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Mahoney Lake Hydro Additonal Information Request 1996
Aberin ae | pispahsr to ) Additional Before the Fics. a spe 9 ey Wes iy j ae Information ley ; October 18, 1996 Ms. Lois Cashell, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room A-1 Washington, D.C. 20426 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to Additional Information Request Dear Ms. Cashell: HDR Engineering, Inc., on behalf of the City of Saxman, Alaska, encloses for filing an original and eight copies of the response to John H. Clements’ letter dated July 22, 1996, and the Additional Information Request (Schedule A) attached to the letter. If you have any questions regarding the response, or need further information, please let me know. Respectfully, HDR ENGINEERING, INC. A Michael V. Stimac, Manager Licensing and Environmental Services Enclosures ce: Service List Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Bellevue, Washington Fax 98004-5538 206 453-7107 MAHONEY LAKE HYDROELECTRIC PROJECT FERC NO. 11393 Certificate of Service I hereby certify that I have this day served the Mahoney Lake Hydroelectric Project Response to Additional Information Request upon all persons listed below in accordance with the requirements of Section 385.2010(h) of the Rules of Practice and Procedure: U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Mr. Andrew Grossman Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg U.S. Fish & Wildlife Service 3000 Vintage Blvd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 Mr. Jim DeHerrera District Ranger US. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 Service List Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main Street, Suite 905 Portland, OR 97204 Mr. Michael Strzelecki OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-70 Washington, DC 20426 Mr. Vince Yearick OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-73 Washington, D.C. 20426 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Mahoney Lake Hydroelectric Project FERC No. 11393 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office 3601 C Street, #1200 Anchorage, AK 99503-5925 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Alaska Public Utiliti¢s Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Service List Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project FERC No. 11393 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 Mr. Tom Fitzgerald City Administrator City of Saxman Route 2, Box 1 Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Service List Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen US. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, OR 97209 Mahoney Lake Hydroelectric Project FERC No. 11393 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20420 Mr. Jim Thrall Locher Interests, Ltd. 406 West Fireweed Lane Suite 101 Anchorage, AK 99503 Dated at Bellevue, Washington, this 18th day of October, 1996. ae re Service List Mahoney Lake Hydroelectric Project FERC No. 11393 MAHONEY LAKE HYDROELECTRIC PROJECT FERC NO. 11393 RESPONSE TO ADDITIONAL INFORMATION REQUEST CITY OF SAXMAN, ALASKA OCTOBER 18, 1996 Applicant's Response to Additional Information Request MAHONEY LAKE HYDROELECTRIC PROJECT FERC NO. 11393 RESPONSE TO ADDITIONAL INFORMATION REQUEST TABLE OF CONTENTS Section Page INTRODUCTION 1 FERC Letter of July 22, 1996 2-10 GENERAL Additional Agency Distribution 11 Aperture Cards 11 Application Acceptance and Agency Notification of AIR 12 SCHEDULE A Item 1: Section 401 Water Quality Certification 12 Item 2: Aquatic Resources Monitoring Plan 13 Item 3: Post-Project Cumulative Degree Days 14 Item 4: Cultural Resources 16 Item 5: Hydrologic Data 18 APPENDIX - CORRESPONDENCE & DOCUMENTATION Additional Agency Distribution - HDR Letter to U.S. Army Corps of Engineers - July 26, 1996 - HDR Letter to Department of Interior - July 26, 1996 - HDR Letter to Alaska Bureau of Land Management - July 26, 1996 Aperture Cards - HDR Letter to FERC, Secretary - August 29, 1996 - HDR Letter to FERC, Portland Regional Office - August 29, 1996 - HDR Letter to Alaska Bureau of Land Management - August 29, 1996 Application Acceptance and Agency Notification of AIR - HDR Letter to Distribution List - July 26, 1996 Section 401 Water Quality Certification - Coastal Project Questionnaire and Certification Statement - May 20, 1996 - Alaska Department of Environmental Conservation Letter to HDR - October 8, 1996 Aquatic Resources Monitoring Plan - HDR Letter to Distribution List - August 2, 1996 - Alaska Department of Fish and Game Letter to HDR - August 27, 1996 - HDR Letter to Alaska Department of Fish and Game - October 14, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 -i- FERC No. 11393 Applicant's Response to Additional Information Request TABLE OF CONTENTS (continued) APPENDIX - CORRESPONDENCE AND DOCUMENTATION (continued) Post-Project Cumulative Degree Days - HDR Letter to Distribution List - August 29, 1996 - HDR Letter to Distribution List - September 11, 1996 Cultural Resources - HDR Letter to U.S. Forest Service - September 18, 1996 - HDR Letter to Alaska State Historic Preservation Office - September 18, 1996 Hydrologic Data - HDR Letter to FERC, OHL - July 26, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 -ii- FERC No. 11393 Applicant's Response to Additional Information Request INTRODUCTION The following information is provided in response to the July 22, 1996, letter from the Director, Division of Project Review (received on July 25, 1996) notifying the Applicant that the license application for the Mahoney Lake Hydroelectric Project has been accepted by the Commission for filing as of May 31, 1996, identifying certain actions and requesting additional information in order to complete review and processing of the application. The organization of this response lists each item requested by the FERC in their July 22, 1996, letter and Schedule A attached to the letter with the Applicant’s response immediately following. All correspondence and documentation is included in the Appendix to this response under the appropriate section heading. Mahoney Lake Hydroelectric Project October 18, 1996 -I- FERC No. 11393 FEDERAL ENERGY REGULATORY COMMISSION il ECE VE WASHINGTON, D. C. 20426 I Project No. 11393-001-AK JUL 2 5 1996 Mahoney Lake Hydroelectric Project City of Saxman, Alaska ‘HOR ENGINEERING, INC © Mr. Tom Fitzgerald City Administrator ede ee City of Saxman UR 2°2 1005 Route 2, Box 1 Ketchikan, Alaska 99901 Dear Mr. Fitzgerald: Your license application for the referenced project has been accepted by the Commission for filing as of May 31, 1996. A public notice for this project will be issued shortly indicating the above finding and soliciting interventions and protests on the application and your reply comments. The notice will also solicit final terms, conditions, and comments. Federal, state, and interstate resource agencies, and any Indian Tribe affected by this project, will be informed in the Commission’s public notice that a copy of the complete application may be obtained directly from you. Within 5 days after you receive this letter, if you haven’t already done so, send one copy of your license application to the following: the Commission’s Portland Regional Office; the Department of the Interior, Office of Environmental Affairs, the U.S. Army Corps of Engineers, North Pacific Office; and the Alaska State Director, Bureau of Land Management. A list of addresses is attached. Within 45 days from the date of this letter, you must file with the Commission’s Secretary an original and a duplicate set of aperture cards showing your exhibit drawings. Also, send a duplicate set of aperture cards to the Commission’s Portland Regional Office and the Alaska State Director, Bureau of Land Management. For the aperture cards showing your exhibit drawings: make an original and two Diazo-type duplicate sets of cards. To make the original set of cards, (1) take the exhibit sheets listed by FERC drawing numbers, (2) make microfilm copies of the sheets, and (3) mount them on type D aperture cards (3 1/4 by 7 3/8 inches). To make the duplicates, reproduce the original set on silver or gelatin 35-millimeter microfilm. For each microfilm drawing, show the FERC drawing number in the margin below the title block. On the top lines of the aperture cards, show (1) the appropriate FERC exhibit name, (2) the project number, (3) the drawing number, (4) the drawing title, and (5) the date of this letter. We also need additional information in order to complete our review and processing of your application. A listing of the information required is presented in the enclosed schedule A. Under section 4.32(g) of the Commission’s regulations, you have 90 days from the date of this letter to provide the additional information requested. If the requested information causes any other part of the application to be inaccurate, that part must also be revised and refiled by the due date. Within five days of receipt, provide a copy of this letter and the enclosed schedule to all entities that received a copy of your final application. Then, when you file the requested information with the Commission, you must also provide a complete copy of that information to each entity that received a copy of your final application. Documents to be filed with the Commission must be filed by providing an original and 8 copies as required by the Commission’s regulations to: Secretary, Federal Energy Regulatory Commission, 888 First Street, N.E., Washington, D.C. 20426. If you have any questions concerning this matter, please call Vince Yearick on (202) 219-3073. Sincerely, Sle CL ne TO John H. Clements Director, Division of Project Review Enclosures: List of Addresses FERC Drawing Numbers Schedule A CG: Mr. Doug Campbell Cape Fox Corporation 2851 S. Tongass P.O. Box 8558 Ketchikan, AK 99901 Mr. Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. 500-108th Avenue, NE Suite 1200 Bellevue, WA 98004 Mr. John Braislin Betts, Patterson, and Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Donald H. Clarke Wilkinson, Barker, Knauer, & Quinn 1735 New York Avenue, N.W. Washington, DC 20006 Addresses Federal Energy Regulatory Commission Portland Regional Office 101 S.W. Main Street, #905 Portland, OR 97204 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, DC 20240 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, OR 97209 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 FERC DRAWING NUMBERS Project No. 11393-0001 Drawing No. 11319- F-0 through F-9 G-1 through G-2 Project No. 11393 Schedule A ADDITIONAL INFORMATION 1. In your application your state that, by agreement between the Alaska Department of Environmental Conservation (ADEC) and the U.S. Army Corps of Engineers (COE), a dredge and fill application under Section 404 of the Clean Water Act may also serve as an application for a state water quality certification under Section 401 of the Clean Water Act. Your application includes a copy of a Section 404 application completed on May 20, 1996. However, there is no evidence that you sent the Section 404 application (or other request for water quality certification) to the ADEC, that the ADEC received the Section 404 application, or that the ADEC accepted the Section 404 application as a request for a Section 401 water quality certification. To establish that you have requested a Section 401 water quality certification please provide: (A) a copy of your certification request to the ADEC; and (B) proof that the ADEC received the request. Proof of receipt must be either: (1) a copy of a certified mail receipt showing the date the ADEC received the Section 401 request; or (2) a letter from the ADEC confirming the receipt date. If the ADEC has accepted the Section 404 application as a request for a Section 401 water quality certification, you must submit written confirmation of the acceptance from the ADEC, including confirmation of the date the ADEC received the Section 404 application. 2. According to Appendix K of your application, on May 9, 1996, you sent a proposed aquatic resources monitoring plan to the National Marine Fisheries Service (NMFS), the U.S. Fish and Wildlife Service (FWS), and the Alaska Department of Fish and Game (ADFG), and requested that the agencies send comments .on the plan to you by May 17, 1996. You did not include a copy of your proposed aquatic resources monitoring plan, along with any agency comment letters, with your application. To help us evaluate your proposed monitoring of aquatic resources in the project area, please provide: (A) a copy of the proposed aquatic resources monitoring plan that you sent to the NMFS, the FWS, and the ADFG; and (B) copies of the comment letters, if any, that you received from the resource agencies. In addition, send a copy of the monitoring plan and a request for comments to each of the entities that received a copy of your final application, but have not received a copy of your monitoring plan, and allow them a minimum of 30 days to provide you with their comments. Include documentation of your request for comments and copies of the comments and recommendations, if any, in your response filed with the Commission. 3. Your estimated post-project cumulative degree days during the sockeye incubation period are derived from estimated post-project temperatures that included assumptions about the mixing of Upper Mahoney Creek flows and ground water at the spawning site and the depth of the drawdowns in Upper Mahoney Lake. There are some discrepancies, however, in your application: e The post-project cumulative degree days in Table 3 (page 31) of the preliminary draft Environmental Assessment (EA) are different than the post-project cumulative degree days in Table 3 (page 7) of Appendix C of the application; ; e Figures 11 and 12 in Appendix C, graphic presentations of the cumulative degree days, do not correspond to the days enumerated in Table 3 of Appendix C, but appear to correspond with Table 3 of the preliminary draft EA; and e Figure 7 in the preliminary draft EA, a graphic presentation of Table 3 of the preliminary draft EA, does not correspond to the cumulative degree days in Table 3 of the preliminary draft EA or Table 3 of Appendix C. e The "minimum post-project mixed" values are not represented in Figure 11 of Appendix C. To help us understand your analysis, please: (A) explain the above discrepancies in cumulative degree days between the preliminary draft EA and Appendix C of the application; (B) provide your best estimate of cumulative degree days; (1) from September 1 through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (2) from October 1 through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming 7 the ground water and with proportionate mixing between the streamflow and the ground water, (3) from September 1 through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (4) from October 1 through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, and (C) explain how the cumulative degree days in B(1) through B(4) were calculated. (Note: The cumulative degree day calculations in Appendix C appear to support Table 3 of Appendix C. If these calculations were changed by another analysis, please explain the basis for the changes.) You must provide the NMFS, the FWS, the ADFG, and each of the other entities that received a copy of your final application with copies of items 3(A) through 3(C), and allow them a minimum of 30 days to provide you with their comments. Include documentation of your request for comments and copies of the comments and recommendations, if any, in your response filed with the Commission. 