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HomeMy WebLinkAboutWhitman Lake Hydroelectric Project FERC Project No. 11597 Initial Consultation Document December 1998 WHITMAN LAKE HYDROELECTRIC PROJECT FERC Project No. 11597 INITIAL CONSULTATION DOCUMENT Ketchikan Public Utilities December 1998 WHITMAN LAKE HYDROELECTRIC PROJECT INITIAL CONSULTATION DOCUMENT Table of Contents TABLE OF CONTENTS 1.0 INTRODUCTION 2.0 GENERAL ENGINEERING DESIGN 3.0 OPERATIONAL MODE 4.0 ENVIRONMENTAL AND REGULATORY ISSUES 4.1 Environmental Issues 4.1.1 Topography 4.1.2 Climate 4.1.3 Water Quality/Quantity 4.1.4 Fishery Resources 4.1.5 Wildlife Resources 4.1.6 Botanical Resources 4.1.7 Aesthetic Resources 4.1.8 Cultural Resources 4.1.9 Recreation and Other Land Uses 4.2 Regulatory Issues 5.0 STREAMFLOW AND WATER REGIME 6.0 PURPA BENEFITS 7.0 LICENSING STUDY PLANS Teh Water Quality and Quantity 72 Fisheries 73 Wildlife 7.4 Botanical 75 Aesthetics 7.6 Cultural Resources 7.7 Recreation and Land Use 8.0 REFERENCES 9.0 CONSULTATION DOCUMENT MAILING LIST December 1998 Initial Consultation Document Whitman Lake Hydroelectric Project Introduction 1.0 INTRODUCTION The Whitman Lake Project is located near the southeast end of Revillagigedo Island, approximately four miles east of the City of Ketchikan, Alaska (Figure 1-1). Whitman Lake is naturally formed, but the normal water surface elevation was raised about 18 feet in 1927 with the construction of a 46 -foot high concrete gravity arch dam at the lake outlet. The dam was originally part of a 1,500 kW hydroelectric project owned by New England Fish Company. The Ketchikan Utilities Board purchased the project in 1957 and the plant was retired from service shortly thereafter. The original penstock and powerhouse have, for the most part, been demolished and removed from the site, but the dam remains in service providing water supply to the Herring Cove Fish Hatchery. The Project is located on lands owned by the State of Alaska and United States Forest Service (USFS). The Federal Energy Regulatory Commission (Commission or FERC) issued a three-year Preliminary Permit for the Whitman Lake Hydroelectric Project on June 5, 1997. The permit gives Ketchikan Public Utility District (KPU) priority for filing a development application while conducting engineering and environmental feasibility studies. KPU intends to file an application for a “Major Project-Existing Dam” with a total installed capacity of 5 MW or less (18 Code of Federal Regulations [CFR] Subpart G, Section 4.60). The FERC regulations require the Applicant to follow a three-stage consultation process in the preparation of a hydropower license application for the Project. The Applicant is combining the Applicant Prepared EA (APEA) process with the three-stage consultation process. This Initial Consultation Document (ICD) begins the first stage of the process. The attached Scoping Document 1 (SD1) begins NEPA scoping as part of the APEA process. The purpose of this ICD is to obtain input from federal/state/local agencies, native groups, and public citizens who are interested in the Project. The applicant wishes to receive input on concerns about the proposed Project, to identify environmental or other issues surrounding the Project development, and to provide clear communication about the proposal and its possible impacts to all interested parties. This ICD has been prepared to provide a general overview of the proposed Project design, operation, and potential impacts. A description of studies proposed in order to gain more detailed information about potential impacts is included in the ICD. After review of this document, public and agency meetings will be held in Ketchikan, Alaska. Following these meetings, agencies and the public are invited to submit written comments about the proposed Project and the proposed study plans. The plans will then be revised to incorporate comments received. A final version of the Consultation Document will be issued that contains finalized study plans and copies of consultation correspondence. This three-stage consultation process will lead to the submittal to the FERC of a license application and draft environmental assessment that have been developed utilizing the results of the agreed-to studies. December 1998 Initial Consultation Document Page 1 Whitman Lake Hydroelectric Project TALBOT. LAKE, Cl LAKE PERSEVERANCE CARLANNA LAKE LOWER KETCHIKAN, KETCHIKAN, GRAVINA ISLAND LAKE HARRIET No, y Q v REVILLAGIGEDO 3 MAHONEY LAK UPPER ey MAHONEY LAKE oS Oo ‘D> UPPER KETCHIKAN LAKE LOWER SILVIS LAKE Quy” UPPER SILVIS LAKE Y PROJECT LOCATION WHITMAN LAKE PROJECT LOCATION SCALE IN MILES ISLAND ALASKA ANCHORAGE \ - a ‘\wneau N \ PROJECT LOCATION KETCHIKAN Vv PAC RIC OCEAN 4 KEY MAP KETCHIKAN PUBLIC UTILITIES WHITMAN LAKE HYDROELECTRIC PROJECT FERC PROJECT NO. 11597 PROJECT LOCATION MAP FIGURE 1-1 General Engineering Design 2.0 GENERAL ENGINEERING DESIGN ~ Existing facilities currently in operation include the dam and two parallel above-ground steel pipelines supplying water to the hatchery. Both pipelines are about 2,260 feet in length. The larger pipeline is 24 inches in diameter at the dam, and reduces to 18 inches diameter over the lower 900 feet. The smaller pipeline is 10 inches in diameter at the dam, and reduces to 8 inches over the lower 900 feet. In addition to these facilities, a small concrete diversion structure is located on Whitman Creek about 3,000 feet downstream of Whitman Dam to supply water for domestic use to 21 homeowners in the Herring Cove area. The Project involves constructing a new 45” steel penstock from Whitman Dam to a powerhouse at Herring Cove containing two turbine/generator units totaling 4.6 MW. The penstock will follow the same general alignment as the existing hatchery water supply pipelines. Dimensions and sizes of principal project features are presented in Table 2-1. Layout of the project is shown on Figures 2-1 through 2-3, and described as follows: Existing Whitman Dam The existing 70-year old dam shows signs of deterioration, but with proper rehabilitation measures and maintenance, it can be made a reliable structure through one or several 30 year FERC license terms. In the most recent dam safety inspection report, published in January 1997, it was reported that areas of leakage were observed through the dam, which may indicate potentially deteriorating concrete joints. It was recommended that the leakage be monitored and the joints be eventualiy grouted. Since the dam will become an important feature of the hydro project, dam repairs and maintenance items should include, at a minimum, grouting the joints, repairing rock pockets, painting exposed metalwork, and installing new safety grating and railings on the dam crest. Based on recent dam safety inspection reports, it appears that the structural stability of the dam has been analyzed, but possibly not to standards required by FERC for licensed hydroelectric projects. Development of a hydroelectric project utilizing Whitman Lake may require additional structural analysis of the dam under seismic and Probable Maximum Flood loading conditions in accordance with FERC’s Engineering Guidelines. If results from previous analyses do not meet FERC’s accepted methods and factors of safety, then such analyses will be required. Remove Timber Crib Dam When Whitman Dam was constructed in 1927 it inundated a timber crib dam located immediately upstream. Remnants of the timber crib dam are still visible below the water surface. Based on a 1926 sketch showing the location of both dams, the crest of the timber crib dam was set at about El. 370, or about 8 feet above the proposed minimum operating pool level. In order to ensure sufficient flow is made available to the Whitman Dam intake down to the proposed minimum operating pool level, El. 362, any flow restrictions caused by the timber crib dam, large trees, root balls or other material, will need to be removed. December 1998 Initial Consultation Document Page 2 Whitman Lake Hydroelectric Project Table 2-1 Project Statistics Preferred Alternative Drainage Area Natural Drainage Area Diversion Area (2 sites) Average Annual Natural Outflow at Dam Combined Average Annual Flow at Diversion Sites Reservoir Normal Maximum Operating Elevation Normal Minimum Operating Elevation Active Storage at El. 380 Surface Area at El. 380 Surface Area at El. 362 Existing Dam Dam Type Maximum Structural Height Crest Length Dam Crest Elevation Spillway Type Spillway Crest Elevation Spillway Width Outlets Penstock Existing Pipelines New Penstock Diameter/Length Powerhouse Type Size (footprint) Unit 1: (Horizontal Francis) Rated Capacity Rated Head Maximum Discharge Unit 2: (Horizontal Francis) Rated Capacity Rated Head Maximum Discharge Transmission Line Voltage Length General Engineering Design 4.1 square miles 1.25 square miles 78 cfs 23 cfs 380 362 2,500 acre-feet 148 acres 129 acres Concrete Gravity Arch 46 feet 220 feet 385 Ogee Sill within Dam 380 40 feet 2-36” dia. and 1-42” dia. 18-inch / 2,260 feet 8-inch / 2,260 feet 45-inch / 2,220 feet Above Ground Concrete 2,800 sq. ft. 3,900 kw 345 feet 150 cfs 700 kw 310 feet 30 cfs 34.5kV 1,200 feet December 1998 Page 3 Initial Consultation Document Whitman Lake Hydroelectric Project General Engineering Design New Diversion Structures The natural drainage area into Whitman Lake is 4.1 square miles. A portion of flow from two creeks that do not naturally flow into the lake will be diverted to the lake via small diameter pipelines in order to increase the amount of flow available for power generation. The two diversions combined will augment the natural basin inflow by as much as 30 percent. One of the diversions will be located about 1,300 feet northeast of Whitman Dam on a tributary that feeds Whitman Creek below the dam. The diversion structure will be capable of diverting up to 35 cfs through a 1,600-foot long, 24-inch diameter, high density polyethylene (HDPE) pipe. The drainage area above the diversion site is 0.95 square miles. The second diversion site will be located about 4,800 feet southwest of the dam on a creek that flows to Herring Cove. The drainage area above this diversion is 0.3 square miles. Streamflow up to 10 cfs will be diverted to Whitman Lake via a 16-inch diameter, 1,760-foot long, HDPE pipe. Both diversions will be rockfill structures constructed from boulders, rock fragments and gravel that can be easily excavated nearby. The diversion structure will have a concrete or HDPE liner blanket