HomeMy WebLinkAboutNuyakuk P-14873 RSP 080122 FINAL_reduced
Nushagak Cooperative, Inc.
Nuyakuk River Hydroelectric Project (P-14873) 1 August 2022
Solutions for the Future
Nushagak Electric & Telephone Cooperative, Inc.
557 Kenny Wren Road • P.O. Box 350 • Dillingham, AK 99576
Ph: 907-842-5251 • Fx: 907-842-2799 • www.nushtel.com
August 1, 2022
Secretary Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
- FILED ELECTRONICALLY -
Revised Study Plan Filing for the Nuyakuk River Hydroelectric Project (P-14783)
Dear Secretary Bose:
On June 11, 2018 the Federal Energy Regulatory Commission (FERC) issued a Preliminary
Permit to the Nushagak Electric and Telephone Cooperative (Cooperative) for the proposed
Nuyakuk River Hydroelectric Project (Project). On October 7, 2019, the Cooperative filed its
Pre-Application Document (PAD) and Notice of Intent (NOI) and formally entered into the
Integrated Licensing Process (ILP). Upon the filing of the PAD, the Cooperative adhered to
all scheduling milestones and FERC approved modifications associated with the ILP, had
substantial consultation and collaboration with Project stakeholders (kick-off meeting, study
planning meetings, numerous phone calls, etc.) and developed a Proposed Study Plan (PSP)
which was filed with FERC on April 16, 2020.
During the study planning phase for the proposed Project, a series of extenuating
circumstances occurred making it abundantly clear that a modification to the current ILP
schedule was necessary to allow for an effective and collaborative licensing process to take
place. Upon dialogue with our stakeholders and FERC, it was mutually agreed that an
abeyance would be the best approach. As was detailed in our June 7, 2020 abeyance request
letter, these items included:
• The COVID Pandemic
• Additional collaboration/agreement time necessary with local stakeholders
• The upcoming commercial fishing season
• The potential for a better overall ILP schedule
Based on the justification provided in our request letter and concurrence from all parties, the
abeyance was formally approved by FERC on June 11, 2020.
Nushagak Cooperative, Inc.
Nuyakuk River Hydroelectric Project (P-14873) 2 August 2022
Solutions for the Future
Nushagak Electric & Telephone Cooperative, Inc.
557 Kenny Wren Road • P.O. Box 350 • Dillingham, AK 99576
Ph: 907-842-5251 • Fx: 907-842-2799 • www.nushtel.com
As FERC is aware and per a previous filing (January 12, 2022), we used the abeyance period
to collaboratively advance the project feasibility assessment as much as possible given the
circumstances. Key advancements included but are not limited to:
• Development of an Aquatic Resources Working Group (ARWG)
• Substantive Technical and Collaborative Revision to the PSP
• Series of ARWG Meetings and Informal Discussions
• Public Engagements and Status Updates
• Informal Public Review of Revised PSP
• Establishment of an On-site Camp to House Technical Staff During the Study Period
• Consistent Communication and Status Updates to with FERC
By early 2022, the combination of the substantial amount of technical collaboration and
COVID subsiding to some degree allowed the Cooperative to file an updated PSP and
formally re-initiate the FERC ILP. Per collaboration with FERC, we were able to extend the
typical 90-day comment period for the PSP to 120 days. This extension was deemed
necessary to allow for a planned ARWG site visit and associated RSP revision meeting as well
as in-person public meeting to solicit any additional comments prior to filing of the attached
RSP. The Project location site visit and associated meetings took place during the week of
June 6, 2022.
The Cooperative can’t stress enough how substantive and collaborative the level of
collaboration has been that has gone into the development of this RFP. In addition to the
requisite review period dictated by the ILP, multiple informal review and comment
opportunities have been utilized with the ARWG to confirm agreement on a vast majority of
the methods proposed in this document. With that as context and the understanding that it is
the Cooperative’s genuine intent to continue the high-level of collaboration with stakeholders
throughout the licensing process, we formally file the Nuyakuk River Hydroelectric Project
Revised Study Plan for FERC’s review.
We sincerely appreciate all of the assistance and communication the ARWG, the public and
FERC have taken part in during this time and look forward to assessing the feasibility of this
project via the proposed study program. Please feel free to contact me (907.842.5251 or
wchaney@nushagak.coop) with any questions regarding this filing.
Will Chaney Electric Operations Manager/CEO Nushagak Cooperative
REVISED STUDY PLAN
NUYAKUK RIVER HYDROELECTRIC PROJECT
FERC NO. 14873
Submitted by:
Nushagak Electric & Telephone Cooperative, Inc.
P.O. Box 350
Dillingham, AK 99576
August 2022
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. i August 2022
TABLE OF CONTENTS
LIST OF FIGURES ....................................................................................................................... iv
LIST OF TABLES ........................................................................................................................ vii
ACRONYMS AND ABBREVIATIONS ...................................................................................... ix
1.0 INTRODUCTION .............................................................................................................. 1
1.1 Revised Study Plan Overview ................................................................................ 2
1.2 Comments on the Revised Study Plan .................................................................... 4
1.3 Proposed Study Plan Meetings ............................................................................... 4
1.4 Public Meetings ...................................................................................................... 4
1.5 FERC Process Plan and Schedule ........................................................................... 5
2.0 PROJECT LOCATION AND DESCRIPTION.................................................................. 7
2.1 Project Location ...................................................................................................... 7
2.2 Project Lands .......................................................................................................... 7
2.3 Project Facilities.................................................................................................... 12
2.3.1 Summary of Project Features .................................................................... 13
2.3.2 Nuyakuk Falls Diversion & Intake ........................................................... 15
2.3.3 Conveyance Tunnels to Powerhouse ........................................................ 15
2.3.4 Bifurcation to Turbine Units ..................................................................... 16
2.3.5 Powerhouse ............................................................................................... 17
2.3.6 Tailrace ..................................................................................................... 17
2.3.7 Switchyard / Transmission Line/Switchyard ............................................ 17
2.3.8 Proposed Construction and Development Schedule ................................. 17
2.4 Project Operation .................................................................................................. 18
2.4.1 Proposed Project Operations ..................................................................... 18
2.4.2 Project Capacity and Production ............................................................... 20
3.0 STUDY REQUESTS RECEIVED AND RESPONSES .................................................. 21
4.0 PROPOSED STUDIES ..................................................................................................... 31
4.1 Aquatics/Fisheries Resources ............................................................................... 31
4.1.1 Characterization of the Fish Community and Behavior Near the Project
Area ........................................................................................................... 34
4.1.2 Nuyakuk Falls Fish Passage Study ........................................................... 48
4.1.3 Fish Entrainment and Impingement Study ............................................... 70
4.1.4 Assessment of False Attraction at the Tailrace Fish Barrier..................... 80
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4.1.5 Chinook and Sockeye Salmon Life Cycle Modeling ................................ 86
4.1.6 Integrated Risk Assessment of Fish Populations ...................................... 96
4.1.7 Future River Flows and Water Temperatures Study ............................... 106
4.2 Water Resources ................................................................................................. 120
4.2.1 Water Quality Assessment – Dissolved Oxygen and Water Temperatures
................................................................................................................. 120
4.2.2 Flow Duration Curve Change Assessment ............................................. 123
4.2.3 Ice Processes Assessment ....................................................................... 126
4.3 Terrestrial Resources .......................................................................................... 128
4.3.1 Botanical and Wetlands Survey .............................................................. 128
4.3.2 Caribou Population Evaluation ............................................................... 131
4.4 Cultural Resources .............................................................................................. 135
4.4.1 Subsistence Study ................................................................................... 135
4.4.2 Section 106 Evaluation ........................................................................... 138
4.5 Recreation and Aesthetic Resources ................................................................... 144
4.5.1 Noise Study ............................................................................................. 144
4.5.2 Recreation Inventory by Season ............................................................. 148
4.6 Environmental Justice ......................................................................................... 153
4.6.1 General Description of Proposed Study .................................................. 153
4.6.2 Geographic Scope ................................................................................... 153
4.6.3 Study Goals and Objectives .................................................................... 153
4.6.4 Relevant Resource Management Goals .................................................. 153
4.6.5 Existing Information and Need for Additional Information ................... 155
4.6.6 Project Nexus .......................................................................................... 155
4.6.7 Methodology ........................................................................................... 155
4.6.8 Proposed Deliverables and Schedule ...................................................... 158
4.6.9 Level of Effort and Cost ......................................................................... 158
4.7 Supplemental Study – Economic Decision Support Tool................................... 159
4.7.1 General Description of Proposed Study .................................................. 159
4.7.2 Geographic Scope ................................................................................... 159
4.7.3 Existing Information and Need for Additional Information ................... 159
4.7.4 Methodology ........................................................................................... 160
5.0 STUDY SCHEDULE AND PROCESS ......................................................................... 162
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6.0 REFERENCES ............................................................................................................... 163
Appendices
Appendix A — PAD Comment Responses
Appendix B — PAD Comments and Study Requests Filed with FERC
Appendix C — Nexus Between the Project and Proposed Fish Studies
Appendix D — Proposed Study Plan Comment Responses (7/23/2021 Aquatics Resources Work
Group Technical Subcommittee Distribution)
Appendix E — Proposed Study Plan Comment Responses (9/24/2021 Project Contact List
Distribution)
Appendix F — Proposed Study Plan Comments
Appendix G — Proposed Study Plan Comment Responses
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FERC No. 14873 Revised Study Plan
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LIST OF FIGURES
Figure 2-1. Proposed Project location. .............................................................................................9
Figure 2-2. Proposed Project boundary. ........................................................................................10
Figure 2-3. Project conceptual plan. ..............................................................................................11
Figure 2-4. Nuyakuk Falls, looking upriver toward Tikchik Lake. The proposed Project
location is on the peninsula on the left side of the photograph. .............................12
Figure 2-5. Nuyakuk Falls, looking across the Nuyakuk River to the proposed Project
location. ..................................................................................................................13
Figure 2-6. Mean daily discharge at USGS Gage No. 1530200 from October 1, 1986 –
September 30, 2019. ..............................................................................................19
Figure 2-7. Estimated average monthly power generation for the proposed Project. ....................20
Figure 4-1. Simple salmon life cycle and potential Project impacts. A similar conceptual
approach may be applicable to resident species. Time and periodicity are
implicit. ..................................................................................................................32
Figure 4-2. Proposed characterization of the fish community and behavior near the Project
area study Zones 1-3, Nuyakuk River, Alaska (FERC No. 14873). ......................35
Figure 4-3. Candidate sampling locations within zones 1 and 3 for characterizing fish
community and behavior near the Project area. .....................................................43
Figure 4-4. Daily hydrograph of the Nuyakuk River with (regulated) and without
(unregulated) preliminary proposed Project operations, with percent flow
diverted for power generation. The regulated hydrograph includes a
minimum bypass flow of 1,000 cfs. .......................................................................49
Figure 4-5. Schematic of Nuyakuk Falls Reach showing possible adult upstream migration
pathways, adult holding areas, and potential stranding and trapping areas.
Photo taken on June 22, 2017; flows approximately 7,200 cfs. ............................50
Figure 4-6. Approximate Fish Passage Assessment Study Area of the Nuyakuk River. ..............51
Figure 4-7. Conceptual representation of potential major effects of Nuyakuk Hydroelectric
Project operations on upstream and downstream fish passage through
Nuyakuk Falls, Alaska. ..........................................................................................53
Figure 4-8. Area of LiDAR coverage and extent of the Fish Passage Study Area in the
Nuyakuk River, Alaska. .........................................................................................55
Figure 4-9. Estimated monthly periodicities of adult upstream and juvenile downstream
migrations of salmon and estimated average monthly flows of the Nuyakuk
River, under unregulated and regulated conditions, with percent flow
diverted for generation. ..........................................................................................57
Figure 4-10. Schematics of chute-type (left) and falls-type (right) potential barriers
(adapted from Powers and Orsborn 1985, as presented in Reiser et al. 2006).
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Variables are defined as follows: Z is the vertical distance from the bottom
of the barrier to the crest of the barrier, H is the vertical distance from the
downstream pool water surface to the water surface at the crest, dc is the
water depth at the crest, dpp is the flow depth of the downstream pool, LS is
the chute length, Sp is the angle of the chute, Se is the angle of the bed
upstream of a falls, FH is the vertical distance from the downstream water
surface elevation to the barrier crest, h0 is the initial leaping angle, and Xsw
is the distance from the location of the impact of the falling water to the
standing wave.........................................................................................................59
Figure 4-11. Schematic of three hypothetical upstream migration routes (Routes 1,2 and 3)
each containing different combinations of Groups/Zones (as defined above)
based on hydraulic parameter limits (e.g., depth, velocity, width, length)
that could allow passage of adult salmonids. More than 3 routes will likely
exist within the Falls Reach and these could overlap/cross, under varying
flow levels; e.g., Route 1 may intersect with and become part of Route 2,
Route 3 may intersect with 2 and 1, etc. Some pathways may actually lead
to dead-ends forcing fish to move back downstream and attempt another
route. A time series analysis covering distinct upstream migration periods
will be completed using different water year types to allow a comparative
assessment of Upstream Passage Probabilities under different flow
conditions. ..............................................................................................................64
Figure 4-12. Schematic of three hypothetical downstream migration routes defined via 2D
modeling. A time series analysis covering distinct downstream migration
periods will be completed using different water year types will allow a
comparative assessment of Downstream Passage Probabilities under
different flow conditions. .......................................................................................65
Figure 4-13. Depiction of potential changes in upstream migration probability as a function
of changes in physical and hydraulic conditions within the Falls Reach, and
potential delay at the tailrace (R) and passage probabilities both with
operations and without (current). Similar analysis would be applied under a
Climate Change scenario as a function of flow changes, not temperature. ...........66
Figure 4-14. Depiction of potential changes in downstream migration probability as a
function of changes in passage probabilities due to delay, stranding/trapping
or entrainment and passage probabilities both with operations and without
(current). Similar analysis would be applied under a Climate Change
scenario as a function of flow changes, not temperature. ......................................66
Figure 4-15. Example passage analysis denoting the ranges of flows that afford suitable
passage conditions for different species. The dashed vertical lines represent
the flow window that is suitable for all species. The PHABSIM and
Tennant flows represent flows recommended via habitat and hydrologic
analysis. (Adopted from Reiser et al. 2006). A similar type of analysis
could be applied in the Nuyakuk Falls Reach. .......................................................67
Figure 4-16. Fish Entrainment and Impingement Study Area. ......................................................71
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Figure 4-17. Assessment of False Attraction at the Tailrace Fish Barrier Study Area. .................81
Figure 4-18. Nuyakuk Falls Fish Life Cycle Modeling Study Schedule. 2023 and 2024 are
projected to be Year 1 and Year 2, respectively. ...................................................95
Figure 4-19. This analysis of the Nuyakuk Gage at Tikchik Lake Outlet (USGS
#15302000) indicates the onset of spring runoff begins 20 days earlier now.
November and December flow were higher the last two decades then in any
time from 1954 - 2000. ........................................................................................108
Figure 4-20. Observed and projected changes (compared to the 1925–1960 average) in near
surface air temperature for Alaska as a whole. Observed data are for 1925–
2020, while model simulations of the historical period are shown for 1901–
2005. Projected changes for 2006–2100 are from global climate models for
two possible futures: one in which greenhouse gas emissions continue to
increase (RCP 8.5, higher emissions) and another in which greenhouse gas
emissions increase at a slower rate (RCP 4.5, lower emissions).
Temperatures in Alaska (orange line) have increased by about 3.5°F since
1925 but with large multidecadal variations. Shading indicates the range of
annual temperatures from the set of models. Observed temperatures are
generally within the envelope of the modeled historical simulations (gray
shading). Historically unprecedented warming is projected during this
century. Less warming is expected under a lower emissions future (the
coldest end-of-century projections being about 2°F warmer than the
historical average; green shading) and more warming under a higher
emissions future (the hottest years being about 15°F warmer than the hottest
year in the historical record; red shading). Sources: CISESS and NOAA
NCEI, Figure 1 in Stewart et al 2022. ..................................................................109
Figure 4-21. Monthly changes in future temperature and precipitation projected for five
GCMs (Figure 3 in Wobus et al. 2018)................................................................111
Figure 4-22. Average daily flow for each May at USGS gage record at Tikchik Lake outlet.
The 69 years exhibit an upward trend due to earlier snowmelt, with current
flows almost double those of the early 1950s (~3,500 vs ~6,500 cfs). Flows
were consistently between 2,000 and 6,000 cfs from 1954 to 1975. From
1975 to 1995 average May flows above 6,000 cfs occur in 33 percent of the
years. After 2002, average May flows are more likely to be above 10,000
cfs than below 4,000 cfs - the average those first 30 years. Average May
flows have not been below 4,000 cfs in eight years. ............................................111
Figure 4-23. Average daily flow for each November at USGS gage record at Tikchik Lake
outlet. The trend over the past 69 years is for about 50% more flow in the
present. Note the interannual variability of the flows (e.g. 2019, 2020, and
2021, or 1979, 1980 and 1981). Note that there are some missing years of
data in the late 1990s. ...........................................................................................112
Figure 4-24. Range of the Mulchatna caribou herd (MCH) and permitted hunt area specific
to this herd (RC503) in Southwest Alaska (Barten and Watine 2020). ...............132
Figure 4-25. Proposed Noise Study Area. ...................................................................................145
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FERC No. 14873 Revised Study Plan
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Figure 4-26. Recreation Study Area ............................................................................................149
Figure 4-27. Geographic scope of Environmental Justice study. ................................................154
LIST OF TABLES
Table 1-1. Nuyakuk Project Aquatics Resources Work Group (ARWG) meeting dates and
general topics discussed. ..........................................................................................2
Table 1-2. Integrated Licensing Process (ILP) milestones for the Nuyakuk River
Hydroelectric Project (FERC 2022).........................................................................5
Table 2-1. Land ownership within the proposed Project boundary. ................................................8
Table 2-2. Summary of proposed Project features. ........................................................................13
Table 3-1. Study requests received and corresponding study plans. .............................................22
Table 4-1. Preliminary life-stage periodicity for a sample of the fish species utilizing the
Nuyakuk River, Alaska. Subject to revision. .........................................................40
Table 4-2. Leaping and Jumping Capabilities of Adult Salmonids, and Preliminary
Migration Periodicity for Nuyakuk River, Alaska (Table modified from
Reiser et al. (2006))................................................................................................58
Table 4-3. Topo-bathymetry survey methodology comparisons considered for the Nuyakuk
River. ......................................................................................................................60
Table 4-4. Downramping rates proposed by Hunter (1992) to minimize stranding and
trapping impacts on salmonids (From Reiser et al. 2007) .....................................69
Table 4-5. Relevant fish entrainment study reports for FERC projects compiled by
Nushagak Cooperative. ..........................................................................................75
Table 4-6. Hypothetical risk assessment summary with example risk values for Chinook
Salmon and potential risk sources. Values are imported from Table 4-8. ..........102
Table 4-7. Hypothetical risk assessment table for one risk source impacting one specific
management objective element. This example is concerned with expected
reductions in downstream passage success for Chinook salmon from
modifications to the flow regime. The values in the table are possible
outcomes calculated by multiplying the ranking of likelihood by the ranking
of consequence. Each consequence level is evaluated for a likelihood.
Highlighted cells provide example selections for an individual risk source
and element pair, including uncertainty. The lowest highlighted value (-4)
is used in Table 4-8 to represent the consequence-likelihood of maximum
risk (in this case, a minor negative impact that is likely) for this risk source /
element pair. .........................................................................................................103
Table 4-8. Hypothetical risk assessment table for one management objective and species
(population sustainability of Chinook), by risk source and ranked elements.
The values for each element column are derived from an individual risk
analysis table (e.g., highlighted consequence and likelihood value of -4
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from Table 4-7. All other values for demonstration only). The values of
this table will be used in Table 4-6 respective of management objective, risk
source and species. ...............................................................................................104
Table 4-9. Environmental Justice Data Table Example...............................................................156
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ACRONYMS AND ABBREVIATIONS
ADEC Alaska Department of Environmental Conservation
ADFG Alaska Department of Fish and Game
ADNR Alaska Department of Natural Resources
AHRS Alaska Historic Resources Survey
APE Area of Potential Effects
BBN Bayesian Belief Networks
BLM Bureau of Land Management
cfs cubic feet per second
Commission Federal Energy Regulatory Commission
DLA Draft License Application
DO dissolved oxygen
EA Environmental Assessment
EPA Environmental Protection Agency
Falls Nuyakuk Falls
FERC Federal Energy Regulatory Commission
FLA Final License Application
ft foot
GIS Geographic Information System
GMU Game Management Unit
HPMP Historic Properties Management Plan
ILP Integrated Licensing Process
IRA Integrated Risk Assessment
IM Intensive Management
ISR Initial Study Report
kV kilovolt
kW kilowatt
LCM Life Cycle Model
MCH Mulchatna Caribou Herd
mg/L milligrams per liter
MOA Memorandum of Agreement
msl mean sea level
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MW megawatt
MWh megawatt hour
NAVD 88 North American Vertical Datum of 1988
NHPA National Historic Preservation Act
NMFS National Marine Fisheries Service
NOAA National Oceanic and Atmospheric Administration
NOI Notice of Intent
NPS National Park Service
NWI National Wetlands Inventory
PA Programmatic Agreement
PAD Pre-Application Document
PLP Preliminary Licensing Proposal
Project Nuyakuk River Hydroelectric Project (P-14873)
psig pounds per square inch, gage
PSP Proposed Study Plan
RSP Revised Study Plan
S&I Survey and Inventory
SD Scoping Document
SHPO State Historic Preservation Office
TBD to be determined
TCP Traditional Cultural Properties
USACE U.S. Army Corps of Engineers
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
USR Updated Study Report
UTBB United Tribes of Bristol Bay
WTSPMC Wood-Tikchik State Park Management Council
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1.0 INTRODUCTION
Nushagak Electric & Telephone Cooperative, Inc. (Cooperative) is filing with the Federal
Energy Regulatory Commission (FERC or Commission) a Revised Study Plan (RSP) describing
the studies proposed for the Nuyakuk River Hydroelectric Project (Project), FERC No. 14873, in
accordance with 18 CFR §5.11. The Cooperative is seeking an original license for the proposed
Project and has elected to use FERC’s Integrated Licensing Process (ILP) as described in 18
CFR Part 5.
The Cooperative filed a Preliminary Permit Application on March 22, 2018. On June 11, 2018,
FERC issued a preliminary permit for the Project effective June 1, 2018, with an expiration date
of June 1, 2021. The Cooperative filed a Notice of Intent (NOI) and Pre-Application Document
(PAD) on October 8, 2019, with the purpose of summarizing existing information on natural
resources in the proposed Project vicinity and describing preliminary and conceptual Project
design and engineering. FERC issued its Scoping Document 1 (SD1) to inform stakeholders
about the scope of the Environmental Assessment (EA) it intends to prepare as part of the
licensing process and to seek additional information pertinent to the analysis. The Cooperative
held a Project kickoff meeting in Anchorage, Alaska on November 18, 2019, to engage Project
stakeholders and present preliminary information about the Project. FERC held two Scoping
Meetings for the Project in Anchorage, Alaska on December 11, 2019, to discuss existing
environmental conditions, potential information needs, and resource issues.
The Cooperative filed a Proposed Study Plan (PSP) with FERC on March 20, 2020, and based on
further discussion with FERC, the Cooperative filed an updated PSP on April 16, 2020. The
Cooperative held a series of virtual PSP meetings to provide additional details on study-specific
methodologies on April 20 and April 22, 2020. Virtual meetings were required in place of in-
person meetings due to COVID-19 gathering and travel restrictions.
Due to COVID-19 restrictions that prevented requisite public meetings and site visits and after
substantive discussion with FERC and stakeholders, the Cooperative requested that FERC place
the Project’s ILP in abeyance on June 7, 2020. On June 9, 2020, FERC placed the ILP in
abeyance, thereby temporarily suspending the licensing process. During the abeyance period the
Cooperative collaborated substantially with federal, state, and local agencies and stakeholders,
particularly with respect to the planning of aquatic and fishery studies. An Aquatics Resources
Work Group (ARWG) was formed early in the abeyance period, which includes local technical
experts from agencies, Bristol Bay Science and Research Institute, the University of Washington
Fisheries Research Institute, and other organizations. These experts have extensive familiarity
with the Bristol Bay area and the fisheries interests therein. The ARWG has met every 1-2
months between fall 2020 and fall 2021 and began meeting monthly in March 2022 (Table 1-1).
During each meeting the group has discussed the studies and methods required to assess any
potential impacts of the proposed Project on aquatic and fisheries resources. Based on the
substantive progress made during these discussions and the work products the ARWG has
collaboratively generated, the Cooperative revised the PSP and provided the document for two
informal reviews during the abeyance: 1) to the ARWG Technical Subcommittee on July 23,
2021, and 2) to the Project contact list, which consists of over 100 community members, Tribal
organizations, state and federal agency personnel, and local municipality contacts. Comments
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received on each iteration of the PSP and the Cooperative’s responses to those comments are
included in Appendix D and E to this PSP. The Cooperative filed the revised PSP with FERC on
March 2, 2022. On March 10, 2022, FERC issued an order accepting the PSP and re-initiated the
formal ILP. FERC’s order also provided the licensing process milestones listed in Table 1-2 and
discussed in Section 1.5.
On June 7-8, 2022, the Cooperative held an in-person site visit for members of the ARWG for
the purpose of evaluating and discussing which field methods to assess aquatic and fishery
resources should be used. Based on the site visit and meeting, significant revisions have been
made to the PSP to refine the aquatic and fishery study methods presented in Section 4.1 of this
RSP.
This RSP incorporates text revisions to address the comments received on the PSP and the
technical recommendations of the ARWG discussed and agreed upon during the June 2022 in-
person meeting and site visit.
Table 1-1. Nuyakuk Project Aquatics Resources Work Group (ARWG) meeting dates and general
topics discussed.
Date Meeting Description
10/11/2020 ARWG Kickoff Meeting: Overview of Aquatics Resources Studies &
Revisions
12/04/2020 ARWG Technical Subcommittee Meeting: Aquatic Resources Studies &
PSP Revisions Discussion
1/21/2021 ARWG Technical Subcommittee Meeting: Fish Studies Framework &
Project Nexus Discussion
3/10/2021 ARWG Technical Subcommittee Meeting: Life Cycle Model & Risk
Assessment Discussion
4/7/2021 ARWG Technical Subcommittee Meeting: Life Cycle Model & Risk
Assessment Discussion
5/24/2021 ARWG Technical Subcommittee Meeting: Project Nexus Table Discussion
7/29/2021 ARWG Technical Subcommittee Meeting: PSP Comment Discussion
1/12/2022 ARWG Technical Subcommittee Meeting: Licensing Re-Initiation
Discussion
3/1/2022 ARWG Technical Subcommittee Meeting: 2022 Planning and ILP Re-
Initiation
5/11/2022 ARWG In-person meeting and site visit planning
6/7/2022 – 6/8/2022 ARWG In-person site visit and meeting (Dillingham, AK)
1.1 Revised Study Plan Overview
In accordance with ILP regulations, comments on the PAD, FERC’s SD 1, and study requests were
due by February 4, 2020. A total of 6 stakeholders filed letters with FERC providing general
comments, comments pertaining to the PAD, comments regarding SD1, and/or study requests.
Study requests received are presented in Section 3.0.
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FERC’s ILP regulations under 18 CFR §5.9(b) require that stakeholders who provide study
requests include specific information to allow the Licensee and FERC staff to determine a
requested study’s appropriateness and relevancy to the Project and proposed action. The criteria
required for inclusion in study requests are as follows:
1. Describe the goals and objectives of each study proposal and the information to be
obtained;
2. If applicable, explain the relevant resource management goals of the agencies or Indian
tribes with jurisdiction over the resource to be studied;
3. If the requester is not a resource agency, explain any relevant public interest
considerations in regard to the proposed study;
4. Describe existing information concerning the subject of the study proposal, and the need
for additional information;
5. Explain any nexus between project operations and effects (direct, indirect, and/or
cumulative) on the resource to be studied, and how the study results would inform the
development of license requirements;
6. Explain how any proposed study methodology (including any preferred data collection
and analysis techniques, or objectively quantified information, and a schedule including
appropriate field season(s) and the duration) is consistent with generally accepted
practice in the scientific community or, as appropriate, considers relevant tribal values
and knowledge; and
7. Describe considerations of level of effort and cost, as applicable, and why any proposed
alternative studies would not be sufficient to meet the stated information needs.
The Cooperative has evaluated all study requests and comments received by stakeholder with
respect to FERC’s study request criteria listed above. Section 3.0 of this RSP provides a list of
all requested studies and the rationale for inclusion or exclusion in the Project’s study program.
Studies deemed appropriate for inclusion in the RSP are described in detail in Section 4.0 of this
RSP, including study goals and objectives, methodology, study schedules, proposed deliverables,
and cost and level of effort.
The PSP was filed with FERC on March 2, 2022. When filing the PSP with FERC, the
Cooperative requested a 30-day extension of time for the PSP comment period to allow for an
ARWG site visit and in-person meeting to occur during the month of June. Per FERC’s March
10, 2022 order, the PSP comment deadline was June 30, 2022. The Cooperative received 10
formal comment letters on the PSP from agencies, organizations, and community members.
Comment letters were received from:
• Alaska Department of Fish & Game
• Alaska Department of Natural Resources, Division of Parks and Outdoor Recreation
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 4 August 2022
• Alaska State Historic Preservation Office
• Bristol Bay Region Seafood Development Association
• Federal Energy Regulatory Commission
• National Marine Fisheries Service
• Royal Coachman Lodge
• United States Fish and Wildlife Service
• United Tribes of Bristol Bay (two comment letters received)
Comment letters filed with FERC and responses to comments are presented in Appendices F and
G.
1.2 Comments on the Revised Study Plan
Formal comments on this RSP, including any additional or revised study requests, must be filed
with FERC by August 14, 2022 (Table 1-2). Comments must include an explanation of any study
plan concerns, and any accommodations reached with the Cooperative regarding those concerns
(18 CFR §5.12). Any proposed modifications to the RSP must address FERC’s criteria as
presented in 18 CFR §5.9(b).
1.3 Proposed Study Plan Meetings
In accordance with 18 CFR §5.11(e), the Cooperative held three virtual/teleconference PSP
Meetings. One meeting was held on April 20 and two were held on April 22, 2020 (afternoon
and evening). In-person meetings were not permissible due to the COVID-19 pandemic and the
associated travel restrictions. The purpose of the PSP Meetings was to present the Cooperative’s
study plan proposal, as outlined in the PSP, provide additional context and answer any questions
in an effort to allow for the most comprehensive review process possible. The Cooperative also
presented the content of the PSP in the series of public meetings described in Section 1.4.
1.4 Public Meetings
The Cooperative realizes the importance of public involvement in the re-initiation of this process
and throughout the remainder of the ILP. We are committed to a high level of transparency
during every phase of this process. As such, the Cooperative hosted a series of two virtual public
meetings on September 21 and 23, 2021 to present the recommendations of the ARWG
associated with the PSP. The timeframe for the public meetings was selected in an effort to both
be timely and avoid the commercial salmon season and fall subsistence hunt, to the extent
possible. The meetings were held on:
September 21, 2021: 1:00pm – 4:00pm (AK time)
September 23, 2021: 5:30pm – 8:30pm (AK time)
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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The meeting times and dates were intended to accommodate individuals during both business
and evening hours. Detailed meeting agendas and virtual meeting logistics information were
provided to the Project contact list in advance of the meetings.
An in-person public meeting was held in Dillingham, Alaska on June 8, 2022. The Project
contact list was notified of the meeting and information was also posted on the Cooperative’s
Project website (www.nuyakukhydro.com) in advance. During the meeting, the Cooperative and
members of the ARWG presented updates regarding the status of the Project licensing and
feasibility study process and information about the added Economic Decision Support Tool
(eDST) that is currently under development (see Section 4.6). Community members had the
opportunity to share their comments and questions with the Cooperative and the ARWG during
the meeting. Presentations given at the meeting and meeting notes were posted on the Project
website and the Project contact list was notified of the available information. The Cooperative
will continue to work closely with the region as a whole and the local communities therein and
will host additional meetings in the coming months. Once scheduled, meeting notices will be
posted on the Project website and the Project contact list will receive email notification.
1.5 FERC Process Plan and Schedule
ILP milestone dates were determined by FERC upon re-initiation of the ILP on March 10, 2022
(FERC 2022). The Cooperative anticipates FERC Study Plan Determination issuance in 2022
and intends to conduct robust study seasons in 2023 and 2024. At the close of each study season,
the Cooperative will produce study reports and hold study report meetings in accordance with
ILP regulations. The Cooperative expects to file draft and final license applications in 2025.
Table 1-2. Integrated Licensing Process (ILP) milestones for the Nuyakuk River Hydroelectric
Project (FERC 2022)1.