4. We cannot evaluate the effect of the project on cultural resources without reviewing the report on the cultural resources survey of the project, and the comments of the Alaska State Historic Preservation Officer (SHPO) and the Forest Service (FS) archeologist on the adequacy of the report. Therefore, file the following: (1) 3 copies of the report; and (2) letters from the SHPO and the FS archeologist on the report. If the SHPO or the FS archeologist recommends additional survey, file a schedule for conducting the survey and filing a report with the Commission, or provide an explanation why such work is not necessary. Work needs to be completed by this year’s field season. If your survey shows that archeological or historic sites or traditional cultural properties of Native American tribes eligible for the National Register of Historic Places would be affected by the project, do the following: (1) File a cultural resources management plan--which you would implement after licensing--for avoiding or mitigating the effects on the sites. 8 (2) Base your plan on the recommendations of the SHPO and the FS archeologist, and include their comments on the plan in your filing. (3) If the SHPO and the FS archeologist recommends that you implement your plan through a memorandum of agreement (MOA), file an MOA, or explain why one is not needed. (4) If you prepare an MOA: (a) make the MOA among us, the SHPO, the FS, and the Advisory Council on Historic Preservation (Council); (b) include the comments of the SHPO and the FS on the MOA in your filing; and (c) revise the MOA as you determine appropriate to address the SHPO’s and the FS’s concerns. Conduct the survey and prepare the report and plan according to the Secretary of the Interior’s Standards and Guidelines for Archeology and Historic Preservation. You may obtain copies by telephoning the National Park Service at (202) 343-4101. In preparing an MOA, follow the Council’s guidelines, "Preparing Agreement Documents". You may get a copy of the guidelines by telephoning the Council at (202) 606-8505. To keep the locations of archeological sites confidential and to protect them from theft or vandalism, you should file three copies of the survey report and the plan or MOA directly with our cultural resources staff. Send this information--clearly marked "Confidential--Not for Public Disclosure"--to Dr. Edwin D. Slatter, Office of Hydropower Licensing, Federal Energy Regulatory Commission, 888 First St., NE, Room 5H-01, Washington, D.C. 20426. When you file this information with our staff, make a separate filing with the Secretary of the Commission that does the following: (1) Says you’ve made the filings with our staff. (2) Briefly describes the purpose and contents of the filing--without referring to site locations--so reviewing parties are informed about the general nature of archeological sites affected by the project. 5. Please provide one computer diskette copy of the complete hydrologic data set for the 35 years of record you used to analyze the Mahoney Lake Project. File the diskette with: Jim Fargo, Office of Hydropower Licensing, Federal Energy Regulatory Commission, 888 First St., NE, Room 52-77, Washington, D.C. 20426. Applicant's Response to Additional Information Request GENERAL ADDITIONAL AGENCY DISTRIBUTION FERC Request: Within 5 days after you receive this letter, if you haven’t already done so, send one copy of your license application to the following: the Commission's Portland Regional Office; the Department of the Interior, Office of Environmental Affairs; the U.S. Army Corps of Engineers, North Pacific Office; and the Alaska State Director, Bureau of Land Management. A list of addressees is attached. Applicant Response: The Commission’s Portland Regional Office received a copy of the license application when it was filed with the Commission on May 31, 1996. Copies of the license application were forwarded to the Department of the Interior, Office of Environmental Affairs, the U.S. Army Corps of Engineers, North Pacific Office, and the Alaska State Director, Bureau of Land Management via letters dated July 26, 1996. These agencies were added to the formal distribution list for the Mahoney Lake Hydroelectric Project. Copies of the submittal letters are included in the Appendix of this response. APERTURE CARDS FERC Request: Within 45 days from the date of this letter, you must file with the Commission’s Secretary an original and a duplicate set of aperture cards showing your exhibit drawings. Also, send a duplicate set of aperture cards to the Commission’s Portland Regional Office and the Alaska State Director, Bureau of Land Management. Applicant Response: Aperture cards of the exhibit drawings were filed with the Commission’s Secretary and sent to the Commission’s Portland Regional Office and the Alaska State Director, Bureau of Land Management via letters dated August 29, 1996. Copies of the submittal letters are included in the Appendix of this response. Mahoney Lake Hydroelectric Project October 18, 1996 -11- FERC No. 11393 Applicant's Response to Additional Information Request APPLICATION ACCEPTANCE AND AGENCY NOTIFICATION OF AIR FERC Request: Within five days of receipt, provide a copy of this letter and the enclosed schedule to all entities that received a copy of your final application. Then, when you file the requested information with the Commission, you must also provide a complete copy of that information to each entity that received a copy of your final application. Applicant Response: Copies of the FERC letter dated July 22, 1996 were forwarded on July 26, 1996, to those agencies/entities receiving the license application. A copy of the July 26 letter is included in the Appendix of this response. Copies of this submittal are also being provided to the same distribution. SCHEDULE A: ADDITIONAL INFORMATION ITEM 1: SECTION 401 WATER QUALITY CERTIFICATION FERC Request: In your application you state that, by agreement between the Alaska Department of Environmental Conservation (ADEC) and the U.S. Army Corps of Engineers (COE), a dredge and fill application under Section 404 of the Clean Water Act may also serve as an application for a state water quality certification under Section 401 of the Clean Water Act. Your application includes a copy of a Section 404 application completed on May 20, 1996. However, there is no evidence that you sent the Section 404 application (or other request for water quality certification) to the ADEC, that the ADEC received the Section 404 application, or that the ADEC accepted the Section 404 application as a request for Section 401 water quality certification. To establish that you have requested a Section 401 water quality certification please provide: (A) a copy of your certification request to the ADEC; and (B) proof that the ADEC received the request. Proof of receipt must be either: (1) a copy of a certified mail receipt showing the date the ADEC received the Section 401 request; or (2) a letter Jrom the ADEC confirming the receipt date. If the ADEC has accepted the Section 404 application as a request for Section 401 water quality certification, you must submit written confirmation of the acceptance from the ADEC, including confirmation of the date the ADEC received the Section 404 application. Mahoney Lake Hydroelectric Project October 18, 1996 -12- FERC No. 11393 Applicant's Response to Additional Information Request Applicant Response: To establish that a Section 401 water quality certification has been requested, the following information is provided: (A) _ The Coastal Project Questionnaire and Certification Statement, Department of Environmental Conservation Approvals, page 5, noted that a Section 401 Water Quality Certification was being submitted “concurrent with this submittal and the Section 404 permit application submittal.” The project Questionnaire/Certification Statement was submitted to the ADEC on May 20, 1996, and also included in Volume 1 of 2, Appendix I, Appendices for Application for License for Major Unconstructed Project submitted to the FERC on May 31, 1996. A copy of the Project Questionnaire/Certification Statement is included in the Appendix of this response. (B) Ina letter dated October 8, 1996, the Alaska Department of Environmental Conservation (ADEC) acknowledged receipt of the Section 404 application by the Cape Fox Corporation to the U.S. Army Corps of Engineers dated May 20, 1996. Further, ADEC states in their letter that “this application and supporting materials serve as application for the Department’s water quality certification of the Corps of Engineers permit, in accordance with Section 401 of the Clean Water Act.” A copy of the ADEC letter is included in the Appendix of this response. ITEM 2: AQUATIC RESOURCES MONITORING PLAN FERC Request: According to Appendix K of your application, on May 9, 1996, you sent a proposed aquatic resources monitoring plan to the National Marine Fisheries Service (NMFS), the U.S. Fish and Wildlife Service (FWS), the Alaska Department of Fish and Game (ADFG), and requested that the agencies send comments on the plan to you by May 17, 1996. You did not include a copy of your proposed aquatic resources monitoring plan, along with any agency comment letters, with your application. To help us evaluate your proposed monitoring of aquatic resources in the project area, please provide: (A) a copy of the proposed aquatic resources monitoring plan that you sent to the NMFS, the FWS, and the ADFG; and (B) copies of the comment letters, if any, that you received from the resource agencies. In addition, send a copy of the monitoring plan and a request for comments to each of the entities that received a copy of your final application, but have not received a copy of your monitoring plan, and allow them a minimum of 30 days to provide you with their comments. Include documentation of your request for comments and copies of the comments and recommendations, if any, in your response filed with the Commission. Mahoney Lake Hydroelectric Project October 18, 1996 -13- FERC No. 11393 Applicant's Response to Additional Information Request Applicant Response: To assist the FERC in evaluating the proposed monitoring of aquatic resources in the project area, the following information is provided: (A) | Acopy of the proposed Aquatic Resources Monitoring Plan sent to the agencies for review and comment is included in the Appendix of this response. (B) _‘Viaa letter dated May 9, 1996, the Aquatic Resource Monitoring Plan was sent to the NMFS, USFWS and ADFG for review and comments were requested by May 17, 1996. NMFS, USFWS and ADFG did not submit any comments on the plan at that time. As requested by this AIR, the Aquatic Resources Monitoring Plan was sent to the entities receiving a copy of the license application (again including NMFS, USFWS and ADFG) via a letter dated August 2, 1996 (included in the Appendix of this response), requesting comments by September 3, 1996. Copies of the August 2 letter and attachment were sent to the FERC staff. As of October 17, 1996, the ADFG is the only entity to provide a response. Their letter dated August 27, 1996, is included in the Appendix to this response along with the Applicant’s reply to the ADFG comments. ITEM 3: POST-PROJECT CUMULATIVE DEGREE DAYS FERC Request: Your estimated post-project cumulative degree days during the sockeye incubation period are derived from estimated post-project temperatures that included assumptions about the mixing of Upper Mahoney Creek flows and ground water at the spawning site and the depth of the drawdowns in Upper Mahoney Lake. There are some discrepancies, however, in your application: e The post-project cumulative degree days in Table 3 (page 31) of the preliminary draft Environmental Assessment (EA) are different than the post-project cumulative degree days in Table 3 (page 7) of Appendix C of the application; e Figures 1] and 12 in Appendix C, graphic presentations of the cumulative degree days, do not correspond to the days enumerated in Table 3 of Appendix C, but appear to correspond with Table 3 of the preliminary draft EA; and e Figure 7 in the preliminary draft EA, a graphic presentation of Table 3 of the preliminary draft EA, does not correspond to the cumulative degree days in Table 3 of the preliminary draft EA or Table 3 of Appendix C. e The “minimum post-project mixed” values are not represented in Figure 11 of Appendix C. To help us understand your analysis, please: Mahoney Lake Hydroelectric Project October 18, 1996 -14- FERC No. 11393 Applicant's Response to Additional Information Request (A) explain the above discrepancies in cumulative degree days between the preliminary draft EA and Appendix C of the application; (B) provide your best estimate of cumulative degree days; (1) from September I through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (2) from October 1 through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (3) from September I through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (4) from October | through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, and (C) _ explain how the cumulative degree days in B(1) through B(4) were calculated. (Note: The cumulative degree day calculations in Appendix C appear to support Table 3 of Appendix C. If these calculations were changed by another analysis, please explain the basis for the changes.) You must provide the NMFS, the FWS, the ADFG, and each of the other entities that received a copy of your final application with copies of items 3(A) through 3(C), and allow them a minimum of 30 days to provide you with their comments. Include documentation of your request for comments and copies of the comments and recommendations, if any, in your response filed with the Commission. Applicant Response: In a letter dated August 29, 1996, NMFS, the USFWS, the ADFG, and each of the other entities that received a copy of our final application were provided with copies of our response to items 3(A) through 3(C) of the AIR, and requested to provide their comments by September 30, 1996. The FERC staff received a copy also. Because of incorrect data entries, corrected tables were forwarded to the same distribution in a letter dated September 11, 1996. As of October 17, 1996, no comment letters were received. A copy of both of our transmittal letters are included in the Appendix to this response. Mahoney Lake Hydroelectric Project October 18, 1996 -15- FERC No. 11393 Applicant's Response to Additional Information Request ITEM 4: CULTURAL RESOURCES We cannot evaluate the effect of the project on cultural resources without reviewing the report on the cultural resources survey of the project, and the comments of the Alaska State Historic Preservation Officer (SHPO) and the Forest Service (FS) archeologist on the adequacy of the report. Therefore, file the following: (1) 3 copies of the report; and (2) letters from the SHPO and the FS archeologist on the report. If the SHPO or the FS archeologist recommends additional survey, file a schedule for conducting the survey and filing a report with the Commission, or provide an explanation of why such work is not necessary. Work needs to be completed by this year’s field season. If your survey shows that the archeological or historic sites or traditional cultural properties of Native American tribes eligible for the National Register of Historic Places would be affected by the project, do the following: (1) File a cultural resources management plan--which you would implement after licensing--for avoiding or mitigating the effects on the sites. (2) Base your plan on the recommendations of the SHPO and the FS archeologist, and include their comments on the plan in your filing. (3) If the SHPO and the FS archeologist recommends that you implement your plan through a memorandum of agreement (MOA), file an MOA, or explain why one is not needed. (4) Ifyou prepare an MOA: (a) make the MOA among us, the SHPO, the FS, and the Advisory Council on Historic Preservation (Council); (b) include the comments of the SHPO and the FS on the MOA in your filing; and (c) revise the MOA as you determine appropriate to address the SHPO’s and the FS’s concerns. Conduct the survey and prepare the report and plan according to the Secretary of the Interior’s Standards and Guidelines for Archeology and Historic Preservation. You may obtain copies by telephoning the National Park Service at (202) 