on the upstream face to act as an impervious barrier. Future field studies should investigate the availability of sufficient clay as an alternative impervious barrier. At each diversion there will be a small gated intake structure, spillway slot with flashboards, and a gated sluice pipe. All gates will be manually operated. The intake gate will be normally in the full open position and will be used primarily to dewater the diversion pipeline for maintenance or repair. Sediment, tree limbs and other debris that collects behind the diversion structure will need to be periodically removed by sluicing or manual means. It may be possible to “walk-in” a small dozer to construct the larger diversion, but materials and equipment will need to be hauled in by air to construct the smaller diversion. Because of the higher cost of hauling equipment and materials by air, and the relatively smaller drainage area, future studies should confirm the economic feasibility of constructing the smaller diversion. The diversion pipelines will be laid at a 1 to 2 percent slope generally following the contours of the land. The pipe will be buried or mounded where feasible to provide protection from falling trees or boulders. The pipe will be anchored to minimize displacement. New 45-inch Diameter Penstock A new 45-inch diameter, 2,220-foot long, steel penstock will be constructed from the dam to the powerhouse at Herring Cove. The penstock will be supported above ground on piers founded on bedrock. Based on geotechnical evaluation of the penstock route), an above ground penstock is more suitable due to the presumed shallow depth to bedrock. It will generally parallel the same alignment of the two existing water supply pipelines from the dam to the existing vacuum valve house. At the valve house, about 200 feet of the new penstock will be buried up to a maximum December 1998 Initial Consultation Document Page 4 Whitman Lake Hydroelectric Project General Engineering Design depth of about 20 feet to ensure that the penstock has sufficient pressure head to convey the full design flow to the turbines. The buried section of penstock will likely require rock blasting. Existing Hatchery Pipelines The two existing pipelines serving the hatchery’s water supply and temperature requirements will continue to serve these functions. The existing valves at the dam used to control temperature and flow rate will be automated to make operations more convenient for the hatchery. Instead of delivering water to the hatchery at high pressure, a small turbine unit will be installed on the lower end of the existing pipelines to convert the high potential energy to useful kinetic energy. In order to optimize the amount of hydroelectric generation, the lower 890 feet of the existing 18-inch diameter pipeline will be replaced with 24-inch diameter pipe. Intake Connection There are three existing outlets through the dam. Two 36-inch diameter outlets have inverts at about El. 349, and a single 42-inch diameter outlet has an invert at about El. 354. The 42-inch outlet and one of the 36-inch outlets are currently being used to collectively supply up to 27 cfs to the hatchery. Flow through the outlets is manually regulated to control the temperature of water delivered to the hatchery. The 42-inch outlet draws from the top portion of the lake and the 36-inch outlet draws from deeper waters through an approximate 1,500-foot pipe connected to it on the upstream side. The unused 36-inch outlet will serve as the inlet to the new 45-inch diameter penstock. Further study will be needed to determine if the existing outlet could be enlarged to provide better hydraulic conditions at the intake. A trashrack will be installed on the upstream face of the dam to prevent large woody debris from entering the penstock and potentially damaging the turbine runner. Instream Flow Release Valve In order to maintain flow in the channel below the dam, a remote operated 8-inch diameter throttling valve will be tapped into the new penstock and the existing 24-inch pipeline at the dam to enable a continuous flow below the dam. An instream flow will satisfy fishery concerns and water rights held by the Herring Cove Water User’s Association. The actual rate of flow will be subject to negotiation during preparation of the FERC license application. Powerhouse A 2,800 square foot composite concrete and steel-framed powerhouse will be located immediately uphill from the existing PRV building. The powerhouse will contain a 3.9 MW unit and a 0.7 MW unit for a total installed capacity of 4.6 MW. The larger unit will operate within a flow range between 50 and 150 cfs, and the small unit will operate between 12 and 30 cfs. Both December 1998 Initial Consultation Document Page 5 Whitman Lake Hydroelectric Project General Engineering Design turbines will be horizontal Francis type machines, which are the most appropriate type unit with the given head and flow conditions. In order to suppress the magnitude of hydraulic transient pressures in the penstocks when flow is abruptly changed, an 18-inch diameter synchronous bypass valve will be installed to automatically open if the turbine wicket gates suddenly close due to a line fault or other reasons. Tailwater level exiting the powerhouse will be controlled at about El. 40 for the small unit, and at El. 20 for the larger unit. Discharge from the small unit will be conveyed to the hatchery for its use, with any excess flow diverted to the lower tailrace. Discharge from the large unit will be conveyed in a buried concrete box culvert running from the powerhouse to a point immediately east of the existing fish ladder entrance. Discharging adjacent to the fish ladder will minimize any confusion to returning fish. Switchyard and Transmission Line ' The plant switchyard will be located adjacent to the powerhouse and will contain a power transformer, circuit breakers and disconnect switches. Transmission line work will involve reconductoring approximately 1,200 feet of the existing distribution line serving the hatchery and several residences along Powerhouse Road. The 34.5 kV transmission line will be constructed from the switchyard to an intertie with the 34.5 kV Beaver Falls line along Tongass Highway. December 1998 Initial Consultation Document Page 6 Whitman Lake Hydroelectric Project WHITMAN LAKE NORMAL MAX. W.S. EL 380 NEW 45"9 SCALE IN FEET KETCHIKAN PUBLIC UTILITIES WHITMAN LAKE HYDROELECTRIC PROJECT FERC PROJECT NO. 11597 PROJECT GENERAL ARRANGEMENT FIGURE 2-1 Paenl —_—~ lie os EXISTING 8” STEEL PIPELINE =—__] LOT LOT if ies 108 107 | —————————c LOT 100 NEW POWERHOUSE al INCUBATION -—~ BUILDING SHOP PRV BUILD! NEW TAILRACE 100 re SCALE IN FEET KETCHIKAN PUBLIC UTILITIES WHITMAN LAKE HYDROELECTRIC PROJECT FERC PROJECT NO. 11597 POWERHOUSE AREA LAYOUT FIGURE 2-2 WESCORP 40'-0 780_kVA EXISTING 86 TEMPERATURE CONTROL PIPELINE GENERATOR — Ye | 24"@ SUPPLY LINE H TO HT GEN. FLR. cl EL. 45.0 NEW 2479 TEMPERATURE CONTOL PIPELINE (REPLACES EXISTING 18"0 PIPELINE) —— STAIRS 18"% SYNCHRONOUS BYPASS NEW 45"9 STEEL PENSTOCK TAILWATER I TAILRACE CONTROL WEIR EL 18 GEN. FLR. EL. 23.0 q EQUIPMENT LEGEND 4330 kVA MK LA\ GENERATOR CONTROL AND RELAY PANEL c SWITCHGEAR AND STATION SERVICE POWER CENTER ll MOTOR CONTROL CENTER 15'-WIDE ROLL-UP DOOR BATTERY BANK AND CHARGER PLAN HYDRAULIC PRESSURE UNIT SUMP PUMP 16 a a a | SCALE IN FEET KETCHIKAN PUBLIC UTILITIES WHITMAN LAKE HYDROELECTRIC PROJECT FERC PROJECT NO. 11597 POWERHOUSE PLAN AND SECTION FIGURE 2-3 Operational Mode 3.0 OPERATIONAL MODE precedence over the operation of all other KPU-owned generating resources. KPU would still purchase power from the Swan Lake Project in accordance with terms under the Four-Dam Pool Agreement. Adopting this operating philosophy will maximize energy generation and minimize spill. Because of the relative lack of storage with this project alternative, the project will operate similar to a run-of-river project, which more or less respond to inflow rather than load. A main premise of this alternative is that plant operation, in response to reservoir inflow, takes / A reservoir level sensing device, installed at the dam and hard-wired to the powerhouse, will periodically transmit water surface elevation and rate of change in elevation to a programmable logic controller (PLC) in the powerhouse. The PLC will transmit a signal to gradually open or close the turbine wicket gates based on a series of pre-programmed logical arguments that take into account variables such as current rate of reservoir inflow, current reservoir level, target reservoir level, hatchery flow demand, and optimum turbine efficiency. Programming the units to respond to reservoir inflow will make more efficient use of inflow and reduce spill. For example, if an inflow of 400 cfs to the reservoir (not an unusual event) were sustained for 4 hours, the reservoir would rise about 1 foot in that time period assuming there were no releases from the dam. If sustained over 24 hours, then the rise would be 6 feet. With reservoir level sensing, wicket gates on the two units would automatically open in an effort to maintain the targeted reservoir level until the full combined maximum turbine discharge of 180 cfs is attained. The reservoir level would still rise because inflow (400 cfs) exceeds outflow (180 cfs), but the rise over 24 hours would be only about 3 feet versus 6 feet. This type of operation will reduce overall spill. The hydroelectric project will be hydraulically integrated with the hatchery’s water supply needs. Water for the hatchery will continue to be taken from the two existing pipelines, however the larger (18” diameter) pipeline will be connected to the 700 kW turbine unit. Water from the small (8-inch diameter) pipeline will not be used for hydropower generation, but will continue to feed the hatchery. December 1998 Initial Consultation Document Page 7 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues 4.0 © ENVIRONMENTAL AND REGULATORY ISSUES This section discusses the environmental setting, preliminary identification of environmental impacts and possible agency concerns, and permitting requirements to the extent known at this time. 4.1 Environmental Issues 4.1.1 Topography The Project site is located on Revillagigedo Island in southeast Alaska. The Project is approximately 4 miles east of Ketchikan within the Ketchikan Gateway Borough. Ketchikan Gateway Borough is characterized by steep mountains and high mountain lakes, deeply incised tributaries, and saltwater shorelines with steep slopes descending to narrow, rocky beaches. The Whitman Lake Dam crest elevation is 385 feet. The proposed powerhouse site is located near sea level. 