Pre-Filing Milestone Responsible
Party
Date and Location (if applicable)
[Required FERC ILP Timeframe]
Comments due on Proposed Study Plan Licensing
Participants June 30, 2022 [90 days after PSP filed]
File Revised Proposed Study Plan Cooperative July 30, 2022 [30 days after PSP
comments filed]
Revised Proposed Study Plan Comments
Due
Licensing
Participants
August 14, 2022 [15 days after Revised
PSP filed]
Study Plan Determination Issued FERC August 29, 2022 [30 days after Revised
PSP filed]
Study Year 1 Cooperative May – October, 2023
File Initial Study Report Cooperative August 29, 2023
Initial Study Report Meeting Cooperative September 13, 2023
Initial Study Report Meeting Summary Cooperative September 28, 2023
1 Unanticipated study disputes or extension of time requests are not included in this tentative schedule. Any milestone date
occurring on a Saturday, Sunday, or holiday is shifted to the next business day.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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Pre-Filing Milestone Responsible
Party
Date and Location (if applicable)
[Required FERC ILP Timeframe]
Study Year 2 Cooperative May – October, 2024
File Updated Study Report Cooperative August 29, 2024
File Preliminary Licensing Proposal (PLP) Cooperative January 2025 [approximate; date TBD]
Comments due on PLP Licensing
Participants [90 days after PLP filed]
File License Application Cooperative December 2025 [approximate; date
TBD]
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 7 August 2022
2.0 PROJECT LOCATION AND DESCRIPTION
The Project would be located in southwest Alaska on the Nuyakuk River approximately 60 miles
north of Dillingham, AK (pop. 2,364) near Tikchik Lake in the watershed that drains the eastern
side of the Wood River Mountains. The Project site is inside the current Wood-Tikchik State Park
boundary by approximately 4 miles. From the Project site, the Nuyakuk River runs approximately
40 miles before converging with the Nushagak River, which continues to Bristol Bay.
The proposed Project is a new 10 megawatt (MW) conventional hydropower project consisting of
an intake structure, power conduit, powerhouse forebay, powerhouse, and tailrace channel
approximately 4 miles downstream of the Tikchik Lake outlet above a natural Falls on the
Nuyakuk River. Power from the Project would be available to the customers of the Cooperative
and potentially other areas in the region. The renewable power provided by the Project would
represent a significant improvement in the current distribution system and minimize the reliance
of local communities on fossil fuels as their primary source of electricity. Currently, the population
that would be served by this Project relies wholly on diesel generation, which is barged upstream
through the Nushagak River drainage to requisite locations. The reduction of water transport of
fuels will reduce the potential for negative environmental impacts due to spills. The primary
industry in the Project service area is related to commercial harvesting and processing of salmon.
The long-term demand for more reliable, efficient, and cost-effective power along with the likely
limited resource impacts makes this Project a highly viable opportunity.
2.1 Project Location
The proposed Project would be located on the Nuyakuk River approximately 60 miles north of
Dillingham, AK (pop. 2,364), within the 1,571 square mile watershed that drains the eastern side
of the Wood River Mountains (Figure 2-1). The Project site is inside the current Wood-Tikchik
State Park boundary by approximately 4 miles. The Project’s river intake would divert water
from the Nuyakuk River, above Nuyakuk Falls (Falls), located about 4.6 river miles downstream
from the Tikchik Lake outlet to a powerhouse located at approximately river mile 5.3
downstream to the base of Nuyakuk Falls. From the Project site, the Nuyakuk River runs
approximately 40 miles before converging with the Nushagak River, which continues to Bristol
Bay.
2.2 Project Lands
The proposed Project boundary consists of roughly 2,861 acres, which includes a 75-ft buffer
around all Project facilities and on either side of the proposed transmission line. Acreage of
proposed Project lands by ownership is presented in Table 2-1. The Alaska Department of
Natural Resources (ADNR) manages a total of about 1,667 acres (58.3 percent) of proposed
Project lands. Of this, roughly 266 acres (9.3 percent) is land within Wood-Tikchik State Park.
Native lands total about 707 acres (24.7 percent) of proposed Project lands. The remainder of
proposed Project lands are owned or managed by the Bureau of Land Management (BLM) (357
acres or 12.5 percent) and private or municipal entities own an additional 130 acres (4.5 percent).
See Table 2-1 for exact values.
Nuyakuk River Hydroelectric Project
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Table 2-1. Land ownership within the proposed Project boundary.
Owner/Agency Acreage
State of Alaska (ADNR – excluding Wood-Tikchik
State Park) 1,400.72
State of Alaska (ADNR - Wood-Tikchik State Park) 265.85
Native 707.39
Federal Government (BLM) 357.08
Private or Municipal 129.56
Total proposed Project lands 2,860.60
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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Figure 2-1. Proposed Project location.
Nuyakuk River Hydroelectric Project
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Nushagak Cooperative, Inc. 10 August 2022
Figure 2-2. Proposed Project boundary.
Nuyakuk River Hydroelectric Project
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Nushagak Cooperative, Inc. 11 August 2022
Figure 2-3. Project conceptual plan.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 12 August 2022
2.3 Project Facilities
The Project will consist of a single primary development centered around a river intake/diversion
located above Nuyakuk Falls and a single powerhouse facility located downstream below
Nuyakuk Falls (Figures 2-4 and 2-5). Additional Project facilities will include two tunnels to
convey water from the intake to the powerhouse, a tailrace conveyance channel to return water to
the Nuyakuk River, an airstrip with local access roads, a small building to house a maintenance
shop on the lower level and an operators’ residence on the upper level, and an electrical
transformer and switchyard area to step power up for high-voltage (34.5 kV) conveyance via
overhead transmission to Dillingham, AK and the other communities served via the transmission
routes. Overhead transmission is currently estimated to cover 135 miles according to the
conceptualized route shown in Figure 2-1. The Project will likely also include a lower dock
facility located near the powerhouse/tailrace outlet to allow for docking of small watercraft that
can navigate the Nuyakuk River back to the Nushagak River.
The powerhouse is conceptualized to contain two Kaplan-style reaction turbine generating units
to accommodate a combined maximum design flow of approximately 6,000 cfs divided evenly
among the units. This combined maximum design flow ranges between 44% and 65% of the
average flow rate over the calendar year, less a design specification of 1,000 cfs for instream
uses. The rated capacity on each unit would be approximately 5.0 MW. The gross head on the
Project is approximately 26 feet, based on site surveying work that occurred in June of 2019.
Figure 2-4. Nuyakuk Falls, looking upriver toward Tikchik Lake. The proposed Project location is
on the peninsula on the left side of the photograph.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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Figure 2-5. Nuyakuk Falls, looking across the Nuyakuk River to the proposed Project location.
2.3.1 Summary of Project Features
The proposed Project features have been developed based upon existing physical and
environmental information and are conceptual in nature. As part of the pre-filing consultation
process, additional information will be obtained through site-specific technical and
environmental studies and continuing research and consultation with equipment manufacturers
and resource agencies. As new information becomes available, the design features presented
below will be expected refined and/or modified as needed to accommodate any changed
conditions, including maintenance of instream flow requirements. Project features as currently
envisioned are summarized in Table 2-2 and described in this section.
Table 2-2. Summary of proposed Project features.
SUMMARY OF PROJECT FEATURES
Number of Generating Units 2
Turbine Type Kaplan (pit style)
Runner Diameter (estimated) 12-ft
Operating Speed 124.1 rpm
Generator Type Synchronous
Rated Generator Output
Unit 1 5.38 MW
Unit 2 5.38 MW
Maximum Rated Turbine Discharge
Unit 1 3,000 cfs
Unit 2 3,000 cfs
Diversion Forebay Water Surface Elevation
Minimum (Preliminary) 250.0 (ft NAVD88)
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Maximum (Preliminary) 275.0 (ft NAVD88)
Turbine Centerline Elevation (Preliminary) 231.67 (ft NAVD88)
Normal Tailwater Elevation
Minimum (Preliminary) 214.0 (ft NAVD88)
Maximum (Preliminary) 231.5 (ft NAVD88)
Average Annual Energy (assuming 23.2 feet of net head and an
average monthly intake diversion flow of 4,047 cfs or 6.7 MW)
58,900 MWh
Gross Head 26.0 feet ± fluctuation
Net Head at Maximum Rated Discharge 23.2 feet
Watershed Characteristics
Drainage Area 1,571 sq. mi.
Maximum Basin Elevation 5,250 (ft NAVD88)
Minimum Basin Elevation 248 (ft NAVD88)
Mean Annual Precipitation 59.0 inches
Area of Ponds or Lakes 12.4 %
Nuyakuk River Diversion (To be refined once geotechnical reconnaissance work is completed)
Structure Type Concrete Diversion / Low Head
Weir (TBD)
Structure Length 100 feet
Average Monthly Water Height above Weir (Max) 5.40 feet
Crest Elevation 250.5
Water Conveyance (Gravity Tunnel from Intake to Powerhouse)
Intake Style Gravity (weir or orifice)
Number of Tunnels 2 (or 1 depending on the outcome
of geotechnical investigations)
Tunnel Construction Type TBD once field geotechnical drilling
and data are compiled
Length of inclined tunnels to powerhouse 750 feet
Tunnel Velocity at Maximum Turbine Discharge ~ 15 ft/sec
Tunnel Flow Capacity 6,000 cfs
Unlined Tunnel Diameter 25-ft
Final Lined Diameter 23-ft
Powerhouse
Approximate Dimensions (for three-unit powerhouse) 45 ft x 100 ft x 30 ft high
Finished Floor Elevation 250.0 (ft NAVD88)
Tailrace
Type Open Channel
Length 450 ft
Typical Water Depth 8-ft +/-
Typical Width 80 ft up to 300 ft
Transmission Line
Type Overhead
Length Approximately 60 miles to
Dillingham; 135 miles total
Voltage 34.5 kV
Access Roads (from Airstrip Runway to Powerhouse)
Type Single lane gravel surfacing with
turnouts
Length 0.5 miles
Nuyakuk River Hydroelectric Project
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2.3.2 Nuyakuk Falls Diversion & Intake
A concrete gravity diversion structure would be constructed above the Falls on the Nuyakuk
River. The intake diversion would move water from the southern portion of the river above the
Falls into a drop shaft-type structure connected with two 23-foot diameter tunnels. The intake
structure could be weir flow or orifice flow, depending on the optimal configuration for both
power production and fish species concerns. A rock groin may be required to divert water to the
intake during low flows. The rock groin would act to split the flow of the river between the Falls
and the intake and to check water up near the intake. The rock groin is intended to help divert
water to the intake at low flow, should it be needed. For this reason, the rock groin would consist
of a low vertical profile and would not extend above the water surface at high or even average
flows. Depending on the hydraulic conditions in the river, it may also be possible to ensure that a
minimum depth of water is maintained over the groin, even at low flow. The rock groin may be
outfitted with a series of sluice gates or bladder weirs to allow the periodic flushing of
accumulated debris or ice, although it is anticipated that such features may not be required.
The inlet zone to the open channel canal would be protected by steel inclined bar-screens (with
openings between bars on the order of 1 to 3 inches) to divert both ice and debris away from the
open channel and downstream over the natural Falls. The trash rack would be oriented parallel
to river flow to maximize sweeping velocity on the rack face, thereby increasing passive flushing
of debris from the rack. The trash rack would be necessary to protect both the downstream
telescoping vertical gates as well as the downstream turbine units. Final concept design would
need to investigate whether or not an additional isolation bulkhead or sluice gates would be
needed behind the trash rack for further safety or maintenance purposes. The diversion structure
and intake would also be equipped with redundant level transmitters to continuously monitor
water levels in these critical conveyance features.
The diversion and intake geometry will be advanced once field site investigations (bathymetry,
sub-bottom profiling, and geotechnical drilling) are completed. In addition, two-dimensional
river hydraulic modeling will be required for approximately 1,000 lineal feet above the Falls to
aid in proper development of the intake diversion hydraulic and structural design. It is
anticipated that river hydraulic modeling and geotechnical studies will be conducted as part of
the overall Project licensing study program.
Each conveyance tunnel would be equipped with an isolation gate at the intake to be able to
independently shut down each tunnel and corresponding turbine unit for maintenance or other
emergency (e.g., turbine runaway) considerations. These gates would be co-located with an
intake house with gate hoists and controls. The tunnels would extend approximately 750-feet
downstream through the bluff, necking down to two 12-foot diameter steel penstocks. The
penstocks would include butterfly valves for powerhouse isolation. Each penstock would connect
with a 5-MW rated Kaplan turbine house below the slab of an approximately 50-foot wide by
100-foot long powerhouse.
2.3.3 Conveyance Tunnels to Powerhouse
Assuming that a two-turbine powerhouse is the most practical and reliable configuration for
power generation, the Project would be developed with either one larger water conveyance
tunnel feeding a bifurcation to two penstocks, or two separate smaller tunnels each of which is
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dedicated to one of the two penstocks and generating units. Better system reliability and Project
redundancy would be provided by an arrangement that dedicates a tunnel to each unit, but the
cost of providing two tunnels could be higher than that of a single tunnel unit. Advantages of a
two-tunnel project would include the following:
• Ability to run one turbine unit while maintenance is performed on the other isolation
gate or turbine unit.
• Design of the steel tunnel liners to fit inside the excavated rock tunnels may be
significantly easier with the smaller tunnels than it would be with a single large-
diameter tunnel.
If on-site geotechnical drilling and investigations show that native rock quality is poor or
inconsistent, then it should be assumed that the tunnels would have to be lined with either a
welded in-place steel liner (a continuous steel shell liner likely of at least 1/2-inch thickness) or
perhaps with a rock-bolt and shotcrete system to protect against the inherent structural
weaknesses or deficiencies in the native rock. If steel liners are used, they would be brought in
longitudinal arc-sections and seem-welded both longitudinally and horizontally inside the tunnel.
Once the steel liners are placed inside the tunnel, the annular void space between the liner and
the native rock would be pressure grouted with structural non-shrink grout mixes designed to be
pumped and flow through annular spaces.
If on-site geotechnical investigations show that native rock is of high enough quality and
consistent enough through the tunnel alignment zone, then it may be possible to omit the need
for an interior steel liner or rock-bolt and shotcrete liner system. This configuration would
provide a large economic benefit to the Project. Detailed on-site geotechnical investigations,
including field drilling and logging, will be used to clarify the design needs of the conveyance
tunnels.
2.3.4 Bifurcation to Turbine Units
If a single conveyance tunnel system is pursued for the Project design, it will be necessary to
provide a bifurcation design near the outlet to the tunnel and prior to the powerhouse. The
bifurcation would be designed of steel pipe and would divide the flow to the two Kaplan units
with their horizontal spiral cage inlet configurations. Geometric symmetry would be required to
ensure an equal division of flow to the two units when all units are in operation. The low system
net heads (estimated at 23 feet or 10 psig [pounds per square inch, gage]) and lack of much
external groundwater or other external loading conditions suggest that the structural design and
resulting plate thickness of a steel pipe bifurcation system should not be very thick. However,
both handling and site-specific seismic considerations will be taken into account in the final
bifurcation design.
If two separate conveyance tunnels are pursued for the Project, then the bifurcation structure can
be eliminated from the Project.
Nuyakuk River Hydroelectric Project
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2.3.5 Powerhouse
The powerhouse would be located on the south bank of the Nuyakuk River near the base of the
Falls. The powerhouse is estimated to be approximately 50 feet wide by 100 feet long by 30 feet
high to accommodate two Kaplan generating units. The powerhouse would have a large
underground foundation that houses the entrance cage to the runners along with the impeller
section of each turbine unit. The main superstructure above ground would be a pre-engineered
metal building anchored to a concrete foundation.
The powerhouse concept is to contain two Kaplan-type turbine/generator units with a rated
capacity of 5.0 MW for each unit at a design flow of approximately 3,000 cfs per unit, with
associated switchgear and controls. The centerline of the turbine and generator units would be
approximately 232 feet above mean sea level (msl). The tailwater elevation at the powerhouse
would range from approximate elevation 225 feet above msl to 235 feet above msl depending
upon output level. Final values for these elevations will be determined once the site topographic
and bathymetric surveys are completed in 2020. The turbines would be designed to operate at
high efficiencies over a range of flows from the maximum of 3,000 cfs to a minimum of around
600 cfs depending on conditions.
2.3.6 Tailrace
The tailrace would be an open rectangular concrete channel approximately 450 feet long and
would range in width from about 80 feet to up to 300 feet to convey water back to the Nuyakuk
River. The tailrace outlet to the river would be designed to exclude fish from entering the
tailrace and to reduce velocities relative to the natural river velocities in the discharge zone. The
reduced velocities may minimize the extent to which native anadromous fish are attracted to the
Project discharge flow instead of the natural river channel flow pathways.
2.3.7 Switchyard / Transmission Line/Switchyard
The switchyard at the powerhouse will consist of a pad-mounted disconnect switch (i.e., breaker)
and a pad-mounted step-up transformer. An overhead 34.5 kV transmission line would run from
the powerhouse switchyard approximately 60 miles to a point of interconnection with the NETC
electrical system. A right-of-way would be established along the proposed transmission line.
This route would be used to construct the transmission line, then serve as a land-based right of
way for the Project site. The route would incorporate setbacks from main waterways and
alignment changes to minimize visual impacts.
The transmission line poles would be designed as tangent line structures located approximately
every 400 feet on center. Transmission line design will also incorporate the latest raptor
protection guidelines. Collision avoidance devices will be installed on the line at appropriate
locations to protect migratory birds.
2.3.8 Proposed Construction and Development Schedule
The Project would be designed over the 12 months immediately after the license is issued and
subsequently constructed over a 24-month timeframe thereafter. Construction would begin in
the spring with the clearing of a right-of-way along the transmission corridor and the
construction of the localized access road at the Project works on the river. A majority of the
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large equipment necessary to construct Project infrastructure would be barged up the river and
stored at the site during construction activities. An airstrip would be constructed adjacent to the
Project site to allow air transport of equipment, materials, and manpower to support construction
activities. A fully equipped man camp would be erected for the Project construction staff.
Portable generation facilities would provide power for the construction work and man camp
facilities. Initially, temporary cofferdams would be constructed at the intake and powerhouse
tailrace channel exit zone into the river. This would allow the intake structure, tunnels, and
powerhouse construction to advance simultaneously to maximize the work completed during a
summer construction season. The intake and tunnels would be completed first, with the
powerhouse structure completed immediately following. The generation equipment would be
installed, and the balance of plant construction advanced during the winter months. The
diversion structure and tailrace channel would be the last components constructed followed by
removal of the river cofferdams. These work activities would be completed in the last season
followed by startup, commissioning, and initiation of commercial power generation.
2.4 Project Operation
2.4.1 Proposed Project Operations
The primary mode of operation for this Project will be level control, whereby outflow is
balanced to inflow. The Project is conceived as a run-of-river project, with no large storage
component. As such, power production will mimic some fraction of total river inflow to the
Project site. The proposed proportion of river diverted to the powerhouse ranges between 44%
and 65% of average river discharge over the calendar year. Currently, Senate Bill 91 of the
2019-2020 legislature establishes that a compatible use by a hydroelectric development at
Nuyakuk River Falls maintains at least 70% of the daily flow in the river. One aspect of the
proposed fish and aquatic studies in this PSP is to evaluate how a range of diversion rates affect
fish and their habitat in the Project Area.
Mean daily discharge for the most recent 25 years in the Nuyakuk River is presented in Figure 2-
6, based on United States Geological Survey (USGS) gaging data available at station 15302000
located near the outlet of Nuyakuk Lake. From the figure, it is clear that the period of high flow
in the river occurs between early summer and early fall. For the remainder of the year, the river
is running at near baseflow conditions. Because the Project will operate in run-of-river mode,
sizing the generating units should be done to either 1) maximize power production during a
specific time of year (e.g., during the winter months) or 2) produce power more or less evenly
throughout the year. Under the current Project conceptualization, units have been sized to
provide a stable amount of power from month to month while attempting to minimize overall
capital costs associated with the hydroelectric units, tunnels, and other Project components.
Average monthly power generation under this operational configuration is shown in Figure 2-7.
When powerhouse flows do not match the system loads, grid system electricity will have to be
supplemented with existing diesel generation. This will most likely be in the winter months when
the amount of water available to the powerhouse is less than the power demand would require.
The transmission grid will therefore have five diesel generation power plants tied together to
complete the electric grid system. The existing power plant in Dillingham has the ability to
provide energy for all six villages serviced by the transmission system throughout the year,
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except for the months of June and July. This gives the Cooperative the ability to feed the system
from different sources as needed for load or maintenance.
Figure 2-6. Mean daily discharge at USGS Gage No. 1530200 from October 1, 1986 – September 30,
2019.
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Figure 2-7. Estimated average monthly power generation for the proposed Project.
2.4.2 Project Capacity and Production
The Project will have an installed total capacity of 10.0 MW and is based on the configuration
discussed above. Energy production also assumes the Project configuration described above,
with two 23-foot diameter tunnels servicing two hydropower generation units over a distance of
about 750 feet. For those months in which the total available inflow to the powerhouse is less
than the total powerhouse flow capacity, a minimum instream flow of 1,000 cfs has been
assumed to pass downstream, while the remainder is passed through the powerhouse to generate
electricity. The predicted average annual energy from the Project is 58,900 MWh representing a
plant factor of 66%. Estimates will be revised once instream flow studies are completed, and any
flow accretions below Nuyakuk Lake are determined.
Nuyakuk River Hydroelectric Project
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3.0 STUDY REQUESTS RECEIVED AND RESPONSES
Comments on the PAD and study requests were received from the following individuals and
organizations:
• Alaska Department of Fish and Game (ADFG), Division of Sport Fish, Research &
Technical Services
• Alaska Department of Natural Resources (ADNR), Division of Parks and Outdoor
Recreation, Office of History & Archaeology (PAD comments only)
• Alaska Department of Natural Resources (ADNR), Division of Parks and Outdoor
Recreation, Wood-Tikchik State Park Management Council (WTSPMC)
• FERC, Office of Energy Projects
• National Oceanic and Atmospheric Administration (NOAA), National Marine
Fisheries Service (NMFS)
• Royal Coachman Lodge
• United Tribes of Bristol Bay (UTBB)
Comments on the PAD that provide additional details about the Project vicinity natural resources
or provide corrections to information provided in the PAD are appreciated by the Cooperative.
These comments will be used to inform the PSP and future licensing documents. Any corrections
to information presented in the PAD will be reflected in future filings prepared by the
Cooperative. Specific responses to comments received on the PAD are presented in Appendix A.
A list of all study requests received, the Cooperative’s responses, and corresponding study plans
are presented in Table 3-1. Study requests filed with FERC are located in Appendix B.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 22 August 2022
Table 3-1. Study requests received and corresponding study plans.
Agency Proposed
Study
Resource
Proposed Study FERC
Study
Criteria
Cooperative’s Response Corresponding RSP
Section (if applicable)
ADFG Fisheries
Resources
Fish Species Seasonal
Distribution and
Abundance Near the
Project Site
Yes
The Cooperative agrees that conducting a fish
species distribution and abundance analysis in the
Project area would be beneficial. See Section
4.1.1 for further details.
4.1.1: Characterization of the
Fish Community and
Behavior Near the Project
Area
ADFG Aquatic
Resources
Two-Dimensional
Bathymetric and
Hydrodynamic Modeling
of Nuyakuk Falls
Yes
The Cooperative agrees that modeling of the Falls
is necessary to document current passage
conditions at all flows and the impact to the Falls
(positive and/or negative) from incorporating the
Project. See Section 4.1.2 for further details.
4.1.2: Nuyakuk Falls Fish
Passage Study
ADFG Fisheries
Resources
Nuyakuk Falls Fish
Passage Evaluation and
Modeling
Yes
The Cooperative agrees that modeling of the Falls
is necessary to document current passage
conditions at all flows and the impact to the Falls
(positive and/or negative) from incorporating the
Project. See Section 4.1.2 for further details.
4.1.2: Nuyakuk Falls Fish
Passage Study
ADFG Fisheries
Resources
Fish Entrainment and
Impingement Study Yes
The Cooperative agrees that conducting this
desktop analysis would assist in informing the
potential for entrainment of fish through Project
routes. See Section 4.1.3 for further details.
4.1.3: Fish Entrainment and
Impingement Study
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 23 August 2022
Agency Proposed
Study
Resource
Proposed Study FERC
Study
Criteria
Cooperative’s Response Corresponding RSP
Section (if applicable)
ADFG Cultural
Resources Subsistence Survey Yes
The Cooperative agrees that updating ADFG’s
subsistence survey data from 15 years ago would
be valuable to updating their record and providing
a baseline to assess relative to data in the future
with the Project in place. Per the ADFG request, it
appears that they are proposing to conduct the
assessment for the Cooperative, presumably via
some fund-sharing agreement. See Section 4.5
below for further details on the Cooperative’s
proposed approach for this study and we look
forward to further dialogue during the study
planning process.
Section 4.4.1: Subsistence
Study
ADNR/WTSPMC Geologic and
Soil Resources
Research geotechnical
integrity of proposed
project site and
transmission line corridor
No
The Cooperative will be evaluating geotechnical
feasibility of proposed Project facilities and
structures as part of ongoing engineering and
design efforts.
n/a
ADNR/WTSPMC Aquatic
Resources
Research site specific
hydro turbine gas
entrainment related to
ultimate design and
operation
No
Given the overall impacts from Project
construction and operation the Cooperative doesn’t
believe this study is warranted.
n/a
ADNR/WTSPMC Fisheries
Resources
Prioritize studying out-
migrating juvenile
salmon and resident
species in water column
and vulnerability to
design and intake
operation
No
The Cooperative believes that this study request is
consistent with several others received from
agencies and studies proposed in this RSP.
Section 4.1.1:
Characterization of the Fish
Community and Behavior
Near the Project Area
Section 4.1.3: Fish
Entrainment and
Impingement Study
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 24 August 2022
Agency Proposed
Study
Resource
Proposed Study FERC
Study
Criteria
Cooperative’s Response Corresponding RSP
Section (if applicable)
ADNR/WTSPMC Fisheries
Resources
Prioritize studying pink
salmon on years of
abundance. Presence of
adult and juveniles
alternate biennially.
No
The Cooperative believes that this study request is
consistent with several others received from
agencies and studies proposed in this RSP.
Section 4.1.1:
Characterization of the Fish
Community and Behavior
Near the Project Area
ADNR/WTSPMC Fisheries
Resources
Study life stage species-
specific habitat suitability
of water depth, water
velocity, substrate and
cover affinities
No
The Cooperative believes that this study request is
consistent with several others received from
agencies and studies proposed in this RSP.
Section 4.1.1:
Characterization of the Fish
Community and Behavior
Near the Project Area
Section 4.1.2: Nuyakuk Falls
Fish Passage Study
ADNR/WTSPMC Fisheries
Resources
Study potential changes
to fish habitat with
alterations to water depth
and substrate conditions
No
The Cooperative believes that this study request is
consistent with several others received from
agencies and studies proposed in this RSP.
Section 4.1.2: Nuyakuk Falls
Fish Passage Study
ADNR/WTSPMC Terrestrial
Resources
Study and assess caribou
population, calving
range, migration routes,
and potential impacts of
noise during construction
and operation
No
The Cooperative believes that this study request is
consistent with several others received from
agencies and studies proposed in this RSP.
Section 4.3.2: Caribou
Population Evaluation
Section 4.5.1: Noise Study
ADNR/WTSPMC Terrestrial
Resources
Study potential impacts
of noise on furbearer
presence, trapping, and
subsistence use during
construction and
operation
No
The Cooperative believes that this study request is
consistent with several others received from
agencies and studies proposed in this RSP.
Section 4.5.1: Noise Study
ADNR/WTSPMC Terrestrial
Resources
Assess the effects of
predation of fish by birds
in the bypass reach area
No Given the overall impacts from Project
construction and operation the Cooperative doesn’t
believe this study is warranted.
n/a
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 25 August 2022
Agency Proposed
Study
Resource
Proposed Study FERC
Study
Criteria
Cooperative’s Response Corresponding RSP
Section (if applicable)
ADNR/WTSPMC
Recreation,
Land Use, and
Aesthetic
Resources
Evaluate impacts to
tourism and commercial
businesses impacts
during studies,
construction, and
operation
No
Given the overall impacts from Project
construction and operation the Cooperative doesn’t
believe this study is warranted.
n/a
ADNR/WTSPMC
Recreation,
Land Use, and
Aesthetic
Resources
Evaluate potential
impacts to overall
recreational experience
related to research,
equipment, noise, and
contractor presence
No
The Cooperative believes that this study request is
consistent with several others received from
agencies and studies proposed in this RSP.
Section 4.5.1: Noise Study
Section 4.5.2: Recreation
Inventory by Season
ADNR/WTSPMC
Recreation,
Land Use, and
Aesthetic
Resources
Assess increased access
to hunting and effects on
hunting regulations
No
Given the overall impacts from Project
construction and operation the Cooperative doesn’t
believe this study is warranted.
n/a
ADNR/WTSPMC Cultural
Resources
Study cultural and
subsistence impacts
related to potential
changes in land use,
terrestrial, and fisheries
resources
No
The Cooperative believes that this study request is
consistent with several others received from
agencies and studies proposed in this RSP.
Section 4.4.1: Subsistence
Study
ADNR/WTSPMC Cultural
Resources
Study potential changes
to portage trail, cultural
resources, subsistence
uses, and access
No
The Cooperative believes that this study request is
consistent with several others received from
agencies and studies proposed in this RSP.
Section 4.4.1: Subsistence
Study
Section 4.4.2: Section 106
Evaluation
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 26 August 2022
Agency Proposed
Study
Resource
Proposed Study FERC
Study
Criteria
Cooperative’s Response Corresponding RSP
Section (if applicable)
ADNR/WTSPMC Socioeconomic
Resources
Assess options for
transmission route and
transportation corridor
from Ekwok to
Dillingham
No
The Cooperative will be evaluating options for the
transmission route and transportation corridor as
part of ongoing engineering and design efforts.
n/a
FERC Aesthetic
Resources Noise Study Yes
The Cooperative agrees that conducting this study
will confirm the limited (if any) impact of noise
from the Project relative to the ambient noise from
the Nuyakuk Falls. See Section 4.5 for further
details.
Section 4.5.1: Noise Study
NMFS Fisheries
Resources
Fish Distribution, Timing
of Migration, and
Abundance
Yes
The Cooperative agrees that conducting a fish
species distribution and abundance analysis in the
Project area would be beneficial. See Section
4.1.1 for further details.
4.1.1: Characterization of the
Fish Community and
Behavior Near the Project
Area
NMFS Fisheries
Resources
Upstream Fish Passage
through Nuyakuk Falls
Yes
The Cooperative agrees that modeling of the Falls
is necessary to document current passage
conditions at all flows and the impact to the Falls
(positive and/or negative) from incorporating the
Project. See Section 4.1.2 for further details.
4.1.2: Nuyakuk Falls Fish
Passage Study
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 27 August 2022
Agency Proposed
Study
Resource
Proposed Study FERC
Study
Criteria
Cooperative’s Response Corresponding RSP
Section (if applicable)
NMFS Fisheries
Resources
Downstream Passage and
Intake Design Yes
The Cooperative agrees that modeling of the Falls
is necessary to document current passage
conditions at all flows and the impact to the Falls
(positive and/or negative) from incorporating the
Project. See Section 4.1.2 for further details.
4.1.2: Nuyakuk Falls Fish
Passage Study
NMFS Aquatic
Resources
Flow Duration Curve
Change Analysis No
Per collaboration with NMFS and other parties
during the abeyance period, this study and the
“Future River Flows” study (see next comment),
have been synthesized into a single agreed upon
study to be conducted during the study program.
Section 4.1.7: Future Flows
Study
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 28 August 2022
Agency Proposed
Study
Resource
Proposed Study FERC
Study
Criteria
Cooperative’s Response Corresponding RSP
Section (if applicable)
NMFS Aquatic
Resources
Future River Flows and
Water Temperatures No
Per discussions with the ARWG during the
abeyance period, the Cooperative has agreed to
conduct the Future River Flows study in
collaboration with NMFS.
Section 4.1.7: Future Flows
Study
NMFS Aquatic
Resources Ice Processes Assessment Yes
The Cooperative understands the concerns
associated with potential icing issues and has
proposed a study to assess those conditions. See
Section 4.2.3 below.
Section 4.2.3: Ice Processes
Assessment
NMFS Fisheries
Resources
Assessment of False
Attraction at the Tailrace
Fish Barrier
Yes The Cooperative agrees that conducting this study
is necessary. See Section 4.1.4 for further details.
Section 4.1.4: Assessment of
False Attraction at the
Tailrace Fish Barrier
Royal Coachman
Lodge
Fisheries
Resources
Effect of hydro turbines
on salmonids (sockeye,
king, and coho salmon
smolts; pink salmon
alevin and fry)
No
The Cooperative appreciates the request and while
sufficient detail isn’t present to fully understand
the intent of the study request, we believe it best
aligns with ADFG’s Fish Entrainment and
Impingement Study. See Section 4.1.3 for further
detail.
4.1.3: Fish Entrainment and
Impingement Study
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 29 August 2022
Agency Proposed
Study
Resource
Proposed Study FERC
Study
Criteria
Cooperative’s Response Corresponding RSP
Section (if applicable)
Royal Coachman
Lodge
Fisheries
Resources
Commercial,
Subsistence, and Sport
Fishing Economic Study
No
The Cooperative appreciates the request and while
sufficient detail isn’t present to fully understand
the intent of the study request, we believe it best
aligns with ADFG’s Subsistence Survey. See
Section 4.4.1 for further detail.
Section 4.4.1: Subsistence
Study
Royal Coachman
Lodge
Fisheries
Resources Resident Fish Passage No
The Cooperative appreciates the request and while
sufficient detail isn’t present to fully understand
the intent of the study request, we believe it best
aligns with ADFG and NMFS’s fish passage study
requests. See Section 4.1.2 for further detail.
4.1.2: Nuyakuk Falls Fish
Passage Study
Royal Coachman
Lodge
Water
Resources Dissolved Oxygen Study No
The Cooperative appreciates the request and while
sufficient detail isn’t present to fully understand
the intent of the study request, we believe it best
aligns with ADFG and NMFS’s fish passage study
requests and the Cooperative will incorporate a
dissolved oxygen assessment into the methods.
See Section 4.2.1 for further detail.