343-4101. In preparing an MOA, follow the Council’s guidelines, “Preparing Agreement Documents”. You may get a copy of the guidelines by telephoning the Council at (202) 606-8505. To keep the locations of archeological sites confidential and to protect them from theft or vandalism, you should file three copies of the survey report and the plan or MOA directly with our cultural resources staff. Send this information--clearly marked “Confidential--Not for Public Disclosure”--to Dr. Edwin D. Slatter, Office of Hydropower Licensing, Federal Energy Regulatory Commission, 888 First St., NE, Room 5H-01, Washington, D.C. 20426. Mahoney Lake Hydroelectric Project October 18, 1996 -16- FERC No. 11393 Applicant's Response to Additional Information Request When you file this information with our staff, make a separate filing with the Secretary of the Commission that does the following: () Says you’ve made the filings with our staff. (2) Briefly describes the purpose and contents of the filing--without referring to site locations--so reviewing parties are informed about the general nature of archeological sites affected by the project. Applicant Response: On September 18, 1996, the cultural resource report entitled An Archeological Survey of Mahoney Hydroelectric Power Project, FERC Project No. 11393-000 for the City of Saxman, Alaska prepared by C.R.C. Cultural Resource Consultant was forwarded to the Alaska State Historic Preservation Office (SHPO) and the U.S. Forest Service for their review and comment. A copy of the report was sent to Dr. Edwin Slatter, OHL, FERC, as well. Copies of the transmittal letters are included in the Appendix to this response. Responses were received from both Alaska agencies. Because of the confidential nature of the report, three (3) copies of the report and comment letters were filed under separate cover with Dr. Edwin Slatter, OHL, FERC, as directed in the AIR. The report indicates that there are sites located nearby but that there will be no direct impacts to those sites by the construction or operation of the Mahoney Lake Project. As recommended in the report, the location of the sites will remain confidential and measures to discourage incidental access to sites during construction will be implemented. The comment letter received from the SHPO suggested that the location of the sites be identified on a map. This will be done. As with the report, the map will only be distributed to the Forest Service, SHPO and Dr. Slatter. Certain protection measures were recommended by the Forest Service (FS). The FS recommendations will be implemented when construction of the Mahoney Lake Hydroelectric Project begins. If any sites are found during construction of the project, work in the immediate vicinity will be suspended until measures as set forth in 36 CFR 800 are completed. Based on the report and response letters, there is no indication that additional survey work, a cultural resources management plan, or a memorandum of agreement are necessary for this project. Mahoney Lake Hydroelectric Project October 18, 1996 -17- FERC No. 11393 Applicant's Response to Additional Information Request ITEM 5: HYDROLOGIC DATA FERC Request: Please provide one computer diskette copy of the completed hydrological data set for the 35 years of record you used to analyze the Mahoney Lake Project. File the diskette with: Jim Fargo, Office of Hydropower Licensing, Federal Energy Regulatory Commission, 888 First St., NE, Room 52-77, Washington, D.C. 20426. Applicant Response: One computer diskette copy of the completed hydrological data set was sent to Jim Fargo, OHL, via a letter dated July 26, 1996. A copy of the transmittal letter is included in the Appendix to this response. Mahoney Lake Hydroelectric Project October 18, 1996 -18- FERC No. 11393 Applicant’s Response to Additional Information Request APPENDIX Correspondence & Documentation Mahoney Lake Hydroelectric Project October 18, 1996 FERC No. 11393 Applicant's Response to Additional Information Request ADDITIONAL AGENCY DISTRIBUTION HDR Letter to U.S. Army Corps of Engineers - July 26, 1996 HDR Letter to Department of Interior - July 26, 1996 HDR Letter to Alaska Bureau of Land Management - July 26, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 FERC No. 11393 July 26, 1996 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, OR 97209 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Application for License In accordance with the enclosed July 22, 1996, letter from the Federal Energy Regulatory Commission (FERC), on behalf of the City of Saxman, Alaska, HDR Engineering, Inc. is providing you with a copy of the Application for License for the above-referenced project filed with the FERC on May 31, 1996. Also enclosed is a copy of the applicant-prepared Preliminary Draft Environmental Assessment (PDEA) that was submitted in lieu of the Exhibit E traditionally required in the Application for License. Your agency will be added to the formal distribution list for this project. Please contact me of you have any questions concerning the Application for License or PDEA for the Mahoney Lake Hydroelectric Project. Sincerely, HDR ENGINEERING, INC. TOU. bina Michael V. Stimac, Manager Licensing and Environmental Services Enclosure Co: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation Don Clarke, Wilkinson, Barker, Knauer & Quinn h:\hyd\mahoney\app\air02.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 July 26, 1996 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20240 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Application for License In accordance with the enclosed July 22, 1996, letter from the Federal Energy Regulatory Commission (FERC), on behalf of the City of Saxman, Alaska, HDR Engineering, Inc. is providing you with a copy of the Application for License for the above-referenced project filed with the FERC on May 31, 1996. Also enclosed is a copy of the applicant-prepared Preliminary Draft Environmental Assessment (PDEA) that was submitted in lieu of the Exhibit E traditionally required in the Application for License. Your agency will be added to the formal distribution list for this project. Please contact me of you have any questions concerning the Application for License or PDEA for the Mahoney Lake Hydroelectric Project. Sincerely, HDR ENGINEERING, INC. FOU, lena Michael V. Stimac, Manager Licensing and Environmental Services Enclosure ce: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation Don Clarke, Wilkinson, Barker, Knauer & Quinn h:\hyd\mahoney\app\air02.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax ~ 98004-5538 206 453-7107 July 26, 1996 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Application for License In accordance with the enclosed July 22, 1996, letter from the Federal Energy Regulatory Commission (FERC), on behalf of the City of Saxman, Alaska, HDR Engineering, Inc. is providing you with a copy of the Application for License for the above-referenced project filed with the FERC on May 31, 1996. Also enclosed is a copy of the applicant-prepared Preliminary Draft Environmental Assessment (PDEA) that was submitted in lieu of the Exhibit E traditionally required in the Application for License. Your agency will be added to the formal distribution list for this project. Please contact me of you have any questions concerning the Application for License or PDEA for the Mahoney Lake Hydroelectric Project. Sincerely, HDR ENGINEERING, INC. FHM. Mlhema— Michael V. Stimac, Manager Licensing and Environmental Services Enclosure cc: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation Don Clarke, Wilkinson, Barker, Knauer & Quinn h: \hyd\mahoney\app\air02.doc HDR Engineering, Inc. Suite 1200 Telephone 500 108th Avenue, N.E. 206 453-1523 = Bellevue, Washington 98004-5538 Applicant’s Response to Additional Information Request APERTURE CARDS HDR Letter to FERC, Secretary - August 29, 1996 HDR Letter to FERC, Portland Regional Office - August 29, 1996 HDR Letter to Alaska Bureau of Land Management - August 29, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 FERC No. 11393 August 29, 1996 a mao 2 ES Se) | Hi Ms. Lois Cashell, Secretary = ye Federal Energy Regulatory Commission > ru 888 First St., NE, Room A-1 Ti Washington, D.C. 20426 = ms Su: we & Re: Mahoney Lake Hydroelectric Project ae) | = ® FERC Project No. 11393 Aperture Cards Dear Ms. Cashell: On behalf of the City of Saxman, Alaska, HDR Engineering, Inc. is providing an original and one duplicate set of aperture cards showing the exhibit drawings for the above-referenced project. The aperture cards have been sent to you as requested in the Federal Energy Regulatory Commission letter of July 22, 1996. A duplicate set of aperture cards were sent to the Commission’s Portland Regional Office and Alaska Bureau of Land Management. If you have any questions or need additional information, please let me know. Sincerely, HDR ENGINEERING, INC. WOU Mirra Michael V. Stimac, Manager Licensing and Environmental Services Enclosures CC: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation h:\hyd\mahoney\app\air05.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 August 29, 1996 Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 SW Main St., Suite 905 Portland, OR 97204 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Aperture Cards Enclosed please find a set of aperture cards showing the exhibit drawings for the above- referenced project. The aperture cards have been sent to you as requested in the Federal Energy Regulatory Commission letter of July 22, 1996. If you have any questions or require additional information, please let me know. Sincerely, HDR ENGINEERING, INC. 7 ee Michael V. Stimac, Manager Licensing and Environmental Services Enclosure cc: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation h:\hyd\mahoney\app\air05.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax Fl 98004-5538 206 453-7107 August 29, 1996 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Aperture Cards Enclosed please find a set of aperture cards showing the exhibit drawings for the above- referenced project. The aperture cards have been sent to you as requested in the Federal Energy Regulatory Commission letter of July 22, 1996. If you have any questions or require additional information, please let me know. Sincerely, HDR ENGINEERING, INC. TOW. bea Michael V. Stimac, Manager Licensing and Environmental Services Enclosure cc: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation h:\hyd\mahoney\app\air05.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax ~ 98004-5538 206 453-7107 Applicant’s Response to Additional Information Request APPLICATION ACCEPTANCE AND AGENCY NOTIFICATION OF AIR HDR Letter to Distribution List - July 26, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 FERC No. 11393 July 26, 1996 (See Attached Distribution List) Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393-000 FERC Acceptance of Application for License and Additional Information Request On behalf of the City of Saxman, Alaska, HDR Engineering, Inc. is providing a copy of the July 22, 1996, letter from the Federal Energy Regulatory Commission (FERC) accepting for filing the Application for License for the Mahoney Lake Hydroelectric Project and requesting additional information. Copies of this letter are being forwarded to only those agencies/entities receiving the Application for License that was filed with FERC on May 31, 1996. If you have any questions or require additional information, please let me know. Sincerely, HDR ENGINEERING, INC. PHU here Michael V. Stimac, Manager Licensing and Environmental Services Enclosure CC: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation Don Clarke, Wilkinson, Barker, Knauer & Quinn h:\hyd\mahoney\app\air01.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 MAHONEY LAKE HYDROELECTRIC PROJECT U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Ms. Tamra Faris Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg U.S. Fish & Wildlife Service 3000 Vintage Blvd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 Mr. Jim DeHerrera District Ranger US. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 FERC NO. 11393 Distribution List Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main St., Suite 905 Portland, OR 97204 Ms. Lois Cashell Federal Energy Regulatory Commission 888 First St. NE, Room A-1 Washington, DC 20426 Mr. Vince Yearick Federal Energy Regulatory Commission 810 First St. NE, Room 504 Washington, D.C. 20426 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office 3601 C St., #1200 Anchorage, AK 99503-5925 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 Mr. Tom Fitzgerald City Administrator City of Saxman Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen USS. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, oR 97209 State Director Alaska State Office Bureau of Land Management Division fo Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20420 a FEDERAL ENERGY REGULATORY COMMISSION in é C E ] VE ~\ | WASHINGTON, D. C. 20426 JUL 2.5 1996 1 Project No. 11393-001-AK Mahoney Lake Hydroelectric Project City of Saxman, Alaska ! HDR ENGINEERING, INC Mr. Tom Fitzgerald City Administrator =a eueaes City of Saxman UR 22 1096 Route 2, Box 1 Ketchikan, Alaska 99901 Dear Mr. Fitzgerald: Your license application for the referenced project has been accepted by the Commission for filing as of May 31, 1996. A public notice for this project will be issued shortly indicating the above finding and soliciting interventions and protests on the application and your reply comments. The notice will also solicit final terms, conditions, and comments. Federal, state, and interstate resource agencies, and any Indian Tribe affected by this project, will be informed in the Commission’s public notice that a copy of the complete application may be obtained directly from you. Within 5 days after you receive this letter, if you haven’t already done so, send one copy of your license application to the following: the Commission's Portland Regional Office; the Department of the Interior, Office of Environmental Affairs, the U.S. Army Corps of Engineers, North Pacific Office; and the Alaska State Director, Bureau of Land Management. A list of addresses is attached. Within 45 days from the date of this letter, you must file with the Commission’s Secretary an original and a duplicate set of aperture cards showing your exhibit drawings. Also, send a duplicate set of aperture cards to the Commission’s Portland Regional Office and the Alaska State Director, Bureau of Land Management . For the aperture cards showing your exhibit drawings: make an original and two Diazo-type duplicate sets of cards. To make the original set of cards, (1) take the exhibit sheets listed by FERC drawing numbers, (2) make microfilm copies of the sheets, and (3) mount them on type D aperture cards (3 1/4 by 7 3/8 inches). To make the duplicates, reproduce the original set on silver or gelatin 35-millimeter microfilm. For each microfilm drawing, show the FERC drawing number in the margin below the title block. On the top lines of the aperture cards, show (1) the appropriate FERC exhibit name, (2) the project number, (3) the drawing number, (4) the drawing title, and (5) the date of this letter. We also need additional information in order to complete our review and processing of your application. A listing of the information required is presented in the enclosed schedule A. Under section 4.32(g) of the Commission’s regulations, you have 90 days from the date of this letter to provide the additional information requested. If the requested information causes any other part of the application to be inaccurate, that part must also be revised and refiled by the due date. Within five days of receipt, provide a copy of this letter and the enclosed schedule to all entities that received a copy of your final application. Then, when you file the requested information with the Commission, you must also provide a complete copy of that information to