4.1.2 Climate The climate in the Project area is typical of a temperate rain forest with mild winters and summers, and plentiful rainfall. Yearly average rainfall is approximately 162 inches per year and snowfall is approximately 32 inches. The heaviest rainfall is from October to December. Average monthly temperature ranges from 34°F in January to 58.7°F in August. Prevailing winds in the Ketchikan area are from the southeast. 4.1.3 Water Quality/Quantity Existing Conditions Whitman Lake is the water supply for the Southern Southeast Regional Aquaculture Association (SSRAA) Herring Cove hatchery and is monitored for water quality. Water from Whitman Lake can be described as cold, clear and clean. SSRAA collects water quality data from a station 80 feet deep. Table 4-1 provides ranges of some of their data: Water Quality Data for Whitman Lake (Source: SSRAA, pers. Comm. 1997). DISSOLVED | DISSOLVED P OXYGEN (mg/l) | Lake Whitman 80 feet depth (% saturation) 4.5-6.5 |9.1- 10.1 80 -90 December 1998 Initial Consultation Document Page 8 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues The quantity of precipitation combined with steep slopes and shallow soils allow surface water to drain quickly into the lakes and reduces the time for water to concentrate dissolved ions and minerals (Dames and Moore, 1990). Though existing information does not include chemical analysis of the water samples, it is likely that chemical conditions of these lakes are consistent with federal and state water quality standards. Currently, SSRAA has a water right for 39 cfs for their Herring Cove salmon hatchery. The Herring Bay Water Users Association has a water right for 100,000 gpd (.15 cfs). A permit was granted to the Herring Bay Water Users Association from the U.S. Forest Service on February 17, 1971 for the diversion and water system. Currently, KPU does not have a water right for appropriations from this system. Median monthly flows (50% exceedence) in Whitman Creek range from a low of 19.2 cfs in August to a high of 88 cfs in October. Water supply available for diversion in the low flow summer months may be greatly reduced or not available. Potential Water Issues/Concerns/Mitigation Water issues that have been identified by Alaska Department of Fish and Game (ADFG) and by SSRAA are temperature, gas saturation and water quantity. These concerns can be managed with project design features and monitoring of water quality. The proposed Whitman Lake Project will not likely have long-term impact on water quality of the lake or bypass reaches. Project construction may cause short-term impacts such as increased turbidity and suspended solids. An erosion and sediment control plan will need to be developed and strict adherence to best-management practices (BMPs) will need to be followed to avoid excessive impacts to the waterbodies during the construction phase. Minimum instream flows in Whitman Creek will be required by the agencies. The quantity of instream flow required will depend on if a significant resident fish population is found downstream of Whitman Lake. 4.1.4 Fishery Resources Existing Conditions Because of steep channel slopes that create predominantly cascade and waterfall habitats throughout much of the stream, anadromous fish are essentially limited to only the lower-most segment of Whitman Creek near the South Tongass Highway bridge. Even within that segment, spawning gravels are generally absent, such that any spawning that may occur would likely be intertidal. However, there are no published or oral accounts of any salmon spawning within the lower segment of Whitman Creek. With respect to resident fish species, an initial review of the literature has indicated that no site- specific studies have been conducted in either Whitman Lake or Whitman Creek. Thus, December 1998 Initial Consultation Document Page 9 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues information is generally lacking regarding fish species composition and abundance in the Whitman Creek drainage. Potential species that may be present include Dolly Varden char (Salvelinus malma), cutthroat trout (Oncorhynchus clarki), rainbow trout (O. mykiss), and possibly, brook trout (Salvelinus fontinalis). Potential Fisheries Issues/Concerns/Mitigation Fisheries and aquatic resource issues that will need to be addressed relative to the Whitman Project include, but are not limited to the following: 1) Flows to protect intertidal spawning at mouth of Whitman Creek — if intertidal spawning is documented, there will be a need to ensure that operations provide flows sufficient to protect that activity; 2) Species composition and relative abundance information for resident fish in Whitman Creek and major tributaries, and their instream flow needs; 3) Species composition and relative abundance information for resident fish in Whitman Lake; 4) Water quality of Whitman Lake, specifically related to temperature and dissolved oxygen concentrations and water supply to the Herring Cove aquaculture facility; 5) Effects of Whitman Hydroelectric project operations on the Herring Cove aquaculture facility, which presently obtains its water supply from Whitman Lake; 6) Effects of lake level changes on habitat, both within the lake and in influent tributaries. 4.1.5 Wildlife Resources Existing Conditions Wildlife habitat in the vicinity of the Project area can be divided into seven broad categories: alpine, subalpine, estuary, riparian forest, upland forest, open water, and wetland. The alpine category encompasses lands above the timberline, including cliff and talus slopes. The subalpine category includes forested and scrub covered areas, with some unvegetated terrain lying between the alpine zone and the upland forest. The upland forest includes all forested and non-forested habitat below the subalpine zone and outside of riparian and wetland areas. Open water habitat includes all lakes, rivers, streams, and coastal waters. Riparian and wetland habitats include those lands adjacent to streams, lakes, and estuaries that support plant and animal species requiring more mesic habitat conditions. Estuaries are comprised of all lands lying within the zone of tidal influence. There are no endangered or threatened wildlife species known to occur in the vicinity of the Project (USFWS 1997; USFS, pers. comm. 1997a; ADFG, pers. comm. 1997). Birds: Peregrine Falcon (Falco peregrinus pealei) is the only listed species with the potential to occur in the vicinity of the Project. This species may occur as a transient in Southeast Alaska, primarily during seasonal migration. No critical habitat has been designed for December 1998 Initial Consultation Document Page 10 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues this species and there have been no historical records of peregrine falcons in the Project area. Preliminary review of photographs and topographic maps did not reveal suitable nesting habitat (cliff eyries) and relatively low usage of waterfowl in the Project area indicates that there may not be much of a prey base to support peregrine falcons. Bald Eagle (Haliaeetus leucocephalus): Although the bald eagle is not a threatened or endangered species in Alaska, it is protected by the state and therefore surveys will likely be requested by the various state and federal agencies in the area. The marbled murrelet (Branchyramphus mamrmoratus) and the Northern goshawk (Accipiter gentilis laingi) are both species of special interest to the USFS and the USFWS due to their association with old growth and mature conifer forest habitats. It is assumed that marbled murrelets and northern goshawks are nesting in the vicinity of the Project area (ADFG, pers, comm. 1997; USFS, pers. comm. 1997a). One known nest site has been documented for Northern Goshawk on the west side of Herring Bay near Whitman Lake. Complete raptor and marbled murrelet surveys will need to be conducted in order to document the presence or absence of these birds within the Project area. Harlequin Duck (Histrionicus histrionicus) was also mentioned as a species of special interest and might warrant surveys due to its close association with open water and riparian habitats (ADFG, pers, comm. 1997) Surveys for this species can be combined with stream habitat inventories. Mammals: The Alexander Archipelago wolf (Canis lupus ligoni) is a high profile species known and/or suspected to occur in the vicinity of the Project (ADFG, pers, comm. 1997). Whitman Lake is expected to contain a relatively large number of wolves. Sitka black- tailed deer is the primary food source for wolves which might also explain the high rating for Whitman Lake (high carrying capacity for deer). Therefore, studies of wolf populations and range are good indicators of the overall deer population and habitat sustainability. The USFS and USFWS have both identified the Alexander wolf as a possible species for federal listing, which also makes surveying for this species important. Revillagigedo Island red-backed vole (Clethrionomys gapperi solus) is a subspecies of the red-backed vole and is only found on Revillagigedo Island. There is a mapped record for this vole in Ketchikan (Natural Heritage Database, 1997) and therefore may occur within the Project area. These voles appear to prefer mesic areas in coniferous, deciduous and mixed forests with dense cover and abundant litter, stumps, rotting logs, exposed roots, and a dense leaf litter. Habitat availability does not appear to be a limiting factor for this species and there was no mention of declining population status in the literature. Therefore surveys for red-backed vole may not be warranted in the Project area. December 1998 Initial Consultation Document Page 11 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues Opportunistic sightings and areas with good habitat suitability could be documented in conjunction with other studies. Although Ketchikan is not classified as a subsistence community, many residents rely on hunting in the surrounding Tongass to provide food for their families. Sitka black-tailed deer and black bear are two primary game species with importance to local residents of Ketchikan. Habitat mapping and field reconnaissance surveys would be useful for identifying baseline conditions and providing an analysis tool for managing deer and bear habitat within