4.2.1: Water Quality
Assessment – Dissolved
Oxygen and Water
Temperatures
Royal Coachman
Lodge
Aquatic
Resources
Effect of Reduced Water
Flows through Nuyakuk
Falls
No
The Cooperative appreciates the request and while
sufficient detail isn’t present to fully understand
the intent of the study request, we believe it best
aligns with ADFG and NMFS’s fish passage study
requests. See Section 4.1.2 for further detail.
4.1.2: Nuyakuk Falls Fish
Passage Study
Royal Coachman
Lodge
Cultural
Resources
Portage Trail
Archaeology Study No
The Cooperative appreciates the request and while
sufficient detail isn’t present to fully understand
the intent of the study request, an assessment of
the Portage Trail, from a Cultural perspective will
be conducted in conjunction with the
comprehensive Section 106 process for the
Project. See Section 4.4.2 for further detail.
4.4.2: Section 106
Evaluation
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 30 August 2022
Agency Proposed
Study
Resource
Proposed Study FERC
Study
Criteria
Cooperative’s Response Corresponding RSP
Section (if applicable)
Royal Coachman
Lodge
Recreation
Resources
Recreation Effect and
Economics Study No
The Cooperative appreciates the request.
Sufficient detail regarding goals and methodology
is not present to determine the feasibility and need
for the proposal.
n/a
Royal Coachman
Lodge
Aesthetic
Resources
Aesthetics and Noise
Study No
The Cooperative appreciates the request and while
sufficient detail isn’t present to fully understand
the intent of the study request, we believe it best
aligns with FERC’s Noise Study. See Section
4.5.1 for further detail.
4.5.1: Noise Study
Royal Coachman
Lodge
Aquatic
Resources
Project Minimum Flow
Requirements Study No
The Cooperative appreciates the request. While
sufficient detail regarding goals and methodology
is not present to determine the feasibility and need
for the proposal, we believe that the results from
the studies proposed below along with the
hydraulic model will define both the minimum
flows required for continued fish success and the
flows that the Project can function with.
n/a
UTBB N/A Engineering Feasibility
Study No
The Cooperative appreciates the request and while
we don’t feel this falls under the category of a
required natural resource study, we plan on
conducting both extensive bathymetric and
geotechnical surveys to confirm the feasibility of
the site for development. While not expected,
based on initial analysis, if either of these
assessment returns unfavorable results, the
Cooperative would not construct the Project.
n/a
UTBB Aquatic
Resources Flow and Sediment Study No
The Cooperative appreciates the request and while
sufficient detail isn’t present to fully understand
the intent of the study request, we believe it best
aligns with ADFG and NMFS’s fish passage study
requests. See Section 4.1.2 for further detail.
4.1.2: Nuyakuk Falls Fish
Passage Study
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 31 August 2022
4.0 PROPOSED STUDIES
4.1 Aquatics/Fisheries Resources
The following draft study plans were developed to address the structural and operational features
of the proposed Project that have a direct connection, i.e., nexus, with the fish and aquatic
resources of the Nuyakuk River. Water diversion through the powerhouse is the fundamental
action from which most of the potential impacts of the Project originate. Water diversion would
reduce flow and may change habitat conditions through the approximately 0.82-mile Falls zone
of hydraulic influence that comprises the Nuyakuk Falls, create an additional downstream
passage route for fish via the power tunnel/penstock, and redistribute river flow below the Falls
to a localized discharge point from the tailrace on the right bank (looking downstream) of the
river. Also, the construction of several Project components (e.g., groin, intake, tailrace) will
replace existing fish habitat in the river with flow control structures upstream and downstream of
the Falls and thereby alter the habitat characteristics of areas in the vicinity of those components.
These changes in flow patterns and channel structure have the potential to positively, or
negatively, alter fish and aquatic habitat and affect fish behavior. In addition, any future changes
in regional climate may influence the flow and temperature of water entering the Project Area
which may influence Project operations (timing and magnitude of flow diversions) necessary to
respond to changes in fish behavior and survival. The relationships between the Project and fish /
habitat are formalized by nexus statements that describe the most likely impacts, appropriate
evaluation metrics and criteria, as well as operational considerations, including monitoring and
adaptive management (Appendix C1).
The Project and water diversion operations may affect multiple life stages and species of fish and
may result in either individual or population level impacts at or away from the Project (Figure 4-
1). In this regard, we have chosen a conceptual and analytical framework approach that
describes the likely relationships of those impacts on fish and their habitat. Conceptually, this
includes both adult and juvenile fish passing upstream and downstream through the Project Area,
and the potential interactions between those components. For salmon, although a substantial
portion of their life history takes place outside the Project Area, the health and vitality of the life
stages when they are within the Project Area can influence the overall population viability. The
framework includes the necessary analytical tools comprised of technical studies, models,
mathematical equations, and metrics, and the underlying assumptions that will be applied to
quantitatively and/or qualitatively define potential Project effects. One key tool in the overall
assessment is the development of a two-dimensional hydraulic model that extends from
approximately 1000 ft (0.19 mi) upstream of the powerhouse intake to 1400 ft (0.27 mi)
downstream of the powerhouse tailrace (4310 ft or 0.82 mi total). The 2D model will be used to
assess hydraulic and fish habitat changes in the Nuyakuk Falls and in proximity to the in-river
Project structures. The framework horizon extends over the anticipated life of the Project and
will encompass factors such as flow and water temperature that may slowly change over time
requiring modification to Project operations to offset potential effects on future populations.
Our proposed approach to formalize the conceptual and analytical framework is to create a Life
Cycle Model (LCM). As a numerical tool, it allows the testing of various scenarios and
assumptions over space, stages, and time. These analyses support the evaluation of which
relationships are most sensitive to changes in the factors that influence them. We can use this
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 32 August 2022
tool to quantitatively assess how the Project and its operations may affect specific fish
populations.
Figure 4-1. Simple salmon life cycle and potential Project impacts. A similar conceptual approach
may be applicable to resident species. Time and periodicity are implicit.
As we are working towards development of a customized LCM, we will also proceed toward
designing it to support an Integrated Risk Assessment (IRA). An IRA can be described as an
approach to evaluate potential Project impacts to fisheries resources at the population level. The
IRA will integrate population responses to a range of environmental and Project conditions or
scenarios, such that we can evaluate the likelihood of certain benefits and costs associated with
the Project across a range of environmental and operational conditions. This component will
describe what fisheries relationships are of concern, how risk to those resources will be assessed,
and the types of scenarios and sensitivity analyses that may be conducted to identify the extent to
which various factors may influence the fish populations.
Nexus statements, the conceptual / analytical framework, Life Cycle Modeling, and the analysis
procedures for the IRA are all components that can be used to assist in the design and refinement
of specific field and desktop studies. At this time, there are four central potential impacts
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 33 August 2022
(positive or negative) associated with construction and operation of the Nuyakuk Project. These
include whether, and the extent to which Project operations may:
1. impact the timing, distribution, and overall success of fish moving upstream and
downstream through the Falls Reach (defined as the river reach from the point of
proposed intake to the downstream end of the pool adjacent to the proposed tailrace);
2. result in direct and/or indirect mortality of downstream moving fish passing via the
powerhouse or the Falls Reach;
3. strand or trap fish in the Falls Reach and result in the potential scour of spawning habitat
below the Falls and tailrace; and
4. result in migration delay or injury which manifests as delayed mortality of fish due to
false attraction at the Project tailrace or changes in habitats below the Falls.
To address the potential Project impacts listed above and described in Appendix C, we have
identified fish and aquatic studies for which a proposed study approach is presented. These
studies constitute a component of the feasibility assessment for the Project based predominantly
on desktop studies, however, this does not preclude the potential need for empirical data
collection to validate the findings or investigate a critical relationship. Information from these
studies will be used in the LCM and the IRA of various fish species and life stages.
• Characterization of the Fish Community and Behavior Near the Project Area
• Nuyakuk Falls Fish Passage Study
• Fish Entrainment and Impingement Study
• Assessment of False Attraction at the Tailrace Fish Barrier
• Sockeye and Chinook Salmon Life Cycle Model
• Integrated Risk Assessment
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 34 August 2022
4.1.1 Characterization of the Fish Community and Behavior Near the Project Area
4.1.1.1 General Description of Proposed Study
In Section 5.2.3 of the PAD, the Cooperative identifies a series of fisheries studies to be utilized
in an effort to document both the existing condition and the level of impact (positive and
negative) to the Project area as a result of construction and operations. One of the potential
studies was identified as:
• Fish Species Seasonal Distribution and Abundance Near the Project Site
• In addition, the Cooperative conducted extensive study collaboration with the Aquatic
Resources Working group through 2020 and into 2021. This collaboration identified
the need to also characterize the current migratory behavior of targeted fish species,
specifically Sockeye and Chinook Salmon.
Per multiple PAD comment and study request letters, including those from ADFG and NMFS,
the Cooperative received general concurrence with their proposal to conduct this study and looks
forward to collaborating with all interested stakeholders in further defining the specific area of
assessment and associated methodologies to utilize for this study.
4.1.1.2 Geographic Scope
The Cooperative proposes to conduct seasonal species abundance and distribution surveys for
resident and anadromous salmonids in potential areas of Project impact from approximately 0.5
miles upstream of the Nuyakuk Falls (the Falls) to an area approximately 0.5 miles downstream
of the Falls, which includes the proposed tailrace area of the Project (Figure 4-2). Based on
current design, this 1.36 mile study area would account for the entire area of potential flow
alteration associated with Project operations. At this time, it is not anticipated that a significant
amount of upstream natural flow alteration would occur more than 0.5 miles upstream of the
intake and all flow is anticipated to be returned to the system well within 0.5 miles downstream
of the Falls.
There will be three key zones of study in which, a variety of methods may be used depending on
likely efficiency of data collection and safety considerations. Those three zones are as follows:
• Zone 1 – 0.5 miles upstream of the Nuyakuk Falls with the downstream end of Zone
1 located at the Falls hydraulic control (Upstream of Falls);
• Zone 2 – The Nuyakuk Falls Reach from the upstream hydraulic control to the Falls
tail-out (Falls); and
• Zone 3 – From the tail-out of the Falls to 0.5 miles downstream (Downstream of
Falls).
The extents of the study area may be modified according to new information on hydraulics and
flow field generated from 2D modeling. In addition, activities such as fish collection for
telemetry may occur outside the proposed study area and may include sampling in areas outside
of the three zones such as downstream of tributary mouths
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 35 August 2022
Figure 4-2. Proposed characterization of the fish community and behavior near the Project area study Zones 1-3, Nuyakuk River, Alaska
(FERC No. 14873).
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. 36 August 2022
4.1.1.3 Study Goals and Objectives
The primary goal of this study is as follows:
Determine the seasonal timing, species composition, relative abundance, habitat use and
migratory patterns (distribution) of fishes within the Project Area.
Eight specific questions will be addressed by this study.
1. What fish species use the aquatic habitats in the Project Area across seasons?
a. Focus on piscivores at intake, potential groin area, in the Falls, powerhouse tailrace,
Falls tailout
b. Seasonal movements and habitat use by Arctic Grayling.
2. What is the relative abundance of fishes in the Project Area seasonally?
3. What are the baseline migratory patterns and behaviors (such as timing, holding, number
of attempts) evident for Sockeye and Chinook Salmon passing upstream through the
Project Area?
4. What is the proportion of adult salmon that successfully pass through the Falls Reach
under baseline conditions?
5. What is the baseline condition of injury/mortality in adult salmon observed downstream
of the Falls proper?
6. What is the baseline migration pattern and distribution across the channel for Sockeye
and Chinook Salmon passing downstream through the Project Area?
7. What is the proportion of juvenile salmon that successfully pass through the Falls Reach
under baseline conditions?
8. What is the baseline condition of injury/mortality in juvenile salmon passing the Falls
proper?
9. Is there visual evidence of avian or mammalian predation of salmon smolts in the Project
Area across seasons?
4.1.1.4 Relevant Resource Management Goals
Five species of anadromous salmonids and multiple resident species are known to utilize the
Nuyakuk River at some point during their life cycle. Limited data exists documenting the extent
to which they utilize the proposed Project area and/or the watershed upstream.
The Fish and Game Act requires ADFG to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the
interest of the economy and general well-being of the state” (AS 16.05.020).
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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ADFG – Division of Sport Fish Mission is “to protect and improve the state’s recreational and
fisheries resources”. According to the 2015-2020 Division of Sport Fish Strategic Plan, the
management priority is to manage Alaska’s recreational fisheries for sustained yield and
recreational angler satisfaction that is centered on an area-based management system. The
division’s fish habitat program is directed at protecting and restoring fish habitats for the benefit
of fish and current and future recreational anglers.
Further, NMFS’s relevant resource management goals are captured in the NOAA Fisheries
Strategic Plan for 2019-2022 (NOAA 2019a) and the Strategic Conservation Action Plan for
Southwest Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy oceans
which support healthy populations of marine species and sustainable commercial and
recreational fisheries. NMFS involvement is supported by mandates under the Fish and Wildlife
Coordination Act and Magnuson-Stevens Fishery Conservation and Management Act.
4.1.1.5 Existing Information and Need for Additional Information
Available fisheries data for the Nuyakuk River was summarized in the PAD; however, since
PAD development, additional data have become available and may provide additional insight
into fish community and habitat use in the Project Area. A brief review of the Alaska
Department of Fish Game’s Anadromous Waters Catalog indicated that five species of Pacific
Salmon have been documented upstream of the Project Area in the Tikchik River (Johnson and
Blossom 2019). In addition, Sockeye Salmon escapement data for the Nuyakuk River is
available for the period from 1950 to 2006. These daily counts also provide an historic record of
run timing for adult Sockeye Salmon entering the Project Area.
More site-specific information is necessary to fill data gaps needed to adequately define the
existing condition at the proposed Project site and assess any potential impacts (positive and
negative) associated with Project development and operations. The Cooperative looks forward
to continued collaboration with stakeholders over the next few months in developing and
refining the best suite of methods to effectively characterize the fish community in the Project
Area.
4.1.1.6 Project Nexus
The proposed Project would divert a percentage of Nuyakuk River flow from upstream of the
Falls through a powerhouse at a variable rate over time. All water would then be returned to the
natural channel immediately below the Falls resulting in a short bypass reach consisting almost
entirely of the Nuyakuk Falls section and herein called the Falls Reach. Riverine habitat in the
Falls Reach would change in quantity and composition of habitats due to a reduced quantity and
altered distribution of flow. Channel configuration, substrate composition, and the composition
and configuration of habitat below the Falls proper could also be modified. Some riverine
habitat will be replaced with water conveyance structures. These potential changes in fish
habitat may affect the timing, distribution, relative abundance, and survival of the present fish
community and respective behaviors. Appendix C contains a more comprehensive listing of
primary and secondary Project nexus issues, methods and hypotheses related to potential
operational effects in the Project Area.
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Understanding the seasonal presence and distribution of anadromous and resident salmonids and
the seasonal habitat use by fishes in the Falls Reach will be essential for evaluating the impacts
(positive and negative) associated with Project development and operation. For specific study
activities, such as observational/telemetry tasks, target species will be selected in cooperation
with the Aquatic Species Working Group.
4.1.1.7 Methodology
The Cooperative has a vested interest in developing a collaborative study that effectively meets
the needs of the stakeholders while at the same time focuses on the area of potential impact. As
such and per commitment from stakeholders such as ADFG, NMFS and BBSRI, the Cooperative
will continue working with stakeholders to refine study methods to be utilized to ensure both
effective documentation of existing conditions and a safe study design for all biologists in the
field.
There are numerous methods that can be used for sampling fish in riverine systems, but the
effectiveness of each is highly dependent on prevailing sampling conditions (water velocity,
depth, turbidity, water temperature, etc.), target fish species and life stages and their behavioral
characteristics, and the timing of sampling. Based on available information, the Cooperative has
developed a preliminary study plan for consideration, that includes a number of candidate
sampling methods deemed initially suitable for the three zones of the Project study reach. The
overall methodology includes an initial compilation and review of literature and available data.
This review and each of the methods under consideration are described below.
Literature Review
This study will begin with a comprehensive literature review summarizing available information
on fish abundance, distribution, and species periodicities in the Nuyakuk River. The review will
include information presented in the PAD as well as data sources identified by NMFS in their
February 4, 2020 Study Request such as ADFG tower counts, Brennan et al. 2019, Igiugig
Project (P-13511), Daigneault et al. 2007 and other similar drainages in Bristol Bay. The
literature review will ultimately result in a better understanding of species potentially present at
the Project, the species-specific periodicities of use of the Project area, and potential interannual
variability in run timing.
Understanding the species and life-stage specific periodicities of fish in the Nuyakuk River will
be important for determining appropriate sampling times for certain fish species likely to be
present, especially during migrations. The initial periodicities will be based in part on a general
understanding of the local populations as described in the published literature and refined via
collection of site-specific data. The Cooperative has identified the following potential data
sources and literature that may be useful in defining species and life stage periodicities:
• Bristol Bay Science and Research Institute Reports
• Observation Tower Counts 2003-2006
• Aerial Escapement Counts 1967-1999
• Alaska Department of Fish and Game Management and Sport Fish Reports
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•Alaska Department of Fish and Game e-Library
•Radio Telemetry Data 2000-2006
•Commercial and Sports Catch Records, including fishing lodge catch locations
•Run Timing Data and Statistics 2006
• University of Washington –Alaska Salmon Program
•U.S. Fish and Wildlife Service
•Alaska State Parks
•FERC Document e-Library
•Local Fishing and Conservation Groups
Based on this review and discussions with state and federal agencies and stakeholders, a
species/life stage periodicity chart will be developed for use in the Aquatics and Fish Resources
studies. A preliminary example of periodicities for the major commercial and sport-fish species
of the Nuyakuk River based on an initial review of published and unpublished information is shown
in Table 4-1. This table will be revised during the study as more site-specific data on fish periodicity
is obtained.
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Table 4-1. Preliminary life-stage periodicity for a sample of the fish species utilizing the Nuyakuk
River, Alaska. Subject to revision.
Species1 Life Stage Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Chinook Salmon Adult Migration
Spawning
Fry Emergence
Juv. Rearing
Juv. Outmigration Chum Salmon Adult Migration
Spawning
Fry Emergence
Juv. Rearing
Juv. Outmigration Coho Salmon Adult Migration
Spawning
Fry Emergence
Juv. Rearing
Juv. Outmigration Pink Salmon Adult Migration
Spawning
Fry Emergence
Juv. Rearing
Juv. Outmigration Sockeye Salmon Adult Migration2
Spawning
Fry Emergence
Juv. Rearing
Juv. Outmigration Arctic Grayling Adult Rearing
Spawning
Fry Emergence
Juv. Rearing Dolly Varden Adult Rearing
Spawning
Fry Emergence
Juv. Rearing Rainbow Trout Adult Rearing
Spawning
Fry Emergence
Juv. Rearing
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Candidate Fish Sampling Methods
The Cooperative has identified various fish sampling methods that may be applicable for the
Project area including methods for characterizing: 1. fish community, 2. upstream adult salmon
migration, 3. downstream juvenile salmon migration, and 4. timing, distribution and relative
abundance piscivores.
1.Fish Community
The application of methods will differ between zones due to varying sampling conditions that in
Zone 2 include areas that would be hazardous to sample. As a result, the surveys conducted in
Zone 2 will be limited due to both effectiveness of the methodology and constraints in sampling
imposed by hazardous conditions. Strict safety protocols will be developed and employed during
all fish sampling activities.
In Zones 1 and 3, the Cooperative suggests application of a systematic seasonal sampling
approach targeting juvenile Pacific salmon and resident fish species. For this, five transects will
be established at 200-meter intervals in Zones 1 and 3; each transect will be surveyed during
(spring, summer, and fall sampling event) (Figure 4-3). The Nuyakuk River is approximately
150-210 meters wide at the Project area. Directed fish collection techniques will likely focus on
the margins of the stream banks due to the potentially hazardous conditions across the rest of the
channel. Fish collection surveys will occur over a 50-m-long reach located on both stream banks
beginning at the downstream end of each transect. We will use at least 3 sampling methods
within the transect area to maximize potential for capturing different species and life stages that
may occupy different habitats. Given multiple methods to deploy, it is anticipated that each
sampling event will last 10 days to cover the 10, 50m transects. Three survey events would
occur from April through September over a range of flow conditions. Based on the average
annual hydrograph, sampling events are proposed during low flows in April to May (during
lower spring discharge conditions), June to July (during high flow conditions), and again in
August to September (under decreased flow conditions) (Figure 2-6). This fish collection
window will allow for surveys to cover the majority of time that fish would likely be migrating
through or residing in the Project area.
In addition, winter sampling focused on resident fish use of habitats immediately downstream
and upstream of the falls will be conducted. This sampling will include use of underwater
imagery in holding habitats, as well as monitoring tagged Arctic grayling within the project area.
Two winter sampling events are planned one for late November or early December when fish
have likely moved to overwintering areas and one for late winter just prior to anticipated
downstream migration of Sockeye salmon juveniles.
In coordination with the entrainment study, hydroacoustics (upward and side-looking split-beam
echosounder, ARIS / DIDSON imaging sonar) may also be used to characterize the horizontal
and vertical distribution of downstream migrating salmon (smolts, fry) as they approach the Falls
and proposed Project. If deployed hydroacoustic sampling would be combined with fish
collection methods to validate species detections.
Fish collection techniques will likely include beach seines, minnow trapping, and gill/trammel
netting. The most effective sampling methods will be selected for each transect and stream bank
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based on site conditions and effectiveness/safety constraints. Beach seining with a skiff or
floating nets may prove feasible for sampling out into areas of deeper water. The use of multiple
methods will allow for the collection or observation of the diversity of fishes and life stages that
are anticipated to be encountered in the Project area. To facilitate comparison among sampling
events, to the extent possible and given that conditions may change and preclude the use of a
gear type (e.g., visibility may change from survey to survey), the same methods will be
implemented with a similar level of effort at each transect and bank on return visits.
As noted above, fish sampling in Zone 2 will occur on an opportunistic basis at locations that are
determined safe to sample based on depth and velocity (Figure 4-3). Instream margins and
accessible slow water habitats will be the focus in Zone 2 to identify juvenile rearing
opportunities within the Falls section. The primary survey method to be used would include
minnow trapping Fyke netting and backpack electrofishing might be an option on a limited basis
if conditions allow for safe deployment and retrieval. Likewise, stationary underwater video or
sonar-based monitoring may prove useful for data collection while minimizing in-water work.
Using the results of the bathymetric survey (from the Fish Passage Study), fish surveys in Zone 2
would target potential stranding areas to evaluate fish use under the existing and potential future
flow regimes. Fish surveys in Zone 2 would occur on the same seasonal sampling schedule as
Zone 1 and 3. Assuming flow conditions allow, we will sample the same sites at each of the three
sampling events to look for changes in fish occupancy over the open-water period. Sampling
efforts in July and August may provide additional information on fish stranding potential as
flows are typically descending during these months (Figure 2-6). Proposed survey areas and
techniques for Zone 2 will initially be evaluated for safety and identified during the
reconnaissance survey. Fish abundance and distribution surveys will also visually identify
migratory fish behavior occurring in the study area while capture techniques occur. Specific data
forms will be generated to enumerate counts of salmon that are observed to be actively staging,
spawning or holding within the cascade. These data will be used to compare peak number per
day and movement patterns past points above and below the proposed Project.
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Figure 4-3. Candidate sampling locations within zones 1 and 3 for characterizing fish community and behavior near the Project area.
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Seines
Hand-held beach or boat-assisted shoreline seining (approximately 10 m long, 1.5 m deep,
comprised of 3-6 mm mesh) may be used to target juvenile salmon and small-bodied resident
fish species. Hand-held seines can be deployed in shallow areas along banks and islands with
one end of the net anchored to the shore and the other end extended out from shore and then
looped around to encircle the fish as the ends are pulled in against the beach or gravel bar.
Larger beach seines (approximately 50 m long, 3 m deep, comprised of 13-25 mm square mesh)
may be used to target adult resident fish species. A 30 m lead and bridle assembly will be
attached to each end of the beach seine which will be deployed from shore with a motorized
skiff. Multiple seine pulls will be required to successfully sample each 50-meter study reach.
Minnow Trapping
Minnow traps are an effective method for passive capture of juvenile salmonids and other
juvenile resident fish species in slow moving water habitats such as pools and sloughs (Bryant
2000). Wire and/or fabric minnow traps will be baited with commercially sterilized salmon roe
and soaked overnight for 16-24 hrs. Approximately 5-10 minnow traps will be deployed at each
study transect/stream bank. Each study site will be delineated into sample quadrants and the
number of minnow traps will be equally distributed among quadrants. Minnow traps will be
placed on the stream bottom, parallel to the current in areas of cover. To prevent the loss of
traps, each trap will be anchored to the stream bank by a tether line connected to the minnow trap
and individually identified with flagging.
Electrofishing
Electrofishing is a widely used method to assess fish presence, relative abundance, and
distribution that has been used successfully by ADFG in the Project Area (Zone 3) to document
fish presence. Electrofishing is effective for a wide range of fish species, life stages, and habitat
types. Electrofishing is an effective methodology to survey juvenile life stages and small-bodied
fish species but can also be utilized to survey adult fish (Temple and Pearsons 2007).
Electrofishing surveys are generally limited by ADFG during the presence of adult salmon.
Thus, adult migration will likely restrict the window of opportunity and or location for
electrofishing surveys. However, electrofishing surveys may prove to be a valuable tool when
adult salmon are not present within the Project area.
Backpack electrofishing may be used as a sampling technique in wadable reaches such as along
banks or islands. A Smith-Root LR-24 backpack electrofishing unit will be operated by a trained
field crew leader and assisted by two people with dipnets. In all cases, the electrofishing unit will
be operated and configured with settings consistent with state and federal guidelines and those
established by the manufacturer (SmithRoot 2009; ADFG [Buckwalter 2011] and NMFS [2000].
Single-pass qualitative surveys will be conducted through the study reach moving in an upstream
direction. All captured fish will be held in buckets, identified and measured, and released in close
proximity to their capture location.
Gill / Trammel Netting
Gill nets and trammel nets can be an effective technique when sampling for the presence and
relative abundance of fish populations for a wide range of anadromous and resident species, life
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stages, and habitat types (Crawford 2007). Gill nets or trammel nets provide an alternative
technique for sampling deeper, non-wadeable, mid-channel waters in the event that boat
electrofishing is not effective or restricted by permit stipulations. These net types are designed to
collect fish by entangling them as they try to swim through the mesh and as a result are not
species selective. One limiting factor of gillnets is that because they are designed to intentionally
entangle fish in the net mesh, fish mortality can be high. The mesh size used typically varies
depending on the species and life stage targeted, with smaller mesh being more effective for
juvenile life stages and smaller-bodied species (Crawford 2007). Trammel nets differ from gill
nets in that instead of a single wall of netting, trammel nets consist of three layers of netting tied
together on a common floatline and leadline. Gill nets can be deployed in a range of habitat
types in streams, rivers and lakes. At sites with current, gill nets will be deployed as drift nets
and allowed to drift with the current through the sample area. At in slow water habitats gillnets
will be deployed as set (fixed) nets for a pre-determined amount of time. When used for
sampling, drift and set gillnets will be fished perpendicular to the stream channel (Crawford
2007). Ideally, nets will cover the entire depth of the stream channel where set. A range of gill
net sizes may be used from 50 to 125 feet in length and 6 to 8 feet in depth. Variable
monofilament mesh sizes ranging from 0.5 to 2.5 inches may be used to target a range of fish
species and sizes. When drift gill nets are selected for use, they will be deployed and allowed to
float through the 50-meter-long sample reach at transect before being collected. Multiple passes
may be necessary to adequately sample the channel width. In order to reduce the variability
between sites and seasons, sampling efforts will be standardized by using similar drift distances
or soak times. Soak times for set gill nets will be developed with input from resource agencies.
2.Upstream Adult Salmon Migration
Methods for characterizing migratory behavior of adult Sockeye and Chinook salmon may
include visual survey methods and active bio-telemetry. Field testing in 2022 will inform the
potential effectiveness of active telemetry, passive and or visual observation to meet study
objectives. Field testing and selection of most effective methods for evaluating adult behavior
will be conducted in collaboration with the Aquatic Resources Working Group.
Visual surveys in combination with biotelemetry (radio or acoustic) will be used to estimate the
timing, number, and migratory patterns of adult Sockeye and Chinook salmon as they migrate
and spawn within the study area. During 2022 field methods testing we will evaluate the
potential to operate Sockeye counting towers in Zone 3, capture adult salmon in holding pools
downstream of the falls, and the potential effectiveness of tracking radio tagged salmon
approaching, moving through, and exiting the falls. Drones are our preferred method for
collecting visual observations, although collection of supplemental behavioral data via
underwater video will be evaluated for use at specific locations such as holding areas,
downstream of the falls.
The study area for adult migratory behavior observations will begin at the downstream end of
potential tailrace area (Zone 3) and extend to the upstream end of Zone 1 (approximately 2.5 km
(1.5 mi) in length). Biotelemetry will coincide with Chinook and Sockeye salmon runs. Based
on a preliminary review of fish periodicity at Nuyakuk Falls (Table 4-1), drone observations
should begin in late-June with the arrival of the first Chinook and continue until all tagged
Sockeye have passed through Zone 1. Drone surveys will be designed to document the spatial
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and temporal distribution of salmon within the study area, evaluate trends such migration timing
and proportion of salmon passing through different routes of Zones 1-3. These surveys will be
weather dependent.
Drone footage will be reviewed to characterize Sockeye and Chinook salmon migratory
behavior. We will attempt to document fish holding or resting in pools located within Zone 2 as
well as passage routes. Drone surveys may also provide information on whether any spawning
occurs within the proposed bypass reach, specifically near proposed Project elements (e.g.,
tailrace, intake, or groin locations), and will allow for documentation of the nearest redd
locations to the Project. Photo or video documentation would provide imagery for later playback
and analysis of tagged fish position within the cascade, if necessary.
Drone surveys completed in reaches above and below the Falls Reach will identify areas where
potential spawning gravel may exist including the area within and downstream of the proposed
tailrace. Any gravel observed during visual surveys will be documented, sampled to determine
size classes present, measured for total area, and flagged in the project database to avoid human
traffic on potentially sensitive spawning areas during other sampling operations. If spawning is
observed, output from 2D models will be reviewed to define areas where potential changes in
operational flows could dewater or scour observed redds. The potential impact area to potential
for fish incubation effects based on estimates of redds/square meter and embryo per redd
(estimated from literature by species) will be related.
Environmental conditions (weather, water clarity/turbidity, discharge/depth, sun angle, glare,
etc.), survey extent or flight path, areas of fish concentrations, and fish behavior (e.g., holding,
migrating, staging, spawning) will be recorded during each survey. It is anticipated that multiple
passes may be necessary to cover the study area especially when multiple species are present.
To collect information on passage routes and holding/resting pools areas in Zone 2, multiple
passes will be made focusing on documenting the spatial distribution of fish (e.g., left bank,
center, right bank, various chutes, or sides of islands) as they move upstream. Any instance of
adult salmon holding, milling, searching, or jumping at passage obstacles will be noted and
included during modeling efforts to identify risks or stranding/ trapping/ migration delay under
the Fish Passage Study. The specific upstream and/ or fallback route selection for adult salmon
could also be documented using bio-telemetry technology for a subset of adults of each species,
captured and tagged during upstream migration at a point downstream of Zone 3. Documentation
of fish spatially distributed in Zone 2 will provide a general understanding of fish passage routes
through the Nuyakuk Falls cascade under a variety of flow conditions and may be useful in
interpreting hydraulic conditions under the fish passage study. However, it is anticipated that
turbulence, air bubble entrainment, or depth may preclude observations in some areas or at
certain flows. The focus of drone surveys is adult salmon; however, if possible, information on
other species will be collected opportunistically.
3. Downstream Juvenile Salmon Migration
In addition to transect sampling, the use of incline plane and/or fyke nets will specifically target
downstream migrating juvenile salmon and movements of other fish species. Downstream
migrant trapping will be conducted to develop site-specific information on the migratory timing
and size of juvenile salmon and other migratory fishes that will be used by the Fish Passage and
Fish Entrainment and Impingement Studies. Downstream migrant trapping may occur at several
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locations in the Project area to account for spatial variability; however, survey efforts will be
focused in Zone 1 on the right bank upstream of the proposed Project intake (Figure 4-3), as well
as across the river on the left bank. Downstream migrant trap/collection will provide a baseline
for migratory timing and species composition of out-migrating fishes.
Prior to selecting specific trapping locations, the area near the proposed intake will be evaluated
during 2022 field testing to find two sites that have suitable depth and velocity conditions, a trap
attachment location, and would be safe to access over a range of anticipated flows. It is
anticipated that small-mesh fyke netting may also be an effective collection technique for
downstream migrants and, depending on flow conditions could be utilized to supplement
trapping efforts downstream of incline plane traps. To capture the entire range of migration
timing, downstream migrant trapping will be initiated as early in spring as feasible given that
traps are difficult to operate during icing conditions. Migrant traps should be operated a
minimum of 72 hours during each week of the run with operation focused on peak daily run
windows (nocturnal or crepuscular periods) as can be determined based on observed behavior
patterns at this location. Thus, the 72 plus hours of operation could be achieved through a
combination of days operated and number of hours operated each trap day. Traps will be checked
as often as necessary to avoid overcrowding and a minimum of once daily.
In coordination with the entrainment study, hydroacoustics (upward and side-looking split-beam
echosounder, ARIS / DIDSON imaging sonar) may also be used to characterize the horizontal
and vertical distribution of downstream migrating salmon (smolts, fry) as they approach the Falls
and proposed Project.