each entity that received a copy of your final application. Documents to be filed with the Commission must be filed by providing an original and 8 copies as required by the Commission’s regulations to: Secretary, Federal Energy Regulatory Commission, 888 First Street, N.E., Washington, D.C. 20426. If you have any questions concerning this matter, please call Vince Yearick on (202) 219-3073. Sincerely, aU eA John H. Clements Director, Division of Project Review Enclosures: List of Addresses FERC Drawing Numbers Schedule A CGe Mr. Doug Campbell Cape Fox Corporation 2851 S. Tongass P.O. Box 8558 Ketchikan, AK 99901 Mr. Michael V. Stimac Manager, Licensing and Environmental Services HDR Engineering, Inc. 500-108th Avenue, NE Suite 1200 Bellevue, WA 98004 Mr. John Braislin Betts, Patterson, and Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Donald H. Clarke Wilkinson, Barker, Knauer, & Quinn 1735 New York Avenue, N.W. Washington, DC 20006 Addresses Federal Energy Regulatory Commission Portland Regional Office 101 S.W. Main Street, #905 Portland, OR 97204 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, DC 20240 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, OR 97209 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Exhibit F G FERC DRAWING NUMBERS Project No. 11393-0011 Drawing No. 11319- F-0 through F-9 G-1 through G-2 Project No. 11393 Schedule A ADDITIONAL INFORMATION 1. In your application your state that, by agreement between the Alaska Department of Environmental Conservation (ADEC) and the U.S. Army Corps of Engineers (COE), a dredge and fill application under Section 404 of the Clean Water Act may also serve as an application for a state water quality certification under Section 401 of the Clean Water Act. Your application includes a copy of a Section 404 application completed on May 20, 1996. However, there is no evidence that you sent the Section 404 application (or other request for water quality certification) to the ADEC, that the ADEC received the Section 404 application, or that the ADEC accepted the Section 404 application as a request for a Section 401 water quality certification. To establish that you have requested a Section 401 water quality certification please provide: (A) a copy of your certification request to the ADEC; and (B) proof that the ADEC received the request. Proof of receipt must be either: (1) a copy of a certified mail receipt showing the date the ADEC received the Section 401 request; or (2) a letter from the ADEC confirming the receipt date. If the ADEC has accepted the Section 404 application as a request for a Section 401 water quality certification, you must submit written confirmation of the acceptance from the ADEC, including confirmation of the date the ADEC received the Section 404 application. 2. According to Appendix K of your application, on May 9, 1996, you sent a proposed aquatic resources monitoring plan to the National Marine Fisheries Service (NMFS), the U.S. Fish and Wildlife Service (FWS), and the Alaska Department of Fish and Game (ADFG), and requested that the agencies send comments .on the plan to you by May 17, 1996. You did not include a copy of your proposed aquatic resources monitoring plan, along with any agency comment letters, with your application. To help us evaluate your proposed monitoring of aquatic resources in the project area, please provide: (A) a copy of the proposed aquatic resources monitoring plan that you sent to the NMFS, the FWS, and the ADFG; and (B) copies of the comment letters, if any, that you received from the resource agencies. In addition, send a copy of the monitoring plan and a request for comments to each of the entities that received a copy of your final application, but have not received a copy of your monitoring plan, and allow them a minimum of 30 days to provide you with their comments. Include documentation of your request for comments and copies of the comments and recommendations, if any, in your response filed with the Commission. 3. Your estimated post-project cumulative degree days during the sockeye incubation period are derived from estimated post-project temperatures that included assumptions about the mixing of Upper Mahoney Creek flows and ground water at the spawning site and the depth of the drawdowns in Upper Mahoney Lake. There are some discrepancies, however, in your application: e The post-project cumulative degree days in Table 3 (page 31) of the preliminary draft Environmental Assessment (EA) are different than the post-project cumulative degree days in Table 3 (page 7) of Appendix C of the application; . e Figures 11 and 12 in Appendix C, graphic presentations of the cumulative degree days, do not correspond to the days enumerated in Table 3 of Appendix C, but appear to correspond with Table 3 of the preliminary draft EA; and e Figure 7 in the preliminary draft EA, a graphic presentation of Table 3 of the preliminary draft EA, does not correspond to the cumulative degree days in Table 3 of the preliminary draft EA or Table 3 of Appendix C. e The "minimum post-project mixed" values are not represented in Figure 11 of Appendix C. To help us understand your analysis, please: (A) explain the above discrepancies in cumulative degree days between the preliminary draft EA and Appendix C of the application; (B) provide your best estimate of cumulative degree days; (1) from September 1 through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (2) from October 1 through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming 7 the ground water and with proportionate mixing between the streamflow and the ground water, (3) from September 1 through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (4) from October 1 through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, and (C) explain how the cumulative degree days in B(1) through B(4) were calculated. (Note: The cumulative degree day calculations in Appendix C appear to support Table 3 of Appendix C. If these calculations were changed by another analysis, please explain the basis for the changes.) You must provide the NMFS, the FWS, the ADFG, and each of the other entities that received a copy of your final application with copies of items 3(A) through 3(C), and allow them a minimum of 30 days to provide you with their comments. Include documentation of your request for comments and copies of the comments and recommendations, if any, in your response filed with the Commission. 4. We cannot evaluate the effect of the project on cultural resources without reviewing the report on the cultural resources survey of the project, and the comments of the Alaska State Historic Preservation Officer (SHPO) and the Forest Service (FS) archeologist on the adequacy of the report. Therefore, file the following: (1) 3 copies of the report; and (2) letters from the SHPO and the FS archeologist on the report. If the SHPO or the FS archeologist recommends additional survey, file a schedule for conducting the survey and filing a report with the Commission, or provide an explanation why such work is not necessary. Work needs to be completed by this year’s field season. If your survey shows that archeological or historic sites or traditional cultural properties of Native American tribes eligible for the National Register of Historic Places would be affected by the project, do the following: (1) File a cultural resources management plan--which you would implement after licensing--for avoiding or mitigating the effects on the sites. 8 (2) Base your plan on the recommendations of the SHPO and the FS archeologist, and include their comments on the plan in your filing. (3) If the SHPO and the FS archeologist recommends that you implement your plan through a memorandum of agreement (MOA), file an MOA, or explain why one is not needed. (4) If you prepare an MOA: (a) make the MOA among us, the SHPO, the FS, and the Advisory Council on Historic Preservation (Council); (b) include the comments of the SHPO and the FS on the MOA in your filing; and (c) revise the MOA as you determine appropriate to address the SHPO’s and the FS’s concerns. Conduct the survey and prepare the report and plan according to the Secretary of the Interior’s Standards and Guidelines for Archeology and Historic Preservation. You may obtain copies by telephoning the National Park Service at (202) 343-4101. In preparing an MOA, follow the Council’s guidelines, "Preparing Agreement Documents". You may get a copy of the guidelines by telephoning the Council at (202) 606-8505. To keep the locations of archeological sites confidential and to protect them from theft or vandalism, you should file three copies of the survey report and the plan or MOA directly with our cultural resources staff. Send this information--clearly marked "Confidential--Not for Public Disclosure"--to Dr. Edwin D. Slatter, Office of Hydropower Licensing, Federal Energy Regulatory Commission, 888 First St., NE, Room 5H-01, Washington, D.C. 20426. When you file this information with our staff, make a separate filing with the Secretary of the Commission that does the following: (1) Says you've made the filings with our staff. (2) Briefly describes the purpose and contents of the filing--without referring to site locations--so reviewing parties are informed about the general nature of archeological sites affected by the project. 5. Please provide one computer diskette copy of the complete hydrologic data set for the 35 years of record you used to analyze the Mahoney Lake Project. File the diskette with: Jim Fargo, Office of Hydropower Licensing, Federal Energy Regulatory Commission, 888 First St., NE, Room 52-77, Washington, D.C. 20426. Applicant's Response to Additional Information Request SECTION 401 WATER QUALITY CERTIFICATION Coastal Project Questionnaire and Certification Statement - May 20, 1996 Alaska Department of Environmental Conservation Letter to HDR - October 8, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 FERC No. 11393 i APPLICANT INFORMATION [ Coastal Project Questionnaire and Certification Statement| Mahoney Lake Hydroelectric Project Anne Leggett 1. _Cape Fox Corporation (Attn: Dou bell) 2. HDR Alaska. Inc. Name of Applicant Agent (or responsible party if other than applicant) P.O. Box 8558 2525 C Street, Suite 305 ‘Address ‘Address Ketchikan, AK 99901 Anchorage, AK 99503 City State Zip Code City State Zip Code (907) 225-5163 (ext. 303) _ (907) 274-2000 Daytime Phone Daytime Phone _(907) 225-3137 (907) 274-2022 Fax Number Fax Number PROJECT INFORMATION 1. Yes No This activity is a: |x] *new project{_ | modification or addition to an existing project *Project is new (not yet constructed) but agencies reviews have been ongoing since early 1980s. If a modification do you currently have any State, federal or local approvals related to this activity? C] Note: Approval means any form of authorization. If “yes,” please list below. Approval Type Approval # Issuance Date Expiration Date Has this project ever been reviewed by the State of Alaska per the ACMP? Previous State I.D. Number: AK 9403-33J, 9504-08J, | Previous Project Name: same as this one 9603-24) PROJECT DESCRIPTION 1. Attach the following: a detailed description of the project and all associated facilities; a project timeline for completion of all major activities in the proposal; a site plan depicting all proposed actions; other supporting documentation that would facilitate review of the project. Note: Ifthe project is a modification, identify existing facilities as well as proposed activities on the site plan. Proposed starting date for project: _7/1/97 (conswuction) Proposed ending date for project: 12/1/99 (construction) — Provide a brief description of your entire project and ALL associated facilities (access roads, caretaker facilities, waste disposal sites, etc.). Construct a hydroelectric power generation project. A tap will be installed below the surface of Upper Mahoney Lake, and water transmitted through a penstock in a tunnel to a powerhouse near Lower Mahoney Lake. The tailrace will discharge water to Mahoney Creek upstream from Lower Mahoney Lake. A 2.6-mile-long access road will connect the powerhouse site and an existing logging road. A buried and overhead electric transmission line will extend from the powerhouse site southward to the Beaver Falls area, a distance of about 3.5 miles. Coastal Project Questionnaire Page | Mahoney Lake Hydroelectric Project PROJECT LOCATION 1 2. Attach a copy of the topographical map with the project location marked on it. Location of project (include nearest community or name of the land feature or body of water. Identify township, range and section): Mahoney Lakes, along George Inlet, northeast of Ketchikan, AK Township Range Section Meridian Latitude/Longitude T. 74S. R. 91 E. 24-27, 34-36 CRM $5°25’N 131°32’W T. 74S. R. 92 E. 31 CRM e752: RS92;E: 5, 6, 8 CRM The project is on: State Land* Federal Land XX PrivateLand XX Municipal Land *State land can be uplands, tidelands, or submerged lands to 3 miles offshore. See Question #1 in DNR section. The project is located in which region (see attached map): Northern C] Southcentral Southeast C] State Pipeline Coordinator’s Office Yes No Is the project located in a coastal district? ah If yes, please contact the district representative listed on the attached sheet. Identify the communities closest to your project location: Ketchikan, Saxman FEDERAL APPROVALS 1 Is the proposed project on U.S. Forest Service (USFS) land or will you need to cross USFS lands for access? Does the cost of the project exceed $250,000? If yes, have you applied for a USFS permit or approval? Date of submittal: concurrent with this submittal Is the proposed project on Bureau of Land Management (BLM) land or will you need to cross BLM lands for access? Does the cost of the project exceed $250,000? If yes, have you applied for a BLM permit or approval? Date of submittal: OOO &eE fee feed Reet Meal ety Will you be constructing a bridge over tidal (ocean) waters, or navigable rivers, streams or lakes? If yes, have you applied for a U.S. Coast Guard permit for a bridge? CT] Date of submittal: [=] Will you be dredging or placing structures or fills in any of the following: [x] tidal (ocean) waters, streams, lakes, wetlands*? If yes, have you applied for U.S. Army Corps of Engineers (COE) permit? Date of submittal: n nt wi i ittal (Note: Your application for this activity to the Corps of Engineers also serves as your application to DEC.) “If you are not certain whether your proposed project is ina wetlands, contact the U.S. Corps of Engineers, Regulatory Branch at (907) 753-2720 for a wetlands determination (outside the Anchorage area call toll free 1-800-478-2712.) Eri nied Coastal Project Questionnaire Page 2 Mahoney Lake Hydroelectric Project Sy: Have you applied for a U.S. Environmental Protection Agency National Pollution Discharge Elimination System (NPDES) permit? Date of submittal: construction will require a general stormwater discharge permit O Of¢ ] 2 [x] i 6. Will you have a putrescible waste discharge within 5 miles of any public airport? Ifyes, please contact the Airports Division of the Federal Aviation Administration at (907) 271-5440. ve Does the project include a nonfederal power project affecting any navigable body of water or located on federal land? Or, is utilization of surplus water from any federal government dam proposed? (Power projects consist of dams, water conduits, reservoirs, powerhouses, and transmission lines.) If yes, have you applied for a permit from the Federal Energy Regulatory Commission (FERC)? Date of submittal: application for license will be submitted 5/31/96 (Note: For information, contact FERC, Office of Hydropower Licensing, at (202) 208-0200.) O KU 8. Have you applied for permits from any other federal agency? Agency Approval Type Date Submitted O [x] DEPARTMENT OF ENVIRONMENTAL CONSERVATION (DEC) APPROVALS? ie Will a discharge of wastewater from industrial or commercial operations occur? Will the discharge be connected to an already approved sewer system? Will the project include a stormwater collection/discharge system? OO fl Ds Do you intend to construct, install, modify, or use any part of a wastewater (sewage or greywater) disposal system? a) If so, will the discharge be 500 gpd or greater? b) If constructing a domestic wastewater treatment or disposal system, will the system be located within fill material requiring a COE permit? If you answered yes to a or b, answer the following: 1) How deep is the bottom of the system to the top of the subsurface water table? Bee) Glaie OU 2) How far is any part of the wastewater disposal system from the nearest surface water? O O 3) Is the surrounding area inundated with water at any time of the year? 4) How big is the fill area to be used for the absorption system? (Questions 1&2 will be used by DEC to determine whether separation distances are being met; Questions 3&4 relate to the required size of the fill if wetlands are involved. Coastal Project Questionnaire Page 3 Mahoney Lake Hydroelectric Project 3. Do you expect to request a mixing zone for your proposed project? C] (f your wastewater discharge will exceed Alaska water quality standards, you may apply for a mixing zone. If so, please contact DEC to discuss information required under 18 AAC 70.032.) 