrest DeWitt Box 5252 Ketchikan, AK 99901 Mr. Guy Galloway Administrator City of Saxman Route 2, Box | Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. Jack Snyder Western Regional Manager Northrup, Devine & Tarbell, Inc. 4601 NE 77th Ave, Suite 185 Vancouver, WA 98662 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 MEETING MINUTES ZN 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 Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 HDR Engineering, Inc. 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 BA, 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 Laké 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 i 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. s 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. a 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. 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. MEETING MINUTES re, 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- Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 HDR Engineering, Inc. 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 morming’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 concers 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 tur 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 USFS, 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 mn 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 mun 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. Al 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) ew 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. , ; 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 word was that there was no fish up there. ie 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 retumed 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. Zo 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. a4 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 __ MAY-15-95 MON 7232 FIRST CITY BUILDERS KETCHIKAN AREA STATE PARKS ADVISORY BOARD 9883 N. Tongass, Ketchikan, Alaska 99901 May 14, 1995 HDR Engineering Suite 1200 500 108th Avenue, N.E. Bellevue, WA 98004-5538 RE: Mahoney Lake Hydroelectric Project, FERC No. 11393 Attention: Mike Stimac The Ketchikan Area State Parks Advisory Board appreciates your informing us about the above project. We often take interest in many projects that may have implications for outdoor recreational opportunities in the Ketchikan Gateway Borough, even though they may not involve State lands. We would like to offer the following comments regarding outdoor recreational uses on the Mahoney Lake Hydroelectric Project area. Our information suggests there is currently minimal recreational use of the upper or lower Mahoney Lakes. Limited sport fishing occasionally occurs in the lower Mahoney Lake, with access from the salt water (George InIct). There are reports of some fall decr hunting in the area, on the ridge to the south of lower Mahoney Lake, but again this activity is minimal. As a participant in the Ketchikan Trails Coalition, we are aware of several types of users that recreate on the alpine ridges above upper Mahoney Lake. Hikers traverse the area, and there is a primitive and difficult route connecting to the Dcer Mountain trail system. Access can be had from the White River, the Silvis Lakes/John Mountain trail system, and the Deer Mountain system. The Ketchikan Snowmobile Club has accessed the upper Mahoney basin from a logging spur off the Whitc River road, and they report the winter snowmobiling opportunities here are expansive and excellent, possibly better than the popular Slide Ridge/ Harriet Hunt areas. Their only problem accessing the area is that the logging spur is often below the snow line. A Ketchikan ski club once proposed a ski lift to the upper Mahoney Basin, and conducted a snow study for the arca. It's our understanding they have abandoned the proposal, however. Though the current recreational uses of the project area are limited, we would urge that access still be allowed for existing and future users. That would include salt water access to lower Mahoney Lake, and alpine access to the upper Mahoney basin. Sincerely, Craig/ M. Moore, Chair 22ss655 P.e2 United States Department of the Interior FISH AND WILDLIFE SERVICE Southeast Alaska Ecological Services 3000 Vintage Bivd., Suite 201 Juneau, Alaska 99801-7100 May 19, 1995 Mr. Michael V. Stimac Licensing and Environmental Services HDR Engineering, Inc. 500-108th Avenue NE, Suite 1200 Bellevue, Washington 98004 Re: Mahoney Lake Hydroelectric Project Scoping FERC Project No. 11393 Attn.: Lisa Fortney Dear Mr. Stimac: The following comments respond to your March 9, 1995, Mahoney Lake Hydroelectric Project Scoping Document 1. On May 15, 1995, Ms. Lisa Fortney of your staff granted the U.S. Fish and Wildlife Service (Service) an extension of one week to provide these comments. We apologize for the need for this extension, and appreciate your approval thereof. The document requested the Service's assistance in identifying issues that should be addressed in the environmental analysis (EA), and provides a final opportunity to request additional studies. Issues to be addressed in the EA are identified below, followed by a request for two additional studies. Issues that should be addressed in the EA include the following: It appears that flows in Upper Mahoney Creek, between the power plant discharge point and Lower Mahoney Lake, will be more uniform throughout the year than occurs naturally. Spring flows will be reduced, while late summer and winter flows may be increased. Please indicate if this will be the case, and evaluate its impact on sockeye salmon that spawn in the lake immediately below the inlet. The effects of the altered stream flows on passage of sockeye and pink salmon through Lower Mahoney Creek, between Lower Mahoney Lake and George Inlet, should also be evaluated. Of particular concern is how such flows would affect the partial blockage in the stream, which currently allows sockeye salmon, but not pink salmon, to reach the lake. The effects or any temporary shut-downs, for maintenance or other reasons, should be described. Accommodations should be made to provide flows in Lower Mahoney Creek, adequate to provide currents through the substrate at spawning sites, from spawning through the alevin life-stage. Such flows may be necessary to provide passage through Lower Mahoney Creek to Lower Mahoney Lake. If a by-pass structure is required at the powerhouse to provide such flows, the project plans should accommodate this need. z 1 —s me © © © © Timing of construction should be addressed in the EA. In-stream work should be avoided when eggs are in the gravel and when adult salmon or alevins are present. Measures to control siltation of spawning gravels, from both construction runoff and long-term operation should be evaluated and described in the EA. Construction near raptor nests should be avoided during spring and summer nesting periods (see discussion of raptor nests, below). Cumulative impacts on the environment of all projects and proposals in the vicinity of the project should be considered. Cumulative impacts are defined as those impacts that result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions (e.g., timber harvest, mining, road construction, outdoor recreation, sport and subsistence hunting and fishing, etc.). The effects of dewatering a substantial portion of Upper Mahoney Creek should be evaluated and described. We note that lenticular sedge, Carex lenticularis var. dolia, a Category 2 candidate for Federal listing as endangered or threatened, was located along Upper Mahoney Creek during a plant survey done in September, 1994’. The potential effects to this plant species from dewatering the stream are of particular concern. One other Category 2 plant species, Calamagrostis crassiglumis, was identified in our letter of June 21, 1994, as potentially occurring on the project site. This species was not identified in the September survey, although the species was not specifically sought, and surveyors noted that many of the plants had senescenced and were difficult to identify. Calamagrostis canadensis was found in both the Upper and Lower Mahoney Lakes areas (Duffy 1994, Appendix E). The identity of this Calamagrostis should be verified, to ensure that it is not actually C. crassiglumis. The potential for avain collisions and electrocutions on the transmission lines should be addressed. We recommend the lines be located and equipped as recommended in the following references: Avian Power Line Interaction Committee (APLIC),1994, Mitigation bird collisions with power lines: the state of the art in 1994. Edison Electric Institute, Washington, D.C. (phone 1-800-334-5453, or write to Edison Electric Institute, 701 Pennsylvania Avenue, N.W., Washington D.C. 20004-2696. Request item #06-94-33). Olendorff, R.R., A.D. Miller, and R.N. Lehman. 1981. Suggested practices for raptor protection on power lines: the state of the art in 1981. Raptor Research Found., c/o Dept. of Veterinary Biol., Univ. Minn., St. Paul, Minn. 55101. Construction underground transmission times, where feasible, will largely eliminate conflicts with raptors, and is encouraged. Locations with high potential for avain collisions (e.g. stream crossings, mountain passes, etc.) should be identified for above-ground portions of all alternative transmission ‘Duffy, M. 1994. The Mahoney Lakes area of Revillagigedo Island, Southeastern Alaska: a sensitive species survey. AK Natur. Her. Prog., Unif. AK, Anchorage. 34pp. line routes, to allow a reasonable evaluation of the alternatives. Areas identified as likely flight corridors should be avoided if possible. Otherwise, lines should be marked to improve their visibility. Several new products are available for economically marking lines. These are described in APLIC (1994). Recent surveys in southern Southeast Alaska have documented the spotted frog, Rana pretiosa, a Category 2 species for Federal listing, although the species was not identified as potentially occurring in the project area in our letter of June 21, 1994. Because of this new information, we believe it prudent to inform the applicant of the potential for this species to occur in the project area. We would appreciate receiving any information on the status of the species in the project area. Please contact John Lindell of this office if you would like information on survey techniques (907) 586-7240. If the species is present, the EA should evaluate potential impacts. The effect of the proposed action on each of the species listed in our letter of June 21, 1994, should be addressed in the EA. This includes the American peregrine falcon (Falco peregrinus anatum), arctic peregrine falcon (F. p. tundris), marbled murrelet (Brachyramphus marmoratus), northern goshawk (Accipiter gentilis), harlequin duck (Histrionicus histrionicus), Alexander Archipelago wolf (Canis lupus ligoni), lenticular sedge (Carex lenticularis var. dollis), and slimstemmed reedgrass, (Calamagrostis crassiglumis). The arctic peregrine falcon has been delisted, however, the Service is required to monitor the species for five years following delisting. We would appreciate any information available on the species. A current list of threatened, endangered, and candidate species in Alaska is enclosed for your information. The potential to affect nesting bald eagles should be evaluated. The Service recommends a minimum 330-foot buffer of undisturbed habitat be left around all bald eagle nest trees. A larger buffer is recommended if vegetation or topography do not adequately screen a nest from view with a 330-boot buffer. If helicopters or other aircraft will be used during construction or operation of the facility, all flight paths should be a least 1,000 feet from eagle nests. No construction should be done within 660 feet of any eagle nest between March 1 and May 31. Active eagle nests should be avoid between March 1 and August 31. The habitat in the vicinity of Lower Mahoney Lake and along the access road and transmission line corridors appears to be suitable nesting habitat for marbled murrelets and northern goshawks. Potential effects on both of these Category 2 candidates should be addressed in the EA. We recommend that the project area be surveyed for nests of