the Project area (ADFG pers. comm. 1997). Amphibians: Spotted Frog is a species of special interest to the agencies (USFWS, ADFG, USFS). Opportunistic searches and dip-netting of selected areas will identify presence of the species and project related effects. Potential Wildlife Issues/Concerns/Mitigation Potential impacts associated with the Whitman Lake Project include: increased road and trail access which may impact local deer hunting and rearing, and landscape clearing which may result in a direct loss of habitat for some wildlife species. The USFWS area biologist has identified Whitman lake as an area with high usage for the Alexander Archipelago wolf (Canis lupus ligoni) a potential species for federal listing (ADFG, pers. comm. 1997). The project’s transmission line and their impacts on birds is a potential concern. The status of threatened and endangered species is a concern and will be addressed during the study phase of licensing. Protecting high wildlife use areas such as emergent vegetation wetlands, riparian corridors and old growth forests will help maintain good biodiversity and species richness within the Project area. New transmission line construction should be built using state of the art practices to avoid and minimize avian collisions with powerlines as well as providing nesting platforms, territorial boundaries, and hunting perches for raptors (Avian Powerline Interaction Committee, 1992). Proper design of roads, pipelines and other project facilities can also reduce the amount of habitat fragmentation which could occur. Gating new and existing roads coupled with seasonal access restrictions may help prevent over hunting and protect rearing habitats for deer, bear, mountain goat, waterfowl, and other game species. December 1998 Initial Consultation Document Page 12 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues 4.1.6 Botanical Resources Existing Conditions The Whitman Project area includes a variety of conifer forest types ranging from mature and old growth stands to managed stands of younger generation trees. Old growth stands are generally characterized by multiaged trees of various sizes, large dead standing and fallen logs, a range in the degree of canopy closure, and variation in the composition and density of understory. In contrast, managed stands typically have even-age trees, a high density of trees until thinned, and a relatively depauperate understory. The most common native species of conifer trees in the area include Sitka spruce (Picea sitchensis), western hemlock (Tsuga heterophylla), and Alaska-cedar (Chamaecyparis nootkatensis), with western red cedar (Thuja plicata), mountain hemlock (Tsuga mertensiana), subalpine fir (Abies lasiocarpa), Pacific silver fir (Abies amabalis), and shorepine (Pinus contorta var. contorta) occurring in lesser amounts. Deciduous tree species include red alder (Alnus rubra) and black cottonwood (Populus trichocarpa). The dominant forest type in the Project area is western hemlock-Sitka spruce, which extends from sea level to treeline. Common understory shrub species in this forest type include huckleberry and blueberry (Vaccinium spp.), devil’s club (Oplopanix horridus), rusty menziesia (Menziesia ferruginea), salmonberry (Rubus spectabilis), western thimbleberry (Rubus parviflorus), and bunchberry (Cornus canadensis). Common herbaceous species include skunk cabbage (Lysichiton americanum), fern-leaved goldthread (Coptis asplenifolia) and a variety of ferns, mosses, grasses and sedges. Acidic bog areas known as muskeg are also common in the Project area. Muskeg occurs in wet poorly drained areas, is typically dominated by sphagnum moss, and has deep accumulations of organic matter. Common muskeg species include small shrubs such as crowberry (Empetrum nigrum), mountain cranberry (Vaccinium vitis-idaea), bog blueberry (Vaccinium uliginosum), Labrador tea (Ledum groenlandicum), and bog kalmia (Kalmia polifolia). Herbaceous species in muskegs include sundews (Drosera spp.), a variety of orchids (e.g., Habenaria spp.), deercabbage (Fauria crista-galli), buckbean (Menyanthes trifoliata); and numerous types of sedges (Carex spp, Eleocharis spp., Eriophorum spp.). A few stunted shorepine, western hemlock, and Alaska-cedar are also common in muskeg areas. Intermediate plant communities that combine elements of forest and muskeg habitat grow near the forest edge and along the shorelines of Whitman Lake. Wetlands in the area include both acidic muskeg and wetlands with flowing water and emergent vegetation (commonly referred to as fens). Fens generally support greater wildlife diversity and richness than muskeg. However, muskeg is the more common wetland type found near the Project area. Potential Botanical Issues/Concerns/Mitigation Some vegetation will likely be lost due to construction activities associated with building the powerhouse. Revegetation of disturbed areas will occur as soon as construction activities are completed. December 1998 Initial Consultation Document Page 13 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues Threatened, endangered or sensitive plant species could potentially be a concern. Table 4-2 details sensitive plants known plants known to occur or potentially occurring within the vicinity of the Whitman Project area. Table 4-2 Sensitive Plants Known to Occur or Potentially Occurring in the Vicinity of the Whitman Project Area (Source: Alaska Natural Heritage Program, 1997 and USFS, pers. comm. 1997a) Choris bog orchid (Platanthera chorisiana) Circumpolar starwort (Stellaria ruscifolia ssp. Aleutica) Bog orchid (Platanthera gracilis) Calder lovage (Ligusticum calderi) Goose-grass sedge (Carex lenticularis var. dolia) Edible thistle (Cirsium edule) Pale poppy (Papaver alboroseum) Loose-flowered bluegrass (Poa laxiflora) Davy mannagrass (Glyceria leptostachya) Northern bog clubmoss (Lycopodium inundatum) Two-flowered marsh marigold (Caltha biflora) Watershield (Brasenia schreberi) Douglas spiraea (Spiraea douglasii) Poverty oat-grass (Danthonia spicata) Straight-beak buttercup (Ranunculus orthorhynchus var. alaschensis) Water lobelia (Lobelia dortmanna) Western paper birch (Betula papyrifera var commutata) Cassiope lycopodioides Small cranberry (Vaccinium oxycoccos) Prairie lupine (Lupinus lepidus) Northern bugleweed (Lycopus uniflorus) Mexican hedge-nettle (Stachys mexicana) Kamchatka spike-rush (Eleocharis kamtschatica) Water bulrush (Scirpus subterminalis) False solomon’s-seal (Smilacina racemosa) Bog bluegrass (Poa leptocoma) Spleenwort (Asplenium viride) Alaska holly fern (Polystichum setigerum) Boreal bedstraw (Galium kamtschaticum) Lewis monkeyflower (Mimulus lewisii) Saxifraga occidentalis Cascade beardtongue (Penstemon serrulatus) Subalpine fir (Abies lasiocarpa) Wright filmy fern (Hymenophyllum wrightii) Pacific yew (Taxus brevifolia) Black hawthorn (Crateagus douglasii var douglasii) Queen Charlotte butterweed (Senecio moresbiensis) Unalaska mist-maid (Romanzoffia unalaschcensis) December 1998 Page 14 Initial Consultation Document Whitman Lake Hydroelectric Project Environmental and Regulatory Issues The majority of sensitive plant species listed above are found in wet, moist habitats such as muskeg and other wetlands, riparian areas, and shorelines. Since these areas typically also have high wildlife value, an emphasis is placed on avoiding them when planning project facilities. However, in cases where the project development can not avoid a sensitive area, steps will be taken to minimize impacts to that area and on-site or near-site mitigation will be provided. 4.1.7 Aesthetic Resources Existing Conditions The Project area consists of western hemlock-sitka forests that extend from the tidewater to the treeline. The forests extend to the edge of Whitman Lake. Whitman Creek is relatively steep with numerous cataracts, waterfalls and rapids. The creek is surrounded by dense forest. The existing dam structure and pipeline to the hatchery are visible from the air and by those who hike up to the lake. The lower portion of the pipeline can be seen extending down the hill to the hatchery. The tunnel portion of the lake tap alternative will not be visible. The penstock will be above ground and will require clearing in currently undisturbed areas. The powerhouse site will also require clearing. The USFS has assigned the Visual Quality Objective of Retention to the Project area. Under the Retention designation, design activities should not be visually evident to the casual observer. Exceptions for small areas of non-conforming developments may be made on a case by case basis. Developments must use designs and materials that are compatible with forms, colors, and textures found in the characteristic landscape (USFS, 1997b). Potential Aesthetic Issues/Concerns/Mitigation Clearing for the pipeline route and roads will produce visual impacts. With both alternatives changes in the lake elevations will have visual impacts. Reductions in flows into Whitman Creek would also have visual impacts. These impacts are expected to be minor since they would only be viewed from the air and from those who hike to the lake. The lower portion of the pipeline route and the powerhouse for both alternatives would be visible from the hatchery. Revegetation following any clearing activities would be required to reduce any visual impacts resulting from construction of the Project. 