4. Do you plan to store or dispose of any type of solid waste resulting from this project? [x]}* LJ (Note: Solid waste means drilling wastes, garbage, refuse, sludge, and other discarded material, including solid, liquid, semi-solid, or contained gaseous material resulting from industrial, commercial, and agricultural operations, and from community activities.) *Tailings from tunnel construction will be disposed of on-site. 5: Will your project require the application of oil, pesticides, and/or any other broadcast chemicals to the surface of the land and/or the waters of the state? CL] [x] 6. a. Will you have a facility that will generate air emissions from processing greater than five tons per hour of material? [] b. Will you have one or more units of fuel burning equipment, including flaring, with a heat input rating of 50 million Btu per hour or more? OOO Oo OQ ] ic! Will you have a facility containing incinerators with a total charging capacity of 1,000 pounds per hour or more? d. Will you incinerate sludge? e. Will you have any of the following processes? Asphalt plant CL] Coal preparation facility Petroleum refinery Portland cement plant Petroleum Contaminated Soils Cleanup ¢ OU ill your facility use the following equipment? L] Diesel internal combustion engines? (Total capacity equal to or greater than /, 750 kilowatts or total rated brake specific horsepower greater than 2,350 bhp) Gas fired boilers Total heat input rating of /00 million Btu per hour) Oil fired boilers (Tota! heat imput rating of 65 million Btu per hour) Combustion turbines (Total rated power output of 8,000 Hp) [x] OU g. Will your facility burn more than the following per year in stationary equipment? LJ [] 1,000,000 gallons of fuel oil L] 35,000 tons of coal CE] 900 million cubic feet of natural gas h. If you answered “yes” to any of the above questions (6 a-g), have you installed, replaced or modified any fuel burning or processing equipment since 1977? 7. Will you be developing, constructing, installing, or altering a public water system? 8. a. Will your project involve the operation of waterborne tank vessels or oil barges that carry crude or non-crude oil as bulk cargo, or the transfer of oil or other petroleum products to or from such avessel or a pipeline system? O OO B&O b. Will your project require or include onshore or offshore oil facilities with an effective aggregate storage capacity of greater than 5,000 barrels of crude oil CT] or greater than 10,000 barrels of non-crude oil? Coastal Project Questionnaire Page 4 Mahoney Lake Hydroelectric Project Yes No c Will you be operating facilities on the land or water for the exploration or production of hydrocarbons? CL] If you answered NO to ALL questions in this section, continue to next section. If you answered YES to ANY of these questions, contact the DEC Regional office for information and application forms. Please be advised that all new DEC permits and approvals require a 30-day public notice period. Based on your discussion with DEC, please complete the following: Approval Type: Section 401 Water Quality Cert’n Date Submitted: concurrent with this submittal and Section 404 permit appl’n submittal Does your project qualify for a general permit for wastewater or solid waste? N/A [] Cl If you answered yes to any questions and are not applying for DEC permits, indicate reason below: Judd Peterson (DEC contact) told me on 2/2/96 that no DEC approvals are required for this type of project. Reason: For the Tazimina hydro project, I asked him whether a solid waste disposal permit is needed for disposal of tunnel spoils. He said they do not consider those spoils “solid waste” unless there is reason to believe they are contaminated. DEPARTMENT OF FISH & GAME (DFG) APPROVALS 1. Will you be working in, or placing anything in, a stream, river or lake? (This includes C] work in running water or on ice, within the active floodplain, on islands, the face of the banks or the tidelands down to mean low tide.) Name of [x] stream [_ ]river, or[x] lake: Upper Mahoney Lake; Upper and Lower Mahoney Creeks; South Creek Will you do any of the following? Xx Please indicate below: U CJ Build a dam, river training structure [x] Alter or stabilize the banks? or instream impoundment? . - __ |X| Mine or dig in the beds or banks? xX| Use the water? _ . x] Use explosives? [| Pump water out of the stream or lake? = . . . . . . X| Build a bridge (including and ice bridge)? Divert or alter the natural stream channel? X| Use the stream as a road (even when frozen), Block or dam the stream (temporarily or crossing the stream with tracked or or permanently)? wheeled vehicles, log dragging or excavation X] Change the water flow or the water equipment (backhoes, bulldozers, etc.)? channel? x|* Install a culvert or other drainage structure? X] Introduce silt, gravel, rock, petroleum *culverts under road are not in fish streams products, debris, chemicals, or other Construct a weir? organic/inorganic waste of any type X]} Use an in-stream structure not mentioned into the water? here? Bypass pipe discharge to upper creek, lake tap in upper lake, tailrace discharge to creek Coastal Project Questionnaire Page § Mahoney Lake Hydroelectric Project Yes No Is your project located in a designated State Game Refuge, Critical Habitat Area gO or State Sanctuary? Does your project include the construction/operation of a salmon hatchery? C] Does your project affect, or is it related to, a previously permitted salmon hatchery? C] Does your project include the construction of an aquatic farm? C] If you answered “No” to ALL questions in this section, continue to next section. If you answered “Yes” to ANY questions under 1-3, contact the Regional DFG Habitat Division Office for information and application forms. If you answered “Yes” to questions 4-6, contact the DFG at the CFMD division headquarters for information and application forms. Based on your discussion with DFG, please complete the following: Approval Type: Fish Habitat Permit Date Submitted: concurrent with this submittal If you answered yes to any questions and are not applying for DFG permits, indicated reason below: [] (DFG contact) told me on that no DFG approvals are required. Reason: C] Other:_The upper lake and creek above the falls do not support anadromous or resident fish, so work in these areas will not be part of the fish habitat permit application. DEPARTMENT OF NATURAL RESOURCES (DNR) APPROVALS Ie Is the proposed project on State-owned land or will you need to cross State-owned land C] for access? (“access” includes temporary access for construction purposes) Note: In addition to State-owned uplands, the State owns almost all land below the ordinary high water line of navigable streams, rivers and lakes, and below the mean high tide line seaward for three miles. Do you plan to dredge or otherwise excavate/remove materials on State-owned land? CJ Location of dredging site if other than the project site: Township Range Section Meridian Do you plan to place fill or dredged material on State-owned land? ) [x] Location of fill disposal site if other than the project site: Township Range Section Meridian Source ison: [ ]StateLand [_ ]Federal Land [_ ]Private Land [ ]Municipal Land Do you plan to use any of the following State-owned resources: x C] Timber: Will you be harvesting timber? Amount: Coastal Project Questionnaire Page 6 Mahoney Lake Hydroelectric Project 10. Te i 2% 1S 14. [] Materials such as rock, sand or gravel, peat, soil, overburden, etc.: Which material? Amount: Location of source{_] Project sitel_ | Other, describe: Township Range Section Meridian Yes Are you planning to use or divert any fresh water? X Amount (gallons per day): approx. 50 million gpd _ Source : Upper Mahoney Lake Intended Use : generation of electricity Llé Will you be building or altering a dam? Do you plan to drill a geothermal well? OO ) KIE) At any one site (regardless of land ownership), do you plan to do any of the following? *Tunnels will be excavated; unless this is considered mining, no mining will occur. C] Mine five or more acres over a year’s time? Mine 50,000 cubic yards or more of materials (rock, sand or gravel, soil, peat, overburden, etc.) over a year’s time? Have a cumulative unreclaimed mined area of five or more acres? If you plan to mine less than the acreage/amount stated above and have a cumulative unreclaimed mined area of less than five acres, do you intend to file a voluntary reclamation plan for approval? Will you be exploring for or extracting coal? Will you be drilling for oil/gas? Will you be investigating or removing historical or archaeological resources on CJ State-owned land? Is the proposed project located within a known geophysical hazard area? FARES PAR EE Is the proposed project located in a unit of the Alaska State Park System? If you answered “NO” to ALL questions in this section, continue to certification statement. If you answered “YES” to ANY questions in this section, contact DNR for information. Based on your discussion with DNR, please complete the following: Approval Type: Water Rights Date Submitted: 5/17/93. An updated application will be submitted concurrently with this application If you answered yes to any questions and are not applying for DNR permits, indicated reason below: (DNR contact) told me on that no DNR approvals are required. Reason: [J Other: Jim Anderson of DNR-Juneau said on 5/15/96 that DNR would not claim ownership of the Upper Mahoney Lake bed. Coastal Project Questionnaire Page 7 Mahoney Lake Hydroelectric Project Please be advised that the CPQ identifies permits subject to a consistency review. You may need additional permits from other agencies or local governments to proceed with your activity. Certification Statement The information contained herein is true and complete to the best of my knowledge. I certify that the proposed activity complies with, and will be conducted in a manner consistent with, the Alaska Coastal Management Program. OrmusiCinG Some Signature of Applicant or Agent Date Note: Federal agencies conducting an activity that will affect the coastal zone are required to submit a federal consistency determination, per 15 CFR 930, Subpart C, rather than this certification statement. This certification statement will not be complete until all required State and federal authorization requests have been submitted to the appropriate agencies. To complete your packet, please attach your State permit applications and copies of your federal permit applications to this questionnaire. Coastal Project Questionnaire Page 8 Mahoney Lake Hydroelectric Project STAVE OF ALASKA. / ~emmnmmm DEPT. OF ENVIRONMENTAL CONSERVATION / Division of Air and Water Quality i Telephone: (907) 465-5276 Watershed Management Section . Fax: (907) 465-5274 410 Willoughby Avenue, Suite 105 ITY: (907) 465-5133 Juneau, Alaska 99801-1795 [RECEIVED IN ANCHORAGE! October 8, 1996 | ] ACT | | 1996 | Mr. Mark Dalton _HDR ENGINEERING, INC. HDR Alaska 2525 C Street, Suite 305 Anchorage, AK 99503 Dear Mr. Dalton: This letter will affirm that the Department of Environmental Conservation has received the application by Cape Fox Corporation, dated 5-20-96, to the U.S. Army Corps of Engineers for a permit for the Mahoney Lake Hydroelectric Project. This application is contained in Volume 1 of 2, Appendix I, Appendices for Application for License for Major Unconstructed Project, Preliminary Draft Environmental Assessment, Mahoney Lake Hydroelectric Project, Before the Federal Energy Regulatory Commission. This application and supporting materials serve as application for the Department’s water quality certification of the Corps of Engineers permit, in accordance with Section 401 of the Clean Water Act. No separate application to the Department is necessary for this purpose. The Department will not initiate the certification procedure until public notice is issued by the Corps of Engineers and State review begins under coordination of the Division of Governmental Coordination, Alaska Coastal Management Program. I will serve as agency contact for the Mahoney Lake project. Please address all correspondence and materials to my name. Sincerely, David Atnrderant David C. Sturdevant 401 Certification Team Leader Applicant's Response to Additional Information Request AQUATIC RESOURCES MONITORING PLAN HDR Letter to Distribution List - August 2, 1996 Alaska Department of Fish and Game Letter to HDR - August 27, 1996 HDR Letter to Alaska Department of Fish and Game - October 14, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 FERC No. 11393 August 2, 1996 (See Distribution List) RE: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Additional Information Request Aquatic Resources Monitoring Plan Ina letter dated July 22, 1996, the Federal Energy Regulatory Commission (FERC) issued an Additional Information Request (AIR) for the above-referenced project. A copy of the FERC letter and AIR (Schedule A) were forwarded to you via our letter dated July 26, 1996. In accordance with item 2 of the AIR, enclosed is a copy of the Aquatic Resources Monitoring Plan for your review. Please provide any comments you may have to me by September 3, 1996. If we do not hear from you by this date, we will assume that you have no comments on the plan. If you have any questions or require additional information, please call me at (206) 453-1523. Sincerely, HDR ENGINEERING, INC. a te Michael V. Stimac, Manager Licensing & Environmental Services Enclosure oe Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation h:\hyd\mahoney\app\air04.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 MAHONEY LAKE HYDROELECTRIC PROJECT U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Ms. Tamra Faris Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg US. Fish & Wildlife Service 3000 Vintage Blvd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 Mr. Jim DeHerrera District Ranger U.S. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project Distribution List FERC NO. 11393 Distribution List Mr. Steve Sams 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 Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main St., Suite 905 Portland, OR 97204 Mr. Michael Strzelecki OHL/DPR Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 Mr. Vince Yearick OHL/DPR Federal Energy Regulatory Commission 810 First St. NE, Room 504 Washington, D.C. 20426 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 August 2, 1996 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office 3601 C St., #1200 Anchorage, AK 99503-5925 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mahoney Lake Hydroelectric Project Distribution List Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 August 2, 1996 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 Mr. Tom Fitzgerald City Administrator City of Saxman Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project Distribution List Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen USS. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 August 2, 1996 Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, oR 97209 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20420 Mahoney Lake Hydroelectric Project Distribution List August 2, 1996 MAHONEY LAKE HYDROELECTRIC PROJECT AQUATIC RESOURCES MONITORING PLAN Introduction During the environmental review and licensing process for the proposed Mahoney Lake Hydroelectric Project various issues have been raised relative to protection of fish resources in the Mahoney Lake drainage. Studies and environmental monitoring programs conducted for the project Environmental Assessment have provided partial answers to these issues. However, study results and input from agencies during the licensing process have suggested that continuing study might be desirable in some areas, both during the remainder of the pre-construction period and for a time after construction of the project. The following plan suggests an approach to continued project monitoring to assure protection of fish resources with emphasis on anadromous species, especially sockeye salmon. Lower Mahoney Creek Fish Passage Studies conducted in 1994 and 1995 indicated that Lower Mahoney Creek contains cascades and falls that are natural barriers to fish movements. These barriers can only be passed by the strongest swimming fish species (adult sockeye and coho salmon) and only at intermediate flow levels. Prior observations have suggested a range of stream flows that will allow fish to pass but have not provided a good idea of threshold and optimal flow required by salmon to be able to pass the most formidable barrier and enter Lower Mahoney Lake. This information is considered desirable to determine whether the predicted post-project flow regime will affect fish passage and, if so, to determine appropriate possible mitigation measures. Lower Mahoney Creek Stream Gaging A continuously recording stream depth monitor (pressure transducer) was installed downstream from the most difficult fish barrier in July 1995 and hydrological measurements were conducted at the stream section to allow calculation of discharge. We propose that this gage continue to be maintained for the duration of the project, and that the hydrological model used to determine discharge be refined and updated as appropriate to assure accuracy. Monitoring of Fish Passage We propose that a study program similar to that which occurred in 1995 be implemented in 1996 and continued through the pre-construction period and for the first three years of Mahoney Lake Hydroelectric Project 1 Aquatic Resources Monitoring Plan project operation. This program would emphasize observation of the progress of salmon movement within Lower Mahoney Creek and the extent of use of Lower Mahoney Lake sockeye salmon spawning areas. The following methodology is suggested: beginning on August 1, a trained technician employed by the Cape Fox Corporation would observe Lower Mahoney Creek and Lower Mahoney Lake approximately every third day. The entire creek would be surveyed on foot and the lake spawning areas would be surveyed by boat. Observations would be documented and would include numbers of salmon of each species observed and the approximate location of fish in the stream or lake. When significant numbers of sockeye salmon are observed in upper portions of Lower Mahoney Creek, the technician would notify a biologist. The biologist would make a decision based on the fish observations, stream flow level, and weather information regarding whether to travel to the site and conduct more detailed observations regarding fish numbers, migratory behavior, success of passage, spawning condition, etc. The time spent on site would depend on the progress of fish movements. It might be desirable for the biologist to divide the field surveys into two time periods. It is expected that the biologist would spend up to 8 days on site. Routine observations by the technician would continue until the end of September. Salmon movement behavior and passage success would be compared with measured stream flows at the time of movement. Emphasis would be on determining threshold and optimum flow conditions for salmon passage in Lower Mahoney Creek. Spawning Area Incubation Conditions Another issue identified early in the planning process was the potential impact of altered Upper Mahoney Creek flow volume and water temperature on upwelling ground water within sockeye salmon spawning areas in Lower Mahoney Lake along the creek delta. Continuously recording water temperature monitoring stations were installed in 1994 within Upper Mahoney Creek near the proposed tailrace and at two locations in salmon spawning areas in Lower Mahoney Lake. The latter two stations included both intragravel water and above gravel water. This monitoring effort provided strong evidence that upwelling of stream water does in fact occur within areas chosen by salmon for spawning and that the temperature of upwelling water is correlated in part with the temperature of Upper Mahoney Creek water. The project environmental assessment concluded that, although pre-project and post-project temperature regimes may be somewhat different, the cumulative temperature units to which salmon eggs will be exposed will be similar and, thus, impact to incubating salmon eggs and fry will be minimal. Water Temperature Monitoring To confirm or reject the EA predictions it is recommended that the temperature monitoring program described above be continued during the pre-project period and for three years after the project is in operation. It is proposed that the Lower Mahoney Lake temperature monitoring stations be modified so that the two intragravel probes are both Mahoney Lake Hydroelectric Project 2 Aquatic Resources Monitoring Plan installed at the same location. This will provide redundancy in case one instrument fails and should increase the likelihood of a continuous record. Instrument temperature readings should be calibrated against an accurate hand thermometer at the time of installation. Water Quantity Monitoring There is no direct way to measure the quantity of upwelling water in the lake spawning areas. However, correlation of powerhouse release volume with intragravel water temperature on the Mahoney Creek delta may provide some insight into the relationship of flow release to upwelling water quantity. This possible relationship provides another reason for continued water temperature and flow monitoring at the proposed tailrace site on Upper Mahoney Creek and water temperature monitoring in Lower Mahoney Lake. Salmon Escapement Monitoring The most direct measure of project impact on fish resources is the actual health of the post-project fish populations. It is proposed that sockeye salmon be selected as a key indicator species and that the escapement of sockeye salmon be monitored with a minimal effort for at least 10 years after project operation. Since sockeye salmon spend 1-2 years in freshwater and 1-3 years in salt water, there is an average 3-4 year delay before the success of spawning in any given year can be determined through actual adult returns; consequently, any monitoring must continue for a substantial period of time in order to be meaningful. The monitoring program described above for Lower Mahoney Creek fish passage would provide sockeye salmon escapement information for the first three years of project operation. It is suggested that the information from these studies be used to develop a simplified index of salmon abundance that could be measured in subsequent years with minimal effort to acquire a long term record of sockeye salmon success in the Mahoney drainage. Such an index would involve a consistent combination of stream counts and lake spawning ground counts at selected optimal times. The observations could be obtained by a trained technician with minimal supervision by a fish biologist. Mahoney Lake Hydroelectric Project 3 Aquatic Resources Monitoring Plan 7 11-K84LH eT h\ Sr Ic (M) Tm i e V7 In / TONY KNOWLES, GOVERNOR DEPARTMENT OF FISH AND GAME 2050 SEA LEVEL DRIVE, SUITE 205 PHONE: (90; > DIVISION OF HABITAT AND RESTORATION FAX. (90) 22678 27 August, 1996 Michael V. Stimac, Manager HDR Engineering Inc. Licensing & Environmental Services Suite 1200500 108th Avenue, N.E. Bellevue, Washington 98004-5538 AUG 29 1996 VIA FA mine HDR ENGINEERING, INC. Dear Mr. Stimac: Re: Mahoney Lake Hydroelectric Project, FERC No. 11393 Monitoring Plan The Alaska Department of Fish and Game (ADFG) is providing the following comments regarding the proposed aquatic resources monitoring plan. The additional data you plan to collect appears to fall under two different categories. The monitoring of fish passage, water temperature, and water quantity are intended to provide the information required to set final terms and conditions. Monitoring of salmon escapement is suggested as means to evaluate potential project impacts. Lower Mahoney Creek Fish Pass In our comments submitted 30 May 1996 we requested information regarding the physical aspects and fish use of a hypothesized natural fish pass. The physical aspects of water velocity, quantity, and turbulence at this fish pass, correlated with changes in discharge were requested to better estimate the discharge values required for fish passage. This information would be used to determine our finalized terms and conditions for the modifications of flows in Lower Mahoney Creek. Terms and conditions would apply to both the FERC licensing and be included as stipulations in a Title 16 permit. As a reminder, modification of flows in an anadromous fish stream requires authorization per Sec 16.05.870. With limited information, ADF&G permits for flow modification will be more conservative. Spawning Area Incubation Conditions Intragravel temperature data is important for evaluating the thermal regime experienced by incubating sockeye salmon eggs and will be included in our recommended terms and conditions for FERC licensing. It is important that probes are both tracking the same change in temperature. Placing both Michael V. Stimac 2 8/29/96 temperature probes in the same location will provide redundant measurements at one location and ensure tracking, but will not document the spatial variation throughout the alluvial fan. We would suggest that five additional intragravel probes be used to adequately measure the spatial variation in intragravel temperatures. Mahoney Lake is a cataloged anadromous waterbody (No. 191-45-10160- 0010), therefore, modification of flows into Mahoney Lake will require a Title 16 permit. Stipulations in that permit will be formulated to prevent dewatering of sockeye salmon spawning redds and a continuation of upwelling in the alluvial fan. Information relating rates of upwelling to Upper Mahoney Creek discharge will allow us to determine stipulations for flow requirements. Some methods were suggested through previous correspondence. A better understanding of this relationship will help us formulate accurate stipulations. Salmon Escapement Monitoring Measurements of sockeye salmon escapement for 10 years following project completion is suggested to determine potential project impacts. There are a number of problems associated with this plan. Escapement varies with the number of spawners, egg survival, rearing survival, ocean survival, and adult migration. In addition, returns are impacted for direct and indirect commercial harvest. Therefore, a direct relationship between the Mahoney Lake hydroelectric project and sockeye salmon escapement will be difficult to verify. In addition, the variability in escapement counts will make determination of significant pre- and post-project differences impossible, particularly with limited pre-project data. As you are aware, our concerns are related to the effects of changing hydrology on adult migration, and temperature and upwelling changes to incubating sockeye salmon eggs. To evaluate potential impacts to migrating adults and to meet permit stipulations we will require counts of total sockeye salmon returning to Lower Mahoney Creek and sockeye salmon escapement. The ratio of escapement to total returns will be used to evaluate potential impacts. As the pre-project distribution is unknown, and no statistical evaluation is indicated in your letter, impacts in relationship to Title 16 permits will be evaluated subjectively by the ADFG. Escapement can be obtained from counts of adults fish in spawning areas and/or at the inlet to Mahoney Lake. We would like to be informed when the biologist is called to make sockeye salmon counts. An ADF&G biologist would like to accompany the biologist to evaluate the effectiveness of the methods suggested. Mean daily discharge measurements from Upper Mahoney Creek and Lower Mahoney Creek also will be required to evaluate escapement/return data in relationship to Michael V. Stimac 3 8/29/96 changes in hydrology. The regression formula and data used to calculate the rating curve for both locations also will be required. Estimates of the potential effects of changes in the physical habitat on incubating salmon eggs and juvenile survival are more difficult. Optimally, egg and juvenile survival would be determined at the Upper Mahoney inlet spawning location. Obtaining these data will be difficult and expensive. Therefore, at this time we will require continued measurements of temperature and hydrology as described previously. If large changes in either of these parameters occur following project operation, then more detailed analysis of egg and juvenile survival will be required. Sincerely, Jeffrey C. Davis cc: Shea-Flanders, Lana, ADFG, Douglas Gustafson, Jack, ADFG, Ketchikan Estes, Christopher, ADFG, Anchorage Carol Denton, ADFG, Ketchikan Steve Hoffman, ADFG, Ketchikan Doug Campbell, Cape Fox Corporation, Saxman Mr. Nevin Holmberg, USFWS, Juneau Mr. Vince Yearick, FERC, Washington D.C. Ms. Tamra Faris, NMFS, Juneau October 14, 1996 cs Jeffrey C. Davis State of Alaska Department of Fish and Game Division of Habitat and Restoration 2030 Sea Level Drive, Suite 206 Ketchikan, Alaska 99901-6067 Subject: Mahoney Lake Hydroelectric Project Monitoring Plan Dear Mr. Davis: Thank you for your August 27, 1996, letter of comment on the monitoring plan for the Mahoney Lake Hydroelectric Project. Through our interactions we are arriving at a better understanding of your information needs and the best plan for collecting that information within present environmental and fiscal constraints. Our informal meeting with you on September 6, 1996, at HDR’s offices in Anchorage, was especially helpful in understanding the position and needs of ADF&G in drafting conditions to the FERC license. The following is a summary of our response to comments in your August 27 letter. ‘Lower Mahoney Creek Fish Passage The latest observations at the point in the stream where fish passage is limited indicate that the hypothesized fish pass does not exist. The rock shelf that it was hoped would allow fish access upstream when flows were moderate, was covered only by turbulent flow. No fish were observed making attempts to reach this part of the barrier. Unfortunately, the morphology of the barrier is too complicated to allow for hydrologic modeling of velocity, discharge, and turbulence characteristics to try to determine optimal flows. We feel that the best approach to determining optimal flows for fish migration past this point is to continue observations of fish movements and correlate successful migration with discharge values developed from gage data, as described in the Aquatic Resources Monitoring Plan. Spawning Area Incubation Conditions We have considered your request that additional temperature probes would be beneficial for more accurately describing natural and post-project temperature variations in the spawning gravel at the outlet