these species, using methods shown to be effective at detecting such nests. Formal study requests are included below. Additional studies that should be accomplished prior to licensing include (1) a nesting survey for marbled murrelets and (2) a nesting survey for northern goshawks. These requests are structured to conform with 18 CFR section 4.32(b)(7), as identified in the Scoping Document. Marbled Murrelet Nesting Survey: This species is a Category 2 candidate for Federal listing as threatened or endangered. This species is listed as threatened in the lower 48 states. Lack of information on the species across its range limits our ability to provide protection. This lack of data is particularly acute in Alaska. The Mahoney Lakes Hydroelectric Project area provides suitable nesting habitat (high-volume, old-growth coniferous forest). The species feeds in the ocean, often many miles from its nest site, and is known to use waters in the vicinity of the project. Who should conduct the Study: Surveyors should be familiar with the vocalizations and behaviors of marbled murrelets. Environmental consultants are available with experience in these surveys. Depending on personnel constraints, the Service's Migratory Bird Management Office may be available to conduct the survey if funding is provided. This alternative is offered only as a possibility, and does not constitute an offer or commitment. To discuss this possibility, contact Kent Wohl in our Anchorage office at (907) 786-3503. Objectives: The objective of the study is to document whether nesting by murrelets is or is not likely in the project vicinity. If nesting is indicated, identification of nest trees would be attempted. Methodology: Dawn watch surveys as described in Kuletz et al.’ are requested. Dawn watch surveys should begin 120 minutes before sunrise and end 15 minutes after sunrise. Survey points should be spaced at 400-yard intervals. The vicinity of the powerhouse and staging area could be adequately surveyed to detect the presence of nesting (although not necessarily the location of individual nest trees) with two or three survey points. The access road and transmission corridors could be surveyed with approximately four survey points per mile. The proposed transmission line corridor is approximately 5.5 miles long, so 22 survey points would be required. The alternative transmission line corridor is approximately four miles long, so 16 survey points would be required. A total of 41 points would be required for the entire project. Acceptance by the scientific community: The technique has been shown to be effective, and results from such surveys have been published in scientific symposium proceedings (Ralph et al.)*. Dusk watch surveys have been less successful, and are not recommended. Utility of the Study: The requested study can be used to identify stands used by murrelets for nesting. This information will help the applicant minimize impacts to the species by avoiding these stands to the extent possible. If avoidance is not possible, the information provided by the survey, combined with monitoring during project operation, may provide data on nesting murrelets' response to construction and operation of such facilities. Such data is currently unavailable. Time required: Two surveyors could complete filed work in 22 days. Additional *Kuletz, K.J., N.L. Naslund, and D.K. Marks. 1994. Exxon Valdez oil spill restoration report: identification of marbled murrelet nesting habitat in the Exxon Valdez oil spill zone. Restoration Project R15, Final Report. U.S. Fish and Wildlife Service, Migratory Bird Management, Anchorage, AK. *Ralph, C.J., G.L. Hunt, Jr., M.G. Raphael, and J.F. Piatt (eds). 1995. Ecology and conservation of the marbled murrelet: an interagency scientific evaluation. USDA For. Serv. Gen. Tech. Rep. PSW-GTR. surveyors would shorten the time required to complete field work. If the presence of nesting is indicated by murrelet activity and behavior, additional field work would be required to locate nest trees (about 10 days). Reporting could take an additional 90 days. Adequacy of existing data: Existing and planned wildlife surveys in the project area are not likely to provide any information on the presence of nesting murrelets. Northern Goshawk Nesting Surveys: This species is a Category 2 candidate for Federal listing as threatened or endangered. Management agencies lack adequate information about the distribution and biology of this species. The project area appears to provide suitable nesting habitat, but has not been adequately surveyed for the species. Who would conduct the study: Environmental consultants are available to conduct the requested survey. The Service's Migratory Bird Management Office may be available, if funding is provided. This alternative is offered only as a possibility, and does not constitute an offer or commitment. Please contact Philip Schempf in our Raptor Management office in Juneau at (9076) 586-7243 if you wish to discuss this possibility. Methodology: Broadcast call surveys following the methods of Kennedy and Stahlecker' and Joy*® are requested. The objective of this study is to determine if the species nests in the project area. If a nest is located, responses to construction and operation of the hydroelectric project could be monitored. Acceptance by the scientific community: The technique is proven, and results of such surveys have been published in peer-reviewed journals. Utility of the Study: Results of the study could be used by the applicant and the Service to cooperatively design the project to minimize impacts to the species. Nest sites could be avoided during construction of facilities, especially during the nesting period. Monitoring of nest activity and success could occur, which would provide valuable information on the effects of the facility on nesting goshawks.. The Service would find such information useful during coordination on similar projects elsewhere. Time required: Approximately one month of field work during the spring/early summer nesting period would be required. Reporting could take an additional 90 days. Adequacy of existing data: Visual searches for nests, as described in the scoping documents provided, are likely to fail to detect nests that exist. ‘Kennedy, P.L., and D.W. Stahlecker. 1993. Responsiveness of nesting northern goshawks to taped broadcasts of 3 conspecific calls. J. Wildl. Manage. 57(2):249-257. ‘Joy, S.M., R.T. Reynold, and D.G. Leslie. 1994. Northern Goshawk broadcast surveys: hawk response variables and survey cost. Studies in Avian Biol. No. 16:24-30. wa Thank you for the opportunity to comment on the project. The Service will continue to work with the applicant in planning the project. If you have any questions, please contact Steve Brockmann at (907) 225-9691. f Sincerely, | ° Vion LA Nevin D. Holl rg Field Supervisor | enclosure: spp. list ec. Mark Dalton, HDR Engineering, Anchorage ADFG, Ketchikan NMFS, Juneau ADEC, Juneau ADEC, Juneau EPA, Anchorage ADNR, Juneau ADGC, Juneau |» TONY KNOWLES, GOVERNOR OFFICE OF THE GOVERNOR OFFICE OF MANAGEMENT AND BUDGET DIVISION OF GOVERNMENTAL COORDINATION (O SOUTHCENTRAL REGIONAL OFFICE yh CENTRAL OFFICE CO PIPELINE COORINDATOR'S OFFICE 3601 “C* STREET, SUITE 370 P.O. BOX 110030 411 WEST 4TH AVENUE, SUITE 2C ANCHORAGE, ALASKA 99503-5930 JUNEAU, ALASKA 99811-0030 ANCHORAGE, ALASKA 99501-2343 PH: (907) 561-6131/FAX: (907) 561-6134 PH: (907) 465-3562/FAX: (907) 465-3075 PH: (907) 271-4336/FAX: (907) 272-0690 May 19, 1995 1-A35LH Mr. Micheal V. Stimac HDR Engineering, Inc. Suite 1200 500 108th Ave., NE Bellevue, WA 98004-5538 Dear Mr. Stimac: SUBJECT: MAHONEY LAKE HYDROELECTRIC PROJECT STATE ID #AK9504-08JJ/FERC PROJECT #11393 NEPA SCOPING REVIEW Thank you for sending a copy of the meeting notes from the April 12 and 13, 1995 National Environmental Policy Act (NEPA) scoping meetings for the Mahoney Lake project. We regret that the Division of Governmental Coordination (DGC) was unable to attend the scoping meetings. This letter is submitted as DGC’s response to the NEPA scoping review for the Mahoney Lake project. The Mahoney Lake project is a proposal by the City of Saxman to construct a small (9.6 megawatt) hydropower plant near Mahoney Lake, about 5 miles northeast of Ketchikan. The purpose of the project is to provide the Ketchikan area with an additional energy supply. The First Consultation Phase of the FERC review was completed in 1994. In the past, the next step in the FERC process has been the Second Consultation Phase. For the Mahoney Lake project, FERC agreed to a new procedure where the NEPA analysis begins early in the process instead of after filing of the license application. The current scoping review was the first step in the NEPA process. An Environmental Assessment (EA) will be developed and submitted to FERC in place of Exhibit E of the license application. HDR anticipates that the next steps in the FERC/NEPA process are: (1) review of scoping comments and determination of whether a second scoping document is necessary, and (2) distribution of the draft EA and draft license application, tentatively scheduled for September 1995, for NEPA and Second Consultation Phase review. Scoping comments on "Scoping Document 1" were due on May 15, 1995. This office received a copy of the Department of Fish and Game’s,scoping comments which were sent io you directly. We have not received scoping comments from anyone else. Apparently, comments were either sent directly to you or other review participants were unable to comment due to staff shortages and large workloads. As a suggestions, HDR could review comments submitted during the First Consultation Stage of the FERC review for issues that should be addressed during the NEPA analysis. The State’s coastal consistency review can commence when DGC receives: (1) a Coastal Project Questionnaire, (2) copies of all necessary state and federal permit applications, (3) supporting information, including maps and drawings, which describes the project, (4) an ACMP public notice is made, and (5) FERC officially accepts the license application and the application is public noticed (this usually occurs at the Third Consultation Phase of the FERC review). If you have any questions regarding this letter or the Alaska Coastal Management Program, _ please contact me at 465-3177. Thank you for providing an opportunity to participate in the FERC/NEPA process. Sincerely Christine Valentine Project Review Coordinator ce: Joan Hughes, DEC, Juneau Lana Shea, DFG, Juneau Jack Gustafson, DFG, Ketchikan Elizaveta Shadura, DNR/DOL, Juneau John Dunker, DNR/DOW, Juneau Melanie Fullman, Coastal Contact, Ketchikan Vince Yearick, FERC, Washington D.C. May 24, 1995 (See attached list) Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Dear : 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. Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 HDR Engineering, Inc. — lll’ May 24, 1995 - Page 2 We would appreciate hearing your questions and potential concerns about this new transmission line alignment by June 23, 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. —Mthack / Si ttt / bee! Michael V. Stimac Manager, Licensing and Environmental Services Enclosure s ce: Vince Yearick, FERC Doug Campbell, Cape Fox Jack Snyder, ND&T Mark Dalton, HDR Don Clarke, WKBQ HDR File, B.4.1 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 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 MAILING LIST Mr. David Rittenhouse U. S. Forest Service Federal Building Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 Mr. Don Ranne 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 Regional Office Federal Energy Regulatory Commission 1120 SW Sth Avenue, Suite 1340 Portland, OR 97204 Ms. Lois Cashell Federal Energy Regulatory Commission 825 N. Capitol St. NE Washington, DC 20426 Area Director Bureau of Indian Affairs P.O. Box 3-8000 Juneau, AK 99802 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. Christine Valentine Alaska Division of Governmental 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 Mr. Barry Hogarty Alaska Department of Environmental Conservation . DEQ/SE Region DEC 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 2030 Sea Level 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 Authority 480 W. Tudor Anchorage, AK 99503 Mr. Stan Sieczkowski Manager, Operations & Maintenance Alaska Energy Authority 480 West 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 Mr. C. L. Cheshire, Director University of Alaska - Southeast Economic Development Center - UofASE 7th Avenue and Madison 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 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 Ms. Melanie Fullman Ketchikan Gateway Borough Planning Department 344 Front Street Ketchikan, AK 99901 Mr. Jim Voetberg Ketchikan Gateway Borough 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. William Jones Acting 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. Thomas Stevenson Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. Rich Trimble Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. Jan Risla 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 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 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. Jack Lee Tongass Sportfishing Association P.O. Box 5898 Ketchikan, AK 99901 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongas’ 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 Keene & Currall Attn: Terrie 540 Water Street, Suite 302 Ketchikan, AK 99901 Mr. and Mrs. Forrest DeWitt Box 5252 . Ketchikan, AK 99901 Mr. Guy Galloway 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. 