4. Timing, distribution and relative abundance of Piscivores
ADF&G has expressed concern that the falls habitat may be important feeding area for resident
fishes. To help improve our understanding of resident fish use of the Project Area, we will use
biotelemetry to evaluate Arctic Grayling habitat use in combination with underwater camera
observations to help understand the seasonal use of the falls. Tagging will occur in the winter or
early spring and again in the fall, assuming successful fish capture locations. This will allow us
to evaluate Arctic grayling behavior during salmon outmigration as well as overwinter behavior.
The types and sizes of tags will be determined based on 2022 field methods testing. Assuming
close proximity of collection locations to the falls, we propose 30 tags allocated to each tag
group, spring and fall for 60 total tags deployed. The telemetry array established for adult
salmon behavior will be refined to support detection of movement and/or residency of tagged
Arctic grayling within the 3 sampling zones.
Additional information on the presence of piscivorous fishes by habitat type will be documented
through seasonal fish collection efforts as well as traditional knowledge, and documentation of
angling efforts by local outfitters. These data can be used in conjunction with the 2D hydraulic
model to evaluate the potential for creation or elimination of piscivore habitat under with-Project
conditions (see Section 4.1,2.1). In addition, during the smolt outmigration period when staff are
on site for fish sampling additional observations of avian and mammalian predators in the project
area will be recorded. If significant avian or mammalian predation is evident in Year 1, we will
evaluate methods that could be used to quantify this mortality in Year 2.
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4.1.1.8 Proposed Deliverables and Schedule
Assuming timely issuance of the Study Plan Determination, the Cooperative plans conducting
the study in 2023 and 2024. Upon implementation, study results will be documented in the Initial
Study Report (ISR) and Updated Study Report (USR). It is notable that the Cooperative
anticipates ongoing collaboration with stakeholders throughout the study process so that
determinations related to efficiency of methodology, any study modifications that may be
necessary and/or the need for extending studies can be discussed and efficiently implemented.
This collaborative process will also allow the Cooperative to provide stakeholders with periodic
status updates when results, anomalies, etc. warrant.
4.1.1.9 Level of Effort and Cost
The Cooperative agrees with stakeholders that this study will need to be a multi-year effort (2023
and 2024) to adequately define the existing condition near the Project site for the fish species of
interest in a seasonal and life stage-specific construct.
The estimated cost for this study is approximately $900,000 - $1,600,000.
4.1.2 Nuyakuk Falls 2 Fish Passage Study
4.1.2.1 General Description of Proposed Study
In Section 5.2.3 of the PAD, the Cooperative identifies a series of fisheries studies to be utilized
in an effort to document both the existing condition and the level of impact (positive and
negative) to the Project area as a result of construction and operations. One of the potential
studies was identified as:
•Nuyakuk Falls Fish Passage Evaluation and Modeling
This study will evaluate the physical and hydraulic conditions that occur within the cascade/Falls
Reach over a range of flow conditions, and then via modeling, assess conditions that could occur
under proposed Project operations and likelihood of fish passage under these new conditions.
The focus will be on determining whether and to what extent the upstream migration of adult
salmon and other fish species, and downstream migration of fry, juveniles and smolts may be
affected by Project operations. One of the central issues to be addressed is whether the currently
proposed minimum bypass release flow of 1,000 cfs will be sufficient to provide unobstructed
fish passage through this reach, or whether alternative flow releases are needed. Figure 4-4
illustrates this by showing potential effects of Project operations on Nuyakuk River flows on a
monthly basis for the most recent 25 years of USGS gage data. As a secondary element, the
study will also evaluate potential risks of stranding and trapping of fry and juvenile/smolts that
may occur during certain periods of Project operations. Figure 4-5 depicts conditions within the
study reach at 7,200 cfs on June 22, 2017, and illustrates potential adult migration pathways and
2 Although this reach of river has been referred to as the Nuyakuk Falls, it is better characterized as a series
of steep cascades and chutes interspersed with localized bedrock Falls that create a series of whitewater rapids
consisting of highly turbulent non-uniform flows. For purposes of this study plan, the reach will continue to be
designated as Nuyakuk Falls.
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potential stranding and trapping areas. This study will evaluate how these pathways may be
affected by alterations in flow, and the potential risk of stranding and trapping.
The study is of paramount importance in the licensing process since the entirety of the Nuyakuk
River salmon escapement must pass through this section of the river to reach upstream spawning
and rearing habitats that adjoin the highly productive lakes within Wood Tikchik State Park.
Likewise, the entirety of the smolt production from these watersheds must pass downstream
through this reach. The Cooperative understands this and is committed to understanding and
providing flow conditions that protect this important passage corridor.
Figure 4-4. Daily hydrograph of the Nuyakuk River with (regulated) and without (unregulated)
preliminary proposed Project operations, with percent flow diverted for power generation.
The regulated hydrograph includes a minimum bypass flow of 1,000 cfs.
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Figure 4-5. Schematic of Nuyakuk Falls Reach showing possible adult upstream migration
pathways, adult holding areas, and potential stranding and trapping areas. Photo taken on
June 22, 2017; flows approximately 7,200 cfs.
4.1.2.2 Geographic Scope
The geographic focus of the Fish Passage Evaluation will extend from approximately 2,640 ft
(0.5 mi) upstream of the upper end of Nuyakuk Falls to approximately 1,400 ft (0.27 mi) below
the lower end of the Falls; total length of the study area is approximately one mile (Figure 4-6).
The distance upstream of the proposed intake location reflects a reasonable distance to
characterize flow field as the water approaches the falls and proposed diversion location. This
study area encompasses the areas from both the Fish Entrainment and Impingement Study and
the Assessment of False Attraction at the Proposed Tailrace Study and defines the principal area
of the 2D hydraulic modeling. The extent of the study area may be modified based on review of
the LiDAR data and preliminary results from the 2D model.
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Figure 4-6. Approximate Fish Passage Assessment Study Area of the Nuyakuk River.
4.1.2.3 Study Goals and Objectives, and Questions to be Addressed
The primary goal of this study is to evaluate how potential Project-related flow changes may
impact fish passage through the Falls Reach.
Five objectives are listed below that define the major focus of this study:
1. Identify major (or primary) upstream (and downstream) fish passage corridors and
hydraulic conditions within the cascade/Falls Reach of the study area (i.e., proposed
bypass reach) and their potential flow sensitivities currently and under proposed Project
operations as relates to potential for stranding, predation risk, migration delay.
2.Estimate species-specific “flow windows” for successful upstream fish passage through
the cascade/ that include upper and lower passage thresholds above and below which
passage may be impaired, migration delayed, risk or predation increased, or seasonal
timing affected.
3. Identify potential areas that may be susceptible to fry and juvenile stranding and trapping
within the proposed bypass reach due to Project induced flow fluctuations (ramp-up and
ramp-down).
4.Evaluate effects of proposed Project operations and flow releases on adult upstream and
fry/juvenile/smolt downstream fish passage and potential stranding, trapping of fish.
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5.Identify potential alternative operations or refinements to operations to facilitate upstream
and downstream passage and minimize/eliminate risk of stranding and trapping.
These objectives revolve around the resolution of a series of questions associated with how
Project operations may affect fish passage conditions within the Falls Reach. Specific questions
to be addressed include:
1. Would flow-related changes in depth and velocity and habitat composition impair or
improve upstream fish passage conditions as compared to species-specific criteria?
2. Would flow-related changes in total available habitat for upstream passage result in
increased densities of fish in the Falls Reach to the point that density dependent effects
are likely?
3. Would flow-related changes in depth and velocity and habitat composition impair or
improve downstream fish passage conditions as compared to species-specific criteria?
4. Would flow-related changes in total available habitat for downstream passage result in
increased densities of fish in the Falls Reach to the point that density dependent effects
are likely?
5. Would hydraulic conditions be created that could delay upstream passage of adult
salmon?
6. Would hydraulic conditions be created that could delay downstream passage of juvenile
salmon?
7. Would flow-related changes in the Falls Reach alter depth and velocities in fish rearing
habitats or change the quantity, composition, or configuration of the rearing habitats?
8. Would rapid changes in flow dewater fringe habitat/passage corridors resulting in
potential fish stranding or trapping zones?
9. Would operational flow changes have the potential to dewater or scour spawning habitats
downstream of the Falls and tailrace?
The majority of these questions are conceptually captured in Figure 4-7, which provides an
overview of the two major potential Project induced life history impacts related to Streamflow
Regulation: upstream passage/survival and downstream passage and survival. These potential
impacts would be centered around the Project footprint that encompasses Nuyakuk Falls and
associated with primarily a flow reduction (due to diversion of flows for power generation)
within the reach. These flow alterations will change the prevailing hydraulic parameters and will
likely lead to changes in migration pathways and resting/rearing habitats that were normally
available under higher flow conditions. Depending on the timing and hydraulic conditions
provided under the draft proposed operations, upstream passage success and survival may be
reduced due to unsuitable passage conditions, shortened passage windows, delay, increased
predation, etc., or improved if more suitable conditions and longer passage windows are
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provided that decrease passage times and energy expenditures of fish. Similarly, downstream
passage success may be reduced due to potential entrainment and turbine mortality as well as
increased predation (shallower conditions) and depending on flow regulation and ramping rates,
potential stranding and trapping. Alternatively, it is also possible that downstream passage
success could be potentially improved if passage survival through fish friendly turbines is greater
than passage survival through the Falls. The flow regulation may also change depth and velocity
patterns associated with some habitats used by Resident Fish.
Figure 4-7 also incorporates the potential effects of climate change on streamflow and stream
temperature. Changes in streamflow may potentially affect Project operations and
correspondingly upstream and downstream passage success as noted above. However, given the
relatively short length of the Nuyakuk Falls Reach, climate change effects on water temperature
are not expected to be directly influenced by Project operations. This “State of Nature –
Stochasticity” effect is depicted by the blue lines in Figure 4-7.
Figure 4-7. Conceptual representation of potential major effects of Nuyakuk Hydroelectric Project
operations on upstream and downstream fish passage through Nuyakuk Falls, Alaska.
4.1.2.4 Relevant Resource Management Goals
Five (5) species of anadromous salmonids and multiple resident species are known to utilize the
Nuyakuk River at some point during their life cycle. Limited data exists documenting the extent
to which they utilize the proposed Project area and/or the watershed upstream. The Falls Reach
fish passage study would be informed by the other fisheries studies described in the PSP. Fish
presence and life history data will be utilized to ensure that appropriate species and range of
flows occurring during specific life stages are incorporated into the passage (upstream and
downstream) assessment.
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The Fish and Game Act requires ADFG to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the
interest of the economy and general well-being of the state” (AS 16.05.020).
The mission of the ADFG – Division of Sport Fish is “to protect and improve the state’s
recreational and fisheries resources”. According to the 2015-2020 Division of Sport Fish
Strategic Plan, the management priority is to manage Alaska’s recreational fisheries for sustained
yield and recreational angler satisfaction that is centered on an area-based management system.
The division’s fish habitat program is directed at protecting and restoring fish habitats for the
benefit of fish and current and future recreational anglers.
Further, NMFS’s relevant resource management goals are captured in the NOAA Fisheries
Strategic Plan for 2019-2022 (NOAA 2019a) and the Strategic Conservation Action Plan for
Southwest Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy oceans
which support healthy populations of marine species and sustainable commercial and
recreational fisheries. NMFS involvement is supported by mandates under the Fish and Wildlife
Coordination Act and Magnuson-Stevens Fishery Conservation and Management Act.
4.1.2.5 Existing Information and Need for Additional Information
Limited information exists that specifically relates to fish passage through the Nuyakuk Falls
Reach. However, fish species information and escapement estimates do exist for areas upstream
and downstream from the Falls that can be used as part of this study to draw inferences regarding
migration timing of different species. This study will also rely heavily on information gathered
as part of Study 4.1.1 – Characterization of the Fish Community and Behavior Near the Project
Area and data collected as part of that study. In addition, the study will rely on existing
information related to fish swimming and jumping criteria (e.g., Powers and Orsborn 1985,
Powers and Saunders 2002; Reiser et al. 2006; Bates 1992; Bell 1990, Katopodis and Gervais
2012; Katopodis and Gervais 2016 and others) which will be used in comparing passage
conditions under different flows.
Surface photographs and aerial imagery are available depicting conditions within the Nuyakuk
Falls Reach at various flows. In addition, on May 14, 2020, Quantum Spatial completed a
topobathymetric LiDAR (Light Detection and Ranging) survey of the Project area,
approximately centered on the Falls Reach (Quantum Spatial 2020) (Figure 4-8). The survey data
included topographic LiDAR and 3 band (RGB – Red, Green, Blue) digital imagery, enabling
the acquisition of a substantial amount of underwater topobathymetric features within the Falls
Reach. More detail regarding this survey is provided in Section 4.1.3.6. This new LiDAR data
set should prove useful in the development of a two dimensional (2D) hydrodynamic model of
the Falls Reach but will require a detailed inspection and QA/QC review to ensure its utility for
model development.
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Figure 4-8. Area of LiDAR coverage and extent of the Fish Passage Study Area in the Nuyakuk
River, Alaska.
Therefore, one of the major study components will be reviewing these data to ensure model
application. This information and data will then be used in developing appropriate two
dimensional (2D) hydraulic model(s) that can be applied to the passage assessment. The
bathymetric data will also be used in identifying potential areas of stranding and trapping. The
hydraulic models will simulate conditions within segments of the reach over a range of flows
which will help identify major passage routes and their sensitivity to changes in flow. Results of
these simulations will include velocities and depths as well as vertical heights at the Falls, which
can then be compared with known swimming and jumping criteria to determine the probabilities
of successful passage for a given flow condition and the risks associated with Project operations.
Ideally, this will lead to development of a set of flow windows that define suitable passage
conditions throughout the reach.
4.1.2.6 Project Nexus
The proposed Project would create a bypass reach and divert a percentage of flow away from the
Falls and into a penstock for power production. Diverted water would then be discharged back
into the natural channel immediately below the Falls resulting in a 0.82mile bypass section that
comprises the Nuyakuk Falls Reach. This action will reduce the quantity of river flow and the
distribution of flow through the Falls Reach. Depth/velocity distributions will affect the quantity
and composition of habitats suitable for passage and rearing. Understanding the potential impacts
to fish passage (upstream and downstream) as a result of reduced flows through the bypass reach
will assist in determining appropriate operational rule curves for power production purposes and
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the associated potential impacts (positive and negative) to fish movement. In addition, depending
on Project operations and ramping constraints, the Project could result in the stranding and/or
trapping of juveniles and fry within low gradient areas along lateral margins of the reach. This
study will identify and evaluate potential stranding and/or trapping risks due to proposed Project
operations. Appendix C contains a more comprehensive listing of primary and secondary Project
nexus issues, methods, and hypotheses related to potential operational effects in the Project Area.
4.1.2.7 Methodology
The Cooperative has a vested interest in developing a collaborative study that effectively meets
the needs of the stakeholders while at the same time focuses on the area of potential impact. As
such and per commitment from stakeholders such as ADFG and NMFS, the Cooperative plans
on working with stakeholders to define the appropriate methods to be utilized to ensure both
effective documentation of existing conditions and a safe study design for all biologists in the
field.
To assist in that effort the Cooperative has developed for consideration, the following
methodological approach for conducting this study. The approach follows that of other studies
that have considered flow induced effects on salmonid fish passage (e.g., Reiser et al. 2006; and
consists of the following five components:
1.Define species migration periodicity;
2.Establish species swimming and leaping criteria using literature-based information;
3.Conduct bathymetric mapping of reach as defined by the May 2020 LiDAR
topobathymetric data (Quantum Spatial 2020);
4. Develop 2D hydraulic model based on the terrain models developed from the LiDAR and
imagery;
5. Conduct modeling and evaluate potential effects of Project operations to address
questions posed in Section 4.1.2.3.
These elements are described more fully below.
Define Species Migration Periodicity
The general migratory life histories of many of the fish species in the Nuyakuk River involve the
upstream migration of adults seeking suitable areas for spawning, and the downstream migration
of fry, juveniles and smolts to the ocean. The timing and duration of these migrations vary by
species and life stage but in general coincide with the hydrologic characteristics of a given
watershed. Thus, both upstream and downstream migrations tend to occur during periods of
increasing or relatively high flows and infrequently during low flow periods. Because proposed
Project operations will occur throughout the year the extent to which the operations may affect
upstream and/or downstream migration success will depend on the timing of those migrations
and prevailing flows. An example of this is depicted in Figure 4-9 that presents in the lower
panel, monthly flows (based on the historical hydrology) for both regulated (with Project) and
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unregulated conditions, and in the upper panel generalized migration periodicities for Nuyakuk
River salmon species. The differential between regulated and unregulated flows varies by month
and correspondingly the potential effects on passage success would also likely differ. Thus, it
will be important to have the best information available regarding each of the species migratory
periods for the Nuyakuk River, which will be established under the Characterization of the Fish
Community and Behavior Near the Project Area study and may be supplemented with
hydroacoustic / telemetry (radio or acoustic) evaluation of passage route selection and timing for
specific migrating species.
Importantly, much/most of this information will be compiled as part of Study 4.1.1. –
Characterization of the Fish Community and Behavior Near the Project Area. That study will
rely on a variety of source materials from the published and unpublished literature, as well as
personal contacts with agency and stakeholder personnel with direct experience with the fishery
resources of the Nushagak River, and certain empirical data collected on-site. For this study, the
objective will be to define for each species, the periodicities of adult upstream migration, and fry,
juvenile/smolt downstream migration. This information will focus the modeling and analysis on
those periods most vulnerable to Project operational effects.
Figure 4-9. Estimated monthly periodicities of adult upstream and juvenile downstream migrations
of salmon and estimated average monthly flows of the Nuyakuk River, under unregulated
and regulated conditions, with percent flow diverted for generation.
Establish Species Swimming and Leaping Criteria
The swimming and leaping capabilities of salmonids largely determine the extent of their
distribution in watersheds. Areas with steep (> 3%) gradients or that contain rigid/sharp breaks
in channel elevations (i.e., Falls or chutes) can pose as barriers to migrating salmon. The barrier
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potential of these areas is often highly influenced by flow; under some flows they may be
passable, and under others impassable. Such is the case for the Nuyakuk Falls Reach and
therefore it will be important to identify and select a set of swimming and leaping criteria from
which to evaluate existing migration pathways and assess potential effects due to Project
operations.
In general, the swimming capabilities of adult salmonids fall into three categories as defined by
Powers and Orsborn (1985), sustained, prolonged, and burst. At sustained velocities, fish can
function normally for long periods of time without fatigue (Hoar and Randall 1978). Prolonged
fish speeds can be maintained over long periods of time (15 s to 200 min). Burst speeds are used
for short periods (15 s or less) to negotiate Falls and high-velocity areas. Of these, burst speeds
and to a lesser extent prolonged speeds are the most relevant for the Nuyakuk Falls passage study
(Table 4-2).
Table 4-2. Leaping and Jumping Capabilities of Adult Salmonids, and Preliminary Migration
Periodicity for Nuyakuk River, Alaska (Table modified from Reiser et al. (2006)).
Steelhead Coho Chinook Sockeye Pink Chum
Sustained Velocity (m/s) 1.40 1.04 1.04 0.97 0.79 0.79
Prolonged Velocity (m/s) 4.17 3.23 3.29 3.11 2.34 2.34
Burst Velocity (m/s) 8.07 6.55 6.82 6.27 4.57 4.57
Minimum
Swimming Depth
(m) 0.17 0.17 0.17 0.17 0.17 0.17
Fish Body Length (m) 0.70 0.70 0.91 0.55 0.58 0.73
Fish Body Depth (m) 0.14 0.20
Max Jumping
Height
(m) 3.35 2.19 2.38 2.10 1.21 1.21
Adult Migration
Periodicity in Ward
Creek
(No. Days)
Mar-Apr
(92)
Aug-Oct
(92)
Jun-Aug
(92)
Aug-Sept
(48)
Jul-Aug
(46)
Jul-Sept
(76)
The swimming and leaping/jumping capabilities of salmonids have been evaluated, both in the
field (Stuart 1964) and under laboratory conditions (Powers and Orsborn 1985) and have been
summarized in in a number of publications (Bell 1991; Powers and Orsborn 1985; Bjornn and
Reiser 1991, Katopodis and Gervais 2012; Katopodis and Gervais 2016). In general, successful
passage at a Falls requires a fish to leap from a standing wave to the waterfall crest. Also, the
flow velocity at the waterfall crest must be less than the burst speed and water depth must be
greater than the fish body depth. Figure 4-8 depicts two conditions – chute and Falls, that may be
encountered in the Nuyakuk Falls Reach, and lists the physical and hydraulic variables that
determine passage success.
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Figure 4-10. Schematics of chute-type (left) and falls-type (right) potential barriers (adapted from
Powers and Orsborn 1985, as presented in Reiser et al. 2006). Variables are defined as
follows: Z is the vertical distance from the bottom of the barrier to the crest of the barrier,
H is the vertical distance from the downstream pool water surface to the water surface at
the crest, dc is the water depth at the crest, dpp is the flow depth of the downstream pool,
LS is the chute length, Sp is the angle of the chute, Se is the angle of the bed upstream of
a falls, FH is the vertical distance from the downstream water surface elevation to the
barrier crest, h0 is the initial leaping angle, and Xsw is the distance from the location of
the impact of the falling water to the standing wave.
As part of this study, a combined literature and internet search will be completed to compile
relevant information related to both swimming and leaping capabilities of salmon. From this, a
set of criteria will be developed in collaboration with the stakeholders that will be used in the
modeling and passage evaluation. Observational data on fish leaping behavior at the Nuyakuk
Falls area during the Characterization of the Fish Community and Behavior Near the Project
Area study and anecdotal information (including videography) will be included for
consideration.
Conduct Bathymetric Mapping of Reach
Successful completion of this study will require survey data of the study reach (Zone 2)
consisting of topo-bathymetric information to define channel elevations occurring at flow
sensitive areas that pose a risk to upstream migration. Data will be linked with depth, swimming
speed, and jumping criteria for passing fish (adult upstream and juvenile downstream) to
determine areas of suitable/ unsuitable passage under different flow conditions. However,
collection of any field data within this reach would be very challenging and dangerous given the
prevailing turbulent and swift water conditions that will make data collection hazardous. The
Cooperative understood these safety concerns and evaluated a number of options for obtaining
the necessary information (Table 4-3). These included the collection of data using helicopter,
fixed wing aircraft, or remote-controlled drone. As noted, collection of data using boat or
pedestrian survey techniques was considered unsafe and was not considered further, other than to
establish ground-based survey control points for measuring water surface elevations, and
benchmarks. Pros and cons of the three modes of data collection were considered and described
in Table 4-3).
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Table 4-3. Topo-bathymetry survey methodology comparisons considered for the Nuyakuk River.
Method
Safe or
Unsafe
Quantitative
or Qualitative
Interpretation
Area-Based or
Transect-
Based
Single or
Multiple Flow
Interpretation
Limited or Not
Limited by
Riparian
Cover
Limited or Not
Limited by Air
Entrainment
Pedestrian Survey (wading) Unsafe Quantitative Transect-Based Single Not Limited Not Limited
Boat Survey (ADCP) Unsafe Quantitative Transect-Based Single Not Limited Not Limited
Cable Survey (ADCP)
Unsafe
(during cable
installation)
Quantitative Transect-Based Single Not Limited Not Limited
Airplane
Survey
3 band (RGB) digital
imagery Safe Qualitative Area-Based Single Limited Not Limited
Topobathymetric LiDAR Safe Quantitative Area-Based Multiple (with
2D model)
Not Limited
(bare earth
interpretation)
Can be Limited
Helicopter
Survey
Frame-Based Video Safe Qualitative Area-Based Single May be Limited Not Limited
Frame-Based Video with
Floating Tracers Safe Quantitative Area-Based Single May be Limited Not Limited
Topobathymetric LiDAR Safe Quantitative Area-Based Multiple (with
2D model)
Not Limited
(bare earth
interpretation)
Can be Limited
Drone
Survey
Frame-Based Video Safe Qualitative Area-Based Single May be Limited Not Limited
Frame-Based Video with
Floating Tracers Safe Quantitative Area-Based Single May be Limited Not Limited
Topobathymetric LiDAR Safe Quantitative Area-Based Multiple (with
2D model)
Not Limited
(bare earth
interpretation)
Can be Limited
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Of these survey modes, the airplane survey with 3 band (RGB) digital imagery and
topobathymetric LiDAR containing a green wavelength (532 nm) was selected as the most
efficient and safe. The survey and LiDAR acquisition occurred on May 14, 2020, using a Riegl
VQ-880-GII mounted on a Cessna Caravan (Quantum Spatial 2020). The survey consisted of
consecutive overlapping flight paths of a reach of the Nuyakuk River that extended
approximately 3,000 ft (0.57 mi) upstream and 2,500 ft (0.47 mi) downstream from the upper
and lower ends of the Fish Passage Study Area (Figure 4-8), respectively (total of 9,810 ft or
1.86 mi). Aerial imagery was co-acquired using a PhaseOne iXU-RS1000 digital camera that
collected imagery in three spectral bands (Red, Green and Blue). The LiDAR allowed for laser
penetration through the water column up to a nominal depth of 20 ft (depending on water clarity,
bed surface reflectivity and turbulence) and in those areas can accurately depict the bed
topography of the channel below the water surface. However, the Falls Reach contains
substantial areas of highly turbulent water, and mapping in those areas can be problematic and
will require post-processing of data using interpolative, nearest neighbor computations.
The surveys were conducted under ice-free conditions during low flows (approximately 5,600
cfs). when water clarity was highest. This provided for high resolution of channel features, that
will be useful for delineating specific passage avenues and potential stranding and trapping areas
throughout the reach.
During each field survey, photographs and video footage will be taken of selected flow sensitive
passage areas. These surveys will also be used to collect data useful for hydraulic model
calibration. For this data collection effort, floating tracers (a variety of objects can be used) will
be deployed from a boat in Zone 1 and monitored via drone-based videography. These data will
be post-processed to determine the magnitude and direction of surface velocities under a given
flow condition. Field safety protocols will be developed and strictly enforced during each survey
effort.
Collection of field data to support the bathymetric mapping will consist of surveys conducted
during open water conditions. The first survey was conducted coincident with the LiDAR aerial
survey and was used in LiDAR calibration and post-processing. The surveys included non-
vegetated accuracy checkpoints as well as wetted edge, and bathymetric checkpoints for
bathymetric accuracy assessment (Quantum Spatial 2020). Additional LiDAR surveys will be
conducted in summer 2022
To further supplement this effort and define habitat and passage conditions, the Cooperative will
utilize either a fixed-wing airplane or drone (likely the latter) to capture a series of high
resolution images over the length of the falls. These images will be captured during multiple
periods of the year that coincide with the variety of flow conditions observed at the Project site
on an annual basis. Per collaborative discussion with the ARWG, the Cooperative will capture
imagery in approximately 5,000 cfs increments up to 20,000 cfs. The work will be done by the
same firm (Quantum Spatial) that completed the green LiDAR data referenced above. It is
anticipated that the imagery will assist in defining both the locations of existing habitat units in
Zone 2 and the corridors for fish passage that exist at the variety of flow conditions the Nuyakuk
River experiences on an annual basis.
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Develop 2D Hydraulic Model
Accurate surveys of topography/bathymetry will enable construction of a two-dimensional (2D)
hydraulic model that will cover Zones 1 –3 within the Project Area. This model will provide fine
scale detailed information such as depth and velocities (magnitude and direction) within each of
the migration pathways and will enable the computation of other variables relevant to both fish
passage (Figure 4-7) and Habitat Suitability Criteria (HSC) above and below the Falls Reach
itself. The model will be calibrated using the water surface elevations surveyed near each
benchmark, data collected from level loggers installed at selected points within the falls reach
that can be safely accessed during low flow conditions, and direction and surface velocity
information measured using floating tracers. The number of loggers installed will be determined
during low flow field observations to evaluate safe access points at a variety of features in the
falls reach.
Established benchmarks will be used where possible, and if not close enough to a desired
location for a level logger then a new benchmark will be established. The elevation of the new
benchmark will be surveyed with RTK-GPS. The water surface elevation at each level logger
will be surveyed with an automatic level with respect to the nearby benchmark. Water surface
elevations will be surveyed during initial installation, each time the level loggers are visited to
download data, and during final recovery of the level loggers. This will allow accurate
measurements of water surface elevations, even if the level logger is reinstalled at a slightly
different elevation.
The level loggers will record both water stage and temperature over the range of flows occurring
during the upstream and downstream migration periods of salmon (Figure 4-9). The level logger
data will be useful in determining localized stage changes over a range of flows that can be used
in refining model predictions for those locations. The calibrated model will then be used to
model passage conditions under different flows.
There are a number of 2D models available that are sufficiently robust to analyze complex flow
conditions like those in Zone 2. Candidate models that exist and will be evaluated for possible
application include the following:
•SRH-2D (Sedimentation and River Hydraulics-Two Dimensions), developed by the
United States Bureau of Reclamation (USBR). This model was recently used in
licensing studies performed on the Susitna River.
https://www.usbr.gov/tsc/techreferences/computer%20software/models/srh2d/index.h
tml
•River2D – developed by the United States Geological Survey (USGS) and the
University of Alberta. This model was recently used in licensing studies performed
on the Susitna River. The River2D model includes a fish habitat analysis component.
http://www.river2d.ualberta.ca/
•HEC-RAS 2D (Hydrologic Engineering Center-River Analysis System Two
Dimensions) HEC-RAS was originally developed by the United States Army Corps
of Engineers (USACE). The two-dimensional extension was developed for the
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USACE by RMA (Resource Management Associates, a firm based in Davis,
California). https://www.hec.usace.army.mil/software/hec-ras/
•RMA2 – originally developed by RMA for the USACE. The model is currently
maintained by Aquaveo (a firm originally based in Utah).
https://www.aquaveo.com/software/sms-rma2
•iRIC (International River Interface Cooperative) – a suite of two-dimensional models
developed as public domain software by researchers from the USGS and Japan. This
collection of models includes a fish habitat analysis component. https://i-
ric.org/en/about/
The Cooperative will evaluate each of these models and will select a candidate model for use that
will be discussed with the stakeholders. Upon stakeholder approval, the selected model will be
used for developing a 2D hydraulic model of the Nuyakuk Falls Reach.
Conduct Modeling and Evaluate Potential Effects of Project Operations.
Development of the 2D – model will enable a more detailed evaluation of Project effects. For
this, the model will be initially run for flows representative of those existing during typical
upstream and downstream migration periods. The model will then be used to identify areas that
meet swimming, and for adult upstream passage, leaping criteria of different species, and hence
represent pathways suitable for upstream and downstream migration. These areas will be
longitudinally linked thereby depicting the most probable pathways of migration through the
entire reach for unregulated flow conditions. Although separate analysis will occur for upstream
adult passage and downstream smolt/juvenile passage, the below discussion focuses on upstream
passage since it would likely be the most affected by Project operations.
The pathways identified from the 2D modeling will likely vary in length, and velocity and depth
characteristics, so that successful upstream passage through each will differ in degree of
difficulty. Therefore, model metrics will be analyzed to identify and categorize pathways into
groups based primarily on velocity conditions and adult fish swimming speeds (sustained,
prolonged and burst). These could nominally include four groupings, with Group 1 -depicting
areas of low velocity (0-4 fps) where fish employ sustained speeds that could be maintained over
relatively long periods of time (~30 minutes or longer); Group 2 of moderate velocity (e.g. 4 – 8
fps) where fish employ both sustained and prolonged speeds that could be maintained for ~ 3-4
minutes before resting areas needed; Group 3 - areas of moderate-fast velocity (8-13 fps) where
fish use prolonged and burst speeds that could be maintained for short periods of time (~20-30
secs) before rest areas needed; and Group 4 – areas of high velocity (13-18 fps) requiring short
duration (~5 secs) burst speeds before resting areas needed.
The model will then be run for a series of flows that represent a range of conditions that may
occur during the migration period due to Project operations. The same swimming and leaping
criteria analysis will be completed for each of the Groups/Zones to determine passage
probabilities as defined by the mix of parameters including localized velocities, plunge pool
depths, crest water depth, crest water velocity and others. The type of analysis envisioned for
migratory pathways in Zone 2 is conceptually displayed in Figures 4-11 and 4-12 for both
upstream and downstream passage leading to the determination of migration probabilities.
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Figure 4-11. Schematic of three hypothetical upstream migration routes (Routes 1,2 and 3) each
containing different combinations of Groups/Zones (as defined above) based on hydraulic
parameter limits (e.g., depth, velocity, width, length) that could allow passage of adult
salmonids. More than 3 routes will likely exist within the Falls Reach and these could
overlap/cross, under varying flow levels; e.g., Route 1 may intersect with and become part
of Route 2, Route 3 may intersect with 2 and 1, etc. Some pathways may actually lead to
dead-ends forcing fish to move back downstream and attempt another route. A time
series analysis covering distinct upstream migration periods will be completed using
different water year types to allow a comparative assessment of Upstream Passage
Probabilities under different flow conditions.
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Figure 4-12. Schematic of three hypothetical downstream migration routes defined via 2D
modeling. A time series analysis covering distinct downstream migration periods will be
completed using different water year types will allow a comparative assessment of
Downstream Passage Probabilities under different flow conditions.
The analyses are depicted more broadly in Figures 4-13 and 4-14 that illustrate the Project layout
superimposed on an aerial imagery of the Nuyakuk Falls Reach. The figures contain inserts of a
flow hydrograph showing potential changes in flows due to Project operations and a draft
periodicity figure on top of a flow hydrograph to indicate periods of upstream and downstream
migration. Analysis of habitat for resident fish due to flow changes will be made based on a
Physical Habitat Simulation (PHABSIM) type analysis (Bovee et al. 1982) using representative
Habitat Suitability Curves (HSC) for those species. These figures conceptually display the final
endpoints of more detailed analyses that would be derived via 2D hydraulic modeling of
migration pathways and specific analyses of tailrace and intake characteristics.