of Upper Mahoney Creek. We are currently reviewing availability and costs of purchasing and installing additional instrumentation. At this time we plan on installing a total of five additional sites and one potential control site to more precisely monitor the spawning area conditions. HDR Alaska, Inc. 2525 C Street Telephone Suite 305 907 274-2000 a Anchorage, Alaska Fax 99503-2639 907 274-2022 We maintain that monitoring natural flows in Upper Mahoney Creek is adequate for comparison to the post-project flow regime. From this we can estimate whether the post- project flows fall within the range of natural conditions and whether there may be impacts on spawning redds and upwelling in the alluvial fan of Upper Mahoney Creek. We also recognize the need to secure Title 16 authorization for this project. Salmon Escapement Monitoring We will continue to observe adult migration in Lower Mahoney Creek and spawners in Lower Mahoney Lake and report this information to ADF&G. To increase the accuracy of our estimates of adult escapement to Lower Mahoney Lake from Lower Mahoney Creek, we are investigating the feasibility and costs of other methods of monitoring fish escapement. In addition, we will continue to monitor flows in Upper and Lower Mahoney Creek and supply the requested information to ADF&G. We will attempt to inform ADF&G each time we travel to the site. Also, we have noted your request for the regression formula and data used to calculate the rating curves for both locations and will provide that information shortly. Thank you again for your cooperation and comments. Sincerely, HDR Alaska, Inc. Mark Dalton Director of Environmental Services ce: D. Campbell, Cape Fox Corporation Nevin Holmberg, USFWS Andy Grossman, NMFS J. Morsell, Northern Ecological Services M. Stimac, HDR Engineering, Inc. Applicant's Response to Additional Information Request POST-PROJECT CUMULATIVE DEGREE DAYS HDR Letter to Distribution List - August 29, 1996 HDR Letter to Distribution List - September 11, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 FERC No. 11393 August 29, 1996 cs (See Distribution List) Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Additional Information Request Post-Project Cumulative Degree Days In a letter dated July 22, 1996, the Federal Energy Regulatory Commission (FERC) issued an Additional Information Request (AIR) for the above-referenced project. A copy of the FERC letter and AIR (Schedule A) were forwarded to you via our letter dated July 26, 1996. In accordance with item 3 of the AIR, enclosed for your review is a copy of our response to items 3(A) through 3(C). Please provide any comments you may have to me by September 30, 1996. If we do not hear from you by this date, we will assume that you have no comments on the response. If you have any questions or require additional information, please call me at (206) 453-1523. Sincerely, HDR ENGINEERING, INC. FOU. More Michael V. Stimac, Manager Licensing & Environmental Services Enclosure ce: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 MAHONEY LAKE HYDROELECTRIC PROJECT U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Mr. Andrew Grossman Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg US. Fish & Wildlife Service 3000 Vintage Blvd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 Mr. Jim DeHerrera District Ranger USS. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Steve Sams USS. Forest Service Federal Building Ketchikan, AK 99901 Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Mahoney Lake Hydroelectric Project Distribution List FERC NO. 11393 Distribution List Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main Street, Suite 905 Portland, OR 97204 Mr. Michael Strzelecki OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-70 Washington, DC 20426 Mr. Vince Yearick OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-73 Washington, D.C. 20426 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office 3601 C Street, #1200 Anchorage, AK 99503-5925 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 August 29, 1996 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project Distribution List Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 August 29, 1996 Mr. Tom Fitzgerald City Administrator City of Saxman Route 2, Box 1 Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen US. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 Mahoney Lake Hydroelectric Project Distribution List Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, OR 97209 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20420 Mr. Jim Thrall Locher Interests, Ltd. 406 West Fireweed Lane, Suite 101 Anchorage, AK 99503 August 29, 1996 MAHONEY LAKE HYDROELECTRIC PROJECT FERC PROJECT NO. 11393 RESPONSE TO JULY 22, 1996, REQUEST FOR ADDITIONAL INFORMATION ITEM 3: POST-PROJECT CUMULATIVE DEGREE DAYS FERC Request: Your estimated post-project cumulative degree days during the sockeye incubation period are derived from estimated post-project temperatures that included assumptions about the mixing of Upper Mahoney Creek flows and ground water at the spawning site and the depth of the drawdowns in Upper Mahoney Lake. There are some discrepancies, however, in your application: e The post-project cumulative degree days in Table 3 (page 31) of the preliminary draft Environmental Assessment (EA) are different than the post-project cumulative degree days in Table 3 (page 7) of Appendix C of the application; e Figures 11 and 12 in Appendix C, graphic presentations of the cumulative degree days, do not correspond to the days enumerated in Table 3 of Appendix C, but appear to correspond with Table 3 of the preliminary draft EA; and e Figure 7 in the preliminary draft EA, a graphic presentation of Table 3 of the preliminary draft EA, does not correspond to the cumulative degree days in Table 3 of the preliminary draft EA or Table 3 of Appendix C. e The “minimum post-project mixed” values are not represented in Figure 11 of Appendix C. To help us understand your analysis, please: (A) explain the above discrepancies in cumulative degree days between the preliminary draft EA and Appendix C of the application; Response to (A): The Water Quality and Temperature Monitoring Report, which was issued in February 1996, was included as Appendix C of the Application for License (Application) to document the methodology that has been used to assess water quality and temperature effects due to the operation of the project. As described in the body of the Application and the Preliminary Draft Environmental Assessment (PDEA), the operation of the project is a function of the electrical demand placed on Ketchikan Public Utilities’ (KPU) system, the sequencing of all of KPU’s resources, and the availability of water. Since completion of the Appendix C report, a slightly different regional demand loading forecast was developed which resulted in a slightly different operational scenario for the project. To prepare the PDEA filed on May 31, 1996, the analysis Mahoney Lake Hydroelectric Project Page 1 FERC Project No. 11393 Response to Request for Additional Information Item 3 - Cumulative Degree Days described in Appendix C of the Application was updated using the most current operational information available. The results are presented in the tables and figures of the PDEA. The difference in the results presented in Appendix C and the PDEA is due to a change in the input parameters to the model for turbine flow and not a change in the methodology used to calculate cumulative degree days. As such, the results presented in the PDEA supersede the results presented in Appendix C. The specific values shown in the tables and figures of the EA are not representations of the results presented in Appendix C. Graphical Representations - Specific Comments Figures 11 and 12 of Appendix C are illustrative of values of Table 3 of Appendix C. As can be seen by comparing Table 3 of Appendix C to Table 3 of the PDEA, the change in the results due to the change in input parameters is small. Because of the scale and clarity of Figures 11 and 12, the differences in the two sets of results may not be readily apparent. Enclosed are better copies of Figures 11 and 12. Because the enclosed copy of Figure 11 is of better quality, the data series “minimum post-project mixed” is clear. Figure 7 of the PDEA is a graphic presentation of the maximum drawdown (>60 ft) results as compared to the natural gravel temperatures for the period September 1 to June 30 as shown in Table 3 of PDEA. FERC Request: (B) _ provide your best estimate of cumulative degree days; (1) from September I through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (2) from October I through June 30 for drawdowns within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, (3) from September | through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water, and (4) from October 1 through June 30 for drawdowns that do not come within 20 feet of the intake with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water. Mahoney Lake Hydroelectric Project Page 2 FERC Project No. 11393 Response to Request for Additional Information Item 3 - Cumulative Degree Days Response to (B): The enclosed tables show the cumulative degree day calculations for (1) September 1 through June 30 for drawdowns within 20 feet of the intake (Table A) with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water; (2) October 1 through June 30 for drawdowns within 20 feet of the intake (Table B) with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water; (3) September 1 through June 30 for drawdowns that do not come within 20 feet of the intake (Table C) with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water; and (4) October 1 through June 30 for drawdowns that do not come within 20 feet of the intake (Table D) with the streamflow overwhelming the ground water and with proportionate mixing between the streamflow and the ground water. FERC Request: (C) _ explain how the cumulative degree days in B(1) through B(4) were calculated. (Note: The cumulative degree day calculations in Appendix C appear to support Table 3 of Appendix C. If these calculations were changed by another analysis, please explain the basis for the changes.) Response to (C): The data listed for B (1) through B (4) above were derived by multiplying the average monthly temperature (a degree day is degrees over 0° C per day, the ground water is always 0° C or over) of the ground water, for each condition, by the number of days in the month. Each month was then summed to estimate a rate of accumulation of degree days. Ground water temperatures were derived by using the Mahoney Lake temperature monitoring data and Ketchikan air temperature data to establish relationships between Ketchikan air temperatures and Mahoney Lake air and water temperatures. Historic Ketchikan temperatures were used to estimate the natural range of temperatures that would be expected in surface and ground water. Mixing was based on normal average and estimated post-project flow regimes. The cumulative degree days were calculated using the flow regime shown in Table 4 of the PDEA. Mahoney Lake Hydroelectric Project Page 3 FERC Project No. 11393 Preliminary Draft Environmental Assessment 7 shows degree day accumulation for the period September 1 through June 30. The data indicate that degree day accumulation through early June under the pre- and post-project flow regimes would likely be very similar. Under the maximum drawdown scenario, post-project conditions would be somewhat cooler than existing conditions, especially for early spawners. Regardless of the drawdown scenario, post-project incubation conditions would fall well within the estimated range of pre-project conditions. TABLE 3 ESTIMATED CUMULATIVE DEGREE DAYS DURING SALMON INCUBATION we fv | om (om [me [mm | [ae vyotues Mustrated 10 74,7 Water temperature impacts to incubating salmon eggs and alevins within the Mahoney Lake upwelling areas would be small. During unusually warm years, development could be delayed compared to what would occur naturally, possibly causing intermittent adverse impact as a result of late emergence. However, the more stable temperature regime during project operation would probably be beneficial to salmon production in Mahoney Lake in the long term, since adverse impacts from natural climatic extremes would be less likely to occur. The applicant proposes to continue monitoring the temperature of the water in the selected upwelling area of the Upper Mahoney Creek delta in Lower Mahoney Lake in conjunction with temperature and stream flow at the proposed tailrace site on Upper Mahoney Creek. Monitoring would continue during project construction and for at least three years after operation begins, resulting in at least five more years of continuous data. Mahoney Lake Hydroelectric Project FERC No: 11393 31 May 1996 mw Wed ¢ wp kOe aS SS Mahoney Lake Hydroelectric Project Preliminary Draft Environmental Assessment FIGURE 7 Pre-Project and Post-Project Degree Day Accumulation Cumulative Degree Days 0 Sep Oct Nov Dec Jan Feb Mar Apr May June —— Unmixed Post-Project = = ------- Post-Project Mixed ssoneeee Maximum Post-Project Mixed -——-—- Minimum Post-Project Mixed Natural Average Natural Average Maximum ~~~ Natural Average Minimum Pre-project and post-project ranges of degree day accumulation, for the period Septmeber 1 to June 30 and considering Upper Mahoney Lake drawdown. a | = a> | Preliminary Draft Environmental Assessment 3) Upwelling Water Volume. The successful development of salmon eggs and alevins also depends on an adequate exchange of water through their gravel environment to supply oxygen and to remove metabolic waste products. Water exchange in Lower Mahoney Lake salmon spawning areas is provided by upwelling ground water. The quantity of this upwelling water is likely determined in large part by the flow in Upper Mahoney Creek. The data collected to date seem to indicate that upwelling is a continuous process. Even at low flows (3 to 5 cfs measured in Upper Mahoney Creek), it appears water is flowing hyporheically through coarse channel substrate, according to the temperature variation seen between spawning gravel substrate and the water column in Lower Mahoney Lake. It is not known how much of the upwelling water volume comes from flows from Upper Mahoney Creek and how much might be from other groundwater sources. After the project is in operation, the flow in Upper Mahoney Creek downstream from the powerhouse would be the sum of the powerhouse discharge plus the contribution from the bypassed reach of the creek between the powerhouse and Upper Mahoney Lake. The bypassed portion of the watershed contributes about 24 percent of the flow in Upper Mahoney Creek below the powerhouse. Pre- and post-project flows in Upper Mahoney Creek (Table 4) are generally similar; post-project flow would be somewhat higher in December through April and lower in May through August. Assuming continuous project operation, no adverse impact to incubating salmon eggs would occur. There are natural changes in flow volume in Upper Mahoney Creek and presumably in upwelling due to storms and melt runoff. The alteration in = = <= <== = TABLE 4 PRE- AND POST-PROJECT FLOWS IN UPPER MAHONEY CREEK (cfs) Pre-Project « Average Upper Post-Project Mahoney Creek Post-Project Average Upper Mahoney Creek j Flows Downstream of Average Flows Downstream of Powerhouse Turbine Flows (cfs) Powerhouse (cfs) May 1996 34 Mahoney Lake Hydroelectric Project FERC No. 11393 Mahoney Lake Hydroelectric Project Appendix C - Water Quality and Temperature Monitoring Report the intake. In that case the tailrace water temperature would correspond more closely to natural temperature fluctuations seen in Upper Mahoney Creek and the salmon spawning gravels. Water temperature variations at all sampling locations are driven by changes in air temperature (e.g. r=0.95, p<0.001 - stream water T vs. air T at the tailrace site) (Figure 7). Because water temperatures, both surface and