4601 NE 77th Ave., Suite 185 Vancouver, WA 98662 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 TONY KNOWLES, GOVERNOR OFFICE OF THE GOVERNOR OFFICE OF MANAGEMENT AND BUDGET DIVISION OF GOVERNMENTAL COORDINATION CO souTHCENTRAL REGIONAL OFFICE Beene OFFICE oO PIPELINE COORDINATOR'S OFFICE 3601 “C” STREET, SUITE 370 P.O. BOX 110030 411 WEST 4TH AVENUE, SUITE 2C ANCHORAGE, ALASKA 99503-5930 JUNEAU, ALASKA 99811-0300 ANCHORAGE, ALASKA 99501-2343 PH: (907) 561-6131/FAX: (907) 561-6134 PH: (907) 465-3562/FAX: (907) 465-3075 PH: (907) 278-8594/F AX: (907) 272-0690 DISTRIBUTION LIST Mahoney Lake Hydro - AK 9504-08JJ New “South Alternative" Joan Hughes, DEC, Juneau Lana Shea, DFG, Juneau Jack Gustafson, DFG, Ketchikan Elizaveta Shadura, DNR, Juneau John Dunker, DNR/DOW, Juneau Bill Garry, DNR/DPOR, Juneau Judith Bittner, DNR/SHPO, Anchorage Bill Ballard, DOT/PF, Juneau Mike McKinnon, DOT/PF, Juneau Melanie Fullman, Coastal Coordinator, Ketchikan Gateway Borough The Honorable Alaire Stanton, Mayor, Ketchikan The Honorable Jim Carlton, Mayor, KGB Dave Arrasmith, USFS, Ketchikan Louis Thompson, Kavilco, Inc., Ketchikan Rick Harris, Sealaska Corporation, Juneau Ron Wolfe, Klukwan, Inc., Juneau Attached are: May 24, 1995 letter from HDR Engineering (2 p.) and a map showing "Transmission Line Alternative Routes". As a result of comments received during NEPA scoping, a new route alternative is being investigated. Comments on the new route alternative are due to HDR Engineering by June 26, 1995. DGC Contact: Christine Valentine, Project Review Coordinator Phone: 907-465-3177 Fax: 907-465-3075 Aaa " 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 conceming 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 concer. 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/JHTicjp Copy: D. Beardsley, AEA V. Yearick, FERC T. Waggoner, KPU J. Thrall, LIL File Alaska State Legislature State Capitol luneau. Aiaska 99801-1182 RECEIVED 1907 465-3873 Fax (907) 465-3922 (chairman udiciary Committee Vice Chairman. a Committee JUN 1 2 1995 Bsaie a Member Ketchikan “Alaska 99901 Resources Committee 5 1907) 225-8088 Nester Legsive Forest task force =» Senator Robin L. Taylor Pra ane anny June 7, 1995 Mr. Michael V. Stimac, Manager Licensing and Environmental Services HDR Engineering, Inc. 500 108th Avenue NE, Suite 1200 Bellvue, WA. 98004-5538 Dear Mr. Stimac: Thank you for seeking my input on the South Alternative transmission line proposed for the Mahoney Lake Hydroelectric Project. While the southern route may cost somewhat more, | believe in the long run it will prove more beneficial to the overall project. A direct connection at Beaver Falls offers more future options, including the potential of power sales to Metlakatla. Routing power through the Swan Lake project would be subject to interruption should the Swan Lake system fail. The direct connection at Beaver Falls makes more sense logistically. While | support the southern alternative, | believe the eventual (\) construction of a road along the access route would be of long-term benefit to the project and to the community it is intended to serve. Sincerely, Ap. Liegd—~ Robin L. Taylor RLT/ja cc: Representative Bill Williams Thomas W. Stevenson, KPU District A Heder ¢ Ketchikan © Kupreanof ¢ Mevers Chuck © Petersburs © Saxman © Sitka © Wrangell June 15, 1995 (See attached list) Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Dear: This letter is to confirm the meeting which will be held on Thursday, June 22, 1995, at 9:00 am at the Westmark-Cape Fox Hotel in Ketchikan to discuss the requests for additional studies for the above referenced project. These additional study requests are set forth in letters from the Alaska Department of Fish and Game and U.S. Fish and Wildlife Service and resulted from the scoping process for the project. All matters identified in the letters will be addressed at the June 22 meeting. A primary concern that will be discussed is the effects on flows in Lower Mahoney Creek due to project operation and the potential impacts of those effects on anadromous fish passage. In that regard, enclosed, for your information, is a flow regime report that discusses the flows in Lower Mahoney Creek when upstream migration occurs and the impacts of project operation on those flows. The report includes a correlation of flow data with anadromous fish observations in Lower Mahoney Creek and Lower Mahoney Lake in 1994. Please call me at (206) 453-1523 if you have any questions or comments concerning the Mahoney Lake Hydroelectric Project or the June 22nd meeting. We look forward to seeing you at the meeting. Sincerely, HDR ENGINEERING, INC. Mithal Vv. Stinac (Lf Michael V. Stimac Manager, Licensing & Environmental Services ce: Doug Campbell, Cape Fox Mark Dalton, HDR Anchorage Jack Snyder, NDT John Morsell, NES HDR File, B.4.1 HDR Engineering, Inc. Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington 98004-5538 Mr. Vince Yearick Federal Energy Regulatory Commission Division of Project Review 810 First St., N.E., Room 504 Washington, DC 20426 Mr. Jim DeHerrera U.S. Forest Service 3031 N. Tongass Avenue Ketchikan, AK 99901 Mr. Steve Brockman U.S. Fish & Wildlife Service P.O. Box 23193 Ketchikan, AK 99901 Mr. Steve Hoffman Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, Room 207 Ketchikan, AK 99901 TONY KNOWLES, covernoll DEPARTMENT OF FISH AND GAME caress KETCHIKAN, ALASKA 99901-6000 DIVISION OF WILDLIFE CONSERVATION PHONE: (907) 225-2475 June 20, 1995 RECEIVED JUN 27 1995 Mr. Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. 500-108th Avenue NE, Suite 1200 Bellevue, WA 98004 Re: Mahoney Lake Hydroelectric Project Scoping FERC Project No. 11393 Dear Mr. Stimac: I apologize for not writing sooner and providing you with wildlife considerations in the i area of the proposed Mahoney Lake hydroelectric project. Although several terrestrial and semi-aquatic species of wildlife inhabit the area (e.g. wolves, black bears, otters, mink, beavers, and deer), I would like to give special consideration to mountain goats which were introduced adjacent to Upper Mahoney Lake on 10 August 1991. At the time of the transplant, seven of fifteen captured goats were outfitted with radio collars. During 15 August 1991 through 24 February 1994, I obtained 124 relocations of the collared goats (see attached map). Distances goats moved away from the Upper Mahoney release site varied among individuals. However, within a short time several nannies had settled in and have subsequently remained on the timbered ridge northwest of Lower Mahoney lake. This frequent use can be seen in section 26 on the attached map. Further, of the 100 relocations shown on the map, 32 were made within the immediate vicinity of Upper and Lower Mahoney Lakes (sections 25-27 and 34-36; outlined in red). All radio collars are now off the air and further relocations are therefore not possible. Nonetheless, during an 8 September 1994 aerial survey, 8 of 14 observed adults and 2 of 4 observed kids were within the area delineated as section 35 on the map. Elevations of relocated goats varied from 400 to 3,300 feet. However, the majority of the relocated goats were observed at elevations between 2,000 and 3,000 feet. Development of the proposed hydroelectric facility will likely have minimal impacts on goats that have established niches distant from the site. However, goats inhabiting the areas immediately adjacent to Upper and Lower Mahoney Lakes may be affected, at least during the construction phase of the project. Noise and human activity associated with construction may cause the goats to leave the area and seek out new niches elsewhere. Whether or not displaced goats would move back into the area once construction is Mr. Michael V. Stimac -2- June 20, 1995 completed is difficult to say, however, I suspect there is a reasonable chance that they would; particularly on the steep, south-facing, timbered slope on the north side of Lower Mahoney Lake. This area appears to provide excellent escape terrain from predators as well as good wintering habitat. , I hope this brief summary showing the distribution of radio collared goats proves useful to you. I would be happy to discuss this with you in more detail at your convenience. Thanks for the opportunity to comment. cc: Bruce Dinneford, ADF&G, Douglas Jack Gustafson, ADF&G, Ketchikan ao ee peccoerg! gn Sal ee Ax oe Mountain goat relocations; 15 February 1994. adjacent to Upper Mahoney lake on 10 August 1991. , SMU UT ($7 WG EIZ FV Fie Xe 7 United States Forest Alaska Region Ketchikan Ranger District Department of Service 3031 Tongass Avenue Agriculture Ketchikan, Alaska 99901 (907) 225-2148 TT/TDD (907) 225-0414 File Code: 1950/2720 JUN 2b 1995 Date: June 21, 1995 Mr. Michael Stimac HDR Engineering, Inc. Suite 1200 500 108th Avenue, N E. Bellevue, WA 98004-5538 HDR ENGINEERING, INC. Dear Mr. Stimac: I have reviewed the proposed south alternative as referenced in your letter dated May 24, 1995. The following are my comments. Cultural Resources As mentioned in our letter to you dated June 21, 1994, if you contract your cultural resources survey, you will need to submit a research design and the qualifications of your primary investigator. This holds true for the south alternative as well as the rest of the project area on Nationa! Forest System (NFS) lands. Wildlife The shoreline north and south of lower Mahoney Lake should be surveyed for eagle nests that could impact the timing of construction activities. Due to the proximity of overhead transmission lines to probable eagle concentrations, you will need to consider measures to reduce potential eagle electrocutions. The revised Tongass Land Management Plan dated August 1991 recommends that we manage natural beach fringe and estuary habitats to favor wiidiife, fish, recreation, visual and other resources associated with beach fringe and estuary areas. If the south alternative is chosen, the powerline corridor should be located at least 500 feet from saltwater where possible. Fish Tree harvest activities on NFS lands will need to comply with erea standards for harvesting around stream channels. Lands It appears that the studies required for the south alternative will be of minimal impact. At this time I am waiving the need for an investigative special use permit. If at any time during your preliminary studies ground disturbance or vegetative removal become necessary, you are required to contact this office to see if a permit is needed. Caring for the Land and Serving People Printed on Recycled Paper Mr. Stimac Recreation & Scenic Resources If the south alternative is chosen, the right-of-way clearing and tower structures should be located low on the existing steep slopes just behind the beach fringe buffer using topographic and vegetative features to minimize visual impacts. Although the south alternative is somewhat shorter in length, the impact from ground and vegetative disturbance will be greater since the road north to the Swan Lake Transmission Line will still be constructed. Thank you for the opportunity to comment on the south alternative. If you have any questions, please contact Teresa Trulock at this address. Sincerely, 1 he ie Lbs te va JIMMY J. DEHERRERA District Ranger ce: Doug Campbell, Cape Fox Caring for the Land and Serving People Pnnted on Recycled Paper » A 06/21/95 08:52 @202 219 0125 FERC/OHL/DPR @oo1 FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON OFFICE SELECOPY MESSAGE (Facsimile) - Machine No. 202, 219-0125 DATE: G@°-Q/-S S~ TIME: OS 3 ro: (Vibe Stra ore: /7 DR —-Eny FROM: |/ ; MOE ese 2k PHONE: 2O2—214-7OF7% oFFI¢e: Of OPR~Ges® SUBJECT: Lf birt ney - - This transmittal consists of cover sheet plus Y pages. 