4.1.8 Cultural Resources Existing Conditions Little is recorded regarding the prehistoric period for southeast Alaska, although it is known that the Tlingit Indians for years had fish camps near the present City of Ketchikan and that they had a village at Ketchikan Creek. White settlements formed around canneries and mines in early December 1998 Initial Consultation Document Page 15 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues Alaska. Ketchikan was founded near the salmon saltery at the mouth of Ketchikan Creek and canneries gradually relocated to Ketchikan because of its convenience for shipping. In 1978 an archaeological survey was conducted in the Herring Bay area and along the water conduit corridor leading to the dam at Whitman Lake. Ethnohistoric sources indicated that the Saxman and Tongass Tlingit had utilized the resources of George Inlet which also included Herring Bay. A petroglyph was found at the entrance to Herring Bay and a local informant also reported that there had been a Tlingit fish camp at the entrance to the bay. The first recorded Euroamerican use of the area was by the New England fish company’s hydroelectric operation which began in 1908 and was associated with the construction of a wooden crib dam and wood stave pipeline that led from the dam to the powerhouse. In 1921 much of the conduit was replaced and in 1927 the wooden crib dam was replaced by a concrete dam which is still in place. Few traces of the houses associated with the powerhouse were visible at the time of the 1978 survey. The Herring Bay fish hatchery constructed by the Southern Southeast Aquaculture Association has been the latest constructional feature in the area. The State Historic Preservation Officer (SHPO) was contacted in 1997 regarding reported historic and prehistoric sites within the Project area. A review of the Alaska Heritage Resources Survey (AHRS) database and maps by the SHPO revealed one reported petroglyph site near the intertidal area at Herring Bay. It not expected that that construction and operation of the proposed Project would impact this site. Additional sites that may have cultural significance in the Project area that are not included on the AHRS database include an old cribbing dam that is submerged in Whitman Lake and remnants of the old wood stave pipeline. Potential Cultural Issues/Concerns/Mitigation No cultural resources issues are anticipated unless additional eligible cultural resources sites are identified during field surveys. If cultural resources are identified during surveys, compliance under Section 106 of the National Historic Preservation Act would be required. The site’s eligibility under the National Register and the effects of activities on the property would need to be determined. If the property is found eligible, avoidance or mitigation measures would need to be developed in consultation with the State of Alaska Department of Natural Resources Office of History and Archaeology. If during construction, it is determined that the Project will have an effect on a previously unidentified but eligible property, work will be suspended and the responsibilities under Section 106 of the National Historic Preservation Act would need to be followed. December 1998 Initial Consultation Document Page 16 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues 4.1.9 Recreation and Other Land Uses Existing Conditions Activities such as hiking, fishing, boating, hunting, camping, and picnicking are popular among residents and tourists of Ketchikan. The USFS Tongass National Forest, which surrounds Ketchikan, has constructed many hiking trails and cabins for public use in southeast Alaska. No developed recreation facilities are located near the proposed Whitman Lake Project area. Mainly local residents hike an unimproved trail to Whitman Lake to fish, hunt and sightsee. The hike is approximately one-half mile long and the use is low. Alaska Department of Fish and Game (ADFG) Sports Fishing Division and others have discussed improving the recreation access to Whitman Lake. The USFS Recreation Opportunity Spectrum (ROS) designation is Semi-Primitive Non- Motorized (SPNM) around Whitman Lake, and Rural at the lower end of Whitman Lake and in the areas where the pipeline alternatives would be located. Under the SPNM designation, alterations are few and subordinate to the landscape, trails and lakes are closed to motorized use, and human use is noticeable but not degrading to the resources elements. Under the Rural designation, alterations to landform and vegetation dominate the landscape, all methods of access and travel may occur, and there is moderate to high concentrations of people. (USFS, 1997b) Other land uses in the Whitman Lake Project area include fish rearing. A hatchery occupies the intertidal area off of Powerhouse Road. The hatchery leases Mental Health Trust lands from the Alaska Department of Natural Resources (ADNR). The proposed powerhouse sites and the lower portion of the pipeline would be located on these lands. The upper portion of the proposed pipeline route would be on lands owned by the State of Alaska. Whitman Lake is within the boundaries of the USFS. The USFS has designated lands around Whitman Lake as Old-Growth Habitat. The primary goal of the Old-Growth Habitat land use designation is to “maintain old-growth forests in a natural or near-natural condition for wildlife and fish habitat”(USFS, 1997b). To the extent feasible, roads, facilities and permitted uses are to be limited to those compatible with Old-Growth Habitat management objectives. New road construction is generally inconsistent with Old-Growth Habitat land use designation objectives, but new roads may be constructed if no feasible alternative is available. The proposed project facilities are located on Future Development Zone lands as designated by Ketchikan Gateway Borough. Under this designation, hydroelectric generation is considered a permitted uses. The Whitman Lake area has been designated as an environmentally sensitive area in the Ketchikan District Coastal Management Program (Ketchikan Gateway Borough, 1983). According to the Environmentally Sensitive Areas Map, the Whitman Lake environmentally December 1998 Initial Consultation Document Page 17 Whitman Lake Hydroelectric Project Environmental and Regulatory Issues sensitive area is located near the outlet of Whitman Creek, along George Inlet. The Whitman Lake area is considered an environmentally sensitive area because the shoreline serves as critical winter range for deer, heavy sportfishing occurs along the shore, and potential avalanche or landslide area exists. Development is not precluded in environmentally sensitive areas. However, special consideration must be given to the identified concerns. No National Wild and Scenic Rivers Systems, National Trails Systems or Wilderness Areas are located within the Whitman Lake Project area. Potential Recreation and Land Use Issues/Concerns/Mitigation Construction activities at the dam and for the pipeline and powerhouse may temporarily disrupt hatchery operations and trail users for short periods of time. 4.2 Regulatory Issues In addition to the FERC License, other environmental and regulatory permits that may be required for the Project are described below. e AUS. Forest Service Special Use/Study Permit will be obtained prior to conducting studies on USFS lands and for construction on USFS lands. e An Alaska Division of Governmental Coordination (ADGC) questionnaire and Coastal Zone Management Act (CZMA) consistency will be submitted along with other permitting requirements including a request for Section 401 Water Quality Certification and a water rights application. These items will be submitted during the early stages of the licensing process. e Ifthe Project requires dredging or filling within tidewaters, a U.S. Army Corps of Engineers Sections 404 Permit will be required e Local building permits may be required prior to construction. December 1998 Initial Consultation Document Page 18 Whitman Lake Hydroelectric Project Streamflow and Water Regime 5.0 STREAMFLOW AND WATER REGIME 5.1 INTRODUCTION In order to estimate average annual energy from the proposed hydroelectric project, long-term streamflow records are required. Unfortunately, there does not exist any published streamflow records above the mouth of Whitman Creek. Therefore, synthesized monthly streamflow records were developed for the area above Whitman Dam based on correlation of recorded streamflow from an adjacent basin. 5.2. METHODOLOGY Inflow to Whitman Lake was synthesized based on correlation of actual USGS published monthly records on Beaver Falls Creek during the period October 1920 through December 1925, and October 1927 through September 1932. Based on precipitation records at Ketchikan, this period was within | percent of the long term average annual precipitation. Therefore, the selected period of record can be considered representative of a long-term average. The Beaver Falls Creek gage was located about 4 miles north of Whitman Dam and measured streamflow from a 5.8 square mile drainage area. Annual streamflow averages 18.8 cfs per square mile. Beaver Falls Creek is the next major drainage north of Whitman Creek, and is the most appropriate gage for synthesizing Whitman Creek records because of the close proximity of the two basins, and the terrain, average basin elevation, basin size, percentage of lake surface, and geographic orientation are all very similar. In order to develop a continuous 12 year record of monthly flows, synthetic monthly streamflows for the Beaver Falls Creek gage were developed for the period January 1926 to September 1927. Monthly flows for the period January 1926 through August 1926 were developed based on regression analysis of monthly precipitation at Ketchikan and 10 years of monthly streamflow records at the Beaver Falls Creek gage. Correlating precipitation and streamflow can sometimes render poor results, particularly where measurement of snowfall and snowmelt skew the figures. But there are no other historical streamflow or precipitation records in the immediate Ketchikan area during the period in question. Fortunately, based on regression analysis of each month, the correlation coefficients varied within an acceptable range of 0.64 to 0.92 for every month. The resulting regression equations were therefore used to predict monthly streamflow at the Beaver Falls Creek gage for the period January 1926 through August 1926 based on the monthly precipitation at Ketchikan. A separate regression analysis was performed for the months of September 1926 through September 1927. For this period, monthly streamflow records on Mahoney Creek were available. The Mahoney Creek basin is the next major basin north of the Beaver Falls Creek basin, and is also similar in character to the Whitman Creek basin. The Mahoney Creek gage December 1998 Initial Consultation Document Page 19 Whitman Lake Hydroelectric Project Streamflow and Water Regime measured streamflow from a 5.7 square mile drainage area. Annual streamflow averages 18.3 cfs per square mile. Based on regression analysis, the correlation coefficients for each month, except June, were all above 0.90 indicating a strong correlation exists. The June coefficient was still an acceptable 0.68. The resulting regression equations were then applied to develop monthly streamflows at the Beaver Falls Creek gage for the missing period of record. 