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Figure 4-13. Depiction of potential changes in upstream migration probability as a function of
changes in physical and hydraulic conditions within the Falls Reach, and potential delay at
the tailrace (R) and passage probabilities both with operations and without (current).
Similar analysis would be applied under a Climate Change scenario as a function of flow
changes, not temperature.
Figure 4-14. Depiction of potential changes in downstream migration probability as a function of
changes in passage probabilities due to delay, stranding/trapping or entrainment and
passage probabilities both with operations and without (current). Similar analysis would
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be applied under a Climate Change scenario as a function of flow changes, not
temperature.
Analysis will include development of a suite of comparative matrices that lists the model-
generated values of each of the parameters for each of the flows (including regulated and
unregulated) and identifies probabilities of values being conducive to successful passage, and
also whether they create suitable migration, rearing, holding, and spawning habitats. These types
of matrix tables will be used for identifying “flow windows,” which illustrates the range of flows
and their associated probabilities (likelihood estimates) successful upstream migration would
occur for the each of the designated areas, and then for the entire reach. A broad example of this
is depicted in Figure 4-15.
Figure 4-15. Example passage analysis denoting the ranges of flows that afford suitable passage
conditions for different species. The dashed vertical lines represent the flow window that
is suitable for all species. The PHABSIM and Tennant flows represent flows recommended
via habitat and hydrologic analysis. (Adopted from Reiser et al. 2006). A similar type of
analysis could be applied in the Nuyakuk Falls Reach.
The bathymetric mapping and modeling will also be used to identify potential areas of stranding
and trapping and the flows at which these areas may develop. The risk of stranding and trapping
most commonly occurs under conditions of pulse type flows such as those associated with
hydroelectric peaking or load following. Under these types of operations, fish, in particular fry
that may be occupying relatively shallow pool areas may suddenly become trapped within the
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isolated pools. Likewise, fry occupying flat shallow water areas may suddenly become stranded.
Factors that influence the degree to which downramping results in stranding and trapping of
small fish may include:
•Channel configuration – presence of side channels and low gradient bars; Monk (1989)
noted greater stranding associated with gently sloping margin (» 1.5-2 percent slope) than
on slopes of around 5 percent;
•Channel topography – presence of potholes and other topographic hollows that can trap
fry as stage decreases;
•Long-side channels that can alternately connect and disconnect side channel areas that
can lead to trapping and eventual stranding of fish;
•Substrate type – larger substrates (e.g., cobbles) result in fry moving vertically down with
receding water levels, whereas within finer substrates that are less permeable, fry tended
to follow outflowing surface water;
•Ramping range – extent of stage drop experienced during downramping operation;
•Critical flow – flow below which stranding risk increases dramatically; generally
associated with changes in channel form (e.g., slope);
•Time of year – smaller fish (e.g., fry) more vulnerable to stranding than larger fish;
Hunter (1992) indicated that salmonid fry < 50 mm in length are the most vulnerable to
stranding, with fingerlings, smolts and adults still susceptible but at higher downramping
rates;
•Time of day – some species may be more vulnerable during day or nighttime periods; and
•Flow stability prior to drop in flow – fry stranding rate may be higher if downramping is
infrequent and occurs after periods of sustained flows, rather than part of daily
fluctuations.
The Nuyakuk Project will not be operated as a peaking or load following facility but rather as a
run-of-river project, with no large storage component. As such, power production will mimic
some fraction of total river inflow to the Project site. Thus, the prevailing flows within the Falls
Reach would generally maintain the same seasonal pattern with or without project operations,
but the flow volumes would be reduced (Figure 4-4). Even so, there is still the potential that
flows could suddenly be reduced. This could occur as storm induced pulses in high flows are
suddenly reduced to minimum flow levels, or from maintenance incurred operational changes
that create a short duration increase in flows in the Falls Reach (to accommodate maintenance
activities) followed by a sudden decrease in flows when operations resume.
The assessment of risk will first identify those areas most susceptible to potential stranding and
trapping via review of the bathymetric map of the Falls Reach for notable depressions and
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potholes. The 2D hydraulic model would then be used to determine the critical flow below which
stranding and trapping would increase dramatically. The Operations Model would subsequently
be run for a number of scenarios including both regulated and unregulated flows and the
frequency of exceedances of the critical flow determined and compared. The Life-Cycle
Modeling will translate these frequencies in terms of a distribution of potential mortality rates
that factor into the determination of population level effects. The analysis may also lead to
derivation of a set of down-ramping criteria that defines the rates of flow decline to protect
against stranding and trapping. This issue has been studied on a number of other Projects that
have led to development of site-specific down-ramping criteria. The State of Washington for
example, defaults to criteria developed by Hunter (1992) when recommending ramping
restrictions (Table 4-4).
Table 4-4. Downramping rates proposed by Hunter (1992) to minimize stranding and trapping
impacts on salmonids (From Reiser et al. 2007)
Season Daylight Rates1 Night Rates
February 16 to June 15 (salmon fry present) No Ramping 2 inches/hour
June 16 to October 31 (steelhead fry present) 1 inch/hour 1 inch/hour
November 1 to February 15 2 inch/hour 2 inch/hour
1 Defined as one hour before sunrise to one hour after sunset
These analyses, as well as those for downstream migration, and operational characteristics
associated with the tailrace and intake will feed into the LCM and will be further evaluated as
part of the overall Project Risk Analysis (see Sections 4.1.6 and Appendix C).
Once the 2 D hydraulic model is completed and flow-habitat effects are predicted, the likelihood
of Sockeye and Chinook salmon successfully passing upstream through the Falls Reach will be
evaluated with agent-based and individualistic models of fish passage behavior. The results of
these models will be used as inputs to the LCM being developed for these species.
4.1.2.8 Proposed Deliverables and Schedule
Assuming timely issuance of the Study Plan Determination, the Cooperative plans conducting
the study in 2023 and 2024. Upon implementation, study results will be documented in the ISR
and USR. It is notable that the Cooperative anticipates ongoing collaboration with stakeholders
throughout the study process so that determinations related to efficiency of methodology, any
study modifications that may be necessary and/or the need for extending studies can be discussed
and efficiently implemented. This collaborative process will also allow the Cooperative to
provide stakeholders with periodic status updates when results, anomalies, etc. warrant.
4.1.2.9 Level of Effort and Cost
The Cooperative agrees with stakeholders that this study will need to be a multi-year effort (2023
and 2024) to adequately define the existing condition near the Project site and the potential
impacts (positive and negative) to fish passage related to reduced flows over the Falls as a result
of Project operations.
The estimated cost for this study is approximately $500,000 - $700,000.
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4.1.3 Fish Entrainment and Impingement Study
4.1.3.1 General Description of Proposed Study
The Nuyakuk River is a tributary to the Nushagak River, which supports regionally important
commercial, subsistence, and recreational salmon fisheries. While existing data is limited for the
Nuyakuk, there are data to indicate that five species of Pacific salmon as well as several other
migratory fishes are present in the Nuyakuk, and that fish spawning does occur upstream of
Nuyakuk Falls in the Tikchik River (Johnson and Blossom 2019). Therefore, the intake for the
proposed hydroelectric Project along with associated infrastructure has the potential to impact
fishes as they migrate, particularly juvenile fishes moving downstream past the Project. A
successful Project design will incorporate intake features that minimize potential impacts
associated with the entrainment, impingement, and mortality of fishes.
In Section 5.2.3 of the PAD, the Cooperative identifies a series of fisheries studies to be utilized
to document both the existing condition and the level of impact (positive and negative) to the
Project area as a result of construction and operations. One of the potential studies was
identified as:
•Hydropower Intake Fish Entrainment and Impingement Study
Per multiple PAD comments and study request letters, including those from ADFG and NMFS,
the Cooperative received general concurrence with their proposal to conduct this study and looks
forward to collaborating with all interested stakeholders in further defining the appropriate
methods and analytical tools to assess the potential for fish entrainment and impingement at the
proposed hydropower intake and provide clear design thresholds to minimize harm to
downstream migrating fish due to entrainment and/or impingement.
4.1.3.2 Geographic Scope
The geographic focus of the Fish Entrainment and Impingement Study will be the area extending
upstream of Nuyakuk Falls approximately 1,000 feet (Figure 4-16). In particular, the area near
the right bank of the river will be of particular interest due to its proximity to the proposed intake
location. The extent of the study area may be modified according to new information on
hydraulics and flow field generated from 2D modeling.
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Figure 4-16. Fish Entrainment and Impingement Study Area.
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4.1.3.3 Study Goals and Objectives
The primary goal of this study is to understand the potential for the Project to entrain fishes that
are in the vicinity of the intake and to minimize the level of injury and mortality that might be
associated with entrainment or passage through the Falls Reach. Specific objectives follow.
1. Inform the preliminary intake design (e.g., infrastructure, orientation and trash rack
spacing) utilizing the hydraulic model developed under the Fish Passage Study and
through a compilation and summary of information from similar projects that are subject
to analogous environmental conditions as well as potential guidance/deterrent structures.
2. Estimate flow fields and magnitude of approach velocities near the hydropower intake
over the range of operating flows to: evaluate threshold conditions at the proposed intake
to minimize entrainment of juvenile salmonids and maximize survival within the Project
area; and measure behavior (including vertical and horizontal distribution across the
river) of downstream migrating juveniles in proximity to the proposed intake site.
3.Utilize information collected under the Fish Abundance and Distribution Study to
identify fish species potentially impacted and their seasonal abundance and size
distribution--develop a list of target fish species.
4.Determine the swimming capacities and flow avoidance/ attraction behavior of target fish
species from available literature.
5. Estimate potential for entrainment and impingement rates for target fish species based on
fish size, swimming ability and periodicity, local hydrology, Project technical features
(including trash rack design), and operating regime using available data from entrainment
studies involving the same species.
6.Estimate turbine mortality rates for target fish species and sizes by evaluating mortality at
other hydroelectric facilities with similar turbine specifications and comparable physical
features and operating conditions.
7.Estimate Project-related and overall mortality of target fish species on a seasonal and
annual basis using flow-based entrainment and mortality models.
Questions and hypotheses that will be addressed by this study are listed below.
1.What is the estimated potential for entrainment of targeted fish species/life stages through
the powerhouse?
2.What is the estimated potential for bypassing entrainment by the targeted fish species/life
stages through the Falls Reach?
3.What is the estimated direct and indirect mortality of fish (by life stage or size class) that
are entrained into the powerhouse?
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4.What is the estimated direct and indirect mortality of fish (by life stage or size class) that
bypass entrainment into the Falls Reach?
5.Is estimated passage-related mortality greater for the powerhouse or Falls Reach?
6.Is estimated future mortality in the Falls Reach greater or lesser than baseline condition
through the Falls?
7.Are intake design modifications available for use at this location to reduce risk of
entrainment?
4.1.3.4 Relevant Resource Management Goals
Five species of anadromous salmonids and multiple resident species are known to utilize the
Nuyakuk River at some point during their life cycle. Limited documentation exists on the extent
to which they utilize the proposed Project area and/or the watershed upstream. The Fish
Entrainment and Impingement Study will be informed by the other fisheries studies described in
the PSP.
The Fish and Game Act requires ADFG to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the
interest of the economy and general well-being of the state” (AS 16.05.020).
ADFG – Division of Sport Fish Mission is “to protect and improve the state’s recreational and
fisheries resources”. According to the 2015-2020 Division of Sport Fish Strategic Plan, the
management priority is to manage Alaska’s recreational fisheries for sustained yield and
recreational angler satisfaction that is centered on an area-based management system. The
division’s fish habitat program is directed at protecting and restoring fish habitats for the benefit
of fish and current and future recreational anglers.
Further, NMFS’s relevant resource management goals are captured in the NOAA Fisheries
Strategic Plan for 2019-2022 (NOAA 2019a) and the Strategic Conservation Action Plan for
Southwest Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy oceans
which support healthy populations of marine species and sustainable commercial and
recreational fisheries. NMFS involvement is supported by mandates under the Fish and Wildlife
Coordination Act and Magnuson-Stevens Fishery Conservation and Management Act.
4.1.3.5 Existing Information and Need for Additional Information
Existing information upon which this study will rely includes:
•Historical flow data in the Nuyakuk River that will serve as a model boundary
condition;
•Proposed operating regime and flow routing through the Project and Falls Reach; and
•Information about the target fish species, local distribution and periodicity, including
swimming abilities across life stages.
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Through literature reviews, other existing information will be obtained, including:
•Operations and maintenance constraints, intake design challenges and solutions at
similar hydropower projects including those susceptible to frazil ice accumulation
(e.g., Iliamna Newhalen Nondalton Electric Cooperative, Inc);
•The efficacy of non-intrusive fish passage deterrents;
•Impingement potential of target fish species by size;
•Injury, mortality and survival rates of entrained primary fish species and sizes passing
through similar projects with similar conventional Kaplan turbines; and
•Injury, mortality and survival rates of entrained primary fish species and sizes passing
through experimental, “fish-friendly” turbine arrangements.
Additional information needed to successfully complete this study includes identification of
presence or habitat use by target species as well as bathymetric data and hydraulic modeling in
and around the Nuyakuk River upstream of the Falls for approximately 1,000 linear feet.
4.1.3.6 Project Nexus
The diversion of variable portions of Nuyakuk River flow into the proposed Project may affect
downstream fish passage and survival through the Project area. Fish may pass downstream
through the powerhouse or through the Falls Reach with reduced flow. Downstream migrating
fish may be susceptible to injury or mortality via powerhouse entrainment and impingement
resulting from abrasion, blade strikes, disorientation, or increased predation likelihood at Project
outlets. When passing downstream via the Falls Reach, they may experience changes in habitat
conditions (depth, velocity, habitat composition) that could impair or improve passage conditions
as compared to baseline. Risk of indirect or longer-term impacts, such as latent mortality, also
may increase associated with potential temperature changes in the Project Area as a result of
Project operation interaction with climate change. Results of this desktop evaluation study are
essential for a complete understanding of the Project’s potential impacts on downstream
migrating juvenile salmon and other migratory fish species that utilize the Project area. Appendix
C contains a more comprehensive listing of primary and secondary Project nexus issues, methods
and hypotheses related to potential operational effects in the Project Area.
4.1.3.7 Methodology
The Cooperative has developed the following approach for consideration, for conducting the
entrainment study. These methods will be refined and revised pending comments from state and
federal agencies and stakeholders.
Use Existing Information to Inform Preliminary Design
This study will begin with a literature review that summarizes intake designs at similar
hydroelectric facilities as protective engineering solutions associated with salmon bearing
waters. The review will include design measures implemented to reduce fish entrainment and/or
impingement. Characteristics to be considered are: target fish species and sizes of concern, fish
presence in the Project area, size and angle of intake, intake screen/trash rack spacing, design
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flow, approach velocities, sweeping velocities, debris management measures, and walls/groins or
other structural modifications. Operators of similar projects will also be contacted to discuss their
experience with facilities susceptible to similar icing conditions (e.g., Iliamna Newhalen
Nondalton Electric Cooperative, Inc). Finally, the review will also summarize the efficacy of
non-intrusive fish entrainment deterrent and guidance systems and their potential for use at the
Nuyakuk Project.
Hydrology, Flow Routing, and Hydraulic Modeling
Site-specific hydrology and flow distribution information (flow through the Project and flow
through the bypass channel) will be refined and summarized as a precursor for hydraulic model
development, the evaluation of intake design alternatives, and assessment of fish entrainment and
impingement potential. A two-dimensional hydraulic model of Zones 1, 2, and 3 of the Nuyakuk
River will be developed under the Fish Passage Study. The hydraulic model will include the
reach upstream from the intake to the tunnels. The purpose of this model will be to inform this
study twofold. First, it will be used to evaluate approach velocities and approach angles in
relation to primary fish species swimming ability and behavior for various intake designs and
orientations. Second, the model will be used to evaluate flow streamlines resulting from a variety
of different groin locations and orientations and to determine those configurations that are suited
to the swimming abilities of downstream migrants. Flow rates simulated in the model will reflect
the entire range of flow anticipated at the Project; however, hydraulic conditions during the out-
migration periods for the target species and life stages are specifically of interest.
Entrainment
The overarching goal of the literature review and hydraulic model evaluation is to refine the
preliminary design for the Nuyakuk Project intake that minimizes potential fish mortality and
injury due to entrainment and impingement. Once a design configuration has been developed an
analysis of entrainment and impingement and turbine mortality will be carried forward. To
evaluate potential impacts of operations on entrainment and impingement of fishes this study
will utilize a desktop entrainment modeling approach. This modeling approach utilizes data from
field studies at other hydropower projects (see EPRI 1997; FERC 1995; Winchell et al. 2000)
and is a generally accepted practice for FERC licensing studies where no hydro project exists.
Examples of hydro projects where desktop entrainment studies were approved by FERC include
Mason Dam Hydroelectric Project (P-12686), Uniontown Hydroelectric Project (P-12958),
Overton Hydroelectric Project (P-13160), Emsworth Back Channel Hydroelectric Project (P-
13761), Montgomery Locks and Dam Hydroelectric Project (P-13768), Evelyn Hydroelectric
Project (P-14799), Braddock Locks and Dam hydroelectric project (P-13739), Allegheny Lock
and Dam 2 Hydroelectric Project (P-13755), and the Emsworth Locks and Dam Hydroelectric
Project (P-13757). A full list of relevant FERC entrainment study reports that has been compiled
by the Cooperative to date is presented in Table 4-5. All of the documents listed below are
publicly available on FERC’s eLibrary document database system.
Table 4-5. Relevant fish entrainment study reports for FERC projects compiled by Nushagak
Cooperative.
FERC Project Study Report Citation
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Mason Dam Hydroelectric Project
(P-12686)
Baker County. 2011. Report on Fish Entrainment and Mortality at
Mason Dam, OR. Mason Dam Hydroelectric Project (FERC No.
12686). February 2011.
Uniontown Hydroelectric Project
(P-12958)
Uniontown Hydro LLC and Newburgh Hydro LLC. 2010. Draft
Initial Study Report. Uniontown and Newburgh Hydroelectric
Projects (FERC No. 12958 and FERC No. 12962). August 2010.
Overton Hydroelectric Project (P-
13160)
Red River Hydro LLC. 2010. Draft Initial Study Report. Overton
Lock and Dam Hydroelectric Project (FERC No. 13160).
November 2010.
Kentucky Lock and Dam 12 & 14
(P-13213; P-13214)
Lock 7 Hydro Partners LLC. 2011. Fish Entrainment and Mortality
Analysis. Kentucky Lock and Dam 12 & 14 Hydroelectric Projects
(FERC No. 13213 and FERC No. 13214). November 2011.
Braddock Locks and Dam
Hydroelectric Project (P-13739)
Lock+ Hydro Friends Fund XLII, LLC. 2012. Fish Entrainment and
Survival Assessment. Braddock Locks and Dam Hydroelectric
Project (FERC No. 13739). August 2012.
Allegheny Lock and Dam 2
Hydroelectric Project (P-13755)
Free Flow Power Corporation. 2013. Fish Entrainment and
Passage Study. Allegheny Lock & Dam Hydroelectric Project
(FERC No. P-13755). October 2013.
Emsworth Locks and Dam
Hydroelectric Project (P-13757)
Free Flow Power Corporation. 2013. Ohio River Projects Fish
Entrainment and Passage Study. Emsworth Locks & Dam Project
(FERC No. P-13757), Emsworth Back Channel Project (FERC No.
13761), Montgomery Locks & Dam Project (FERC No. P-13768).
October 2013.
Emsworth Back Channel
Hydroelectric Project (P-13761)
Free Flow Power Corporation. 2013. Ohio River Projects Fish
Entrainment and Passage Study. Emsworth Locks & Dam Project
(FERC No. P-13757), Emsworth Back Channel Project (FERC No.
13761), Montgomery Locks & Dam Project (FERC No. P-13768).
October 2013.
Montgomery Locks and Dam
Hydroelectric Project (P-13768)
Free Flow Power Corporation. 2013. Ohio River Projects Fish
Entrainment and Passage Study. Emsworth Locks & Dam Project
(FERC No. P-13757), Emsworth Back Channel Project (FERC No.
13761), Montgomery Locks & Dam Project (FERC No. P-13768).
October 2013.
The potential for fish to become entrained at a hydroelectric facility is dependent on a variety of
biotic factors such as fish composition, size, swimming ability, behavior and life history; and
abiotic factors including intake configuration, intake screen/trash rack spacing, operating regime,
flow, and intake velocities. Particular species and life history events (migration, dispersal,
freshets) as well as the physical layout of a Project can greatly influence the susceptibility or
potential for entrainment (Coutant and Whitney 2000). Target species for evaluation will be
selected to provide entrainment estimates for those species potentially present in the Project
intake flow field that are the most abundant and important for fisheries values, as well as species
that are representative of the diversity of fish families potentially present. The criteria used to
evaluate potential approach and sweeping velocity will need to be species- and lifestage-specific,
with NMFS criteria serving as guidelines for protection. The velocities and approach angles that
result in sweeping velocity will likely vary with different intake design configurations. These
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values will need to be determined during the study once flow patterns, species and design options
are known.
Additional supporting information may come from the fish community study. Data obtained
from use of an upward and side-looking sonar array upstream of the falls will provide
information on relative abundance of migrants over time and both the temporal and physical
(horizontal and vertical) distribution of migrants moving as they approach the Falls and proposed
Project. Juvenile fish captured during fish monitoring with incline plane traps (described in the
Fish Community and Behavior Study) will be used to help understand the species composition of
downstream migrations.
The basic approach will be to combine site-specific information on fish species composition, fish
size (traps and sonar operated as part of the Fish Community and Behavior Study), fish behavior
and periodicity as well as modeled flow fields (from the Fish Passage Study) with the results of
both field and desktop studies at other Projects (with similar characteristics) to model and
estimate entrainment rates. Hypothetical, species-specific and seasonal entrainment density
estimates (fish-per-unit-flow) will be determined for various size categories of target species as
based on realistic densities at existing Projects. Species-specific entrainment densities will then
be filtered for those size categories that could physically pass through the trash rack (see
Impingement). The seasonal entrainment densities for each species and/or size class will then be
extrapolated to seasonal estimates of turbine flow at the Nuyakuk Project using estimated
average monthly (or seasonal) flow through the turbines. Estimated monthly (or seasonal)
entrainment numbers will then be generated using the product of entrainment density and flow
for each species and size group. Monthly (or seasonal) estimates can then be summed to produce
annual estimates for an average hydrologic year. Site-specific hydrology for wet and dry years
may also be used to produce a range of entrainment estimates. Sensitivity analysis will be
conducted for a reasonable range in the input parameters for calculating
entrainment/impingement to context the estimate and identify potentially good and poor designs.
Impingement
Impingement occurs when fish do not become entrained through a hydroelectric Project but are
instead held or impinged on the intake screen/trash rack and are unable to overcome the inflow
force with swimming ability. The potential for fish to become impinged at a hydroelectric
facility is dependent on several factors -- primarily fish size, clear or open spacing of the intake
screen or trash rack, and operations or flow through the Project and associated approach
velocities. Intake features are often developed considering a balance of cost, debris management,
and that tradeoffs exist between entrainment and impingement risks for fishes. Specifically, for
fish that do not have the swimming ability to maintain upstream position, a narrower trash rack
spacing increases the risk of impingement mortality when it is exceeded by the body width of
target species. In contrast, a wider trash rack spacing increases the probability of turbine
entrainment if fish are unable to maintain upstream position or are actively migrating
downstream.
Impingement vulnerability is largely determined by habitat use, migratory habitats, and
swimming ability. Impingement is a phenomenon that has been studied extensively and
summarized by the Electric Power Research Institute (EPRI 2005). Studies at other facilities can
offer insights into potential levels and rates of impingement for fish species found in the Project
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intake flow field. Swimming capacity of individual species large enough to be impinged is also a
useful tool in assessing vulnerability. A review of swimming ability (sustained, prolonged, and
burst) will be developed for a number of the key species that occur in the Project intake flow
field. In the absence of species-specific information, swimming performance of a comparable
species may be used, or species will be categorized by swimming ability (e.g., strong, moderate,
or weak) to assess size-based impingement vulnerability. Further consideration will be made for
any available information on species-specific delayed or latent injury or mortality associated
with impingement or entrainment at similar hydropower facilities that might be relevant to the
Project area.
Some individuals of larger fish species may be vulnerable to impingement at higher operating
flows. A scaling factor relating fish body width to total length will be used for the impingement
assessment to determine minimum sizes of the target fish species that would physically be
excluded and not able to pass through the open spaces in the trash rack. The swimming ability of
large-bodied fishes that cannot physically pass through the trash rack spaces will be compared to
the maximum approach velocity for the Project. If swimming ability exceeds approach velocity,
fish of these sizes are generally considered to not be suspectable to impingement or entrainment
and are omitted from further analysis.
Mortality
Entrainment mortality includes both direct turbine mortality as well as shear and cavitation stress
and pressures effects. Turbine mortality at each hydroelectric facility is variable and is dependent
on the size and species of fish and turbine characteristics. These characteristics include turbine
runner type (i.e., Francis or Kaplan), size, speed, number of blades, blade spacing and thickness
(EPRI 1997; Gibson and Myers 2002; Pracheil et al. 2016). Estimated rates of entrainment and
impingement can then be applied to estimated rates of mortality based on previous field studies
with similar turbine types and intake spacing. Numerous studies of fish injury and survival
associated with Kaplan turbines have been conducted and summarized (Algera et al. 2020; Čada
and Rinehart 2000; EPRI 1997; EPRI 2005) and will be used to estimate mortality rates by
species and size. Size-specific direct mortality rates for Kaplan turbines can also be estimated
using predictive models such as the Franke blade strike model (Franke et al. 1997) and used to
compare to those observed in field studies.
A portion of the flow at Nuyakuk Falls would be diverted for power production, so the overall
impact of the Project in terms of fish entrainment and mortality may be relative to that
proportional flow, particularly during the outmigration period. Fish and water flowing through
the Nuyakuk Falls bypass reach will continue to pass downstream and survive at or near the
current rate or baseline which will be assumed to be high in this study. Under the Fish Passage
Study, a bathymetric survey and hydraulic model will be used to evaluate the maintenance of
appropriate downstream fish passage conditions in the bypass channel over a range of anticipated
flow conditions. To put entrainment and impingement impacts into context an estimate of fish
passage survival will be developed considering flows through both passage routes, turbines and
bypass, using the proposed operating regime.
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4.1.3.8 Proposed Deliverables and Schedule
Assuming timely issuance of the Study Plan Determination, the Cooperative plans conducting
the study in 2023 and 2024. Upon implementation, study results will be documented in the ISR
and USR. It is notable that the Cooperative anticipates ongoing collaboration with stakeholders
throughout the study process so that determinations related to efficiency of methodology, any
study modifications that may be necessary and/or the need for extending studies can be discussed
and efficiently implemented. This collaborative process will also allow the Cooperative to
provide stakeholders with periodic status updates when results, anomalies, etc. warrant.
4.1.3.9 Level of Effort and Cost
Overall, the level of effort and cost is commensurate with a Project the size of the Nuyakuk
Project and the likely 50-year license term. The Fish Entrainment and Impingement Study will
rely on data and information obtained, created and used in the Nuyakuk Falls Fish Passage Study
(see Section 4.1.2) so that efforts are not unnecessarily duplicated. Specifically, the present study
will rely on bathymetric data to build a hydraulic model of the river upstream of the Falls. The
overall level of effort will depend, in part, on the degree to which the model geometry needs to
be adjusted and model runs iterated to arrive at a suitable groin configuration for downstream
migrants. The range of cost for this study is projected to be $150,000 - $250,000.
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4.1.4 Assessment of False Attraction at the Tailrace Fish Barrier
4.1.4.1 General Description of Proposed Study
Hydropower Project operations can result in false attraction to Project works, resulting in
migration delay and loss of productivity. The Nuyakuk Falls are located at the approximate half-
way point in a migration of nearly 100 miles for some salmon species. Understanding the various
solutions for minimizing false attraction to tailrace discharge will inform the Project design and
licensing process, and lead to more effective and cost-efficient mitigation measures for
protecting aquatic resources.
In Section 5.2.3 of the PAD, the Cooperative identifies a series of fisheries studies to be
implemented to document both existing conditions and the estimated level of impact (positive
and negative) to the Project area as a result of construction and operations. One of the potential
studies was identified as:
•Assessment of False Attraction at the Tailrace Fish Barrier
Per multiple PAD comments and study request letters, including those from ADFG and NMFS,
the Cooperative received general concurrence with their proposal to conduct this study and looks
forward to collaborating with all interested stakeholders in further defining the appropriate
methods and analytical tools to utilize in assessing and minimizing conditions of false attraction
to fish at the proposed tailrace location.
4.1.4.2 Geographic Scope
The geographic scope of the False Attraction Assessment will focus on the area surrounding the
proposed tailrace outfall below Nuyakuk Falls. The area of focus will extend from the three
distinct chutes or route options at the downstream end of the Nuyakuk Falls cascade that includes
the proposed tailrace outfall area, downstream approximately 1,500 ft along the right bank of the
river (looking downstream) (Figure 4-17). The extents of the study area may be modified
according to new information on hydraulics and flow field generated from 2D modeling.
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Figure 4-17. Assessment of False Attraction at the Tailrace Fish Barrier Study Area.
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4.1.4.3 Study Goals and Objectives
The overall goal of this study is to inform tailrace design and outflow options to minimize
potential impacts to upstream migrating fishes.
The primary objectives of this study are as follows:
1.Complete a review of tailrace designs that minimize false attraction by salmon to
determine any conceptual alternatives that would be suited to the Project and would
likely minimize false attraction;
2. Conduct a feasibility evaluation of the performance of tailrace location and design
concepts that might minimize false attraction under a variety of operating regimes;
3. Determine and provide preliminary level designs of any tailrace refinements to minimize
adult salmon injury and mortality associated with tailrace conditions, e.g., jumping at
turbine draft tubes and the potential for blade strike;
4. In coordination with the fish community study, assess pre-Project across channel
distribution of upstream migrating salmon with respect to the proposed tailrace and Falls
tailouts;
5.In coordination with the fish passage study, evaluate potential changes post-Project in
staging and ascension habitat below the Falls proper for suitability and connectiveness
with respect to upstream migration and the potential for delay;
6. In coordination with the Life Cycle Model study, assess potential risk that results from
incidental or latent mortality for fish that are falsely attracted to the tailrace.
Specific questions that will be addressed by this study follow.
1.Can the powerhouse discharge and tailrace design features minimize potential to attract
fish to the tailrace at this location?
4.1.4.4 Relevant Resource Management Goals
The Fish and Game Act requires ADFG to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the
interest of the economy and general well-being of the state” (AS 16.05.020).
ADFG – Division of Sport Fish Mission is “to protect and improve the state’s recreational and
fisheries resources”. According to the 2015-2020 Division of Sport Fish Strategic Plan, the
management priority is to manage Alaska’s recreational fisheries for sustained yield and
recreational angler satisfaction that is centered on an area-based management system. The
division’s fish habitat program is directed at protecting and restoring fish habitats for the benefit
of fish and current and future recreational anglers.
Further, NMFS’s relevant resource management goals are captured in the NOAA Fisheries
Strategic Plan for 2019-2022 (NOAA 2019a) and the Strategic Conservation Action Plan for
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Southwest Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy oceans
which support healthy populations of marine species and sustainable commercial and
recreational fisheries. NMFS involvement is supported by mandates under the Fish and Wildlife
Coordination Act and Magnuson-Stevens Fishery Conservation and Management Act.
4.1.4.5 Existing Information and Need for Additional Information
Existing information upon which this study will rely includes:
•Historical flow data in the Nuyakuk River that will serve as a model boundary
condition;
•Information about the target species, including swimming abilities across life stages.
Through literature reviews, other existing information will be obtained, including:
•Existing guidelines for tailrace infrastructure designs that do not allow fish to pass and
where fish do not physically injure themselves while trying to pass (NMFS 2011)
•Project studies and literature supporting an understanding of the functionally of physical
barriers.
Additional information needed to successfully complete this study includes bathymetric and
topographic data in and around the Nuyakuk River downstream of the Falls for approximately ¼
mile.
4.1.4.6 Project Nexus
The Nuyakuk Falls are approximately half-way through a migration of close to 100 miles for
some salmon species. The diversion of variable portions of Nuyakuk River flow into the
proposed Project may affect upstream fish passage and survival through the Project area. Project
operations will result in a higher proportion of flow in the tailrace compared to the Falls Reach
and may change the flow field, channel configuration, and water depths/velocity below the Falls
proper. The composition, configuration, connectivity, and suitability of
holding/staging/migration/ascension habitats downstream of the Falls proper and tailrace may
change. Upstream migrating fish may be attracted to the predominant flow of the impassible
route of the tailrace and thereby be delayed in finding the migration pathway into the Falls
proper or subject to higher rates of injury. Understanding how the various solutions for
minimizing false attraction to tailrace discharge will inform the Project design and licensing
process, and lead to more effective and cost-efficient mitigation measures for protecting aquatic
resources. Appendix C contains a more comprehensive listing of primary and secondary Project
nexus issues, methods and hypotheses related to potential operational effects in the Project Area.
4.1.4.7 Methodology
The Cooperative has developed the following approach for consideration, for conducting the
Tailrace False Attraction study. These methods will be refined and revised pending comments
from state and federal agencies and stakeholders.