06/21/95 08:53 @202 219 0125 FERC/OHL/DPR Boo Vince - I see no aquatic issues in the alternative routing of the power. line and no additional aquatic study needs. My recommended change to SD-1 is to delete all asterisks on issues under Aquatic Resources section 5.5.2. Regarding 5.1.2 Geographic Scope section (page 20) for cumulative impacts, it looks like the geog scope could be narrowed. Last two sentences read: "Further, the project induced effects on upwelling and water temperature in the lower lake could impact the sockeye salmon population and any related recreational fishery. Thus, we have defined the geographic scope of i the cumulative analysis as the Mahoney Creek basin from Upper Mahoney Creek to the outlet of Lower Mahoney Creek." Upwelling and water temperature are only project effects, so this could be reworded to narrow the geog scope of cumulative analysis to the recreational sockeye fishery area - which seems § to be Lower Mahoney Lake only, with maybe a short reach into Lower Mahoney Creek. Thanks, Nan 06/21/95 08:53 202 219 0125 FERC/OHL/DPR From: Slatter, Edwin (SLATTER-E) To: YEARICK-V Date: Tuesday, June 20, 1995 10:28 am Subject:Mahoney Lake Update -Reply THE SOUTH ALTERNATIVE TRANSMISSION LINE CORRIDOR NEEDS TO BE INCLUDED IN THE CULTURAL RESOURCES SURVEY PROPOSED IN THE SD1 APPENDIX A IF THERE IS A GOOD CHANCE IT WILL BE THE CORRIDOR CONSTRUCTED FOR THE PROJECT. THE ONLY CHANGE IN THE SD1 NEEDED IS IN THE CULTURAL RESOURCES STUDY PLAN IN APPENDIX A WHERE THE ALTERNATIVE SHOULD BE NOTED AND CIRCUMSTANCES IDENTIFIED UNDER WHICH IT WOULD BE INVENTORIED, INCLUDING A SCHEDULE FOR INVENTORY IF NECESSARY. cc: WARREN-G @oo3 06/21/95 08:54 202 219 0125 FERC/OHL/DPR Qooa From: Keller, Carl J. (KELLER-C) To: Yearick-V Date: Wednesday, May 31, 1995 10:17 am Subject: Mahoney Although HDR's May 24, 1995 letter delineates on a map the Southern alternative transmission line routing, I'm still unsure whether this is the least-environmentally damaging, or most acceptable. You may wish to express to HDR that we feel a discussion is needed in the arene as to why the alignment i is proposed where it i to avoid as, or is an inventory planned to be conducted along this alignment? HDR should also identify reasons (other than those mentioned in their May 24th letter) why this Southern alignment may be preferred when compared to other alternatives. poss: 2 Stnome (Bsuso a ALL: tamal Stud eeLs, 7) 06/21/95 08:54 @202 219 0125 FERC/OHL/DPR Moos From: Keller, Carl J. (KELLER-C) To: Yearick-V Date: Wednesday, May 31, 1995 9:25 am Subject:Mahoney Lake This responds to your May 31 E-Mail message regarding Cape Fox's new alternative to route the power generated southward toward the Beaver Falls area. Not knowing any more about this alternative at this time, the following are concerns_tha gme to mind which the applicant/contractor should thoroughly address in theiy“application/EA): 1) Why this routing as an alternative? Describe the benefits of this alternative versus the other~ alternatives, including financial (balancing). Are there potential environmental/natural resource benefits of this option versus the other considerations? ae Has this alternative routing of the power to the Beaver Falls area been designed to avoid/minimize all possible adverse impacts (ie., avoid any old-growth or mature timber resources, avoid crossing wetland habitats, minimize effects to bald eagles and other large birds by designing the power line to conform to raptor protection standards, avoid any other sensitiv, habitats, minimize the visual effect to the area, etc.)? tenfativé a) , to fe iatheir powe: ifg able (o this, it it quickly stot 0 a jéntatj ahone; € prop hat? eid se the ee smissiorf Toutin, speculative? 8 Migh: this new routing alternative create additional access opportunities for recreationists (hunters, fishemen, campers, hikers, photographers, nature watchers, etc.) to the Tongass ational Forest that may otherwise not be available? Ce: MITCHNICK-A Greater Ketchikan ChamsBer of Commerce P.O. Box 5957, Ketchikan, alaska 99901 KETONRAN YH RAINGIRO a (907) 225-3184 June 23, 1995 Mr. Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. Suite 1200 500 108th Avenue, N.E. Bellevue, WA 98004-5538 Dear Mr. Stimac: It has long been a priority of the Ketchikan Chamber of Commerce to see the development of a stable supply of electrical power for our community's future. Toward that end, we have supported KPU's efforts to develop an intertie between Tyee and Swan Lakes. We have been aware that the Mahoney Lake project and the intertie were being developed separately, and concerned about the sense of "competition" between them. Your correspondence tells us that KPU has proposed a realignment of the Mahoney Lake project in order to connect to the Beaver Falls power system. We would like to know whether this realign- (\) ment will allow a more cooperative planning process so that the two projects may both go forth to development. We believe the community would be well served by a further discussion of this possibility in future publications about Mahoney Lake. Thank you for the opportunity to comment. Sincerely, Srncate Padkard by. Anne mane Seert irs Emesta Ballard President Greater Ketchikan Chamber of Commerce 11-K88LH TONY KNOWLES, GOVERNOR DEPARTMENT OF FISH AND GAME P.O. BOX 240020 SOUTHEAST REGIONAL OFFICE DOUGIASTALASKAl ooe2e onc HABITAT AND RESTORATION DIVISION PHONE — (907) 465-4290 June 27, 1995 RECEIVED Mr. Michael V. Stimac JUN 30 1995 HDR Engineering, Inc. Suite 1200 500 108th Avenue, N.E. Bellevue, Washington 98004-5538 Dear Mr. Stimac: Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 We have reviewed your proposal to reroute the overhead electrical transmission line which was originally proposed to go from Lower Mahoney Lake to the White River area. The changed routing would instead connect the transmission line in a southerly direction from Lower Mahoney Lake to the existing transmission line at Beaver Falls. No new roading would result from this change, but clearing on the coastal alignment would occur in a southerly direction rather than a northerly one. Our concerns with this proposed change are minimal. However, we recommend a bald eagle nest survey be conducted in the coastal forest between Lower Mahoney Lake and Beaver Falls during the active nesting period by qualified personnel using protocols established by the U.S. Fish and Wildlife Service. We also recommend the transmission line alignment avoid the 500’-wide coastal fringe of forest to minimize the loss of habitat important for bald eagles, land otters, bears, and other species. If you have any questions regarding these comments or need additional, input please contact Jack Gustafson, Ketchikan Area Habitat Biologist, at 907-225- 2027. Thank you. Sincerely, ale heat Lana Shea Regional Supervisor Habitat & Restoration Division cc: Jack Gustafson, ADF&G, Ketchikan Christine Valentine, DGC, Juneau Nevin Holmberg, USFWS, Juneau LS/JG/Ic C 4851 July 12, 1995 Mr. Bill Baer U.S. Forest Service 3031 N. Tongass Avenue Ketchikan, AK 99901 Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear Mr. Baer : Enclosed are the minutes from the June 21 and June 22, 1995, meetings for the above- referenced project. Please review these minutes and provide any corrections, additions, or changes by July 24th. If no changes are requested, these minutes will be considered final. We thank you for attending the meeting and look forward to your continued participation in this project. Sincerely, HDR ENGINEERING, INC. Michal V. Shmne (0 Michael V. Stimac Manager, Licensing & Environmental Services Enclosure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Corporation Jack Snyder, NDT Mark Dalton, HDR Anchorage John Morsell, NES Don Clarke, Wilkinson, Barker, Knauer, & Quinn HDR File, B.4.1 Binder HDR Engineering, Inc. Suite 1200 Telephone 500 108th Avenue, N.E 206 453-1523 Bellevue, Washington : 98004-5538 July 12, 1995 a Ms. Teresa Trulock U.S. Forest Service 3031 N. Tongass Avenue Ketchikan, AK 99901 Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear Ms. Trulock : Enclosed are the minutes from the June 21 and June 22, 1995, meetings for the above-referenced project. Please review these minutes and provide any corrections, additions, or changes by July 24th. If no changes are requested, these minutes will be considered final. . We thank you for attending the meeting and look forward to your continued participation in this project. Sincerely, HDR ENGINEERING, INC. Michal v aimee LEK Michael V. Stimac Manager, Licensing & Environmental Services Enclosure ce: Vince Yearick, FERC Doug Campbell, Cape Fox Corporation Jack Snyder, NDT Mark Dalton, HDR Anchorage John Morsell, NES Don Clarke, Wilkinson, Barker, Knauer, & Quinn HDR File, B.4.1 Binder HDR Engineering, Inc. Suite 1200 . Telephone 500 108th Avenue, N.E 206 453-1523 Bellevue, Washington 98004-5538 July 12, 1995 Mr. Steve Hoffman Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, Room 207 Ketchikan, AK 99901 Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear Mr. Hoffman : Enclosed are the minutes from the June 22, 1995, meeting for the above-referenced project. Please review these minutes and provide any corrections, additions, or changes by July 24th. If no changes are requested, these minutes will be considered final. We thank you for attending the meeting and look forward to your continued participation in this project. Sincerely, HDR ENGINEERING, INC. Michal Vv. Stinnae (Ly Michael V. Stimac Manager, Licensing & Environmental Services Enclosure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Corporation Jack Snyder, NDT Mark Dalton, HDR Anchorage John Morsell, NES 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 July 12, 1995 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, Room 205 Ketchikan, AK 99901 Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear Ms. Denton: Enclosed are the minutes from the June 22, 1995, meeting for the above-referenced project. Please review these minutes and provide any corrections, additions, or changes by July 24th. If no changes are requested, these minutes will be considered final. We thank you for attending the meeting and look forward to your continued participation in this project. Sincerely, HDR ENGINEERING, INC. Michal V, Stimac IL Michael V. Stimac Manager, Licensing & Environmental Services Enclosure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Corporation Jack Snyder, NDT Mark Dalton, HDR Anchorage John Morsell, NES 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 July 12, 1995 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, Room 207 Ketchikan, AK 99901 Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear Mr. Gustafson : Enclosed are the minutes from the June 22, 1995, meeting for the above-referenced project. Please review these minutes and provide any corrections, additions, or changes by July 24th. If no changes are requested, these minutes will be considered final. We thank you for attending the meeting and look forward to your continued participation in this project. Sincerely, HDR ENGINEERING, INC. Mehal v. Hine [64 Michael V. Stimac Manager, Licensing & Environmental Services Enclosure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Corporation Jack Snyder, NDT Mark Dalton, HDR Anchorage John Morsell, NES 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 July 12, 1995 Mr. Steve Brockman U.S. Fish & Wildlife