5.3. INFLOW TO WHITMAN LAKE The similarities of the Whitman Creek and Beaver Falls Creek basins are very strong. For example, the weighted average elevation of each basin is the same, 1,600 feet, and the terrain and geographic orientation with respect to mountain ridges are also nearly identical. For these reasons the average monthly streamflow in the Whitman Creek basin was estimated based on the ratio of the drainage areas, or 0.71 times the monthly streamflow at the Beaver Falls Creek gage. Table 5-1 presents estimated inflow to Whitman Lake for the period October 1920 to September 1932. These flows were used in the energy generation analysis and adjusted to account for the estimated distribution of daily peak flows in a given month. December 1998 Initial Consultation Document Page 20 Whitman Lake Hydroelectric Project Table 5-1 SYNTHESIZED MONTHLY NATURAL INFLOW TO WHITMAN LAKE AVERAGE INFLOW IN CUBIC FEET PER SECOND Calendar| WY Year J F M A M J J A Ss oO N D Total Total 1920 104 54 35 1921 23 94 29 33) 90) 151 84 70: 108 176 90 138 90.5 72.8 1922 18 10 15 51 110 139 65 46 124 132 155 40 75.4 81.8 1923 12 52 55 101 129 100 42 52 87 73 175 86 80.3 79.8} 1924 52 84 39 46 155 92 89 41 144 131 123 51 87.2 89.7 1925 21 11 32 50 116 102 102 53 22 65 132 176 73.4) 67.7 1926 78 49 67 49 129 97 80 45 19 117 64 73 72.2, 82.1 1927 39 21 41 46 92 104 80 62 93 119 23 36 63.1 69.3 1928 119 45 92 48 119 80 65 46 41 109 84 78 77.2 69.6) 1929 85 10 39 33 69 89 77 117 11 127 151 38 70.5; 66.8 1930 8 53 35 58 84 131 55 18 75 158 167 181 85.0 69.1 1931 105 69 46 77 116 75 67 65 73 121 75 39 77.2, 99.8} 1932 64 65 39 64 110 119 98 47 121 80.1 Mo. Avg. | 51.9 46.8 44.1 54.7, 109.9 106.5) 75.2) 55.0 76.4) 119.3) 107.8 81.0) 77.5 77.4 cfs /sm 12.7 11.4) 10.8 13.3 26.8 26.0) 18.3 13.4 18.6 29.1 26.3) 19.8| 18.9 18.9 PURPA Benefits 6.0 PURPA BENEFITS PURPA benefits will not be sought for the Whitman Lake Project. December 1998 Initial Consultation Document Page 21 Whitman Lake Hydroelectric Project Licensing Study Plans 7.0 LICENSING STUDY PLANS 7.1 WATER QUALITY AND QUANTITY Purpose The purpose of the water quality and quantity studies is to refine information developed during the feasibility study of the project and to develop final operating criteria for the project. A new gauging station will be constructed and maintained and the data developed will be used to determine if the flow relationships described earlier are still valid. The water quality study will evaluate the impact that reservoir elevation will have on downstream flow releases. Agencies to be Consulted State and federal agencies and non-governmental agencies that will be contacted as part of the water quality and quantity investigations will include, but not limited to, the following: Alaska Department of Natural Resources (ADNR) U.S. Geological Survey (USGS) Methodology A stream gauging station will be developed on Whitman Creek, calibrated and a rating curve developed, and the station maintained for the life of the FERC license. Data developed for the site during the life of the license application phase of the project will be evaluated to determine if the data developed previously was still valid. If newly collected data or data developed by the stream gauging station indicates that flow estimates should be revised, then the flow data developed previously will be re-worked and a new set of data developed. The new data will be presented to the consulted agencies before proceeding to the revised energy studies. The operations studies from earlier studies will be revised utilizing any new flow data that becomes available and agreed-upon minimum flow from the fishery studies. The purpose of the revised studies is to determine if a revision and modification of the operations studies will result in increases in energy and an optimization of the minimum instream flows to better meet fishery needs. An optimum operating procedure for the project will be developed. The revised studies will also reflect other operating criteria which may develop out of other ongoing studies of the project. The results of the operations studies will be reviewed and used to predict water temperatures for the water that is released from Whitman Lake. The results of the temperature analysis will be analyzed to determine if resultant temperatures will be detrimental to hatchery operations and if changes in operations are needed. December 1998 Initial Consultation Document Page 22 Whitman Lake Hydroelectric Project Licensing Study Plans 7.2. FISHERIES Purpose The purpose of the fisheries studies is to describe the fishery resources existing within and reliant upon the streams and lakes within the Whitman Hydroelectric Project area, and to evaluate potential impacts resulting from project construction and operation. For this, fisheries literature/data and information pertaining to the Whitman Creek watershed shall be identified, compiled and reviewed. In addition, pedestrian habitat and fisheries surveys shall be completed of Whitman Creek (and adjoining tributaries) to collect qualitative physical habitat and biological information needed to address project impacts. Qualitative site surveys shall also be completed of Whitman Lake. Agencies to be Consulted State and federal agencies and non-governmental organizations that will be consulted as part of the fishery investigations will include but not be limited to the following: Alaska Department of Fish and Game (ADF&G) Alaska Department of Natural Resources (ADNR) Alaska Department of Environmental Conservation (ADEC) U.S. Fish and Wildlife Service (USFWS) National Marine Fisheries Service (NMFS) U.S. Forest Service (USFS) U.S. Geological Survey (USGS) Southern Southeast Regional Aquaculture Association (SSRAA) Methodology Literature Review Sources and types of information that will be collected and reviewed shall likely include but not be limited to: - ADF&G: stocking records, fish population data, management plans; State listed T& E species - ADNR: water quantity information and flow records - ADEC: water quality information, NPDES permits - USFWS: general fisheries data; ESA listed species December 1998 Initial Consultation Document Page 23 Whitman Lake Hydroelectric Project Licensing Study Plans - NMFS:: anadromous fisheries data; escapement estimates; ESA listed species - USFS: habitat information, species presence/absence data - SSRAA: hatchery production and stocking records for Whitman Creek - KPU: technical reports prepared by consultants, anecdotal information - University of Alaska: thesis, technical reports - USGS: streamflow statistics, regional hydrology data Supplemental information shall be provided via personal contacts made with local and regional biologists within the ADF&G (e.g. Steve Hoffman, Jack Gustafson, Ricardo Sainz) to discuss individual species distributions and management goals for the Ward Creek watersheds. Qualitative Habitat and Fish Surveys The qualitative habitat and fish surveys shall be conducted in a downstream direction; from Whitman Lake to Whitman Creek outlet. The surveys shall be completed by a two — person field crew experienced in habitat assessments and fisheries surveys. The surveys shall be completed following protocols specified by the USFS using a modified Hankin — Reeves approach, and shall include the mapping of habitats (classified as to riffle, pool, run, cascade, glide, ripple) throughout the stream length, as well as fish species composition. Fish species composition shall be determined via electrofishing using a Smith - Root POW backpack shocker. Fish sampling (to determine species composition and relative abundance) shall be conducted at selected intervals throughout the length of the each stream. All salmonids captured during the surveys shall identified, measured (length and weight) and released unharmed within the general vicinity of capture. Scale samples shall be collected from a representative number of salmonids (> 200 mm in length) to enable age: growth analysis, should it be deemed necessary at some later time. Non-salmonid fishes shall be identified, enumerated and released. In addition, qualitative fish sampling shall be completed within the first 50 ft (depending on access) of each of the tributaries entering Whitman Creek. Impacts Assessment Based on the information and data obtained and reviewed, and the results of the habitat and fishery surveys, an assessment of the effects of the proposed project construction and operations on the existing fishery resources shall be made. This shall include potential habitat loss, habitat alteration/degradation (e.g. water quality changes — temperature), effects on resident fish and aquatic biota, and modifications in streamflow and lake level regime. The assessment shall also focus on the effects of lake level fluctuations on littoral margin habitats and productivity. The impacts on fish shall focus on determining to what extent project operations will directly or indirectly impact existing fish populations within the watershed. Examples of direct impacts December 1998 Initial Consultation Document Page 24 Whitman Lake Hydroelectric Project Licensing Study Plans include habitat loss (due to passage barriers, loss of stream length, fluctuations in lake levels), false attraction to powerhouse outfalls resulting in delay of adult migrations, and mortality occurring during construction. Indirect impacts include loss of food production within a given reach which could influence fish population abundance, reduction in spawning gravel recruitment below the dam, changes in water quality (e.g. temperature alterations) that could alter the timing of certain life history components (e.g. spawning, egg incubation and fry emergence), and changes in flow availability and quantity. Identification of Mitigation Measures For each of the impacts identified, mitigation measures shall be described and discussed that serve to reduce or eliminate project impacts. Such measures may include the provision of instream flows within the diverted reach of Whitman Creek, development and funding of a lake stocking program (if deemed desirable by the ADF&G), development of lake level and flow operation rule curves that are compatible with salmonid life history requirements and periodicities, and other measures as “agreed-to” during agency consultations. Emphasis shall be placed on identifying those measures which substantially reduce or eliminate project impacts, and which in some cases may actually provide an enhancement of existing conditions. 