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Review Existing Information to Inform Preliminary Design
This study will begin with a review of available information regarding tailrace designs at similar
hydroelectric facilities as well as protective engineering design criterion associated with
minimizing salmon false attraction and the potential for migration delay. The study will involve
compilation and review of various engineering design measures implemented at similar facilities.
Characteristics may include salmon species of concern, tailrace dimensions and orientation
relative to the natural channel, design flows, flow routing information (e.g., proportion of overall
flow), a summary of tailrace flow vectors (velocity and direction), tailrace exclusion barriers, and
walls/groins or other structural modifications that should be considered to minimize false
attraction to turbine outflows.
Feasibility evaluation
Once the existing information on tailrace refinements has been compiled and summarized, the
Cooperative proposes to conduct a brainstorming session focused on selecting two to three
preferred conceptual alternatives. These concepts will then be developed further with respect to
Project-specific physical, ecological, and operational criteria. This step will include completion
of 2D model runs focused on the tailrace area.
To support this feasibility evaluation, the two-dimensional hydraulic model of the Nuyakuk Falls
Reach developed under the Fish Passage Study will be used to assess the three chutes or passage
route options located at the base of the cascade, the proposed Project tailrace area, and the
Nuyakuk River channel immediately downstream. The model will be used first to evaluate flow
volumes, depths, velocities, and angles in relation to existing tailrace and Falls chute conditions
and, if necessary, to evaluate flow streamlines resulting from potential engineered solutions. The
flow output from the model will allow a comparative assessment of the potential effectiveness of
options for enhancing fish attraction to one of the passage routes at the base of Nuyakuk Falls.
Kleinschmidt/R2 staff have developed and utilized similar models in assessing downstream
passage alternatives at multiple dams throughout the West. This approach provides a transparent
tool for the cooperative and other interested parties to use is assessing future potential effects of
different flow conditions, passage routes and/or facility options. The alternative considered and
criteria used to evaluate those alternatives will be developed in collaboration with the ARWG or
a subcommittee thereof. Kleinschmidt/R2’s downstream passage biological performance tool
(BPT) has been approved by state and federal agencies for application in passage feasibility
study and has been promoted by NMFS as the model required for fish passage evaluations in
California. While the model developed for this study is a novel application for upstream
passage, the basic modeling principles and comparative analysis are similar. Specific conditions
of this model application are presented below.
Flow rates simulated in the model will reflect the entire range of flow anticipated at the Project;
however, hydraulic conditions during the upstream migration periods for the five species of
Pacific salmon will be the focus for this study. Specially, for each month during which more than
10% of the run of a species of concern has traditionally returned, the model will be run at the
20% exceedance flow and the 80% exceedance flow. These runs will be performed in
combination with various operating scenarios for the hydropower facility including:
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1) operating at 100% capacity (up to 6,000 cfs) and leaving the remaining flow or 1000 cfs,
whichever is greater in the river; 2) removing 30% of the flow (up to 6,000 cfs Project capacity)
and leaving a minimum of 70% in the river (current state law); 3) removing 50% of the flow (up
to 6,000 cfs Project capacity) and leaving a minimum of 50% in the river; and 4) removing 70%
of the flow (up to 6,000 cfs Project capacity) and leaving a minimum of 30% in the river.
Results of the model runs will be used in combination with other biological ecological, physical
and operational characteristics to select the best engineering alternative for minimizing potential
impacts to adult salmon in the Project tailrace. This would include empirical data collected on
baseline conditions collected during other studies such as data on upstream Falls passage timing
and delay, flow proportions and patterns, depths and velocities in the tailrace and below the
Falls. This also would include data from adult telemetry (radio or acoustic) efforts conducted
und the Fish Community and Behavior Study to characterize the distribution of upstream
migrating salmon as they approach the Falls under baseline condition. These data collection
efforts would inform model development and consideration of post-Project fish behavior with
respect to the tailrace, the Falls and modified flows design. The design selection process will be
completed collaboratively and will use a matrix-based analysis to facilitate transparency.
Preliminary design of tailrace exclusion refinements
Depending on tailrace design, an exclusion barrier may be needed to prevent fish from entering
the turbine draft tubes and minimizing the potential for turbine blade strikes. This tailrace option
will be incorporated into the feasibility evaluation. If a tailrace barrier is advanced, the study will
include an assessment of physical criteria such as picket opening spacing, porosity, velocity,
orientation, height or freeboard, and swimming and leaping ability of target fish species. The
Cooperative looks forward to collaborating with stakeholders, during continued development of
the study plan, and during study implementation to evaluate and select feasible tailrace design
and operational alternatives for the Project, that serve to minimize false attraction and delay.
4.1.4.8 Proposed Deliverables and Schedule
Assuming timely issuance of the Study Plan Determination, the Cooperative plans conducting
the study in 2023 and 2024. Upon implementation, study results will be documented in the ISR
and USR. It is notable that the Cooperative anticipates ongoing collaboration with stakeholders
throughout the study process so that determinations related to efficiency of methodology, any
study modifications that may be necessary and/or the need for extending studies can be discussed
and efficiently implemented. This collaborative process will also allow the Cooperative to
provide stakeholders with periodic status updates when results, anomalies, etc. warrant.
4.1.4.9 Level of Effort and Cost
Overall, the level of effort and cost is commensurate with a Project the size of the Nuyakuk
Project and the likely 50-year license term. The Assessment of False Attraction at the Tailrace
Fish Barrier Study will rely on data and information obtained, created and used in the Nuyakuk
Falls Fish Passage Study (see Section 4.1.2) so that efforts are not unnecessarily duplicated.
Specifically, the present study will rely on bathymetric data to build a hydraulic model of the
river downstream of the Falls. The range of cost for this study is projected to be $150,000 -
$250,000.
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4.1.5 Chinook and Sockeye Salmon Life Cycle Modeling
4.1.5.1 General Description of Proposed Study
In Section 5.2.3 of the PAD, the Cooperative identified a series of fisheries studies to be utilized
to document both the existing condition and the level of impact (positive and negative) to the
Project Area because of construction, the physical structure and operations. Evaluating the
impact of Project conditions to two important salmonid species in the Nuyakuk River – Chinook
and Sockeye salmon – will be aided by the construction of life cycle models (LCM) wherein
impacts can be put into the context of population dynamics.
The LCMs were proposed by the Aquatic Resources Working Group to address potential Project
impacts to fisheries resources at the population level. Each LCM will integrate population
responses to a range of environmental and Project conditions or scenarios, such that we can
evaluate the magnitude and likelihood of certain responses associated with the Project across a
range of environmental and operational conditions. This study will construct stage-structured
population dynamics models that will relate Project and environment information to stage
transitions (describing movement, survival, and reproduction) that drive population dynamics
(Hendrix et al. 2014, Cunningham et. al 2015, Figure 4-1. These models will be used to integrate
changes to habitat over time and space to predict the potential impact to the long-term status of
the populations. This study will support the Cooperative, agencies, and stakeholders in
conducting an Integrated Risk Assessment (IRA) to decide what impacts to the populations are
acceptable or not acceptable (see study plan to conduct an IRA in Section 4.1.6).
4.1.5.2 Geographic Scope
Direct effects of the Project on fish populations may occur within its hydraulic zone of influence
which is approximately 0.5 miles upstream and downstream of the Nuyakuk Falls (Figure 4-2).
In some cases, effects in that zone have the potential to influence the abundance and productivity
of fish populations that migrate through or temporarily reside there. Potential impacts can
therefore indirectly influence those populations in time and space outside the Project Area
through density dependent processes that may buffer or amplify direct Project effects on fish.
The geographic area is thereby described as the migration route over the life history of the
population (Nuyakuk, to and through the ocean, and return to the Nuyakuk).
4.1.5.3 Study Goals and Objectives
The primary goal of this study is to:
•Develop a LCM for Sockeye and Chinook on the Nuyakuk River that includes important
life stages and is capable of reflecting Project direct and indirect effects.
The primary objectives of this study are to:
•Construct a life cycle model that includes the Nuyakuk Hydro Project reach and the life
cycle of these populations.
•Develop a life cycle model that can calculate the management relevant metrics and the
magnitude and probability of exceeding management relevant thresholds.
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•Run the life cycle model for strategic scenarios including current conditions (without-
Project) and current conditions with-Project. These metrics will be supplied to the
quantitative IRA, which will calculate the risk to the population and fishery (magnitude
and probability of exceeding the management thresholds) under these two scenarios.
•Run the life cycle model for strategic scenarios including a baseline future climate
condition (without-Project) and the future climate condition with-Project. These metrics
will be supplied to the quantitative IRA, which will calculate the risk to the population
and fishery (magnitude and probability of exceeding the management thresholds) under
these two scenarios.
Specific questions that will be addressed by this study include:
1.How will Project operations, which affect different stages of the life cycle, be evaluated
for their overall effect on the populations? Project effect questions could include:
a.How will estimated changes to upstream passage, behavior and survival of salmon
through the Falls Reach impact population projections?
b. How will estimated changes to downstream passage and behavior of salmon through
the Falls Reach impact population projections?
c.How will estimated rearing habitat changes in the Falls Reach impact the
populations?
d. How will estimated changes to downstream survival impact the populations?
e.How will estimated stranding/trapping rates impact the populations?
f.How will estimated reductions in fringe spawning habitats impact the populations?
g.How will estimated migration delays and injuries due to false attraction to the tailrace
impact the populations?
2.What is the expected natural level of variability (without-Project) in population dynamics?
3. What is the probability that Chinook and Sockeye salmon escapement will drop below
their escapement goals under the Project compared to without-Project?
4. How will the Nuyakuk River flow and temperature under future climate conditions affect
the population dynamics of Chinook and Sockeye salmon?
5. How will Project operations affect population dynamics and the magnitude and how do
these compare to the population dynamics without-Project under future climate
conditions?
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4.1.5.4 Relevant Resource Management Goals
Chinook and Sockeye salmon are known to utilize the Nuyakuk River during their life cycle as
they pass through the Project Area during upstream and downstream migrations. Limited data
exists documenting the extent to which they utilize the proposed Project Area and/or the
watershed upstream.
The Fish and Game Act requires ADFG to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the
interest of the economy and general well-being of the state” (AS 16.05.020).
The mission of the ADFG – Division of Sport Fish is “to protect and improve the state’s
recreational and fisheries resources”. According to the 2015-2020 Division of Sport Fish
Strategic Plan, the management priority is to manage Alaska’s recreational fisheries for sustained
yield and recreational angler satisfaction that is centered on an area-based management system.
The division’s fish habitat program is directed at protecting and restoring fish habitats for the
benefit of fish and current and future recreational anglers.
Further, NMFS’s relevant resource management goals are captured in the NOAA Fisheries
Strategic Plan for 2019-2022 (NOAA 2019a) and the Strategic Conservation Action Plan for
Southwest Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy oceans
which support healthy populations of marine species and sustainable commercial and
recreational fisheries. NMFS involvement is supported by mandates under the Fish and Wildlife
Coordination Act and Magnuson-Stevens Fishery Conservation and Management Act.
4.1.5.5 Existing Information and Need for Additional Information
The LCM assessment will rely on limited existing information from the Nushagak, other Bristol
Bay watersheds, the evaluation of direct effects and those derived from future flows and
temperature regimes (Wobus et. al 2015), and from the literature. Fish survival information and
escapement estimates do exist for areas upstream and downstream from the Falls that can be
used as part of this study. New or existing information will be collected by or generated from
the other proposed fisheries studies and/or the broader Proposed Study Plan for the Project. For
example, the results produced from the 2-D flow model combined with the individual-based
passage model will provide information for several species in terms of upstream and downstream
passage success. For Chinook and Sockeye salmon, the LCM will provide quantitative
information to support an Integrated Risk Assessment.
4.1.5.6 Project Nexus
The physical Project and its operation have the potential to have positive or negative effects on
fish populations that reside in or pass through the Project Area. Water diversion from the river
and through the powerhouse is the fundamental action from which potential impacts of the
Project originate. Water diversion has the effects of reducing flow through the Falls Reach,
creating an additional downstream passage route for fish via the powerhouse, and relocating bulk
flow of the river below the Falls to a localized discharge point from the tailrace on the right bank
of the river. This action results in a 0.34-mile section of river that comprises the Nuyakuk Falls
Reach. These hydraulic changes may affect the timing, distribution, passage and survival of
resident and migratory fish populations (adults and juveniles) and their long-term sustainability.
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Therefore, it is important to understand the impacts to these populations because of reduced
flows through the Falls Reach, entrainment, stranding/trapping, and migration delays due to false
attraction at the tailrace.
For Chinook and Sockeye, the fundamental questions related to this nexus are a) what effect does
the Project have on the number of successful spawners and the number of juvenile outmigrants,
and b) what magnitude and likelihood of this effect is necessary to jeopardize the sustainability
of the populations. These questions are assessed within the context of environmental and harvest
effects. This study will support an Integrated Risk Assessment for Chinook and Sockeye salmon
populations as related to the proposed Project and its operations.
4.1.5.7 Methodology
Justification for an LCM
Resource managers and stakeholders decide what magnitude and type of change in fish
population dynamics is acceptable when introducing a hydroelectric Project to the system. One
tool that can be useful in that decision making process is an LCM that provides estimates of what
change in population dynamics are likely under different operational and environmental
conditions. To understand how the Project and its operations are going to affect the population, it
is prudent to use a model that integrates the various processes that affect how that the Project is
going to affect different life stages at geographic locations of the population.
One type of model that can do this integration is an LCM. The LCM specifies life stages and
tracks the relative abundance in each one of the stages (Hendrix et. al 2014). For example, a
simple life cycle might be composed of an adult and a juvenile stage. The LCM also defines how
the abundance changes between stages (so called "transitions"). So, for the simple model, there
would be a transition equation that defines how juveniles survived to the adult stage, and a
second transition equation that defines how adults produced the juveniles. When the stages are
linked into a cycle, then the LCM is capable of modeling multiple cohorts of animals by
repeatedly calculating the abundances of a stage at a given time via the transition equations.
Transition equations can also be defined as a function of the abundance in the previous stage. For
example, in the simple model, the transition that defines the abundance in the juvenile stage can
be affected by the abundance of adults. These density-dependent processes are important in
population dynamics because they can result in one stage affecting the following stage in a non-
linear fashion. Density dependence is common in salmonid population dynamics, and thus a
LCM of salmonids should be capable of incorporating density-dependence in the transition
equations.
If the transition equations are static, then the LCM will arrive at an equilibrium abundance for
each stage. On the other hand, if the transition equations are allowed to vary due to the influence
of environmental factors, then the stage abundances will vary through time reflecting the
influence of the environment on the population.
The transition equations can also be allowed to vary using the outputs of other models. These
process-based models may operate on a finer temporal or spatial scale than the LCM and focus
on reflecting the dynamics of a specific process, such as survival or movement. Often these
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process-based models incorporate physical driver variables that affect the mechanisms by which
animals survive or move. For example, a model that calculates the time duration it takes an adult
salmon to pass through a set of Falls under different flow conditions would be an example of a
process-based model that defines a movement rate. In this manner, the effect of the process-
based drivers can be integrated to understand the population level effects. Returning to the adult
movement process-level model and the simple adult and juvenile life stages, the transition from
adult to juvenile could be made a function of the movement model. Thus, the production of
juveniles would be affected by the movement of adults past the Falls, which in turn would be
affected by the flow conditions during passage. As a result, the population abundance could be
affected by the flow conditions during adult passage of the Falls.
One useful application of an LCM is to conduct a sensitivity analysis. A sensitivity analysis uses
a quantitative approach to understand how model outputs (e.g., spawner abundance) change for a
given change in model parameters (e.g., juvenile survival). For example, if juvenile salmon are
entrained (diverted) through the powerhouse amounts to 20% of the downstream migrants, and
100% of those fish die because of using that passage route, we can model the question “how does
20% mortality of juvenile migrants affect the number of returning adult spawners”? The same
question can be posed with respect to those fish that migrate downstream through the falls at
substantially lower flow conditions than natural. The follow-on question for both scenarios can
then be, “does the population continue to survive in perpetuity with those losses in juvenile
production, or does it dwindle towards extinction? Similarly, if adult salmon migrating upstream
are delayed in their journey by an additional week due to false attraction to the Project tailrace,
and those conditions result in 20% fewer spawning adults, “does the long-term production and
survival of that population remain stable or does it persistently decline”?
The LCM is linked to a quantitative risk assessment. Managers and stakeholders define the
values for abundance or process rates in a quantitative risk assessment as specific thresholds
(e.g., escapement threshold, survival threshold, productivity threshold, etc.). Those abundances
or rates are then calculated in the LCM (e.g., escapement, survival, productivity, etc.) to evaluate
whether the population exceeds those thresholds. Further, if the LCM includes stochasticity, then
it can be run multiple times under the same environmental and operational conditions to calculate
the magnitude and probability of exceeding those thresholds. In this way, the LCM can be used
to perform a quantitative risk assessment when the threshold values are associated with different
levels of risk to the population.
Allowing the transition functions to be affected by environmental conditions means that the
LCM can be run under different environmental scenarios. One scenario might be the
environmental conditions experienced in the recent past. In another case, a scenario might be the
environmental conditions consistent with a different climate, such as predicted environmental
conditions in 2050 from a climate model (see NMFS future flows study), and yet a third scenario
might be predicted environmental conditions in 2100.
In summary, an LCM:
•forces the scientific community to explicitly state the overarching questions,
assumptions, and knowns / unknowns about a system;
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•formalizes and quantifies the relationships connecting the Project to the environment
and fish populations, and supports refinements in study design;
•develops a mechanism to integrate across environmental processes and the proposed
studies into metrics of potential impact;
•identifies the influential and useful variables, types of data, the level of resolution
necessary to parameterize the model, and an opportunity for validating model
components;
•partly compensates for a limited number of years of data for the Project site;
•establishes a basis for running scenario-based conditions to quantify potential
outcomes and conduct sensitivity analysis of driving factors;
•provides the opportunity for risk assessment to focus on the magnitude of potential
impacts necessary to materially affect fish population production and sustainability;
•allows a forward-looking perspective to guide the identification of potential
monitoring and analyses of Project construction / operation that support before / after
evaluations with comparable datasets.
Components of the LCM
•Integrate Project effects (e.g., effects to upstream passage rates) over the life cycle to
calculate population-level metrics such as abundance and productivity.
•Provide outputs that can then be evaluated in a decision-making framework (e.g.,
quantitative risk assessment) at the level that is relevant to resource managers. For
example, providing an estimate of delayed migration of adult passage does not
determine how the Project is going to affect the Nuyakuk population or whether there
will need to be a change in fishery management to deal with the Nushagak as a weak
stock of the fishery (i.e., resource level effects). However, an LCM can integrate the
effect of delayed migration and other factors to determine potential Project impact.
•Incorporate process-based models. Examples of a process-based models are those
that calculate the duration of migration delay, or the proportion of fish delayed in
adult passage as a function of flow, or the quantity and quality of rearing and
migratory habitat. Similarly, a process-based model that calculates the proportion of
juvenile fish that are diverted through the powerhouse as a function of flow.
•Incorporate climate change scenarios (see NMFS future flows study).
•Incorporate density dependent population processes such as during production of
juveniles or during rearing of juveniles.
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•Incorporate direct Project effects that are occurring in the Project Area (e.g., delay in
passage, or mortality) and indirect Project effects that manifest outside of the Project
due to injury incurred during Project passage.
•Develop a "sensitivity analysis" to understand which components (e.g., flow impacts
on life stage survival) of the model are most responsible for changes in management
relevant metrics.
Tasks
Task 1: Model Development
•Develop an initial life cycle model.
•Revise the initial model to ensure that the model can address important questions and
can calculate management metrics from Task 1.
Task 2: Data Acquisition
•Acquire data for the model.
o Identify information where available on population vital rates (e.g., survival,
movement, and production, smolt to adult return ratios, etc.) and information
on density dependence from the Nuyakuk, Nushagak, other Bristol Bay
systems, or appropriate Alaskan Sockeye or Chinook populations.
o Identify abundance data, brood tables, run reconstructions, etc. (e.g., ADFG
data series, Cunningham et al. 2015) that can provide indices of abundance
that will be useful for the model.
o Identify passage success and changes in habitat conditions as related to
changes in flows and habitat. These inputs will be developed using 2D
hydrologic and individual based fish migration models as part of the Fish
Passage Study (see Section 4.1.2).
Task 3: Calibrate Baseline Model
•Calibrate a baseline model without-Project using a statistical fitting approach, such as
Bayesian estimation.
•Use the information identified on population vital rates in Task 3 to help define model
parameters for the life cycle model.
•Use the abundance data identified in Task 3 to further refine the population vital rate
parameters and their dependence on environmental factors such as flow and
temperature.
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Task 4: Develop Baseline Model and Calculate Model Sensitivity
•Define the baseline model using the parameters obtained from the LCM calibration in
Task 4.
•Link the baseline model outputs to the management metrics defined in Task 1 via
explicit mathematical relationships and model code.
•Perform a sensitivity analysis to identify what life stages and transitions are most
influential in affecting the management relevant metrics identified in Task 1.
Task 5: Develop Expected Project Effects
•Define both direct and indirect Project effects that occur in and outside of the Project
reach.
•Define the expected effects of the Project on specific life stage rates. For example,
the Project may affect movement rate of adult salmon migration by increasing
passage times through the Project reach. The expected effects should also have an
explicit mechanism. For example, passage times increase due to a higher fall-back
rate. Note that the hypothesis tables are meant to provide a good set of mechanistic
hypotheses about Project effects.
•Translate written Project effects into mathematical descriptions of Project effects.
•Develop expected range of Project effects using data from existing hydro Projects
(e.g., juvenile survival rates through turbines) or using professional judgement
estimates of what the range of Project effects are expected to be.
•Convert mathematical descriptions into model code.
•Incorporate process-based models that affect vital rates such as survival, movement,
and production into model code, making explicit mathematical linkages between the
LCM and the process-based models. Process-based models could include (but not be
limited to):
•Passage study 2D model
•False attraction model
•Entrainment model
Task 6: Incorporate Future Climate and Water Flow Scenarios
•Use strategic climatic periods given the expected period of operation of the Project.
•Use climate scenarios of environmental conditions (e.g., flow, temperature, etc.) that
correspond to the climatic periods of interest.
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•Incorporate information of climate effect on flow and temperature from a NMFS
Future Flows study being implemented with the Cooperative. That model will predict
flows and water temperatures for strategic periods from a hydrologic model for the
Nuyakuk River and a climate projection database.
Task 7: Evaluate Project Effects
•Run the LCM under baseline conditions and historical climate.
•Run the LCM under with-Project conditions from Task 6 and historical climate.
•Run the LCM under baseline conditions and climate change scenarios.
•Run the LCM under with-Project conditions from Task 6 and climate change
scenarios.
•Compare management metrics (Task 1) under baseline and with-Project operational
scenarios, paired by climate scenario. Evaluate effects on population dynamics for
the Project relative to baseline conditions for a given climate scenario.
4.1.5.8 Proposed Deliverables and Schedule
Task 1
Report defining the LCM structure in terms of model states (e.g., abundance of specific life
stages) and the model transition functions, their dependencies on environmental factors (e.g.,
flow) and the methods by which the metrics identified in Task 1 will be calculated from the
LCM.
Task 2
Report defining the sources of useful information on population vital rates and levels of density
dependence. The report would include a series of tables identifying the information, caveats, and
source for population vital rates. The report would also include a table describing the abundance
data, period of record, type of data collection, life history stage surveyed, location, source, and
caveats.
Task 3
Report describing the statistical fitting approach and how the model incorporated the information
on population vital rates and abundance data sources in Task 3. Report will also describe the
results from fitting the statistical model and the parameter estimates obtained from the model
fitting.
Task 4
Report that will define the baseline model and the sensitivity of important management metrics
to variation in model parameters.
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Task 5
Report describing the expected Project effects, the mathematical relationships between Project
effects and population vital rates (e.g., survival, movement, and reproduction), and the
description of all process-based models.
Task 6
Report defining the approach used for developing flow and temperature data under future climate
change, how those data are being incorporated into the LCM, and the patterns in the future
climate change relative to the baseline hydrologic conditions.
Task 7
Report describing the results of running the baseline scenario with historical climate conditions,
Project effects with historical climate conditions, baseline with climate change conditions, and
Project effects with climate change conditions. The output of the model will be in terms of the
management- relevant metrics developed in Task 1.
Schedule
Figure 4-18 below depicts the projected schedule for conducting the Nuyakuk Falls LCM study.
Figure 4-18. Nuyakuk Falls Fish Life Cycle Modeling Study Schedule. 2023 and 2024 are projected
to be Year 1 and Year 2, respectively.
4.1.5.9 Level of Effort and Cost
The Cooperative agrees with stakeholders that this study will need to be a multi-year effort
(starting in 2022 into 2024) to adequately model the existing condition near the Project site and
the potential impacts (positive and negative) to fish populations because of Project operations.
The estimated cost for this study is approximately $200,000 - 245,000.
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4.1.6 Integrated Risk Assessment of Fish Populations
4.1.6.1 General Description of Proposed Study
An integrated risk assessment (IRA) is proposed by the Aquatic Resources Working Group to
address to evaluate potential Project impacts to fisheries resources at the fish population/fish
community level. The IRA will integrate population responses to a range of environmental and
Project conditions or scenarios, such that we can evaluate the likelihood of certain benefits and
costs associated with the Project across a range of environmental and operational conditions.
This assessment will allow the Cooperative, agencies, and stakeholders to decide what impacts to
the populations are acceptable or not.
The study will develop a semi-quantitative evaluation of risk that integrates the accumulated
knowledge from available expert, local, empirical sources, and ranging from professional
judgment for target fish species to Life Cycle Model development for Sockeye and Chinook
salmon (LCM; Fletcher, 2015). The ultimate outcome is a ranked risk assessment that highlights
the most negative risk issues for further evaluation and mitigation. The risk assessment
framework includes an explicit consideration of uncertainty by including the likelihood of risks
of varying magnitude.
4.1.6.2 Geographic Scope
Direct effects of the Project to fish populations may occur within its hydraulic zone of influence
which is approximately 0.5 miles upstream and downstream of the Nuyakuk Falls. In some
cases, any effects in that zone have the potential to influence the abundance and productivity of
fish populations that migrate through, or temporarily reside, there. Potential impacts can
therefore indirectly influence those populations in time and space outside the Project Area
through density dependent processes that may buffer or amplify direct Project effects on fish.
4.1.6.3 Study Goals and Objectives
The overarching goal of this study is to provide a framework for quantifying and/or qualifying
the relative risk of Project-related impacts to fish population dynamics over the course of the life
cycle of fish, and over the life of the Project. This project will address target fish species
including Pacific Salmon, other migratory fishes and resident fish species that utilize the Project
Area.
The primary goal of this study is to:
•Develop integrated risk assessments for all aquatic species of management interest
that are potentially affected by the Nuyakuk Project.
The primary objectives for this study are to:
Quantify risk
•Develop a set of management relevant metrics that reflect: 1) the Nuyakuk population
level impacts on the Nushugak fishery, 2) population variability in the Nuyakuk.
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•Identify a set of management relevant thresholds for the metrics that constitute “risk”,
such that exceeding those thresholds could have a significant negative impact on the
population.
Qualify Risk
•Define the management objectives for the fish population/community, which could be a
single objective for each species, or could be multiple objectives for some species (i.e.,
what is at risk? abundance, sustainability). The management objectives have respective
elements (e.g., habitat, predation, passage) that can influence achieving the objectives,
and indicators (metrics for survival, passage success, habitat suitability, injury/stress) that
measure change to the elements.
•Define specific risk sources (Project structures or operations, climate change variables).
•Define risk ranking criteria (thresholds of consequence and likelihood).
•Convene a workshop(s) with agencies and stakeholders (public) for input on objectives
and risk analysis. Refine risk analysis as needed.
•Conduct a quantitative risk evaluation using Life Cycle Modeling for Sockeye and
Chinook to assess the potential magnitude of impacts as based on what-if scenarios,
sensitivity analysis (variation of relative Project or environmental effect from baseline
conditions) and supported by empirical / process-based studies.
•Conduct a qualitative risk evaluation (e.g., low, moderate, high) for target species, by
management objective, elements, and risk sources. Analyses will rank the potential
impact of risk sources on the target species population. This approach to assessing risk is
particularly useful for species for which there are too few data to develop a reasonable
LCM.
4.1.6.4 Relevant Resource Management Goals
Five species of anadromous salmonids and multiple resident species are known to utilize the
Nuyakuk River at some point during their life cycle. Limited data exists documenting the extent
to which they utilize the proposed Project area and/or upstream reaches of the watershed.
The Fish and Game Act requires ADFG to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the
interest of the economy and general well-being of the state” (AS 16.05.020).
ADFG – Division of Sport Fish Mission is “to protect and improve the state’s recreational and
fisheries resources.” According to the 2015-2020 Division of Sport Fish Strategic Plan, the
management priority is to manage Alaska’s recreational fisheries for sustained yield and
recreational angler satisfaction that is centered on an area-based management system. The
division’s fish habitat program is directed at protecting and restoring fish habitats for the benefit
of fish and current and future recreational anglers.
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Further, NMFS’s relevant resource management goals are captured in the NOAA Fisheries
Strategic Plan for 2019-2022 (NOAA 2019a) and the Strategic Conservation Action Plan for
Southwest Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy oceans
which support healthy populations of marine species and sustainable commercial and
recreational fisheries. NMFS involvement is supported by mandates under the Fish and Wildlife
Coordination Act and Magnuson-Stevens Fishery Conservation and Management Act.
4.1.6.5 Existing Information and Need for Additional Information
The IRA process is partly informed by the regional community (stakeholders, agencies,
outfitters, industry) input on management objectives, elements and risk criteria. These intrinsic,
social and economic values of the Nuyakuk fisheries resource may be available in regional, state,
and federal management plans that document the answer to the question of “what’s most
important” to the community. However, these perspectives also need to be directly solicited
from the community to ensure the completeness and relative value of aspects of the aquatic
resource are included in the analysis.
The risk assessment approach outlined here has been adapted from international standards
developed for ecosystem approaches to fisheries and aquatic management (Fletcher, 2015). A
similar process was used for a qualitative ecosystem-level risk assessment for the U.S. Mid-
Atlantic Fishery Management Council that included economic, social, and other types of risks
along with fish production and mortality metrics (Gaichas et al. 2018). The process proposed for
the Nuyakuk River is smaller in scope than that study but is amenable to expansion including
additional types of risk for the Project. Bradford (2020) reviewed methods used to assess the
effects of large hydropower Projects on aquatic ecosystems in British Columbia, Canada,
particularly under the term of adaptive management. Bradford (2020) recommends a structured
approach to incorporating expert, local and empirical knowledge, specifically mentioning
Bayesian Belief Networks (BBNs). The approach proposed here is less formal than a BBN, but
the elements are similar in that they provide a means of quantifying risk as estimated from
different levels of information for different elements. Also, the structure is again amenable to
expansion into a BBN if necessary (see Barton et al. 2020 for an example of a BBN used for a
hydropower application).
New or existing information will be collected by, or generated from, the other proposed fisheries
studies and/or the broader Proposed Study Plan for the Project. For example, the results
produced from the 2-D flow model combined with the individual-based passage model will
provide information on risk to several species in terms of upstream and downstream passage
success. For Chinook and Sockeye salmon, an LCM will provide a quantitative risk assessment.
The same information that feeds the LCM will also be used in qualitative risk assessment for
other species. The LCM and the qualitative risk assessment will rely on existing information
from the Nushagak, other Bristol Bay watersheds, results from PSP process-based studies, the
evaluation of direct effects and those derived from future flows and temperature regimes, and
from the literature.
4.1.6.6 Project Nexus
The physical Project and its operation have the potential to have good or bad effects on fish
populations that reside in or pass through the Project Area. Water diversion from the river and
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through the powerhouse is the fundamental action from which potential impacts of the Project
originate. Water diversion has the effects of reducing flow through the Falls Reach, creating an
additional downstream passage route for fish via the power tunnel/penstock, and relocating bulk
flow of the river below the Falls to a localized discharge point from the tailrace on the right bank
of the river. These hydraulic changes may affect the timing, distribution, passage and survival of
resident and migratory fish populations (adults and juveniles) and their long-term sustainability.
In the case of salmon, the fundamental questions related to this nexus are a) what effect does the
Project have on the number of successful spawners and the number of juvenile outmigrants, and
b) what magnitude of this effect is necessary to jeopardize the sustainability of the populations.
These questions are assessed within the context of environmental and harvest effects. Details on
Project nexus for fish and aquatic habitats are presented in Appendix C.
4.1.6.7 Methodology
Within the integrated risk assessment framework for Nuyakuk River fish populations, the
question to be addressed is: what is the risk to achieving management objectives for fish species
present in the Project Area, considering all activities involved with the Project and climate
change?
To answer that question, several steps are required:
1. Define management objectives or questions for each target species;
2. Identify the elements that are measured as indicators of impact to a population;
3. Identify the potential risk sources from the Project and environment (e.g., climate) to
achieving species management objectives;
4. Gather, collect, evaluate, and analyze available knowledge on the likelihood and
magnitude of impact from each potential risk to each management objective;
5. Developing and implementing an appropriate method for summarizing identified risks
into a semi-quantitative scale; and
6. Evaluate the potential risk of Project and environmental factors affecting fish
populations.
Clear management objectives or questions for each population must first be established. For
example, the management objectives for this Nuyakuk River fisheries risk assessment might
include a particular population abundance or escapement number for each species present in the
system, or it might be a more general objective of sustainable populations. A specific
management question may be “what magnitude of an effect by the Project on juvenile and adult
passage success will it take to cause a continual decline of abundance in the returning adult
population?”.