Service P.O. Box 23193 Ketchikan, AK 99901 Re: Mahoney Lake Hydroelectric Project FERC No. 11393 Dear Mr. Brockman : Enclosed are the minutes from the June 22, 1995, meeting for the above-referenced project. Please review these minutes and provide any corrections, additions, or changes by July 24th. If no changes are requested, these minutes will be considered final. We thank you for attending the meeting and look forward to your continued participation in this project. Sincerely, HDR ENGINEERING, INC. Michal U, imac Leh Michael V. Stimac Manager, Licensing & Environmental Services Enclosure cc: Vince Yearick, FERC Doug Campbell, Cape Fox Corporation Jack Snyder, NDT Mark Dalton, HDR Anchorage John Morsell, NES 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 Notes Project: Mahoney Lake Hydroelectric Project Date: June 21, 1995 Location: USFS Ranger Station, Ketchikan, Alaska Time: 2:00 PM Attendees: Doug Campbell (Cape Fox Corp.) Mark Dalton (HDR), John Morsell (Northem Ecological Services), Jack Snyder (NDT) Teresa Trulock, Bill Baer (USFS) Purpose: Review HDR’s Flow Regime Report, review proposed study plans for summer 1995, and review draft biological evaluations (BE’s) The following topics were discussed: lL. Mark Dalton opened the meeting by explaining that the purpose of the meeting was to review study plans and remaining work to be done this year, to reach concurrence with USFS on scope and methodologies of proposed study plans, and to review the flow regime report and draft BE’s prepared for the Mahoney Lake Project. : ; Jack Snyder went through the flow regime report and described its features and how the report was prepared. Based on comments received at the scoping meeting in Apnil, it was clear some additional data on pre-project and post-project flows in Mahoney Creek was necessary. The flow regime report is divided into four basic parts: a) description of how the Mahoney Lake Hydroelectric Project fits into the other generation resources in Ketchikan; ; b) an analysis of average flow conditions pre-project and post-project in the bypass reach of Upper Mahoney Creek, in Upper Mahoney Creek downstream of the powerhouse, and in Lower Mahoney Creek downstream of the outlet of Lower Mahoney Lake; c) an analysis of pre-project and post-project flows during non-normal operating conditions such as plant shutdowns or plant full load operation periods, and d) an analysis of stream flows and salmon passage in Lower Mahoney Creek based on data collected in August and September, 1994. Jack Snyder presented a graphic depiction of the turbine operation and how deflectors could be used for short-term bypass purposes. One of the main conditions of this report is that the project only impacts 39% of the drainage basin that feeds the outlet of Lower Mahoney Lake. Sixty-one percent of the drainage basin is unaffected by the project. Post-project flows at the outlet to Lower Mahoney Lake are only slightly influenced by the project Meeting Notes Date: June 21, 1995 Page 2 Jack discussed the correlation prepared to show the relation between recorded flows in Upper Mahoney Creek (at tailrace) and Lower Mahoney Creek fish movement observations during August and September of 1994. This was then linked to a threshold flow that is presumed to pass sockeye into Lower Mahoney Lake. The intent of the summer 1995 field program is to better establish flows necessary to pass fish. Jack Snyder stated that during a dry season, project flows could be artificially “spiked” to increase flows to facilitate fish movement. John Morsell stated that no modification (including barrier removal) to Lower Mahoney Creek is proposed because of concern about introducing pinks into lake system in potentially significant numbers. Bill Baer asked if Cape Fox would be monitoring flows and salmon passage at Lower Mahoney Creek this year. Mark Dalton and John Morsell answered yes and described the proposed study plan. The main purpose of the plan is to attempt to establish the threshold flow in Lower Mahoney Creek that will allow sockeye salmon passage up to Lower Mahoney Lake. Cape Fox staff will observe the creek every 3 days, and when sockeye appear in the middle section of Lower Mahoney Creek, John will come to the site for detailed observations. Lake population and spawning data will also be gathered at this time. No other passage or other fisheries studies are planned at this time. Resident fish in Upper Mahoney Lake and Upper Mahoney Creek were discussed. John Morsell described USFWS’ unsuccessful attempts at planting grayling in the Upper Mahoney Lake in the 1970’s. There have been no concems raised about resident fish in the Upper Mahoney Lake, and no studies are planned. Mark Dalton discussed plants and the plant BE. According to Bill Baer, he had been advised by Mary Stensvold (USFS) that she is leaning toward more plant surveys because additional occurrences of choris bog orchid are not known. Mark stated that orchid field work will be done in July as described in the BE. Bill Baer explained that this would be very helpful because if additional populations are located in areas on USFS land not affected by the project, the impacts from project construction will be easier to accept. There have been 2 populations identified on Revillagigedo Island in the past, one near Back Island and one in Misty Fiords. Additional populations in the area, if found, will relieve USFS concerns. Bill Baer provided comments on the draft plant BE. He said it looked good and was nght on track. He had a few comments and clarifications on the draft that he provided to Mark Dalton. The orchid sensitive species is the USFS’s main concern. He asked about 95 plants around Upper Mahoney Lake and what discussion could be added to the BE to address the impact of lake drawdown on these plants. Mark stated that this would be considered further. Mark Dalton reiterated that the real driving force for additional studies this summer is the new alternate “‘southern” transmission line route. As long as studies are being done for this new route, additional data will be gathered in the project area too. The animal BE was discussed. Bill Baer thought it looked very good, and provided a few comments on the draft document. He pointed out that if active eagle nests were found, that USFS may place restrictions on blasting during construction in the spring within % mile of Meeting Notes Date: June 21, 1995 Page 3 10 11 12 those nests. Bill was also satisfied with the goshawk and frog field survey work that is being proposed. Mark asked about USFS policy if a goshawk nest is located. Bill stated that typically, USFS requires that an area of suitable habitat (600 acres in size) be set aside around the nest. Bill Baer reminded the applicant that when selecting the transmission line route for the “southern” transmission line, that we attempt to stay at least 500 feet from the shoreline, as USFS manages this strip of land as beach fringe area. The BE process was discussed. Bill Baer stated the applicant was nght-on-track to address only USFS lands. On private lands, required studies should be worked out between owner, USFWS, and the State of Alaska) The USFS is satisfied that their concerns are being addressed on their lands. The applicant stated that the study plans being proposed to address USFS concems will also be presented to USFWS and ADF&G to address their concerns at the June 22 meeting. Bill asked if HDR was using the USFS plant survey forms provided by Mary Stensvold when doing the plant survey Mark Dalton confirmed this was so. Teresa Trulock asked about the status of the cultural survey. She reminded HDR/Cape Fox that the USFS wants to see a study/survey methodology or protocol, and information on the qualifications of the principal investigator before the survey is done. The need for an investigative special use permit to do this work is waived, but USFS still wants to see the methodology (research design) and investigator qualifications. HDR/Cape Fox agreed that this would be supplied to USFS soon The meeting adjoumed at approximately 4:00 PM. Recorded by John J. Snyder and Mark Dalton. 6/21/95 h:\hyd\mahoney\ca\scoping\062 | note.doc Meeting Notes Project: Mahoney Lake Hydroelectric Project Date: June 22, 1995 Location: Westmark-Cape Fox Hotel, Ketchikan, Alaska Time 9:00 AM Attendees: Doug Campbell (Cape Fox Corp.) Mark Dalton (HDR), John Morsell (NES), Jack Snyder (NDT) Teresa Trulock (USFS) Steve Brockman (USFWS) Steve Hoffman, Carol Denton, Jack Gustafson (ADF&G) Purpose: Review of Agency Response Letters to Scoping Meeting No.1, Review of Proposed Study Plans. Mark Dalton opened the meeting with a discussion of the purpose of the meeting - to review comment letters and additional study requests made by USFWS and ADF&G, particularly as they are affected by the proposed southern transmission line alternative. Jack Snyder reviewed the Flow Regime Report recently issued for review; he went through the report and highlighted the basic findings in the report. John Morsell described the study plan for salmon monitoring at the outlet to Lower Mahoney Creek planned for August and September 1995. The purpose of this study will be to attempt to better determine the “threshold” flow where sockeye are able to pass up Lower Mahoney Creek to Lower Mahoney Lake. The flow regime report shows very little impact on natural flows during August and September. It should be possible for the project to increase releases if necessary to supplement natural flows, and to actually enhance fish passage if conditions warrant. A discussion of long-term monitoring followed. ADF&G has indicated that 5 years of post-project construction monitoring should be sufficient, but if we propose to enhance passage if necessary, monitoring of sockeye passage should occur every year, for the term of the license. Cape Fox agreed that a license condition requiring monitoring of sockeye passage, and release of extra water through the project to improve passage, for up to 10 days per year, would be acceptable. The agencies could request this as a 4(e) condition. The stream gage would also be left in place in Lower Mahoney Creek indefinitely. Other long-term monitoring plans have not been proposed or developed yet. The Applicant will propose some monitoring plans. USFWS expressed several concems, that were discussed, including: a) What happens if the plant shuts down in winter - it seems flows are greatly reduced below the powerhouse. Would this adversely affect eggs incubating in the lake? b) Are dissolved oxygen levels greatly lowered when using deep lake water in the plant? Meeting Notes Date: June 22, 1995 Page 2 10. il c) Would a bypass valve be as effective in oxygenating the water as the turbine itself? A discussion followed. Mark Dalton stated that a technical report 1s being prepared, and will be issued for review, showing results of oxygen monitoring and temperature studies having to do with upwelling water in spawning areas. This report will shed a lot of light on these issues. Preliminary results show lake oxygen levels, even at depth, are quite high. The pelton wheel turbine and turbulent tailrace will also further oxygenate the water. Jack Snyder recalled a project in Northern Idaho called Smith Creek where fairly extensive oxygen monitoring was done. Steve Brockman asked if reports on this monitoring can be found and sent to him. Jack Snyder will try to get this and provide it to him. There were no further fishenies-related questions. Mark Dalton reviewed the specific points of the USFWS letter with Steve Brockman. USFWS concems about upwelling in the spawning beds will be addressed in a technical report currently being developed. A draft water quality technical report will be provided to the agencies when it is available. Cumulative impacts will be addressed, but in general there is expected to be very little “cumulative” impacts due to little or no past or future planned developments in this basin. Recreation or logging impacts will be addressed in the EA, but these are mostly impacts, not “cumulative impacts”. Regarding plants, the applicant will address all the species indicated as concerns to USFWS. The Carex species will not be impacted. Most plant work proposed this summer is due to the new “southern” transmission route. Doug Campbell explained KPU’s desire for this southem route, and that Cape Fox would rather use the northern route, but may offer the south route to the City as a sign of willingness to be cooperative. Some plant species observed last season will be re-visited to allow more positive identification to be made (last season’s studies were conducted a little late in the year). Attempts to identify additional populations of USFS sensitive plant species will be made during the July field work. Regarding birds, the standards referenced in USFWS’s letter will be utilized. HDR will follow the USFS protocols for bird surveys. Additional spotted frog sampling will be done this summer using baited minnow traps - USFWS uses clams for bait. Traps are set in edge habitats in emergent vegetation along edges of streams and ponds in back water areas where project impacts are likely to occur and the habitat appears to be suitable. A bald eagle nest survey will be conducted July 10 with USFWS and Cape Fox personnel. Goshawks were discussed. Mark Dalton described the methodology that is proposed and has been accepted by USFS for studies on USFS land. The basic methods are the same as suggested by USFWS in their letter, but the intensity of the study will be considerably less. Recordings will be played about every 150 meters along transmission line route. Steve Brockman is aware of goshawk survey protocols written up by USFS. If the methods proposed follow these same protocols and are acceptable to USFS, he agrees it will satisfy USFWS too. Teresa Trulock agreed that the proposed goshawk study plans are acceptable to USFS as they are currently proposed. Meeting Notes Date: June 22, 1995 Page 3 12. Marbled murrelets were discussed. Mark Dalton stated that since they are only candidate species, there is no regulatory requirement for the applicant to do any studies of this species. No studies are planned or proposed. USFWS stated that they still would like to see some information gathered. If good nesting areas can be identified, perhaps the transmission line route could be adjusted to avoid the best locations. USFWS suggested the study scope could be reduced considerably and still be acceptable, maybe just a few observations around Lower Mahoney Creek outlet area and at high probability stands of old growth along the beach. Mark Dalton agreed to produce a map, based on interpretation of aerial photos, showing the old growth stands and where project impacts might be. Based on this map and related information, Mark will propose a study methodology consistent with the amount of expected impacts. This was acceptable to USFWS and they will wait for Mark’s proposal 13 ADF&G brought up goats and wants to be sure they are addressed in the EA. Mark Dalton agreed that they would be addressed in the EA, for both construction and post-construction impacts. HDR agreed to provide the final study plans and schedules ASAP. Meeting adjourned at 11:15 AM Prepared by John J. Snyder and Mark Dalton IN REPLY REFER TO: 0) United States Department of the Interior FISH AND WILDLIFE SERVICE Southeast Alaska Ecological Services 3000 Vintage Blvd., Suire 201 we Juneau, Alaska 99801-7100 ‘ an ‘HDA ENGINEERING, INC Wiis July 13, 1995 Mr. Michael V. Stimic HDR Engineering, Inc. Suite 1200 500 108th Avenue, N.E. Bellevue, Washington 92004--5522 Re: Mahoney Lakes Hydroelectric Project Dear Mr. Stimic: This responds to your letter of May 24, 1995, concerning an alternative transmission line route how being considered for the subject project. Many of the issues identified in our letter of May 19, 1995, are relevant to the alternative transmission line corridor. Our May 19 letter discussed transmission line designs and routes to minimize both electrocution and collision hazards for birds. These considerations apply equally to any alternative transmission line routes. The new route should be surveyed for raptor nests, to allow for scheduling of construction that will not conflict with nesting activities. The bald eagle survey conducted by Mike Jacobson of our Raptor Management Branch in June, 1994, did not cover the alternative transmission line route. Murrelet and goshawk nests surveys, as requested in our May 19 letter, should cover any alternative transmission line route. Vegetation surveys should also be done along the alternative route to ensure that no unique communities or candidate species will be adversely impacted. The southern half of the alternative transmission line route passes through deer winter range. The originally proposed route, including the access road, travels through or adjacent to deer winter range for essentially its entire length. Potential effects on the deer population should be addressed. Cumulative effect potentially resulting from use of the alternative transmission line route should also be evaluated. For example, if creation of the corridor will facilitate access for recreation, timber harvest, or other uses, the effects of adding these uses to the area, in consideration of all past, present, and reasonably foreseeable future projects should be evaluated. If construction of a road along the alternative transmission line is considered as an option, the effects of the corridor with and without the road should be evaluated and disclosed. Beaver Falls Creek appears to be the only anadromous fish stream crossed by the alternative transmission line route. In-stream work should be avoided in this stream, if possible. Otherwise, such work should be scheduled when anadromous fish, their eggs, or alevins are not present. In any case, the operators of the Beaver Falls Hatchery should be contacted at (907)225-9605 to ensure that construction of the transmission line does not unduly interfere with their operation. Thank you for the opportunity to comment on this modification. If you have any questions, contact Steve Brockmann at (907)225-9691. Sincerely, us glebll, Nevin D. Holmberg Field Supervisor cc: Mark Dalton, HDR Engineering, Anchorage ADFG, Ketchikan EPA, Anchorage NMFS, Juneau ADNR, Juneau ADEC, Juneau Div. of Governmental Coordination, Juneau APPENDIX C RESPONSE TO AGENCY COMMENTS Response to Agency Comments APPENDIX C RESPONSE TO AGENCY COMMENTS Agency comment letters regarding SD1 were annotated and responses to specific issues raised in these letters are below. Alaska Division of Governmental Coordination (ADGC) April 5, 1995 Issue 1: Response: Issue 2: Response: Revisions need to be made to distribution list. Comment noted. Distribution list has been revised accordingly. Review of state coastal management program consistency process. Comment noted. Applications will be submitted prior to submitting the DEA and license application to the FERC. Ketchikan Public Utilities (KPU) April 12, 1995 Issue 1: Response: September 1995 Our previous studies and the study recently done by HDR leads us to the conclusion that the Mahoney Lake Project simply will not meet Ketchikan’s needs at this time. Although the City has met and corresponded with KPU many times since 1993 to describe the project, the benefits of the project to the KPU system and the KPU ratepayers still seem to be unclear to KPU at the time this comment was written. The City believes that in a meeting with KPU on April 24, 1995, KPU achieved a better understanding of the proposed operation of the Mahoney Lake Project. The City is proposing to sell power from the Mahoney Lake Project to KPU to replace energy generated by KPU’s diesel units. As KPU’s load continues to grow, as projected by KPU and all other available load growth projections, more and more diesel generation will be required. KPU’s residential rates as of June 1995 are $0.0875 per kilowatt-hour (kWh). Diesel fuel alone costs approximately $0.07 per kWh. The power produced by the proposed project will be less expensive than equivalent diesel generation. This can be of great benefit to KPU and its ratepayers. The operating scenarios described in the scoping document do not include any coordination of the project operation with existing KPU facilities. The City believes that since all existing KPU hydro resources are currently being fully utilized on an annual basis, and diesel generation is still necessary, that by coordinating operation of Mahoney Lake with other KPU resources, no spill and no diesel operation will be necessary for up to ten years Mahoney Lake Hydroelectric Project C-1 FERC No. 11393-000 Response to Agency Comments Issue 2: Response: Issue 3: into the future. This is because there is significant storage available at other KPU hydro facilities. Water could be "banked" at these reservoirs and saved until needed, while fully utilizing Mahoney Lake when there is excess water there. KPU’s existing hydro resources would, thus, still be 100% utilized on an annual basis, but the timing of generation of each would be shifted slightly. This type of operation is consistent with KPU’s contractual requirements for use of Swan Lake Project (FERC No. 2911) energy before taking other new power into their system. At a meeting with KPU on April 24, 1995, (two weeks after the date of the KPU letter), Tom Stevenson of KPU agreed that this type of integration of Mahoney Lake into their system would indeed be possible. Furthermore, the proposed project has 3,760 acre-feet of storage in the upper lake that can be used by KPU as they see fit for emergency capacity or energy. This much water represents the ability to run the plant at full load output for 24 days with no reservoir inflow at all. With the average annual reservoir inflow of 44 cfs, a full reservoir could be operated at full load for 55.7 days before it was depleted. 55.7 days of full load operation represent 12.8 million kWh of energy that KPU could use at any time in their system to offset diesel generation. This provides a clear benefit to KPU. Finally, the City and Cape Fox have offered KPU control of the operations of the plant as well as full dispatchability of the project as KPU sees fit, as long as KPU agrees to use best efforts to minimize avoidable spill of water from the upper lake. This would give KPU complete flexibility to integrate the project into their system as they see fit. The scoping of this project seems to be premature...(KPU) expect(s) there to be at least tentative terms negotiated for the sale of power to be produced by the project before proceeding with scoping. Comment noted. Scoping is a part of the NEPA process, and in general, the terms of a power sale agreement are not typically addressed. The purpose of scoping is to identify possible issues, and as such, the City believes that scoping can never be "premature", but in fact, is most beneficial to all concerned the sooner it occurs in a regulatory process. Although the City has made it clear to KPU that a power purchase agreement would be desirable for the Mahoney Lake Project, the City wishes to preserve its rights under the Public Utility Regulatory Policies Act of 1978 (PURPA) to guarantee that KPU will purchase the project output at its avoided cost. The City believes that all parties concerned would benefit if a power purchase agreement were finalized with KPU as soon as possible, and will diligently continue to pursue this with KPU. The City has met and corresponded with KPU to discuss this issue many times since 1993. 