7.3 WILDLIFE Purpose The purpose of the wildlife study is to describe and quantify habitats and confirm presence or absence wildlife species. The potential impact of the Project on wildlife resources will be evaluated and measures to avoid, minimize, or mitigate impacts will be developed. Agencies to be Consulted USFWS USFS ADFG NMFS Methodology Studies will include agency consultation, literature reviews, field studies, interpretation of field data, analysis of aerial photographs, and documentation. Tasks All existing data on wildlife species and habitat in or near the Project area will be reviewed. This will include lists, survey data, aerial photographs, and reports from with USFWS, USFS, ADFG and NMFS. December 1998 Initial Consultation Document Page 25 Whitman Lake Hydroelectric Project Licensing Study Plans Field Surveys A field survey will be conducted to confirm existing project data. Areas to be surveyed will include the dam, penstock route, power house location, and access road/transmission route. The field survey will confirm presence/absence of common wildlife species, as well as species of concern (i.e., threatened and endangered species). The field survey will consist of: a) qualitative survey of wildlife habitats; b) general inventory of wildlife species will be conducted for mammals and birds. Ancillary observations will include identification of calls, tracks, scat, and raptor pellet analysis. Surveys of the Project area will be conducted while walking to and from fixed points. If individuals of an animal species of concern are located, the pertinent officials will be informed The appropriate extent of the analysis area for other potential animal species will be determined in consultation with the agencies. 7.4 VEGETATION Purpose The purpose of the vegetation studies is to characterize the plant communities in and around the Project area and to identify any populations of threatened, endangered, or sensitive (TES) plant species that will be potentially impacted by the Project. Any potential impacts to botanical resources will be evaluated and measures to avoid, minimize, or mitigate impacts will be developed. Agencies to be Consulted USFS USFWS ANHP Methodology Plant Community Classification and Identification Characterization of botanical resources shall include a classification and description of plant communities in and around existing and proposed facilities (lakeshores, dams, penstocks, powerhouses, and access roads). The vegetation in the area around the existing and proposed facilities will be described in terms of dominant tree species, component understory shrubs, and understory herbaceous species. Successional stage and evidence of past disturbance will also be characterized. A list of species observed in the Project area will be developed and included in the Environmental Assessment. The regional and local importance of plant communities occurring in the Project area will be discussed to provide a basis for assessing impacts to plant communities as a result of the proposed Project. Coordination of wildlife studies with plant December 1998 Initial Consultation Document Page 26 Whitman Lake Hydroelectric Project Licensing Study Plans community classification and identification will ensure consistency between the two resource studies and how they are addressed in the Environmental Assessment. Threatened, Endangered, and Sensitive Species Surveys A survey for threatened, endangered, and sensitive (TES) plant species occurring in areas to be impacted by the Whitman Project will be conducted. An up-to-date list of TES will be determined from information requests to the Alaska Natural Heritage Program (ANHP) and U.S. Forest Service (USFS). Surveys will consist of two individuals walking the pipeline corridors and examining areas to be affected by ground disturbance, shoreline effects, or indirect impacts from changes in hydrology. Consultation with USFS and ANHP botanists will be conducted to ensure that local knowledge and all available information is being incorporated into the study. Any individuals or populations of TES plant species found will be thoroughly documented with photographs, maps, and notes. An ANHP form will be completed for each population/individual found and submitted to the ANHP. Results The project alternatives will be evaluated for potential impacts to both plant communities and TES plant species. Loss or conversion of native plant communities will be assessed in terms of their relative sensitivity and rarity in the region, as well as their importance to hydrology and wildlife habitat. Special attention will be given to wetland plant communities. Areal extent of disturbance to each community type will be estimated and the nature and degree of disturbance described. Any individuals/populations of TES plant species that are potentially impacted by the Whitman Project will be identified. Where high value plant communities or TES plant species occur in areas to be impacted, possible mitigation measures will be developed. Avoidance of impacts will be the highest priority, and the project botanist will work with the project engineers to determine possible design or route changes to avoid impacts to important botanical resources. The botanist will also help develop revegetation/reclamation plans to identify ways to mitigate for loss of botanical resources. Use of native species, establishment or relocation of TES species, and design of revegetated natural communities are possible mitigation measures that can be incorporated into revegetation/reclamation plans. 7.5 AESTHETICS Purpose The primary purpose of the aesthetics study is to evaluate aesthetic impacts from the proposed Project and describe measures proposed by the Applicant to reduce impacts. December 1998 Initial Consultation Document Page 27 Whitman Lake Hydroelectric Project Licensing Study Plans Agencies to be Consulted e USFS e City and Borough of Ketchikan e ADNR Methodology The aesthetic study will evaluate existing visual conditions, assess project effects, and identify potential mitigation measures. Existing Visual Conditions A summary of existing visual conditions that addresses both project facilities and the adjacent landscape will be addressed. Existing visual resource data related to the Project area, including the USFS Visual Management System, will be reviewed. Landscape character of the Project area will also be described. Approximate seen areas from selected viewpoints at and near the Project will be identified. Project Effects Assessment The effects of the proposed project facilities on visual quality will be determined. The visibility of project features and changes in instream flows from selected viewpoints will be evaluated. Proposed Aesthetic Measures Potential measures that will reduce the visual contrast of project features with the surrounding environment will be identified and their feasibility will be reviewed. 7.6 CULTURAL RESOURCES Purpose The purpose is to develop information on the nature and distribution of cultural resources within the Project area that have not been previously surveyed. This information, together with professional opinions and consultations with affected native groups, and agencies will be presented in a written cultural resources report. Agencies to be Consulted Native Corporations U.S. Forest Service SHPO December 1998 Initial Consultation Document Page 28 Whitman Lake Hydroelectric Project Licensing Study Plans Methodology Historical/Archeological studies will be conducted to comply with FERC’s regulations and requirements of the NEPA EA. A literature search and surficial investigation of the existing and proposed structures will be performed to determine if there are any cultural remains that might be impacted. This will include a pedestrian survey of the Project area. Subsurface testing will be conducted in areas judged to have archeological potential. The search will be for indications of prehistoric as well as proto-historic materials. 7.7 | RECREATION AND LAND USE Purpose The purpose of the recreational resources study is to identify information regarding existing recreation use, future demand and opportunities, and the potential impacts on recreation resulting from development of the Project. The purpose of studying other land uses is to provide updated information on existing land use and ownership in the Project area and evaluate the project’s consistency with relevant comprehensive and land management plans. Agencies to be Consulted Agencies who are responsible for recreation and land use planning and management within the Project area will be consulted. Methodology Evaluation of Existing Recreation and Land Uses Existing information will be collected including maps, recreation guides, USFS plans and policies, assessors information and local and regional planning documents. From data collected, existing recreation facilities in the Project area will be described and mapped. Land use and ownership in the Project area will described and ownership information will also be mapped. Evaluate Recreation Demand Existing recreation facilities in terms of activity type, physical setting, experience required, economic costs, and current demand will be evaluated. Future recreation use within the Project area will be identified and evaluated. Anticipated recreation demand with and without the proposed Project will be estimated using demographic data, the Alaska State Comprehensive Outdoor Recreation Plan, USFS and other local and regional planning documents. December 1998 Initial Consultation Document Page 29 Whitman Lake Hydroelectric Project Licensing Study Plans Consistency with Comprehensive and Land Management Plans Project facilities will be examined for consistency with existing federal, state, and local comprehensive and land management plans. Evaluate Project Impacts of Existing and Future Recreation and Other Land Uses Potential environmental, social and economic impacts created by the Project regarding existing and future recreation and other land uses in the Project area will be identified. If appropriate, mitigation measures will be recommended if it is determined that the Project will produce adverse effects on existing and proposed future recreation and other land uses. December 1998 Initial Consultation Document Page 30 Whitman Lake Hydroelectric Project References 8.0 REFERENCES Alaska Department of Fish and Game. 1997. Personal Communication with S. Brockman and J. Gustafson. November 18, 1997. Alaska Department of Natural Resources. 1997. Letter from J. Bittner. October 7, 1997. Alaska Department of Natural Resources. 