In addition, indicator elements must be selected to represent processes and conditions. These
elements may be metrics that indicate potential impact to fish populations. These elements are of
primary interest in the process-based studies of the fish and aquatics PSP.
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The identification of risk sources will be accomplished with an ecosystem approach that
evaluates potential risks over life stages and geographic location. For example, entrainment is a
potential risk to downstream migrants through the Project reach. Additional risks may be added
as stakeholders are consulted within the IRA process.
The collection and gathering of data, and modeling where possible, will be accomplished
through a series of fish and aquatic studies currently developed and presented in this PSP. Under
this integrated risk assessment study, workshops with stakeholders are proposed to augment
these expert and empirical data sources with local knowledge.
Developing an appropriate methodology for implementing an integrated risk assessment with a
common scale is a major task of this study. Below, we outline a proposed process based on the
adaptation of methods used in relevant literature (Bradford 2020, Fletcher 2015, Gaichas et al.
2018).
Approach for a Qualitative Integrated Risk Analysis
Management objectives and risk sources form the basis of a risk assessment summary (Table 4-
6). In this table, the management objectives (developed under Step #1 in the process outlined
above) are the columns labeled by fish species, and the risk sources (developed under Step #2 in
the process outlined above) are the rows. Each cell in a completed table will contain a semi-
quantitative risk value. The risk values in each cell of Table 4-6 are derived from the risk
analysis tables, with each table representing a paired analysis of a single risk source versus a
single element of the objective. For example, using a sustainable Chinook salmon population as
one objective, risk analysis tables for each risk source are partitioned into the elements of rearing
habitat, downstream passage success, predation, etc. Using these elements will inform the
analysis of risk based on different types of information and data.
Each risk analysis, performed for a risk-element pair (risk sources and management objective
elements) will include an examination of the magnitude of the potential consequences to the
objective and the likelihood that those consequences will occur (given the current state of
knowledge) under planned operations, with consideration of climate change (Table 4-7). Data
from indicator metrics will support the evaluation. This part of the risk analysis will produce a
consequence–likelihood matrix that combines the magnitude of potential impacts (consequences)
with the likelihood of those impacts occurring. Consequences can be negative (-2, -1), no
consequence (0) or positive (1, 2), and likelihoods range from no possibility (score 0) to likely
(score 4).
For example, the 2-D flow model combined with the individual-based passage model will
provide information to populate a risk analysis table for Chinook Salmon downstream passage
due to modifications to the flow regime. Presented selections of consequence-likelihood in this
example matrix were highlighted in yellow to show this scenario (Table 4-6). The value
indicating the maximum negative risk of the selected magnitude-likelihood combinations (in this
example, the lowest numerical value of -4 described as a minor negative impact of likely
occurrence) becomes the risk value in Table 4-8 for the downstream migration flow regime row,
with some probability of other magnitudes of effect (i.e., uncertainty). The results of a single risk
analysis table (Table 4-7) will fill a single cell in the risk source-element table, i.e., the
highlighted cells in Table 4-8 correspond to the risk analysis in Table 4-7.
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There will likely be multiple elements (i.e., predation, migration delay, loss of habitat) or a given
management objective impacted by each risk source (Table 4-8). The columns in Table 4-7 are
example elements for the Chinook Salmon objective. As in Table 4-7, the values for the
elements are integrated by selecting the value of maximum negative risk (i.e., the lowest value
for each risk source). When risk analysis Tables 4-7 and 4-8 are populated for each element and
risk source, the management objective element with the most negative value is used to represent
the risk level for a management objective and species, by risk source (i.e., column in Table 4-6).
In this step, we are assuming the element with the lowest value represents the value of maximum
negative risk for a specific management objective, species, and risk source.
For Chinook and Sockeye salmon, life cycle modeling will provide a quantitative integrated risk
assessment for those populations (see proposed study plan for Life Cycle Modeling). This
approach will provide the ability to simulate strategic scenarios (what-if questions) for Project
and environment (e.g., climate) related factors that may affect the abundance and long-term
sustainability of those populations, as well as provide an indication of how sensitive the
populations to changes in those factors. The results of the LCM will inform the qualitative
integrated risk assessment (for these two species) and results will be compared to evaluate
consistency. The two methods are complementary but the LCM is species-specific. The
qualitative approach is most applicable for the other species where the available fish resource
information is not appropriate for use in the LCM.
Important points for completing the risk analysis tables:
1.Consequences, as viewed for the risk analysis step (Table 4-7), must be viewed as
potential consequences to the overall stated management objective. This is the step that
insures common currency amongst species and risk sources. For example, it is not
necessarily a major increase in mortality that we are concerned with, but whether the
level of mortality that is expected would constitute a major impact to the sustainability of
a population (if that is the decided objective).
2.It is important to assess the risk associated with an issue even when there is a perceived
lack of information. Otherwise, the current level of action or inaction is, by default, rated
as acceptable. The approach outlined here can incorporate clear uncertainties into the
justifications for the final scores that are selected. The justifications should include a
detailed narrative that refers to, and to the extent possible, is consistent with available
lines of evidence, including their levels of uncertainty.
The IRA concludes with an evidence-based summary that has translated different levels of
available information into a common currency of risks that can be evaluated by stakeholders.
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Table 4-6. Hypothetical risk assessment summary with example risk values for Chinook Salmon and potential risk sources. Values are
imported from Table 4-8.
Management Objective (e.g., sustainable population)
Sockeye
Salmon
Chinook
Salmon
Coho
Salmon
Pink
Salmon
Chum
Salmon
Arctic
Char
Northern
Pike
Burbot Whitefish Sculpin Total?
Risk
Sources
Change to Flow
regime during
upstream migration 0
Change to flow
during downstream
migration -4
False attraction at
tailrace -4
Rates of flow
change
(stranding/trapping)
0
Entrainment 0
….
Change to flow
regime during
rearing -2
Total? -4
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Table 4-7. Hypothetical risk assessment table for one risk source impacting one specific management objective element. This example
is concerned with expected reductions in downstream passage success for Chinook salmon from modifications to the
flow regime. The values in the table are possible outcomes calculated by multiplying the ranking of likelihood by the
ranking of consequence. Each consequence level is evaluated for a likelihood. Highlighted cells provide example
selections for an individual risk source and element pair, including uncertainty. The lowest highlighted value (-4) is used
in Table 4-8 to represent the consequence-likelihood of maximum risk (in this case, a minor negative impact that is
likely) for this risk source / element pair.
Risk Source:
Flow regime
Element:
Downstream
passage
success Likelihood of occurrence
No
Possibility Remote Unlikely Possible Likely
Magnitude of
impact
Rank
Value 0 1 2 3 4
Consequence
Level
Major negative -2 0 -2 -4 -6 -8
Minor negative -1 0 -1 -2 -3 -4
No consequence 0 0 0 0 0 0
Minor positive 1 0 1 2 3 4
Major positive 2 0 2 4 6 8
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Table 4-8. Hypothetical risk assessment table for one management objective and species (population sustainability of Chinook), by risk
source and ranked elements. The values for each element column are derived from an individual risk analysis table (e.g.,
highlighted consequence and likelihood value of -4 from Table 4-7. All other values for demonstration only). The values
of this table will be used in Table 4-6 respective of management objective, risk source and species.
Chinook Elements of the management objective
Maximum
Risk
Nexus: 1,2 1,2 1,2,3 1,2,3 1,4 2,3
Predation
Stress/
Energetics
Spawning
Habitat Area
Rearing
Habitat Area
Upstream
passage
success
Downstream
passage
success
Risk
Source
Change to flow regime
during upstream
migration
0 0 0 0 2 0 2
Change to flow regime
during downstream
migration
0 0 8 8 0 -4 -4
False attraction at
tailrace -4 -2 0 0 -4 0 -4
Rates of flow change
(stranding/trapping) 0 0 0 0 0 0 0
Entrainment 0 0 0 0 0 0 0
Change to flow regime
during rearing -1 0 0 -2 0 0 -2
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4.1.6.8 Deliverables and Schedule
Assuming approval of the RSP, the Cooperative plans on beginning the study in late 2022. Upon
implementation, study results will be documented in the ISR and USR. It is notable that the
Cooperative anticipates ongoing collaboration with stakeholders throughout the study process so
that determinations related to efficiency of methodology, any study modifications that may be
necessary and/or the need for extending studies can be discussed and efficiently implemented.
This collaborative process will also allow the Cooperative to provide stakeholders with periodic
status updates when results, anomalies, etc. warrant.
4.1.6.9 Level of Effort and Cost
A multi-year study (2022-2024) coordinating with other studies in the Proposed Study Plan to
describe the potential impact of the Project on target fish species.
The estimated cost for this study is approximately $180,000 - $240,000.
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4.1.7 Future River Flows and Water Temperatures Study
4.1.7.1 Overview
The Nuyakuk Project has the potential to be designed and operated in a manner that maintains
habitat quality and suitability for the fish and provides renewable hydropower for six Alaskan
communities currently dependent on diesel for power generation. To realize the combined benefits
it is necessary to understand the consistent projection of increases in precipitation and the
changing timing of flows in the Nuyakuk watershed. Therefore, existing peer reviewed climate
model predictions will be used to model future discharges and water temperatures for the Nuyakuk
River, in accordance with peer- reviewed published methods and generally accepted practice as
described below. This information will inform the development of license articles guiding
operation and maintenance, including mitigation measures, as well as the development of a
climate resilient project design.
The best available science indicates temperature, precipitation, and stream flows will increase in
the Bristol Bay region, and much of south-central Alaska (IPCC 2018; Walsh et al. 2018;
USGCRP 2018; Chapin et al. 2018). Thus, higher stream flows are likely to occur within the
project area during the prospective license term. Some ongoing trends and anticipated climate
changes have implications for management of the hydropower facility and fish habitat. These
include a decrease in the proportion of precipitation falling as snow, with many sub-basins no
longer expected to be snow-dominated (Littell et al 2018), and as a consequence, an altered
hydrograph with earlier but perhaps lower spring/summer peak. January through April flows will
continue to increase as low elevation sub-basins partially melt out during freshets rather than
staying frozen for four continuous months. Peer-reviewed, publicly available downscaled climate
model projections have been developed for this region. These model projections will be analyzed
as part of this licensing process to support flow analysis for this project.
There is a significant body of literature on climate change in the Arctic and Alaska in particular
(Stewart et al 2022, Markon et al 2018). While these publications give a sense of what kinds of
changes may be observed in the Nushugak River, due to proximity, analysis of a region including
this basin, and other similarities, a study of the Nuyakuk basin itself is needed to understand the
combined changes of the proposed project and climate change on fish habitat.
4.1.7.2 General Description of Proposed Study
The Nuyakuk River supports a commercial, subsistence, and recreational Sockeye fishery, as well
as many other fish species, including large runs of Chinook and coho salmon. These species rely
on these riverine systems for refuge, spawning, rearing, and nursery habitat. The Nuyakuk River
and Tikchik Lake supports the second largest Sockeye run in the world; second only to the
Kvichak River and Lake Iliamna. Adult Sockeye pass through the Nuyakuk cascade to spawn in
the lakes above. Smolts pass back down the cascade on route to the ocean to mature. Furthermore,
the timing of adult escapement and smolt outmigration is keyed to water temperature, which is
strongly affected by air temperature (Mauger et al. 2016) and projected to change with increasing
air temperature.
Salmonids are affected by changes in flows because stages in their life history are timed to
coincide with periods of flow and appropriate water temperature. Future flows through the
Nuyakuk cascade will be altered by the Project’s water withdrawal and by changing climate
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patterns. Many of the climate change effects described below have likely impacts on salmonids
(Leppi et al 2014; Wobus et al 2015) and potentially compounded by the proposed Project’s
operations. Given that increased flows are projected by the five-member ensemble of global
climate models (GCM) best fitted for Western Alaska, these increases provide opportunities to
benefit both the hydropower generation and fish management and protection. Therefore, it is
critical to have estimates of future flows and stream temperatures to assess the combined effects of
the project and climate on these trust resources. This study is at the core of producing more evenly
distributed year-around hydropower generation, while at the same time protecting and maintaining
this salmon fishery. This is in line with recent literature that highlights opportunities to design and
operate hydropower projects for sustainability of both power production and the riverine
environment (Brown et al. 2015; Poff et al. 2016). Thus, this study will identify forward-looking,
climate resilient outcomes for hydropower development and fisheries.
Trends in the Region
We included published literature for the Bristol Bay Watershed. Documented trends include
(all Thoman & Walsh 2019 unless noted):
●Increase of 3.7º F in air temperature in the Bristol Bay region, 1969-2018
●Increase of 13 percent increase in annual total precipitation in Bristol Bay Region,
1969- 2018.
●Lowest sea ice extent in Bering Sea in February 2019 in last 170 years
●Total change in mean annual temperature in Alaska from 1976-2020 of 5.3°F, and
9.6°F, 5.2°F, 2.5°F, 3.2°F changes seasonally (winter, spring, summer, fall)3
●The climate normals for the Bristol Bay region for 1991-2020, announced by
NOAA in May 2021, are +1.1°F compared to the climate normal for 1981-2010 4
●Bristol Bay has rarely frozen in the last decade; people and animals used to walk or
sled to the nearby islands mid-winter on a regular basis (Markoff 2019).
Nuyakuk Watershed Hydrology
The proposed project will be located on the Nuyakuk River at a cascade approximately five river
miles downstream from the Tikchik Lake outlet, which drains the northern Wood River
Mountains, a 1,544 square mile watershed. The watershed contains six large lakes that comprise
12 percent of the land area. An additional 50 percent of the watershed is below 1,000 feet in
elevation. While the highest peak is over 5,000 feet, the vast majority of the watershed is below
3,000 feet in elevation. There are no significant glaciers, and permanent snowfields make up less
than 1% of the watershed. The proposed project would divert water out of the river above
Nuyakuk Falls, pass it through a tunnel(s) to a powerhouse located at the base of Nuyakuk Falls.
Nuyakuk Falls is a ½ mile long cascade with only 28 feet of elevation change. The Nuyakuk
watershed drains the west side of the Nushagak River basin. The Koktuli River, another tributary
3 https://akclimate.org/climate-change-in-alaska/
4 https://akclimate.org/the-new-climate-normals/
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to the Nushagak that was modeled in a project discussed below, drains from the east side of the
Nushagak.
There is a 69-year USGS gage record at Tikchik Lake outlet. The lowest mean daily winter flows
this decade are approximately 2,000 cfs, with the daily flows dropping below 1,500 cfs during two
winters. A broad, snowmelt-driven peak arrives in late-May/early-June and remains through mid-
August. The flow typically remains above 10,000 cfs for two months with a peak flow between
15,000 and 22,000 cfs. Half of the Octobers in the last decade have had a second peak over 10,000
cfs lasting days to two weeks. The Nuyakuk River hydrograph is not flashy because it has several
large upstream lakes.The hydrology of the Nuyakuk basin is changing (Figures 4-19, 4-22 and 4-
23). Consistent with climate models, mid-winter flows are higher, spring melt is happening 20
days earlier, and late falls flows are also higher. While late summer months flows have decreased
slightly, there is still sufficient water to generate energy and provide sufficient flow for fish
passage through Nuyakuk cascade.
Figure 4-19. This analysis of the Nuyakuk Gage at Tikchik Lake Outlet (USGS #15302000) indicates
the onset of spring runoff begins 20 days earlier now. November and December flow were
higher the last two decades then in any time from 1954 - 2000.
Relevant Climate Studies
Global climate models strongly agree on 21st century projections of significant increases in winter
precipitation and temperature in Alaska and across high latitudes (Maloney et al 2014). This
finding of increases in winter precipitation is also consistent across three generations of the IPCC
Coupled Model Intercomparison Project (CMIP). CMIP is an internationally coordinated project
that provides a standard experimental protocol for studying global climate models (GCMs)
CMIP3, CMIP5 and recently available CMIP6. Temperatures in Alaska are projected to rise
dramatically in the next decades, within the period of the proposed license (Figure 4-20) (Stewart
et al 2022). Most of the warming has occurred in the winter and spring and the least amount in the
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summer and fall. Spring temperatures have been above average since the late 1980s, and winter
temperatures have been mostly above average since 2001.
Figure 4-20. Observed and projected changes (compared to the 1925–1960 average) in near surface
air temperature for Alaska as a whole. Observed data are for 1925–2020, while model
simulations of the historical period are shown for 1901–2005. Projected changes for 2006–
2100 are from global climate models for two possible futures: one in which greenhouse gas
emissions continue to increase (RCP 8.5, higher emissions) and another in which greenhouse
gas emissions increase at a slower rate (RCP 4.5, lower emissions). Temperatures in Alaska
(orange line) have increased by about 3.5°F since 1925 but with large multidecadal
variations. Shading indicates the range of annual temperatures from the set of models.
Observed temperatures are generally within the envelope of the modeled historical
simulations (gray shading). Historically unprecedented warming is projected during this
century. Less warming is expected under a lower emissions future (the coldest end-of-
century projections being about 2°F warmer than the historical average; green shading) and
more warming under a higher emissions future (the hottest years being about 15°F warmer
than the hottest year in the historical record; red shading). Sources: CISESS and NOAA
NCEI, Figure 1 in Stewart et al 2022.
With respect to precipitation, Alaska is projected to have higher precipitation across the state, with
a statistically significant increase of 10 to >15% for the Nushagak basin based on CMIP5 models
(Stewart et al 2022). Significant changes in the hydrograph are projected, due to both these
projected temperature and precipitation changes.
Recent work has emphasized several trends and projections that are highly relevant for the
nexus/combined management of hydropower and fish habitat. In particular, there is both a trend in
the proportion of precipitation falling as rain vs snow, and the same trend is seen in GCM
projections (Littell et al 2018). This results in an altered seasonal hydrograph, with earlier peak
flows, and lower late summer flows because most of what would have run off slowly as snowmelt
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has already run off. One effect of increasing temperatures is a shift in the proportion of
precipitation falling as rain vs snow that will result in an altered hydrograph and necessitate
different management of the hydropower facility both for power and for fish habitat. Littell et al
(2018) have analyzed basins including those in the Bristol Bay climate division to assess the
snowfall equivalent to precipitation ratio (SFE:P). They find that the historically snow-dominated
or transitional watersheds in the Bristol Bay region watersheds (grouped together in this study,
includes the Nushagak), shift to transitional or rain-dominant watersheds in the 2050s to 2080s.
The SFE decreases by about 25% for mid-century and about 41% under the higher scenario
(RCP8.5) (their table 5). While overall more precipitation is projected, the SFE:P ratio decreases
to about 45 percent by mid-century and to about 34 percent by the 2080’s (their table 7). By the
late 21st century, only 33-50 percent of the HUC-12 watersheds in the Bristol Bay climate
division that are currently snow dominated will be snow dominated. This will require a different
management of the hydropower facility both for power and for fish habitat.
Recent peer-reviewed studies have described the changes projected by the CMIP5 generation of
IPCC models (few CMIP6-based studies are published yet). Wobus et al (2015) analyzed the
changes by CMIP5 models to assess flow changes in other parts of the Nushagak basin, finding
large changes in monthly temperature and precipitation projected based on five global climate
models (Figure 4-21).
Leppi et al. (2014) linked climate scenarios from GCMs and habitat models for the Chuitna River
in south central Alaska and used this in a coho salmon population model to assess how projected
climate change could affect survival at each freshwater life stage and, in turn, production of coho
salmon smolts. Relevant for the Nuyakuk basin, this study finds a significant increase in peak
discharge, temperature, and other stream variables at several points in the salmon migration and
development period.
These changes seen by Wobus et al (2015) are consistent with those already being seen in the
observed USGS gage record at Tikchik Lake outlet. The trend in flows for May (Figure 4-22) and
November (Figure 4-23), two months that are important for potential changes in salmonids, as
well as for hydropower demand. After 2002, average May flows are more likely to be above
10,000 cfs than below 4,000 cfs - the average those first 30 years. Average May flows have not
been below 4,000 cfs in eight years. Higher May flows could provide hydropower in the late
spring, when less water has been available in the historic record. If this upward trend continues,
coho runs might start extending into November and there will be sufficient water for energy
production to support the needs of the six communities while leaving sufficient water in the river
for fish.
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Figure 4-21. Monthly changes in future temperature and precipitation projected for five GCMs
(Figure 3 in Wobus et al. 2018).
Figure 4-22. Average daily flow for each May at USGS gage record at Tikchik Lake outlet. The 69
years exhibit an upward trend due to earlier snowmelt, with current flows almost double
those of the early 1950s (~3,500 vs ~6,500 cfs). Flows were consistently between 2,000 and
6,000 cfs from 1954 to 1975. From 1975 to 1995 average May flows above 6,000 cfs occur in
33 percent of the years. After 2002, average May flows are more likely to be above 10,000 cfs
than below 4,000 cfs - the average those first 30 years. Average May flows have not been
below 4,000 cfs in eight years.
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Figure 4-23. Average daily flow for each November at USGS gage record at Tikchik Lake outlet.
The trend over the past 69 years is for about 50% more flow in the present. Note the
interannual variability of the flows (e.g. 2019, 2020, and 2021, or 1979, 1980 and 1981). Note
that there are some missing years of data in the late 1990s.
The Future River Flows and Water Temperatures study includes employing the data from an
existing peer-reviewed ensemble of downscaled GCMs (Walsh 2018; Wobus 2015) and use a
hydrologic model to project mean monthly (at a minimum) or daily Nuyakuk River discharges
and stream temperature. The Wobus and Walsh climate projections, each based on five state-of-
the-art models developed for the IPCC, provide mean monthly precipitation and air temperatures
in the Nushagak watershed during the license term. They project a range of plausible future
scenarios.
4.1.7.3 Geographic Scope
The future river flows and water temperature study is a desktop exercise. The assessment will
encompass the Nuyakuk River watershed with an approximate drainage area of 1,510 square
miles.
4.1.7.4 Study Goals and Objectives
The goals of this study are to determine mean flows and water temperature during the assumed
50-year term of the license, at least at a monthly time scale, and weekly or daily if feasible.
Details of the study are provided in the § 5.9 (b) Generally Accepted Practices section below.
NOAA Fisheries and its NOAA climate science partners are available and willing to discuss the
details of the climate and flow studies to ensure its value for all parties. We assume a 50-year
license will be issued, and total project development time of eight years, so we propose
projecting the climate from 2030 to 2080. The objectives of this study are:
1.Use existing downscaled climate projections preferably supplied by University
of Alaska, Fairbanks (Walsh et al 2018; Wobus et al 2015) to model and predict
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Nuyakuk River flow and temperatures during the license term. These should be
done at least at a monthly time scale and weekly or daily if feasible.
2.Use this information to determine the future timing of returning adult salmon
and when water will be needed in the river to support fish passage both up and
down the falls. This information will inform the Nuyakuk Falls Fish Passage
(Study 1.2); Assessment of False Attraction (Study Request 1.4); Chinook and
Sockeye Salmon Life Cycle Modeling (Study 1.5) and the Economic Decision
Support Tool.
3.Use this information to project timing of out-migrating smolt. This
information will inform the Ice Process (Study 2.3) and Fish Entrainment and
Impingement (Study 1.3).
4.Use future flow information to inform turbine sizing and winter, spring and
fall energy production.
5.Use future flow information to inform project design and operation including tunnel
design, groin design, and any attempt to mesh winter hydropower with other
electric generation facilities to meet domestic winter power demands of the six
communities.
4.1.7.5 Relevant Resource Management Goals and Public Interest Considerations
The relevant resource management goals are captured in the NOAA Fisheries Alaska Geographic
Strategic Plan for 2020-2023 (NOAA 2020) and the Strategic Conservation Action Plan for
Southwest Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy oceans
support healthy populations of marine species and sustainable commercial and recreational
fisheries. The National Marine Fisheries Service involvement is also supported by mandates
under the Fish and Wildlife Coordination Act and Magnuson-Stevens Fishery Conservation and
Management Act. The National Marine Fisheries Service is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
4.1.7.6 Existing Information and Need for Additional Information
The USGS Nuyakuk gauge at the Tikchik Lake Outlet has an existing, mostly complete, flow
record spanning 69 years (1953 - 2022). Since it is four miles upriver from the proposed site,
those values can be scaled to the larger watershed and used for the analysis.
Baseline flows in the Nuyakuk River have already changed based on 69 years of USGS gauge
and are likely to continue changing in the coming decades due to the effects of climate change
(Figures 4-19, 4-22 and 4-23). The climate-induced changes to existing conditions will interact
with the project operations and the diversion of substantial flow from the river reach where
migrating fish are challenged by a series of cascades. An understanding of how the river flows
will change over time will inform the design, operations, project viability, and need for
mitigation measures over the term of the license.
Projected future daily or weekly flow values would better inform the project design and license
review process than only projected future monthly flows. For example, knowing the projected
average March flow in the Nuyakuk will be 3,000 cfs, is less useful than knowing most days in
March the flow will be between 2,200 and 2,600, but a two-day rain on snow event causing
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8,000 cfs will be likely (Figure 4-20), and in the last week of March flows will average 3,200 cfs
caused by the early onset of spring melt.
Bristol Bay Regional Seafood Development Association and Bristol Bay Native Corporation
funded an integrated watershed model in 2021 for the Nushagak Watershed constructed using the
MIKE SHE modeling code developed by the Danish Hydrology Institute. Calibration will be
substantially complete in 2022 using Fish Habitat Partnership money. Once this existing model is
adapted to a more spatially dense grid with a more frequent time step, it will work well for
projecting future flows and temperatures in Nuyakuk River. One piece of this study is to retrofit
the existing model to the smaller Nuyakuk watershed.
Additional information includes developed projections of air temperature and precipitation for
the upper Nushagak and Kvichak rivers (Figure 4-20) (Wodbus 2015). This analysis does not
project flows or temperatures in the Nuyakuk River. While the CMIP 6 model’s outputs might
refine those air temperature and precipitation projections, it is also reasonable to consider the
integrated watershed model (discussed below) using either CMIP 5 data or CMIP 6 data
depending on availability of appropriate downscaled products. Several studies have documented
climate induced changes in flows and stream temperature in other areas of southcentral and
southwest Alaska (Leppi 2014; Winfree 2014; and references within). The methods from these
studies could be replicated. The steps and data available to complete the analyses are described
below. Walsh (2018), in a project at the University of Alaska, also recently published
downscaled monthly climate data for Western Alaska that includes this region.
4.1.7.7 Project Nexus
There is a direct nexus between the combined impacts of changes in flow and fish habitat caused
by water withdrawals to supply the project turbines and climate change. The Nushagak Utility
proposes to remove different amounts of water from the Nuyakuk River at different times of the
year. The timing and volume of flows are projected to change due to climate warming. During
some time periods this could have a significant effect on salmon productivity, particularly during
smolt outmigration. However, operations could be designed, and conditioned in the license, to
maintain appropriate fish passage protection measures. This study will help estimate how much
water will be available for power generation in each month during the license term. It will
provide the flow analysis to indicate how salmon migration timing (both upstream and
downstream) will change due to water temperature changes. Finally, it will inform and integrate
with the Ice Processes Study, Sockeye and Chinook Lifecycle Study, Risk Analysis Study, and
the Economic Decision Support Tool. Developing the requested future flow and temperature data
at the onset will also help limit the need for revisiting project design features, including
mitigation measures, as future environmental conditions change.
The project is not causing climate change, however, the project’s operations, long-term viability,
and the fish habitat will be affected by changing climate. The proposed project operations will
compound the effects of climate change by altering the volume of water flowing through the
Nuyakuk cascades. As flow patterns change, changes in project operations often occur. Likewise,
project operations influence the behavior of migrating fish within the project area. The
information collected by this study will support the analysis of direct and cumulative effects of
the proposed project on migratory fish and aid in the development of any necessary license
articles regarding measures to achieve fish passage. Projections of a range of flow volumes at
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different times of the year will inform the quantity of water necessary to ensure economical
project operations and suitable habitat function during the salmon migration periods.
4.1.7.8 Methodology
It has become generally accepted practice to consider climate change in hydropower design
among planners and designers of hydropower and water supply facilities. The best available
science now includes the presently observed and projected future impacts of climate change on
water resources, as demonstrated by Congress directing the Secretary of Interior, via the Secure
Water Act, to coordinate with NOAA and its programs to ensure access to the best available
information on climate change [Secure Water Act (§) 9503 (c)]. The following are examples -
dating back more than fifteen years - from water projects such as Nuyakuk and others permitted
by FERC - in which managers and planners incorporate the risks of climate change in their
project design of projects, as well as in long-range operations planning:
•The U.S. Bureau of Reclamation (BOR) and Army Corps of Engineers (ACOE) both
use climate projections in their long-range operations planning and design, including
hydropower generation, flood control, and water supply. These agencies jointly
commissioned and released a report that identifies the needs of local, state, and
federal water management agencies for climate change information and tools to
support long-term planning (Brekke 2009). Beginning more than a decade ago,
ACOE and BOR and a consortium of agencies funded downscaled hydrologic
projections for use in planning for reservoirs and hydropower operations (Bureau of
Reclamation 2009, Dalton et al 2010). The BOR-funded project was then
subsequently updated for the next generation of IPCC global climate models (CMIP5,
Brekke 2013, Pierce et al. 2015). These flow projections are currently being updated
using the CMIP6 GCMs.
•The River Management Joint Operating Committee for Bonneville Power
Administration, ACOE, and BOR commissioned climate scenarios for use (River
Management Joint Operating Committee, 2010, a-c). The plans for this were
published as a peer-reviewed article (Hamlet, et al 2013).
•Non-Federal facilities are also being designed and managed with consideration of
climate risks. The Water Utility Climate Alliance (WUCA) includes twelve of the
Nation's largest water providers, many of which manage hydropower facilities. It was
formed to provide leadership and collaboration on climate change issues affecting the
country's water agencies. Among WUCA’s key messages is, “Warming is here and
now. Climate adaptation planning is not just about the future. Water utilities are
experiencing the effects of a changing climate on their water resources today.”5
WUCA and its member cities advocate the use of climate projections and planning
for a range of futures (Stratus Consulting and Denver Water 2015, Vogel et al. 2015).
5 https://www.wucaonline.org/
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•The American Society of Civil Engineers (ASCE) recommended the use of climate
change in design criteria. In a policy statement originally approved in 1990, (PS360)6,
ASCE highlighted the importance of climate change on the built environment. This
policy has been revised and adopted several times since then. In 2018 it indicated a
growing need for engineers to incorporate future climate change into project design
criteria, and in 2021, support for “Revisions to engineering design standards, codes,
regulations and associated laws that strengthen the sustainability and resiliency of
infrastructure at high risk of being affected by climate change.”7
A growing body of U.S. policy requires and provides guidance on consideration of climate risks
and use of climate information by federal agencies. In addition to the Secure Water Act, this
includes Executive Orders dating back to 2009 have directed federal water and hydropower
agencies such as the BOR, ACOE and Department of Energy to consider climate change in
their projects (Executive Order (EO) 13514, replaced by EO 13693, titled Planning for Federal
Sustainability in the Next Decade, March 19, 2015). On Dec 8, 2021, President Biden signed
EO 14057 8, which orders agencies to integrate climate-readiness across missions and programs
and bolster resilience of Federal assets, including hydropower facilities 9. Federal agencies have
increasingly considered the risks of climate change (e.g. NMFS 2016 and Udall 2013).
The downscaled climate projections follow in this tradition, based on the same IPCC global
climate models. In particular, the University of Alaska Fairbanks’ Alaska Climate Research
Center (http://akclimate.org/) has produced the Scenarios Network for Alaska and Arctic
Planning (SNAP, https://www.snap.uaf.edu).
In FERC’s Order rejecting the request for rehearing by National Marine Fisheries Service and
the Center for Water Advocacy of the formal study dispute determination regarding Susitna
(July 18, 2014), FERC stated, “as climate change modeling continues to advance, it may
eventually yield data and knowledge that can and should be used to formulate license
requirements that respond to environmental effects caused by climate change.” That time has
come. Another generation of IPCC models (IPCC 2021) has consistent findings - albeit further
refined - with previous IPCC (IPCC 2013 and IPCC 2007) and U.S. National Climate
Assessment analysis, while also providing more detailed and relevant information for natural
resource planners. Climate modeling and especially downscaling methodology has improved
6 https://www.asce.org/advocacy/policy-statements/ps360---climate-change
7 Ibid.
8 https://www.whitehouse.gov/briefing-room/statements-releases/2021/12/08/fact-sheet-president-biden-
signs- executive-order-catalyzing-americas-clean-energy-economy-through-federal-
sustainability/#:~:text=The%20executive%20order%20will%20reduce,%2C%20healthy%2C%20and%20resilient%2
0communities
9 https://www.whitehouse.gov/briefing-room/statements-releases/2021/10/07/fact-sheet-biden-
administration-releases- agency-climate-adaptation-and-resilience-plans-from-across-federal-government/
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significantly in the last decade. Furthermore, in the last five years climate change effects have
been acknowledged across all departments of the State of Alaska Government. Downscaled
climate projections datasets developed for Alaska (Walsh 2018) and elsewhere are being used
as generally accepted practice in the design and operational planning for hydropower. This
study takes into consideration the advances in science, the generally accepted practice, and
understanding both the risks of climate change and the potential opportunities of the projected
increases in temperature and precipitation and the effects on managing flows both for
hydropower and fish habitat.
The steps and data available to do these analyses are described below. New climate modeling is
not needed. Rather, analyses of existing, publicly available and peer-reviewed datasets will be
conducted based on existing CMIP dataset, using peer-reviewed and generally accepted
practices, as described in those articles and cites therein.