groundwater, are strongly correlated to air temperatures, estimates of normal monthly average, average maximum, and average minimum temperatures were made based on Ketchikan air temperature data. Figure 8 illustrates the range of expected natural spawning gravel temperatures. To predict the range of possible temperatures in the spawning gravels after the project is in place, we assumed the actual groundwater temperature would fall between two conditions. In one scenario the project would overwhelm natural conditions and the ground water would be the same temperature as water at the intake in Upper Mahoney Lake. In the second scenario there would be mixing in the aquifer of post-project flows with runoff from the lower drainage basin in proportion to their volume. Figures 9 and 10 illustrate the range of temperatures expected in the spawning gravels after the project is operating based on these two conditions and the amount of drawdown in Upper Mahoney Lake. Critical to salmon egg development is the amount of heat to which they are exposed. This is calculated as cumulative degree days (CDD) or the number of degrees above 0°C per day per a designated time period. Estimates were made based on an average water temperature at the intake of 4°C and of 2° - 3°C during March and April in the case of drawdown in excess of 60 feet. Figures 11] and 12 illustrate these results. Table 3 lists estimates of natural, unmixed post- project and mixed post-project degree day accumulations TABLE 3 Estimated CDD in the Lower Mahoney Lake Spawning Gravels for the Incubation Period, September 1 - June 30 Estimated Natural Estimated Unmixed Estimated Mixed cDD CDD cDD Spring Drawdown 1266 (2260-637) © 1212 1172 c1aes-1004) 3 Figure \ < 60 ft. Spring Drawdown 1266 (2260-637) 1112 983 csoss2m f Fi ve \Q > 60 ft. qd) Range 7 - 7 Mahoney Lake Hydroelectric Project Appendix C - Water Quality and Temperature Monitoring Report Degree Day Accumulation During Salmon Incubation (Sept. 1 - June 30): Less than 60 Feet of Drawdown 8 oO 0 Sep Oct Nov Dec Jan Feb Mar Apr May June Month ——— Unmixed Post-Project = =—S -------- Post-Project Mixed swe Maximum Post-Project Mixed ceenenee Minimum Post-Project Mixed Natural Average Figure 11. Cumulative degree days in the spawning garvels for the period of salmon incubation, showing average natural conditions and post project conditions. Mahoney Lake Hydroelectric Project Appendix C - Water Quality and Temperature Monitoring Report Degree Day Accumulation During Salmon Incubation (Sept. 1 - June 30): More than 60 Feet of Drawdown a a Oo 0 Sep Oct Nov Dec Jan Feb Mar Apr May June Month -------» Unmixed Post-Project —— Post-Project Mixed “owes _Mlaximum Post-Project Mixed mnenmeeee Minimum Post-Project Mixed Natural Average Figure 12. Cumulative degree days in the spawning gravels for the period of salmon incubation showing average natural conditions and post-project conditions. Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE A - Summed Accumulation September 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown Within 20 Feet of Intake Post - Project Grivel tem peratures Natural Gravel Ten peratures [Usesined | Mised | Maximum Mixed | Minimum Mized| Average | Average Maximum | Average Minimum Sep 154 239 Oct pe ne 408 Nov 708 984 408 Dec 751 1133 408 Jan 791 1272 408 Feb 842 1427 408 Mar 868 1522 408 Apr 940 1657 408 May 1039 1903 484 June 1266 2260 637 Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 Nov TABLE B - Summed Accumulation October 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown Within 20 Feet of Intake Post - Project Gravel Te: [Unmixed [Mixed | Maximum Mixed | 159 Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE C - Summed Accumulation September 1 - June 30 Estimated CDD During a en Drawdown > 20 Feet from Intake Post - Proj td Gravel Team p Natural Gravel Tes peratures Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE D - Summed Accumulation October 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown > 20 Feet From Intake Post - Project Gravel Temperatures Natural Gravel Temperatures [Unmixed [Mixed [Maximum Mixed | Minimum Mixed | Average |Average Maximum _| 124 141 159 126 235 313 124 141 159 126 235 313 169 235 313 169 235 313 169 235 313 169 235 313 169 235 313 169 235 313 169 235 313 169 September 11, 1996 (See Distribution List) Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Additional Information Request Post-Project Cumulative Degree Days Revised Tables The response to Item 3 of the AIR for the above-referenced project was sent to you for review and comment via my letter dated August 29, 1996. It was recently discovered that Tables B and D of the response contained some incorrect data entries. The corrected tables are enclosed to assist you in completing your review. As in our original request, please provide your comments to me by September 30, 1996. I hope this has not caused you any inconvenience. If you have any questions or require additional information, please let me know. Sincerely, HDR ENGINEERING, INC. Pil Vlarma Michael V. Stimac, Manager Licensing & Environmental Services Enclosure cc: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 MAHONEY LAKE HYDROELECTRIC PROJECT U.S. Army Corps of Engineers Alaska District Office P.O. Box 898 Anchorage, AK 99506-0898 Mr. Andrew Grossman Supervisor-Protected Resources Management Division National Marine Fisheries Service Alaska Region P.O. Box 21668 Juneau, AK 99602-1668 Mr. Nevin Holmberg US. Fish & Wildlife Service 3000 Vintage Blvd., Suite 201 Juneau, AK 99801 National Park Service Alaska Region 2825 Gambell Street Anchorage, AK 99503 U.S. Environmental Protection Agency Region X 1200 Sixth Avenue Seattle, WA 98101 Mr. Jim DeHerrera District Ranger US. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Steve Sams U.S. Forest Service Federal Building Ketchikan, AK 99901 Department of the Interior Office of Environmental Affairs Anchorage Regional Office 1689 C Street, Room 119 Anchorage, AK 99501-5126 Mahoney Lake Hydroelectric Project Distribution List FERC NO. 11393 Distribution List Regional Director Portland Regional Office Federal Energy Regulatory Commission 101 S.W. Main Street, Suite 905 Portland, OR 97204 Mr. Michael Strzelecki OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-70 Washington, DC 20426 Mr. Vince Yearick OHL/DPR Federal Energy Regulatory Commission 888 First Street NE, Room 52-73 Washington, D.C. 20426 Ms. Lorraine Marshall Alaska Division of Governmental Coordination P.O. Box 110030 Juneau, AK 99811-0030 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Ms. Judith Bittner Alaska Department of Natural Resources State Historic Preservation Office 3601 C Street, #1200 Anchorage, AK 99503-5925 Mr. John Dunker Alaska Department of Natural Resources Division of Mining & Water Management 400 Willoughby Avenue Juneau, AK 99801-1796 September 11, 1996 Mr. Bill Garry Alaska Department of Natural Resources Parks & Outdoor Recreation 400 Willoughby Avenue Juneau, AK 99801-1796 Mr. Jack Gustafson Alaska Department of Fish and Game Habitat Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Ms. Carol Denton Alaska Department of Fish and Game Commercial Fisheries Management and Development Division 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Honorable Tony Knowles Governor, State of Alaska P.O. Box 110001 Juneau, AK 99811-0001 Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Alaska Public Utilities Commission 1016 W. Sixth Avenue, Suite 400 Anchorage, AK 99501 Senator Robin Taylor Alaska State Senate State Capitol Juneau, AK 99801 Mr. Bill Williams Representative 352 Front Street Ketchikan, AK 99901 Honorable Alaire Stanton Mayor City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mahoney Lake Hydroelectric Project Distribution List Mr. Karl Amylon City Manager City of Ketchikan 334 Front Street Ketchikan, AK 99901 Mr. John Magyar General Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. and Mrs. Richard Andrew Ketchikan Advisory Committee P.O. Box 7211 Ketchikan, AK 99901 Mr. and Mrs. Fred Athorp Ketchikan Advisory Committee 10 Creek Street Ketchikan, AK 99901 Mr. Larry Painter Ketchikan Advisory Committee P.O. Box 6181 Ketchikan, AK 99901 Mr. Ralph C. Gregory Citizen's Advisory Committee Federal Areas P.O. Box 7011 Ketchikan, AK 99901 Ms. Bridget Stearns Ketchikan Public Library 629 Dock Street Ketchikan, AK 99901 Mr. Chas Edwardsen Vice President Haida Society 3213 Timberline Court Ketchikan, AK 99901 Southeast Alaska Conservation Council 419 Sixth Street, Suite 328 Juneau, AK 99801 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 September 11, 1996 Mr. Tom Fitzgerald City Administrator City of Saxman Route 2, Box 1 Ketchikan, AK 99901 Mr. Doug Campbell Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Mr. John Braislin Betts, Patterson & Mines 800 Financial Center 1215 Fourth Avenue Seattle, WA 98161-1000 Mr. Don Clarke Wilkinson, Barker, Knauer & Quinn 1735 New York Ave NW Washington, DC 20006 Mr. Christopher Estes Alaska Department of Fish & Game Sport Fish Division 333 Raspberry Road Anchorage, AK 99518-1599 Ms. Lana Shea Flanders Alaska Department of Fish & Game P.O. Box 240020 Douglas, AK 99824-0020 Ms. Elizaveta Shadura Alaska Department of Natural Resources Division of Land 400 Willoughby Avenue Suite 400 Juneau, AK 99801-1724 Mr. Duane Petersen USS. Fish & Wildlife Service 3000 Vintage Blvd., No. 201 Juneau, AK 99801 Mr. Stanley Sieczkowski, Manager Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 Mahoney Lake Hydroelectric Project Distribution List Mr. Bob Bright Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 U.S. Army Corps of Engineers 220 NW 8th Avenue Portland, OR 97209 State Director Alaska State Office Bureau of Land Management Division of Lands and Renewable Resources (AK-930) Attn: FERC Withdrawal Recordation 222 W. 7th Avenue, No. 13 Anchorage, AK 99513-7599 Department of the Interior Office of Environmental Affairs Room 2340 MIB 1849 C Street, NW Washington, D.C. 20420 Mr. Jim Thrall Locher Interests, Ltd. 406 West Fireweed Lane, Suite 101 Anchorage, AK 99503 September 11, 1996 Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE B - Summed Accumulation October 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown Within 20 Feet of Intake Natural Gravel Temperatures g g Average Minimum 235 313 169 141 Nov 244 247 310 202 388 590 169 Dec 368 342 437 289 431 740 169 Jan 492 419 563 366 47\ 878 169 Feb 604 501 684 436 522 1033 169 Mar 713 585 786 517 548 1128 169 Apr 788 660 879 572 620 1264 169 May 896 762 1006 642 719 1510 246 June 1016 905 1180 769 946 1867 398 Revised September 11, 1996 Mahoney Lake Hydroelectric Project FERC Project No. 11393 Response to July 22, 1996 Request for Additional Information Item 3 TABLE D - Summed Accumulation October 1 - June 30 Estimated CDD During Salmon Incubation: Drawdown > 20 Feet From Intake Post - Project Gravel Temperatures Natural Gravel Temperatures Unmixed | Mixed [Maximum Mixed | Minimum Mixed | Average [Average Maximum _ | Averag Oct 124 141 159 126 235 313 169 Nov 244 247 310 202 388 590 169 Dec 368 342 437 289 431 740 169 Jan 492 419 563 366 471 878 169 Feb 604 501 684 436 522 1033 169 Mar 728 596 798 528 548 1128 169 Apr 848 705 923 616 620 1264 169 May 972 816 1060 696 719 1510 246 June 1092 960 1234 823 946 1867 398 Revised September 11, 1996 Applicant's Response to Additional Information Request CULTURAL RESOURCES HDR Letter to U.S. Forest Service - September 18, 1996 HDR Letter to Alaska State Historic Preservation Office - September 18, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 FERC No. 11393 September 18, 1996 Teresa Trulock U.S. Forest Service 3031 Tongass Avenue Ketchikan, AK 99901 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Additional Information Request Cultural Resources Report Dear Ms. Trulock: In a letter dated July 22, 1996, the Federal Energy Regulatory Commission (FERC) issued an Additional Information Request (AIR) for the above-referenced project. A copy of the FERC letter and AIR (Schedule A) were forwarded to the Forest Service via our letter dated July 26, 1996. In accordance with Item 4 of the AIR, enclosed for your review are two copies of the cultural resource report entitled An Archeological Survey of Mahoney Hydroelectric Power Project, FERC Project No. 11393-000 for the City of Saxman, Alaska prepared by C.R.C. Cultural Resource Consultant. Because the report contains sensitive information concerning cultural resource sites, it is confidential and not for public disclosure. Please provide any comments you may have to me by October 9, 1996. If we do not hear from you by this date, we will assume that you have no comments on the report. If you have any questions or require additional information, please call me at (206) 453-1523. Sincerely, HDR ENGINEERING, INC. POU, silbcrna Michael V. Stimac, Manager Licensing & Environmental Services Enclosures CG: Dr. Edwin Slatter, FERC (w/enclosure) Vince Yearick, FERC Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation Chris Campbell, C.R.C. HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 September 18, 1996 Ms. Judith Bitmer Alaska Department of Natural Resources State Historic Preservation Office 3601 C Street, #1200 Anchorage, AK 99801 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Additional Information Request Cultural Resources Report Dear Ms. Bittner: Ina letter dated July 22, 1996, the Federal Energy Regulatory Commission (FERC) issued an Additional Information Request (AIR) for the above-referenced project. A copy of the FERC letter and AIR (Schedule A) were forwarded to you via our letter dated July 26, 1996. In accordance with Item 4 of the AIR, enclosed are two copies, one for review and one for your files, of the cultural resource report entitled An Archeological Survey of Mahoney Hydroelectric Power Project, FERC Project No. 11393-000 for the City of Saxman, Alaska prepared by C.R.C. Cultural Resource Consultant. Because the report contains sensitive information concerning cultural resource sites, it is confidential and not for public disclosure. Please provide any comments you may have to me by October 9, 1996. If we do not hear from you by this date, we will assume that you have no comments on the report. If you have any questions or require additional information, please call me at (206) 453-1523. Sincerely, HDR ENGINEERING, INC. a Michael V. Stimac, Manager Licensing & Environmental Services Enclosure Cc; Dr. Edwin Slatter, FERC (w/enclosure) Vince Yearick, FERC Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Corporation Chris Campbell, C.R.C. HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107 Applicant's Response to Additional Information Request HYDROLOGIC DATA HDR Letter to FERC, OHL - July 26, 1996 Mahoney Lake Hydroelectric Project October 18, 1996 FERC No. 11393 July 26, 1996 Mr. Jim Fargo Office of Hydropower Licensing Federal Energy Regulatory Commission 888 First St., NE, Room 52-77 Washington, D.C. 20426 Re: Mahoney Lake Hydroelectric Project FERC Project No. 11393 Additional Information Request Dear Mr. Fargo: In accordance with the July 22, 1996, letter from the Federal Energy Regulatory Commission (FERC) accepting for filing the Application for License for the above-referenced project and requesting additional information, enclosed is a computer diskette copy of the complete hydrologic data set for the 35 years of record used to analyze the Mahoney Lake Hydroelectric Project. If you have any questions or require additional information regarding the data set, please call Mr. Paul Berkshire, Project Engineer, at (206) 453-1523. Sincerely, HDR ENGINEERING, INC. FL bran Michael V. Stimac, Manager Licensing and Environmental Services Enclosure Cc: Tom Fitzgerald, City of Saxman Doug Campbell, Cape Fox Don Clarke, Wilkinson, Barker, Knauer & Quinn h:\hyd\mahoney\app\air03.doc HDR Engineering, Inc. Suite 1200 Telephone Engineering 500 108th Avenue, N.E. 206 453-1523 Construction Services Bellevue, Washington Fax 98004-5538 206 453-7107