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 Mahoney Lake Hydroelectric Project FERC No. 11393-000 C-2 September 1995 £ Response: Issue 4: September 1995 Response to Agency Comments 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. See response to KPU Issue No. 1. The City is definitely not basing project economics upon preferential use or on use of Mahoney Lake instead of KPU’s existing resources. Project economics are solely based on offsetting diesel generation by KPU, and avoiding future diesel plant expansions or other large capital intensive projects such as the Lake Tyee Hydroelectric Project (FERC No. 3015)/Swan Lake Project (FERC No. 2911) Intertie. Project economic projections show a net benefit to KPU and its ratepayers if cheap, renewable energy from Mahoney Lake is used in Ketchikan for the next 50 years instead of using energy generated by burning diesel fuel. The City has retained an independent economic analysis consultant, Economic and Engineering Services, Inc. (EES) to perform a complete economic analysis of the project and to compare the project to diesel generation and other potential future energy resources in the Ketchikan area. The results of their analysis show that the Mahoney Lake Project is the most cost effective option for Ketchikan at this time, and in fact, is the only option that will not result in rate shock for the ratepayers of KPU. This study also shows that other projects such as the intertie would result in significant rate shock for the KPU ratepayers unless it was constructed completely with grant monies and could obtain subsidized rates for energy from the Lake Tyee Project (FERC No. 3015). This economic analysis has been provided to KPU. The intertie is clearly not a complete answer for Ketchikan. As Ketchikan, Petersburg, and Wrangell loads grow, less and less energy will be available to Ketchikan over the intertie, and by 2013, even with the intertie, diesel generation would have to resume in Ketchikan. Projections including the intertie show that by 2023, diesel generation capacity equivalent to the Mahoney Lake Project would be necessary. Building the Mahoney Lake Project now would provide capacity and energy for KPU as it pursues authorization for the intertie. Mahoney Lake could help avoid diesel generation completely until at least 2023. The Mahoney Lake Project will be a cost-effective, long-term source of energy that will be available for at least SO years for the region, and likely for in excess of 100 years. This long-term benefit needs to receive full/complete consideration by KPU. All project energy projections made to date, all of which have been shared with KPU, show Mahoney Lake energy being used only after all KPU hydro resources and the Swan Lake Project (FERC No. 2911) have been exhausted on an annual basis. The City is convinced that the Mahoney Lake Project is not only feasible, but is the best and lowest cost option for the citizens of Ketchikan as their system loads continue to grow. For the project to be a meaningful addition to the Ketchikan area power system, it should include a dam for additional storage. Mahoney Lake Hydroelectric Project Cc-3 FERC No. 11393-000 Response to Agency Comments Response: Issue 5: Response: Addition of a dam at the upper lake was investigated by the City in order to increase storage at the project. There are several factors involved in the City’s decision to not to include a dam in the project design at this time: a) In the first few years of project operation, projections show that only about 90- 95% of the proposed project’s output would be used by KPU until diesel loads grow a little further. Addition of a dam into the initial project configuration would not be cost effective because the additional flexibility it would provide KPU would not be necessary until some time off in the future. If a dam would prove to be of benefit, and is cost effective and environmentally acceptable, the City would agree to study its feasibility in the future and to add a dam at the upper lake in the future through a license amendment process when it appears warranted. If FERC were to add a license condition to the license requiring the City to review the feasibility of adding a dam in the future and to apply to FERC for an amendment when such an addition was feasible, the City would accept such a condition. b) The area in the vicinity of the upper lake outlet is subject to avalanche in the winter and has slope instability and evidence of historic landslide activity along the left side of the outlet creek. The presence of these problems presents some challenges for construction of a dam at this location, although we agree that these concerns could probably be addressed by good engineering design and by keeping the dam relatively small. c) No road access will be possible to the dam location. It will have to be constructed of local materials and by use of helicopters, so it will probably be very expensive. d) Raising the lake level by constructing a dam will inundate some habitat for plants and animals, so some environmental concerns by the public and the resource agencies are likely. The proposed project results in 3,760 acre-feet of storage without the need for any dam whatsoever. e) The project as proposed has 3,760 acre-feet of storage. A 25-foot high dam would add an additional 2,000 acre-feet, or a 50-foot high dam would add 3,300 acre-feet. It is difficult to see how this increase in storage could make the project more attractive to KPU. As stated earlier, the City is willing to look at adding a dam in the future when it appears to be necessary and feasible. Interconnection of the Mahoney Lake transmission line to the Ketchikan system should be moved to the Beaver Falls Project (FERC No. 1922). The City recognizes that this change in project configuration would be of benefit to KPU. For this reason, the City agrees to add the review of this new "southern" intertie route to the scope of study for the project feasibility studies and the Mahoney Lake Hydroelectric Project FERC No. 11393-000 C4 September 1995 Issue 6: Response: Issue 7: Response: September 1995 Response to Agency Comments Environmental Assessment. A potential route has already been identified and flagged in the field. Bald eagle, marbled murrelet, and northern goshawk surveys have been conducted of this new route along with vegetation, sensitive plant and cultural resource surveys. This potential route will be evaluated throughout the environmental review process. The economic analysis of this project would be incomplete without pursuing the market potential of Mahoney Lake power in Metlakatla. Two meetings have been held since the date of this comment letter to pursue the idea of interconnection to Metlakatla. This interconnection would require construction of roads, above ground transmission lines, and a submarine transmission line to Annette Island before it could become a reality. Metlakatla is reviewing this project and deciding whether or not to proceed. If Metlakatla were to build these facilities, the City would be interested in further pursuing the notion of power sales to Metlakatla. If the "southern" intertie route to the Beaver Falls Project (FERC No. 1922) is adopted, the transfer of power to Metlakatla could occur with almost no additional facilities being necessary. The City believes that KPU, who is the locally franchised utility, would be the most appropriate agency to contract with Metlakatla for sale of energy. KPU could provide Metlakatla with more capacity~and flexibility, and would also be able to best integrate Metlakatla’s needs with the KPU system. Until the significant new facilities are constructed, or even proposed by Metlakatla formally, the City is unable to evaluate or commit to sale of energy to Metlakatla. We believe that more than sufficient basis for economic evaluation of the project exists by analyzing the present and future needs of the KPU system alone. The possibility of future sales to Metlakatla only further enhances the already attractive economic viability of the project. The project is even less economically feasible when you add an anticipated mark- up for the power for the benefit of the City, who would obviously expect a return on their investment. See previous responses. The City is proposing to sell power from the Mahoney Lake Project to KPU to replace energy generated by KPU’s diesel units. As KPU loads continue to grow, as projected by KPU and all other available load growth projections, more and more diesel generation will be required. KPU’s residential rates as of June 1995 are $0.0875 per kWh. Diesel fuel alone costs approximately $0.07 per kWh and this does not include the cost of operation and maintenance, replacement funds or debt service retirement. The power produced by the proposed project will be less expensive than equivalent diesel generation. This can be of great benefit to KPU and its ratepayers. The City has the ability not only to sell bonds at rates equivalent to bond money available to KPU, but as a Native Alaskan entity, also may be able to obtain low interest loans or grant monies from the federal government that may not be available to KPU. Due to all these Mahoney Lake Hydroelectric Project C-5 FERC No. 11393-000 Response to Agency Comments factors, the City is confident that a power purchase agreement can be worked out that will provide the KPU ratepayers relief from expensive diesel generation costs while assisting the City in developing an economic base to help insure the future viability of this community. An independent economic evaluation of the project was conducted by EES as discussed above in response to Issue No. 3. This analysis shows the Mahoney Lake Project is not only economically feasible, but is the only option available to KPU for new energy resources that will not result in rate shock to the ratepayers. This report has been shared with KPU and its consultants. Alaska Department of Fish and Game (ADFG) May 11, 1995 Issue 1: Response: Issue 2: Response: Impact of post-project flows on fish in Lower Mahoney Lake and fish passage in Lower Mahoney Creek. The City prepared a flow regime report in June that directly responds to the concern for fish passage through Lower Mahoney Creek. The indications are that the project will not appreciably change conditions in the Mahoney basin, as the project flows are derived from 39% of the total Mahoney basin and planned post- project average flows in August and September track very closely with existing pre-project conditions. A water quality report that will soon be available for agency review discusses the impacts to spawning fish at the outlet of Upper Mahoney Creek. As discussed at the June 22, 1995, meeting, with the USFS, ADFG, and USFWS, the project will be able to augment flows in the Mahoney Lake system for a brief period to facilitate fish passage through Lower Mahoney Creek and into Mahoney Lake. The City has been conducting additional fish studies this summer to better identify the dynamics of fish passage through Lower Mahoney Creek. The fisheries study plan is described in Appendix A. The observations will be linked with flow information from a new stream gage that was installed on Lower Mahoney Creek in the approximate location of the former U.S. Geological Survey gage site. As discussed at the June 22, 1995, meeting, the project will be capable of increasing flows to facilitate fish passage should conditions warrant. The need for gage data and the verification of fish passage blockages. Refer to Appendix A for the proposed summer field program. This information will be collected and appended to the fish report for agency review and ultimate incorporation in to the EA. At the June 22, 1995, meeting in Ketchikan, the City agreed to construct a bypass pipe to allow for the release of water into Upper Mahoney Creek. The water would be diverted to the creek in the vicinity of the upper construction site and would provide water through the upper creek and into Mahoney Lake Hydroelectric Project FERC No. 11393-000 C-6 September 1995 Response to Agency Comments the outlet at Lower Mahoney Lake. This will support salmon spawning and overwintering at the delta of Lower Mahoney Lake. Issue 3: Maintenance of groundwater upwelling flows and incubating eggs. Response: A water resources report is being prepared that will be distributed for review. The water resources report, in conjunction with the fish report, specifically addresses the impact of post-construction project flows on incubating eggs in salmon redds at the outlet delta of Upper Mahoney Creek. Issue 4: The necessity of post-construction monitoring Response: The EA will contain measures to monitor the effects of the operation of the project. Additional measures will be discussed with the agencies once the results of the 1995 field program have been analyzed. Issue 5: Preliminary Stipulations Response: Comment noted. Ketchikan Area State Parks Advisory Board : May 14, 1995 Issue 1: Accessibility of recreationists to project site. Response: Comments noted. No response required. U.S. Fish & Wildlife Service (USFWS) May 19, 1995 Issue 1: Impact of post-project flows on fish in Lower Mahoney Lake and fish