1993. Alaska’s Outdoor Legacy. Statewide Comprehensive Outdoor Recreation Plan. Alaska Natural Heritage Program. 1997. Letter from J. Lenz. October 3, 1997. Avian Powerline Interaction Committee. 1992. State of the Art Powerline Designs. Dames and Moore. 1990. Ketchikan Pulp Company Environmental Analysis of Supplemental Water Supply. Prepared for the Forest Service. August 9, 1990. Denton, C. 1997. Alaska Department of Fish and Game. Personal communication October 17, 1997 and meeting minutes from October 8, 1997. Freeman, G.M. 1995. An evaluation of steelhead enhancement in the Ward Creek drainage, Ketchikan, Alaska, 1991-1994. Alaska Department of Fish and Game Division of Sport Fish. Fishery Manuscript NO. 95-2. December 1995. Hubbart, D.J. 1990. Evaluation of lake characteristics and fish population size and status for three lakes in the vicinity of Ketchikan, Alaska during 1989. Alaska Department of Fish and Game Division of Sport Fish. Fishery Data Series No. 90-39. September 1990. Hubbart, D. J., and A. E. Bingham. 1989. Evaluation of population size, status of fish populations, and the lake characteristics for three lakes in the vicinity of Ketchikan, Alaska during 1988. Alaska Department of Fish and Game Division of Sport Fish. Fishery Data Series No. 110. September 1989. Ketchikan Gateway Borough Planning Department. 1993. Ketchikan District Coastal Management Program. Ketchikan Gateway Borough. 1994. Parks and Recreation Plan. Ketchikan Trails Coalition. 1995. Ketchikan Trails Plan. A cooperative effort to improve Ketchikan’s Trail System. Southern Southeast Regional Aquaculture Association. 1997. Personal Communication with J. Creasy. November 21, 1997. December 1998 Initial Consultation Document Page 31 Whitman Lake Hydroelectric Project References Swift, C.H. 1976. Estimation of stream discharges preferred by steelhead trout for spawning and rearing in Western Washington. Open File Report 75-155. United States Department of the Interior Geological Survey. Tacoma, WA. Swift, CH. 1979. Preferred stream discharges for salmon spawning and rearing in Washington. Open File Report 77-422. United States Department of the Interior Geological Survey. Tacoma, WA. U.S. Fish and Wildlife Service. 1997. Letter from J. Lindell. September 18, 1997. U.S. Forest Service, Ketchikan Ranger District. 1997a. Personal Communication with K. Burnds. November 18, 1997. U.S. Forest Service, Tongass National Forest. 1997b. Land and Resources Management Plan and Final Environmental Impact Statement. U.S. Forest Service, Tongass National Forest. 1997c. Personal Communication with T. Trulock. October 8, 1997. WESCORP, 1998, Whitman Lake Hydroelectric Feasibility Study, Ketchikan Public Utilities, August 1998 Final Report. December 1998 Initial Consultation Document Page 32 Whitman Lake Hydroelectric Project Consultation Document Mailing List 9.0 CONSULTATION DOCUMENT MAILING LIST Federal Agencies: Mr. David P. Boergers Acting Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Mr. Vincent Yearick Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426 Mr. Mike Henry Federal Energy Regulatory Commission 101 SW Main Street, Suite 905 Portland, OR 97204 Mr. Paul D. Gates U.S. Dept. of the Interior Office of Environmental Policy & Compliance Regional Environmental officer 1689 C. Street, Room 119 Anchorage, AK 99501-5126 Mr. John Lindell, Regional Endangered Species Coordinator U.S. Fish and Wildlife Service Southeast Alaska Ecological Services 3000 Vintage Blvd. Suite 201 Juneau, AK 99801-7100 Steve Brockmann U.S. Fish & Wildlife Service 624 Mill St. Ketchikan, Alaska 99901 Mr. Andy Grossman, Fisheries Biologist U.S. Department of Commerce National Marine Fisheries Service Resources Management Division P.O. 21668 Juneau, AK 99802-1668 Mr. Pete Griffin, Acting District Ranger Ms. Theresa Trulock, Recreation Contact U.S. Forest Service Ketchikan Ranger District Tongass National Forest 3031 Tongass Avenue Ketchikan, AK 99901 Mr. Brad Powell, Forest Supervisor Mr. Tom Somrak, Lands Forester U.S. Forest Service Tongass National Forest Federal Building Ketchikan, AK 99901 Mr. Stan Burst U.S. Army Corps of Engineers Civil Works - Public Facilities C-ENPA-EN-CW-PF P.O. Box 898 Anchorage, AK 99506-0898 Ms. Victoria Taylor U.S. Army Corps of Engineers Permit Processing Section Regulatory Branch C-ENPA-CO-R P.O. Box 898 Anchorage, AK 99506-0898 December 1998 Page 33 Initial Consultation Document Whitman Lake Hydroelectric Project Mr. Ralph Thompson U.S. Army Corps of Engineers Juneau COE Office Suite 106B, Jordan Ck Center 8800 Glacier Highway Juneau, AK 99801 Mr. Bruce Bigelow U.S. Geological Survey P.O. Box 21568 Juneau, AK 99802 Mr. Mark Jen U.S. Environmental Protection Agency Environmental Scientist EPA - Alaska Operations Office 222 W. Seventh Ave #19 Anchorage, AK 99513 Mr. John Bregar U.S. Environmental Protection Agency MS-ECO-088 1200 6" Avenue Seattle, WA 98101 Mr. Robert L. Lloyd Assistant District Manager, Lands U.S. Bureau of Land Management Anchorage District Office 6881 Abbott Loop Road Anchorage, AK 99507 Mr. Larry Wright U.S. National Park Service Alaska Regional Office 2525 Gambell Street Anchorage, AK 99503-2892 Consultation Document Mailing List State Agencies and Native Groups: Ms. Lorraine Marshall Project Review Coordinator Alaska Division of Governmental Coordination Office of Management and Budget P.O. Box 110030 Juneau, AK 99811-0030 Mr. Jack Gustafson, Habitat Division Ms. Carol Denton, Commercial Fisheries Mr. Steve Hoffman, Sport Fish Division Alaska Department of Fish and Game 2030 Sea Level Drive, #205 Ketchikan, AK 99901 Mr. Clayton Hawkes Alaska Department of Fish and Game Habitat And Restoration Division P.O. Box 240020 Douglas, AK 99824-0020 Mr. Kevin Brownlee Alaska Department of Fish and Game Division of Sport Fish/RTS Region 1 P.O.Box 240020 Douglas, AK 99824-0020 Mr. Christopher Estes Statewide Instream Flow Coordinator Sport Fish Division Alaska Department of Fish and Game 333 Raspberry Road Anchorage, AK 99518-1599 Mr. John Dunker, Water Resources Division of Mining and Water Management Department of Natural Resources Southeast Regional Office Water Resources Section 400 West Willoughby Avenue Juneau, AK 99801-1795 December 1998 Initial Consultation Document Page 34 Whitman Lake Hydroelectric Project Mr. Chris Landis, Natural Resource Manager, Ms. Elizaveta Shadura, Regional ACMP Coordinator Department of Natural Resources Southeast Regional Office Division of Lands 400 West Willoughby Avenue Juneau, AK 99801-1795 Mr. Bill Garry, Superintendent Department of Natural Resources Southeast Regional Office Division of Parks and Outdoor Recreation 400 West Willoughby Avenue Juneau, AK 99801-1795 Ms. Mary Kowalczyk Ranger Department of Natural Resources Alaska State Parks 9983 North Tongass Highway Ketchikan, AK 99901 Mr. Gary Prokosch Chief of Water Resources Department of Natural Resources Division of Mining and Water Management 3601 C. Street #800 Anchorage, AK 99503-5935 Mr. Steve Planchon Executive Director Trust Land Office Department of Natural Resources 3601 C. Street #1122 Anchorage, AK 99503-5935 Mr. Dave Sturdevant Alaska Department of Environmental Conservation 410 Willoughby Avenue, Suite 105 Juneau, AK 99801 Consultation Document Mailing List Ms. Judith E. Bittner State Historic Preservation Officer Office of History and Archaeology 3601 C Street, Suite 1278 Anchorage, AK 98503-8921 Mr. Dick Emerman State of Alaska Dept. of Community and Regional Affairs Division of Energy 333 W. Fourth Avenue Suite 220 Anchorage, AK 99501-2341 Mr. Stanley Sieczkowski, Operations Mgr. Alaska Energy Authority 480 West Tudor Rd. Anchorage, AK 99503 Mr. Dennis McCrohan Maintenance and Operations Alaska Industrial Development and Export Authority 480 West Tudor Rd. Anchorage, AK 99503 Mr. Andy Hughes Department of Transportation 6860 Glacier Avenue Juneau, AK 99801-7999 Mr. Percy Frisby, Division Director Alaska Department of Community and Regional Affairs Division of Energy 333 West 4" Avenue Anchorage, AK 99501-2341 Mr. Paul Morrison Alaska Public Utilities Commission Chief Utility Engineer 1016 West Sixth #400 Anchorage, AK 99501-1963 December 1998 Initial Consultation Document Page 35 Whitman Lake Hydroelectric Project Ms. Corrine Garza, General Manager Ketchikan Indian Corporation 429 Deermount Ketchikan, AK 99901 Mr. Charles W. White Ketchikan Indian Corporation 429 Deermount Ketchikan, AK 99901 Mr. Rick Harris Sealaska Corporation One Sealaska Plaza #400 Juneau, AK 99801 Ms. Beatrice Watson Chairman, Tongass Tribe Tongass Tribe P.O. Box 23116 Ketchikan, AK 99901 General Manager Cape Fox Corporation P.O. Box 8558 Ketchikan, AK 99901 Local Governments: Mr. Bob Weinstein, Mayor Mr. Jim Wingren, Council Member Mr. Tom Coyne, Council Member Mr. Tom Friesen, Council Member Ms. Judy Jenkinson, Council Member Mr. Robert Norton, Council Member Mr. Lew Williams III, Council Member Ms. Kay Suiter, City Clerk City of Ketchikan 334 Front Street Ketchikan, AK 99901 Ms. Joy Butler Council Member City of Ketchikan P.O. Box 6013 Ketchikan, AK 99901 December 1998 Consultation Document Mailing List Ms. Theresa Garland Executive Director Ketchikan Chamber of Commerce P.O. Box 5957 Ketchikan, AK 99901 Mr. Tom Fitzgerald Ketchikan City Administrator Route 2, Box 1 - Saxman Ketchikan, AK 99901 Ms. Georgiana Zimmerle, Borough Manager Mr. Jack Shay, Borough Mayor Mr. John Hill, Coastal Coordinator Ms. Susan Dickinson, Planning Director Ketchikan Gateway Borough 344 Front Street Ketchikan, AK 99901 Mr. Craig Moore KTN Area State Parks Advisory Board 9883 N. Tongass Highway Ketchikan, AK 99901 Other Interested Parties: Mr. William J. Halloran Southern Southeast Regional Aquaculture Association 2721 N. Tongass Ave Ketchikan, AK 99901 Mr. Ron Wolfe Klukwan Forest Products, Inc. P.O. Box 34659 Juneau, AK 99803 Mr. Dave Pflaum Herring Cove Water Users Association 8256 South Tongass Highway Ketchikan, AK 99901 Initial Consultation Document Page 36 Whitman Lake Hydroelectric Project Mr. Paul Berkshire Ketchikan Electric Company 2727 Tongass Avenue Ketchikan, AK 99901 Mr. Ron Settje, Administrative Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. Rich Trimble Power Projects Manager Ketchikan Public Utilities 2930 Tongass Avenue Ketchikan, AK 99901 Mr. Don Thompson WESCORP 3035 Island Crest Way Suite 200 Mercer Island, WA 98040 Mr. Dudley Reiser R2 Resource Consultants, Inc. 15250 NE 95" Street Redmond, WA 98052 Consultation Document Mailing List December 1998 Page 37 Initial Consultation Document Whitman Lake Hydroelectric Project