passage in Lower Mahoney Creek. Response: See Response No. 1 to the ADFG May 11, 1995, letter. Issue 2: The impact of temporary shut-downs should be described. Response: The EA will describe project operational features that address concerns arising from temporary shut-downs. At the June 22, 1995, meeting in Ketchikan, the City agreed to construct a bypass pipe to allow for the release of water into Upper Mahoney Creek. The water would be diverted to the creek in the vicinity of the upper construction site and would provide water through Upper Mahoney Mahoney Lake Hydroelectric Project September 1995 C7 FERC No. 11393-000 Response to Agency Comments Issue 3: Response: Issue 4: Response: Issue 5: Response: Issue 6: Response: Issue 7: Response: Issue 8: Creek and into the outlet at Lower Mahoney Lake. This will support salmon spawning and overwintering at the delta of Lower Mahoney Lake. Construction timing. The method of construction of the project was discussed at the June 22, 1995, meeting. The tailrace can be constructed by maintaining a plug of rock to eliminate the potential for excess water entering the creek. This rock plug can be left in place to eliminate project construction runoff from entering the creek. This and other construction measures, particularly those involving timing of construction, will be evaluated and described in the EA. An Erosion and Sediment Control Plan is being developed for project construction and will be included as an appendix to the License Application. Cumulative impacts. The EA will contain a discussion of cumulative impacts, though at present the project is not expected to contribute to any significant cumulative impacts. The facility, including roads and related facilities, will be maintained as private property. Impact to Carex lenticularis. This particular species was identified in an area that will not be affected by project activities. It is being addressed in the biological evaluation (BE) being prepared for the U.S. Forest Service. The BE will be provided to agency staff for their review. A note will be added to construction drawings to alert crews to its location and the need to protect it from adverse impact. Impact to Calamagrostis crassiglumis. Field staff will attempt to clarify the status of this species and present their findings in the BE being prepared for the U.S. Forest Service. The BE will be provided to agency staff for their review. Transmission line impacts to avian resources. The transmission line will be constructed in accordance with the guidance referenced. Options for burying the line in areas identified as flight corridors will be explored. Spotted frog occurrence in the project area. Mahoney Lake Hydroelectric Project FERC No. 11393-000 C-8 September 1995 Response: Issue 9: Response: Issue 10: Response: Issue 11: Response: Issue 12: Response: Response to Agency Comments As discussed at the June 22, 1995, meeting, the City will attempt to identify habitat likely to support spotted frogs from aerial photography. Areas with a potential to support the species will be surveyed using minnow traps set in shallow water. Impacts to other species. The EA and BEs being prepared for the project will discuss the potential for impact to the other species listed. Impacts to nesting bald eagles. A bald eagle nest survey was conducted by USFWS and Cape Fox Corporation staff on July 10, 1995. Pending final location of the proposed transmission line and other project features, attempts will be made to establish the minimum buffer areas recommended. The recommendations for use of aircraft in support of project construction and operation activities will be incorporated into the EA and project construction bid documents. Impacts to Marbled Murrelets. The proposed field program includes work to determine the presence or absence of marbled murrelets in the project area. Please refer to Appendix A for more detail about how and where this work will be conducted. The approach to be taken for marbled murrelets was discussed at the June 22, 1995, meeting and the agencies present were in general agreement with that approach. Impacts to Northern Goshawks. The proposed field program includes work to determine the presence or absence of northern goshawks in the project area. Please refer to Appendix A for more detail about how and where this work will be conducted. The approach to be taken for northern goshawks was discussed at the June 22, 1995, meeting and the agencies present were in general agreement with that approach. Alaska Division of Governmental Coordination May 19, 1995 Issue 1: Response: Review of state coastal management program consistency process. See Response No. 2 to ADGC April 5, 1995, letter. September 1995 Mahoney Lake Hydroelectric Project c-9 FERC No. 11393-000 Response to Agency Comments Alaska Division of Governmental Coordination Undated 1. No response required. Alaska Industrial Development and Export Authority June 1, 1995 Issue 1: Recommends adoption of the Southern Alternative transmission line route as preferred alternative. Response: Comment noted. Senator Robin L. Taylor June 7, 1995 Issue 1: Support for Southern Alternative and recommendation for construction of access road along the route. Response: Comment noted. Alaska Department of Fish and Game June 20, 1995 Issue 1: Potential Impacts to Mountain Goats Response: The project EA will contain recommendations to limit project-related impacts to mountain goats relocated to the area above the upper contruction site. These recommendations will include limiting the operation of helicopters in the vicinity of the reported locations of mountain goats near the upper construction area. U.S. Forest Service (USFS) June 21, 1995 Issue 1: Need to submit a research design and qualifications of primary cultural resource investigator prior to surveying project area. Response: Comment noted. Issue 2: Eagle nest surveys Response: See Response No. 10 to the USFWS May 19, 1995, letter. Mahoney Lake Hydroelectric Project FERC No. 11393-000 C-10 : September 1995 ~« Issue 3: Response: Issue 4: Response: Issue 5: Response: Issue 6: Response: Response to Agency Comments Siting of Southern Alternative Transmission Line Comment noted. Where possible, the transmission line for the Southern Alternative will be located at least 500 feet from.saltwater. a Compliance with tree harvesting standards around stream channels. Compliance with tree harvesting standards around stream channels will be observed. Waiver of Investigative Special Use Permit for Southern Alternative studies Comment noted. It is not anticipated that the studies along the Southern Alternative transmission line corridor will cause adverse environmental impacts. The USFS will be contacted if it appears that ground disturbing activities would be required. Visual impacts due to the Southern Alternative transmission line need to be minimal. Where feasible along the transmission line route, visual impacts will be mitigated through use of topographic and vegetative features. Federal Energy Regulatory Commission June 21, 1995 Issue 1: Response: Issue 2: Response: Issue 3: Response: September 1995 Recommend deleting asterisks on issues under Aquatic Resources, Section 5.2.2 of SD1. Comment noted. Asterisks have been deleted. Narrow the geographical scope of cumulative analysis to the recreational sockeye fishery area which seems to be Lower Mahoney Lake and maybe a short section of Lower Mahoney Creek. Comment noted. Sentences have been revised. Need for cultural resource survey along Southern Alternative corridor. A cultural resource survey will be conducted along the Southern Alternative corridor as well as the other areas of the project that will be impacted by ground- disturbing activities prior to submittal of the application for license and the DEA. Mahoney Lake Hydroelectric Project C-11 FERC No. 11393-000 Response to Agency Comments Issue 4: Response: Issue 5: Response: Issue 6: Response: Will an inventory be conducted along this alignment? Wildlife and plant surveys are proposed to be conducted along the Southern Alternative transmission line corridor. See Appendix A for the study plans that were developed in consultation with the appropriate agencies. Has the Southern Alternative been designed to avoid/minimize all possible adverse impacts? The results of the studies that will be conducted this summer along the Southern Alternative corridor will be used to evaluate if design changes need to be made so that the environmental impacts of the transmission line will be minimal. Additional access opportunities for recreationists. 7 The Southern Alternative might create some new opportunities for accessing the TNF but not without difficulties. There is a locked gate at the Beaver Falls Project (FERC No. 1922) on the southern end of the route. There is a locked gate at the boundary of the Cape Fox Corporation property on the White River Road approximately 7 miles northwest of Lower Mahoney Creek. So someone would have to hike or bike 7 miles to access the northern end of the southern alternative route. Boaters could access the corridor by beaching their boat and scrambling up the hill to the proposed right-of-way clearing. Greater Ketchikan Chamber of Commerce June 23, 1995 Issue 1: Response: We would like to know whether this realignment (of the transmission line from the Swan Lake Project [FERC No. 2911] to the Beaver Falls Project [FERC No. 1922] interconnection point) will allow a more cooperative planning process so the two projects (Swan Lake-Lake Tyee Intertie Project and Mahoney Lake Project) may both go forth to development. After receipt of the KPU response letter, the City added the "southern route" realignment to the scope of study for the EA, and has agreed to make a complete assessment of it. Clearly, this route has some benefits to KPU and the City is anxious to work out the final agreements with KPU that will formalize both the use of this route to the Beaver Falls Project (FERC No. 1922) and finalize power sales agreements. Several meetings that have taken place between the City and KPU since the date of their comment letter indicate that a more cooperative planning process is indeed possible. Recently, KPU: began a formal search for new resources for their system and is presently conducting feasibility studies for additional hydro facilities. The City believes this indicates that KPU realizes that their Swan Lake (FERC No. 2911)/Lake Tyee (FERC No. 3015) Intertie Project Mahoney Lake Hydroelectric Project ; FERC No. 11393-000 C-12 : ; September 1995 ADFG Response to Agency Comments may not be the complete solution to their energy needs and that some new resources will soon be necessary. If the Mahoney Lake Project compares favorably to other resources, which the City believes it does, KPU may become more receptive to the Mahoney Lake Project in the future. June 27, 1995 Issue 1: Response: Issue 2: Response: USFWS July 13, 1995 Issue 1: Response: Issue 2: Response: Issue 3: Response: Issue 4: Response: September 1995 Bald eagle nest survey. See Response No. 10 to USFWS May 19, 1995, letter. Avoidance of 500’ coastal fringe for siting Southern Alternative transmission line. See Response No. 3 to USFS June 21, 1995, letter. Impacts to raptor nests, marbled murrelets, northern goshawks, and candidate plant species. The issues raised are all addressed in the field program description in Appendix A. Impact to deer winter range. The EA will contain a discussion of the potential impacts to deer winter range and deer populations in the vicinity of the southern transmission line. Cumulative effects. See Response No. 4 to the USFWS May 19, 1995, letter. Impact of a road along the southern transmission line route. The City does not propose construction of an access road along the Southern Alternative transmission line route. Mahoney Lake Hydroelectric Project C-13 FERC No. 11393-000 Response to Agency Comments Issue 5: Work at Beaver Falls. Response: Any in-water work anticipated at the transmission line crossing of Beaver Falls Creek will be coordinated with the ADFG and staff at the Beaver Falls Hatchery. The work will be timed so as not to interfere with the operations of the hatchery. Mahoney Lake Hydroelectric Project FERC No. 11393-000 C-14 September 1995