The basic analysis that is needed is to move from downscaled GCM projections of temperature
and precipitation to projected flows and water temperatures from a integrated hydrologic model
for the Nuyakuk River specifically. The hydrologic modeling will then be analyzed and
presented in a technical report of the future flows available, and thus the hydropower and fish
habitat needs. Additionally, this report will include an analysis of the impacts of projections on
the project nexus, and hydropower facilities. The three major steps are:
a)Downscaled GCM Outputs. Use of the dataset described by Walsh et al (2018), an
existing, peer-reviewed and publicly available monthly downscaled climate projection
dataset, and related data. Scenarios Network for Alaska and Arctic Planning (SNAP),
along with related data is available for download at: https://www.snap.uaf.edu. This
dataset is based on the 5th IPCC generation of global climate models (CMIP5). Walsh
et al (2018) analyzed the over 35 GCMs to assess which five best represent climates in
Alaska as a whole. See (Lader 2017) or (Bieniek et al. 2015) for a more detailed
description of the downscaling model procedure and an evaluation against historical
temperature and precipitation data. Their product provides monthly values of projected
future air temperature and precipitation. Monthly values are the minimum needed for
analyses of future flows but may average out changes. Wobus et al (2015) generated
daily values, and thus were able to discern shorter time scale features in river flows. If
technically feasible and available for the Nuyakuk River, this daily scale is preferable
because of the finer time scale changes that daily analyses would detect.
Because 30 months have passed since this study was originally proposed (2/4/2020),
new downscaling efforts are underway and downscaled CMIP 6 climate products may
become available before this study is started. Furthermore, a dynamically downscaled
product for all of Alaska may be available soon. If by the time this study is executed, a
sub-monthly or daily downscaled product is available, that would be preferable. If a
CMIP6-based appropriate downscaled product becomes available, that product may be
used instead of the Walsh et al 2018 dataset. However, it is not necessary to wait for
CMIP6.
Predicted temperatures and precipitation will be analyzed for at least three periods of
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the license, for example, early, the first third (e.g. 2030 – 2047); the middle third, (e.g.
2047-2064); and the late or final third (e.g. 2064 to 2080) for the Nuyakuk watershed.
This will allow consideration of flow trends that may evolve over the period, and
potentially different operations as projected conditions change.
b)Hydrologic Modeling. A published, vetted hydrologic model will be used to translate
these downscaled climate outputs (precipitation and temperature) into other
hydroclimate variables (evaporation, soil percolation, surface runoff) and ultimately the
timing and volume of runoff into the Nuyakuk River, and stream temperatures. Several
watershed models that integrate atmospheric conditions with surface water and
groundwater could be applied to the Nuyakuk watershed; however, they would require
extensive development.
We will use the MIKE SHE system (Graham and Butts 2005), a fully distributed,
parameter integrated, hydrologic code that simulates the flow of water within and
among surface water, groundwater, and the unsaturated zone. Atmospheric conditions,
including precipitation, air temperature, and evapotranspiration drive continuous flows
within the hydrologic system. A modified degree-day snowmelt method, the code
simulates snow accumulation if air temperatures fall below a freezing threshold, and it
also simulates snowmelt processes including evaporation (sublimation and wet- snow
evaporation), rain-on-snow, changes in wet and dry snow storage, and refreezing of wet
snow. The Wobus et al (2014) effort, also implemented a heat balance algorithm to
simulate stream temperatures (Loinaz et al. 2013). The hydrologic models then projects
monthly (or daily) water temperatures based on predicted air temperature and the
relative river contributions from surface water versus groundwater sources versus
snowfields sources.
Furthermore, the MIKE/SHE system is useful because Bristol Bay Regional Seafood
Development Association and Bristol Bay Native Corporation already funded the
development of an integrated watershed model for the Nushagak watershed using
MIKE/SHE MIKE 11 code developed by the Danish Hydrologic Institute (DHI). MIKE
SHE has been used and verified extensively worldwide and in the U.S. since the mid-
1970s, by multiple federal agencies including USACE, FEMA, USDOE, USDA,
academic researchers and others to support evaluation of complex networks of
hydraulic structures and operations, nature and extent of impacts on hydrologic/ecologic
systems, and optimization of mitigations. As a cost saving measure, we will adapt the
existing larger Nushagak model to the Nuyakuk watershed.
c)Technical Report. The potential climate change effects will be summarized in a
Technical Report. This technical report will include a description of the assumptions
made, models used, and other background information. The report will provide
interpretation and guidance on the science knowledge developed, in order to translate
them into useable knowledge, through syntheses and translational products developed to
address the hydropower, water, and fisher habitat needs. Additionally, this report will
include an analysis of the impacts of projections on the project nexus, and hydropower
facilities. The report will include an electronic supplement that makes the data used in
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this study available for the use of other studies.
4.1.7.9 Level of Effort and Cost
This study can be completed in six months because climate projections for the region already
exist. It will be ready as input to other studies. The cost ($50,000-75,000) is reasonable
considering the PAD estimated that $1,000,000 annually in diesel cost could be avoided once
this project comes online. Correctly sizing turbines and designing them for maximum efficiency
at the flows expected during the license term could change the unit efficiency by ten percent.
Producing daily projected flows and temperatures, compared to monthly, will increase the cost
and time required slightly, but not significantly.
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4.2 Water Resources
4.2.1 Water Quality Assessment – Dissolved Oxygen and Water Temperatures
4.2.1.1 General Description of Proposed Study
Section 5.2.2. of the PAD listed “Water Quality and Water Temperature Assessment of the
Nuyakuk River near the Project Site” as a potential water resource study.
In their PAD comment letter dated February 4, 2020, ADFG was supportive of this study topic
because it has “a direct impact on fish resources”. ADFG did not submit a detailed study request
but offered to work with the Cooperative to ensure a water quality assessment would be carried
out in a way that the quality and relevance of the data collected informs the decision-making
process.
The Royal Coachman Lodge also submitted comments on the PAD to FERC in a letter dated
February 3, 2020. Specifically, representatives from the lodge requested the following to be
studied:
“Study the oxygenation provided by the Falls and its benefit to the fish in the system. With water
temps rising (due to climate change), changing the oxygenation levels of the river could cause
damage to the fishery and the ability of the anadromous fish to proceed upstream on their
spawning runs. Given that warmer water carries less oxygen for the fish, oxygen levels could
become more important to fish survival in the future.”
Based on these comments, the Cooperative is proposing to collect dissolved oxygen (DO) and
water temperature data in the vicinity of the proposed Project.
4.2.1.2 Geographic Scope
The DO and water temperature study will include two main study locations. Study location 1 will
be upstream of Nuyakuk Falls in proximity to the intake structure. Study location 2 will be
downstream of the Falls in an area near the proposed Project tailrace (Figure 4-2).
4.2.1.3 Study Goals and Objectives
The primary goals of this study are the following:
1. Collect baseline continuous (DO) data during periods of peak water temperatures (July –
August) for a minimum of 72 hours.
2. Collect baseline continuous water temperature data for a minimum of a calendar year
(January – December).
3. Determine if DO concentrations are substantially different above and below Nuyakuk
Falls.
4.Compare the study results to DO and water temperature criteria established by the Alaska
Department of Environmental Conservation (ADEC).
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4.2.1.4 Relevant Resource Management Goals
The Nuyakuk River is protected by the following designated use criteria (C): “Growth and
Propagation of Fish, Shellfish, Other Aquatic Life, and Wildlife” (ADEC 2018). Therefore, DO
concentrations must be greater than 7 mg/l in waters used by anadromous or resident fish. In
addition, ADFG details two agency mandates that provide oversight to the water resources of the
Nuyakuk River.
The Fish and Game Act requires ADFG to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the
interest of the economy and general well-being of the state” (AS 16.05.020).
ADFG – Division of Sport Fish Mission is “to protect and improve the state’s recreational and
fisheries resources”. According to the 2015-2020 Division of Sport Fish Strategic Plan, the
management priority is to manage Alaska’s recreational fisheries for sustained yield and
recreational angler satisfaction that is centered on an area-based management system. The
division’s fish habitat program is directed at protecting and restoring fish habitats for the benefit
of fish and current and future recreational anglers.
4.2.1.5 Existing Information and Need for Additional Information
Available water quality data were summarized in the PAD upstream and downstream of the
proposed Project. Although historical data indicates excellent water quality conditions for
nutrients, trace metals, turbidity, and coliform bacteria there were limited DO data above and
below the Nuyakuk Falls.
4.2.1.6 Project Nexus
The proposed Project would create a bypass reach and divert a percentage of water volume away
from the Falls and into a penstock for power production. Understanding the baseline conditions
of how dissolved oxygen concentrations vary upstream and downstream of the Falls is critical to
understanding if Project diversion for power production would impact DO concentrations.
4.2.1.7 Methodology
The Cooperative will deploy calibrated, continuous DO and temperature loggers at two locations,
one upstream and one downstream of Nuyakuk Falls. The data loggers will be set to record DO
and temperature data at 30-minute intervals and be deployed for a minimum of 72 hours. Field
calibration readings will consist of taking measurements of DO and water temperature at the
beginning and end of the deployment period. This will be achieved by collecting spot DO and
temperature readings from a calibrated multiparameter sonde adjacent to the deployed logger.
4.2.1.8 Proposed Deliverables and Schedule
Study results will be summarized in time series graphics and in tables for each unique 72-hour
study period. The 2023 results will be presented in an ISR and collaboratively discussed with
stakeholders during both mandated process meetings and regular status calls/meetings scheduled
by the Cooperative to determine if additional data collection is needed for a second monitoring
season.
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4.2.1.9 Level of Effort and Cost
The Cooperative believes that the proposed study effort is appropriate to assess potential effects
the Project may have on DO concentrations. A single year of study is all that would be
necessary to meet baseline study objectives.
The estimated cost for this study is approximately $35,000 to $45,000.
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4.2.2 Flow Duration Curve Change Assessment
4.2.2.1 General Description of Proposed Study
Published studies indicate shifting climate conditions for Bristol Bay watershed over the last 50
years (Thoman 2019) and forecast future change as a result of climate change (Wobus 2015)
during the next century. During the term of any new license for this project, Southwest Alaska
will experience increasing temperatures and increasing annual precipitation (Walsh 2018). The
resulting changes in environmental conditions during the next 30-50 years will influence project
operations, scope and scale of project related impacts, and the effectiveness of mitigation
measures designed to protect fish habitat. This study will help identify trends in flow conditions
to provide a forward-looking evaluation of the flow duration curve. Data from this study will
inform the licensing process with specific application to project design, operation and fish
protection measures. The Applicant suggested a similar study during the November 18, 2019
project kickoff meeting.
4.2.2.2 Geographic Scope
The flow duration change analysis is a desktop exercise. The assessment encompasses the
Nuyakuk River watershed with an approximate drainage area of 1,510 square miles.
4.2.2.3 Study Goals and Objectives
The goal of the study is to evaluate changes in the flow duration curve for the Nuyakuk
River that have happened during the USGS 15302000 gage record which spans 69 years
(1953- 2022). There are a few years with no data and many years where the winter flow is
estimated from nearby rivers. This study will not analyze climate projections or future
flows. The objectives of this study are:
a.Determine if flow pattern observable for the USGS Nuyakuk River gage record
exhibit stationarity as hydrologist assumed for decades, or if there is a statistically
significant trend (Milly 2008) consistent with other gage records in Northern
climates where a change analysis has been completed.
b.Use the appropriate data to inform the development of climate resilient
license articles. This is a statistical study using peer reviewed existing USGS
flow data.
4.2.2.4 Relevant Resource Management Goals and Public Interest Considerations
The relevant resource management goals are captured in the NOAA Fisheries’ Alaska
Geographic Strategic Plan for 2020-2023 (NOAA 2020) and the Strategic Conservation Action
Plan for Southwest Alaska (SASHP 2017). Identified in the Alaska Geographic strategic plan is
(1) ensuring healthy, sustainable fisheries and mariculture over the long term with ecological,
economic, and socio-cultural benefits for the nation and (2) supporting the socio-economic well-
being of fisheries, and fishing communities through science-based decision-making and
compliance with regulations. The National Marine Fisheries Service involvement is also
supported by mandates under the Fish and Wildlife Coordination Act and Magnuson-Stevens
Fishery Conservation and Management Act.
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The National Marine Fisheries Service, is a federal resource agency with a mandate to protect
and conserve fisheries resources and associated habitat.
4.2.2.5 Existing Information and Need for Additional Information
The existing flow curve relies on methods developed prior to our current understanding of
climate, especially that although stream flows are variable between years and months, they are
often no-longer tied to a static horizontal line (stationarity). The analysis will indicate if
stationarity (Milly 2008) exists at the Nuyakuk gage. This evaluation has not been completed for
this USGS gage record. Methods exist to complete a similar analysis in a more rigorous fashion
and indicate the months showing clear trends versus those merely indicating variation between
years.
4.2.2.6 Project Nexus
River flow and its seasonal patterns directly influence project design and operations, and
mitigation measures intended to protect public trust resources. As this is a new project
development, the applicant is considering the changing environmental conditions on which the
project is dependent for successful operation. As flow patterns change, changes in project
operations often occur. For example, the Bradley Lake Project (P-8221) licensee decided not to
divert water from Battle Creek from November through May based on gage data from the
historical record. Historical data indicated no flow worthy of diversion during this timeframe. In
2019, both November and December saw 1,000’s of acre feet flow down Battle Creek as large
precipitation events arrived primarily as rain. Based on the license condition, which was
premised on the historical, stationary hydrograph, the licensee could not capture this potential
generation.
Likewise, project operations influence the behavior of migrating fish within the project area. The
information collected by this study will support the analysis of direct and cumulative effects of
the proposed project on migratory fish and aid in the development of any necessary license
articles regarding measures to achieve fish passage. If this watershed runoff pattern is non-
stationary, then design consideration, operations models and license articles should be flexible
enough to deal with to manage future change.
4.2.2.7 Methodology
Studies will use current literature, existing data from the USGS gage (USGS No. 15302000), and
standard practices accepted by the scientific community. Based on an ADF&G request, the study
may also utilize a synthetic flow record based on correlations from a recently installed stream
gage at the Project location. The Project stream gage is located approximately 4.6 miles
downstream of the USGS gaging station and would represent more accurate flow volumes at the
point of diversion. A duration curve change analysis is a standard Bureau of Reclamation
analysis method. Many utilities with hydropower projects are employing it for their decision-
making processes.
4.2.2.8 Proposed Deliverables and Schedule
Results from the change analysis will be summarized as annual and monthly flow duration
curves and tables. The updated flow duration curves will also be compared to results from the
historical streamflow record directly calculated from USGS gage 15302000 15302000 and
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potentially at the Project stream gage. Assuming approval of the RSP, the Cooperative plans on
beginning the study in the spring/summer of 2023 and will continue to supplement this effort
with additional hydrologic information during the study years.
4.2.2.9 Level of Effort and Cost
All the data necessary to complete this study are available. The analysis could be completed
within two to four months. The level of effort and cost is commensurate with the proposed
Project size and the likely license term. No alternatives have been proposed.
The estimated cost for this study is approximately $100,000 to $125,000.
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4.2.3 Ice Processes Assessment
4.2.3.1 General Description of Proposed Study
Per PAD comment and study request letters, including from NMFS, the Cooperative received a
request to conduct an Ice Processes Assessment and looks forward to collaborating with all
interested stakeholders in further defining the appropriate desktop methods and analysis tools to
utilize in assessing existing conditions and determining potential impacts (positive and negative)
related to operations of the Project.
4.2.3.2 Geographic Scope
The geographic focus of the Ice Processes Assessment will be the entire span of the river from
the hydraulic control for the Nuyakuk Falls upstream approximately 1500 feet with an emphasis
on the area near the proposed Project intake (see Zone 1 on Figure 4-2).
4.2.3.3 Study Goals and Objectives
The primary goal of this study is to utilize literature and data supplemented by site-specific
photos and video to gain a better understanding of both existing ice formation processes and the
potential localized modifications to these processes as a result of Project operations.
4.2.3.4 Relevant Resource Management Goals
As it relates to this particular study, the primary resource management goal is associated with
NOAA fisheries strategic Plan which describes, “the long-term goal of healthy oceans that
support healthy populations of marine species and sustainable commercial and recreational
fisheries. Our involvement is also supported by mandates under the Fish and Wildlife
Coordination Act and Magnuson-Stevens Fishery Conservation and Management Act.”
4.2.3.5 Existing Information and Need for Additional Information
Relevant regional satellite footage for the area does exist and a series of Alaska-based studies
have been conducted over the past 40 years which should prove valuable to assess precedent and
to correlate the Project’s proposed operational regime to potential impacts for ice formation.
This existing data will be the foundation of the study and once fully evaluated, will be
supplemented with additional site-specific data, if necessary.
4.2.3.6 Project Nexus
The proposed Project would divert water from the existing channel of the Nuyakuk river and
potentially alter the flow dynamics of the bypass reach. This alteration during winter months
may modify the natural ice formation processes that occur immediately upstream of the proposed
intake each year. Understanding the level of change and associated impact (if any) to ice
processes and Project operations during winter months will assist in determining the appropriate
Project layout and operational regime.
4.2.3.7 Methodology
The Cooperative has a vested interest in developing a collaborative study that effectively meets
the needs of the stakeholders while at the same time focuses on the area of potential impact. As
such and per commitment from stakeholders such as ADFG and NMFS, the Cooperative plans
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on working with stakeholders over the spring and summer of 2022 to define the appropriate
methods to be utilized to ensure both effective documentation of existing conditions and a safe
study design for necessary field efforts.
The Cooperative has developed a preliminary list of potential methods to utilize with a focus on
desktop efforts. These methods include:
•Review of recent (past 20 years) of satellite images for the Nuyakuk Falls area to
document existing natural conditions and year to year variation.
•Conduct a literature review of existing hydropower facilities in Alaska and other cold
weather environments to evaluate their methods for continued winter operation in
harsh environments with substantial temperature variations.
•Potentially, establish locations for video and/or frequent photo data to be collected
near the Nuyakuk Falls during the winter and early spring of the 2022 and 2023 study
seasons to document ice process at the Project site.
Again, the Cooperative looks forward to collaborating with stakeholders to define the
appropriate methodological regime for this Project site.
4.2.3.8 Proposed Deliverables and Schedule
Assuming timely issuance of the Study Plan Determination, the Cooperative plans conducting
the study in 2023 and 2024. Upon implementation, study results will be documented in the ISR
and USR. It is notable that the Cooperative anticipates ongoing collaboration with stakeholders
throughout the study process so that determinations related to efficiency of methodology, any
study modifications that may be necessary and/or the need for extending studies can be discussed
and efficiently implemented. This collaborative process will also allow the Cooperative to
provide stakeholders with periodic status updates when results, anomalies, etc. warrant.
4.2.3.9 Level of Effort and Cost
The estimated cost for this study is approximately $35,000 - $50,000.
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4.3 Terrestrial Resources
4.3.1 Botanical and Wetlands Survey
4.3.1.1 General Description of Proposed Study
The Cooperative proposes to conduct a study to gather baseline botanical and wetlands data,
including surveying vegetation types, wetlands, BLM Special Status plant species, and non-
native plant species in the proposed Project vicinity. The study will consist of both desktop and
field-based data collection methods.
4.3.1.2 Geographic Scope
The desktop portion of the study will cover the entire proposed Project boundary, as shown in
Figure 2-2. While it is anticipated that field data collection will be focused on the intake and
powerhouse facility vicinity shown in Figure 2-3, where the majority of impacts to terrestrial
resources are expected to occur, the desktop effort will also assist in defining areas to avoid
when designing the appropriate transmission line corridor for the Project Because no access
roads are proposed as part of this Project, impacts to terrestrial resources outside of the intake
and powerhouse facility area are generally limited to transmission line placement.
4.3.1.3 Study Goals and Objectives
Study goals and objectives include the following:
•Refine existing vegetation and wetland mapping available for the Project vicinity,
both through desktop analysis and field data collection, in order to be able to assess
Project impacts on these resources.
•Identify any BLM Alaska Special Status plant species that may occur in the area
where Project impacts to terrestrial resources may occur.
•Locate any populations of non-native vegetation species in the Project facilities
vicinity, so that appropriate management practices can be developed, if needed.
•Identify and classify wetlands in the proposed Project boundary and other Waters of
the United States in accordance with U.S. Army Corps of Engineers (USACE)
practices to define areas subject to federal regulation and policies.
4.3.1.4 Relevant Resource Management Goals
The proposed Project boundary includes land owned by the State of Alaska, Native villages or
corporations, BLM, and private or municipal entities. The proposed Project facilities will be
located on land owned by the State of Alaska, within Wood-Tikchik State Park. The Wood-
Tikchik State Park Management Plan describes the coniferous and mixed coniferous-deciduous
forests, willow-alder thickets, tundra, and alpine meadows that characterize the vegetation within
the park. Vegetation in the State Park provides wildlife habitat and is sometimes utilized for
firewood collection or subsistence harvesting. Wetlands and Waters of the U.S. are subject to
federal government regulations and policies, although some waters and shorelands within Wood-
Tikchik State Park are owned by the State of Alaska (ADNR 2002).
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4.3.1.5 Existing Information and Need for Additional Information
High-resolution, site-specific botanical and wetlands data currently does not exist for the
proposed Project location. General descriptions of types of terrestrial vegetation and wetlands
were provided in the Project’s PAD. Detailed surveys of non-native vegetation species or Special
Status plant species have not been conducted in the proposed Project vicinity to date. Site-
specific data are necessary in order to assess any potential impacts to these resources and to
guide appropriate delineation of the transmission line corridor for the project.
4.3.1.6 Project Nexus
Construction and operation of the Project will require ground disturbance that may impact
botanical resources or wetlands. Impacts to these resources need to be assessed using data
collected during the proposed botanical and wetland mapping and field survey efforts. Project
design and management plans will rely on information collected during this study, and study data
may aid in the development of mitigation plans to avoid, minimize, reduce over time, and
compensate for impacts to botanical or wetland resources.
4.3.1.7 Methodology
Study Component #1 – General Vegetation Type/Wetland Mapping
Desktop analysis of the best available aerial imagery and existing wetland and vegetation
Geographic Information System (GIS) datasets from available sources including federal, state,
and local entities will be used in this analysis. Using these data, refined GIS layers covering the
entire proposed Project boundary will be developed. This information will subsequently be used
to guide field data collection efforts, including wetland delineation locations and areas for
sensitive and non-native plant surveys. A final map will be produced which will display
vegetation type polygon boundaries, specific Project components, and impact areas.
It is important to note that conceptual layout developed to this point for the transmission line has
been established per existing topography to utilize the higher-elevation areas (ridgelines, etc.) in
an effort to avoid any wetlands. That said, the Study Component #1 will assist in refining the
transmission line corridor by combining the known topography with specific wetland location
data.
Study Component #2 – Field Vegetation Surveys/Wetland Delineation
A field vegetation survey and delineation of wetlands and Waters of the U.S. will be conducted
in the area where Project facilities are proposed for construction. The field vegetation survey will
include the following:
•Identification and mapping of any BLM Alaska Special Status plant species occurring
in the vicinity of the proposed Project facilities.
•Identification and mapping of any non-native plants appearing on the list maintained
by University of Alaska Anchorage/Alaska Center for Conservation Science (UAA
2020).
The wetland delineation will include the following:
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•Collect detailed information on soil conditions, hydrology, and plant community
composition in representative upland and wetland sites using guidelines from the
1987 wetland delineation manual (USACE 1987) and 2007 Alaska Regional
Supplement (USACE 2007).
•Collect functional assessment data for each wetland. The functional assessment
method used will be discussed with the USACE prior to field sampling.
•Coordinates of wetland boundaries will be collected by GPS in the field.
•Prepare a final wetland and waters of the U.S. map for areas potentially disturbed by
Project activity using field delineation results. Map will include wetlands and other
waters by National Wetlands Inventory (NWI) class (Cowardin 1979), and field data
collection locations. Prepare a table of acres per NWI class using data and maps.
•Prepare a wetland and waters of the U.S. report that will include a detailed map of
areas potentially disturbed by Project activity, the general map of the entire study
area, methods and findings, a wetland functional assessment, and copies of the field
data forms.
4.3.1.8 Proposed Deliverables and Schedule
Study Component #1 – General Vegetation Type/Wetland Mapping
Desktop mapping of vegetation types and wetlands will occur in advance of field vegetation
surveys and wetland delineation in 2023. Deliverables from this study component include GIS
layers of vegetation types and wetlands located in the proposed FERC Project boundary and
maps displaying the GIS data for presentation purposes. The results of this study component will
be included in the Project’s ISR and presented to stakeholders at the ISR meeting.
Study Component #2 – Field Vegetation Surveys/Wetland Delineation
Field vegetation surveys and wetland delineation will occur in summer 2023, during the season
of peak flowering in Alaska. Deliverables from this study component will include a written
report summarizing the results from the detailed field vegetation survey and wetland delineation,
field data sheets including standard USACE Alaska Region wetland delineation forms, and GIS
data containing the location of delineated wetlands, Special Status plant populations, and non-
native plant populations. Results of the field vegetation survey and wetland delineation will be
included in the Project’s USR. Results will be presented at the Project’s USR meeting.
4.3.1.9 Level of Effort and Cost
The Cooperative estimates that the cost to conduct this study is approximately $150,000 -
$200,000.
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4.3.2 Caribou Population Evaluation
4.3.2.1 General Description of Proposed Study
The Cooperative proposes to conduct a study to evaluate caribou data from ADFG’s Division of
Wildlife Conservation ongoing Mulchatna caribou herd (MCH) Survey and Inventory (S&I)
program (Barten and Watine 2020). The Cooperative has initiated preliminary discussion with
ADFG to establish collaboration and mechanisms for data sharing. ADFG manages an expansive
caribou S&I program for the MCH and collects data on an annual basis to document migration,
productivity, health, population size and composition, and calf survival. ADFG has expressed a
willingness to share the data from their ongoing study with the Cooperative for the purposes of
conducting and impact assessment related to Project development and operations. The
Cooperative proposes to analyze ADFG’s dataset to evaluate potential impacts to caribou as a
result of the proposed Project.
4.3.2.2 Geographic Scope
The study area will encompass the entire proposed FERC Project boundary and surrounding
areas within Game Management Units (GMUs) 17B and 17C (Figure 4-24, Barten and Watine
2020). ADFG’s caribou S&I program for the MCH covers a large area within southwest Alaska
corresponding to the range of the MCH (Figure 4-24). The proposed Project facilities are located
within GMU 17B, and proposed transmission lines extend into GMU 17C (Figure 4-24).
Therefore, this study will focus on the MCH S&I data collected by ADFG within GMUs 17B
and 17C.
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Figure 4-24. Range of the Mulchatna caribou herd (MCH) and permitted hunt area specific to this
herd (RC503) in Southwest Alaska (Barten and Watine 2020).
4.3.2.3 Study Goals and Objectives
The goals of the study are to evaluate any potential impacts to the MCH as a result of the
proposed Project. Study objectives include:
• Evaluate the MCH population status and trends, including population size,
population composition, and breeding trends within GMU 17B and 17C
• Evaluate caribou health within GMU 17B and 17C, including body condition, calf
survival, and mortality rates
• Evaluate caribou habitat assessment within GMU 17B and 17C and by monitoring the
condition and productivity of captured female caribou
• Evaluate MCH land use within GMU 17B and 17C, including migration corridors,
calving areas, and foraging patterns
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4.3.2.4 Relevant Resource Management Goals
Federal and state agencies, including U.S. Fish and Wildlife Service (USFWS) and ADFG,
cooperatively manage the MCH, seeking to balance subsistence harvesting and protection of the
population. The population has seen steep declines in recent years, leading to early closures of
hunting season on federal lands (Macarthur 2019). Federal and state managers closely monitor
the population of the MCH through ADFG’s S&I program for conservation purposes. ADFG
administers an intensive management (IM) program for the MCH due to the declining herd
population size in recent years. ADFG partners with ADNR, USFWS, BLM, and National Park
Service (NPS) to manage the MCH according to the Mulchatna Caribou Monitoring Plan, with
goals related to both caribou conservation and maintenance of the herd for subsistence use
(Barten and Watine 2020).
4.3.2.5 Existing Information and Need for Additional Information
Section 4.5.1.2 of the PAD presented the existing information for the MCH in the vicinity of the
proposed Project. As discussed in the PAD, caribou herds experience long-term population
fluctuations and changing patterns of range use. To meet these information needs, ADFG
conducts its extensive MCH S&I program on an annual basis (Barten and Watine 2020). ADFG
maintains these diverse and long-ranging MCH datasets, covering much of southwest Alaska
including the proposed Project vicinity. Through the data-sharing agreement that the Cooperative
proposes to establish with ADFG, the Cooperative will have access to a robust dataset
documenting MCH population health, demographics, and use of the proposed Project vicinity
over time.
4.3.2.6 Project Nexus
Construction and operation of the proposed Project may impact habitat that caribou use
seasonally or annually for foraging, migration, or calving. Habitat impacts have the potential to
affect the overall MCH population in terms of size and composition. Development of any
necessary mitigation measures for the Project’s construction and operation will be based on
MCH population statistics and documented use of the proposed Project vicinity on an annual
basis.
4.3.2.7 Methodology
The study will consist of a desktop analysis of ADFG MCH S&I datasets (Barten and Watine
2020). The Cooperative intends to obtain available MCH S&I data from ADFG to analyze
caribou population size, migration, and habitat utilization in the Project vicinity (GMU 17B and
17C). ADFG conducts the following activities under the annual S&I program, which will be used
in the desktop analysis (Barten and Watine 2020):
•Population Status and Trend:
- Activity 1.1 – Maintain a sample of radiocollared caribou
- Activity 1.2 – Conduct partuition surveys each spring using radiocollared female
caribou of known age to determine age-specific pregnancy rates
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- Activity 1.3 – Conduct an annual photo survey of the MCH to obtain a population
estimate
- Activity 1.4 – Conduct fall composition surveys to estimate sex ratio, age ratios,
and recruitment of calves to fall
- Activity 1.5 – Investigate and monitor calf survival to determine factors
responsible for calf mortalities
•Habitat Assessment-Enhancement
- Activity 3.1 – Evaluate the condition of the Mulchatna caribou range by
monitoring the condition and productivity of captured female caribou
Data collected will be analyzed and correlated with proposed Project infrastructure location and
operational parameters to determine what impacts (if any) related to current caribou behavior and
success can be expected as a result of Project development.
4.3.2.8 Proposed Deliverables and Schedule
The desktop portion of the study will be conducted from fall 2023 through fall 2024. The
desktop study will also incorporate historic ADFG S&I data for the MCH and will include the
data collected during the study period (2022-2023), as available.
Data will be synthesized in the Project’s ISR and USR filings. The findings will be presented to
stakeholder at the ISR and USR meetings.
4.3.2.9 Level of Effort and Cost
The study will be conducted over approximately two years’ time by a qualified wildlife biologist
in collaboration with ADFG Division of Wildlife Conservation. The Cooperative estimates that
the cost to conduct this study is approximately $50,000 - $75,000.
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4.4 Cultural Resources
4.4.1 Subsistence Study
4.4.1.1 General Description of Proposed Study
Based on the study request received from ADFG, it is the Cooperative’s understanding that
ADFG intends to assist the Cooperative by conducting a subsistence study to update information
about subsistence use in the proposed Project vicinity last gathered in 2005. The Cooperative
will be responsible for funding the study, which, based on the study request, the Cooperative
expects will be executed by ADFG using their standard methodology for collecting this type of
information. The Cooperative will consult further with ADFG regarding the planning and
execution of this study and will consult with ADFG regarding the funds required to undertake
the work.
4.4.1.2 Geographic Scope
The Cooperative will consult further with ADFG but expects that the geographic scope of the
Project will focus on the use of the proposed Project vicinity by people living in the villages in
the Bristol Bay region. It is understood that ADFG’s overall geographic scope for their global
subsistence survey may be beyond the bounds of the dataset needed for the Cooperative’s
assessment. As such, the subset of data within the proposed Project’s boundary will be utilized.
4.4.1.3 Study Goals and Objectives
The goal of this study is to document traditional and contemporary subsistence harvest and use in
the Project area in order to provide a basis for impact assessment, avoidance, minimization, and
development of PME measures and to provide the information that will serve as the basis for
compliance with FERC’s National Environmental Policy Act (NEPA) analysis for the Project
license.
Study Objectives include the utilization of subsistence data collected by ADFG to assess current
subsistence uses and document anticipated impacts (if any) resulting from the construction and
development of the Project. Key survey areas from a subsistence perspective will be:
1. Koliganek
2. New Stuyahok
3. Ekwok
4. Aleknagik
5.Levelock
6.Dillingham
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4.4.1.4 Relevant Resource Management Goals
The Fish and Game Act requires ADFG to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the
interest of the economy and general well-being of the state” (AS 16.05.020).
ADFG – Division of Subsistence Mission is “to scientifically gather, quantify, evaluate, and
report about customary and traditional uses of Alaska’s fish and wildlife resources”. One of the
core services of the division is to assist fisheries and wildlife managers in preparing management
plans to ensure information on customary and traditional uses and fish and wildlife harvests is
incorporated.
4.4.1.5 Existing Information and Need for Additional Information
Subsistence surveys were carried out in the vicinity of the Project in 2005. That data is now
fifteen years old and should be updated to more accurately reflect contemporary subsistence
harvest and use patterns. In particular, subsistence harvest surveys for the communities of
Koliganek, New Stuyahok, Ekwok, Levelock and Aleknagik would provide the necessary
information to determine potential effects of the proposed Project.
4.4.1.6 Project Nexus
Residents of Koliganek, New Stuyahok, Ekwok, Levelock and Aleknagik may use the Project
area for subsistence hunting, fishing and gathering. Project construction and operation could lead
to impacts on subsistence use of the Project area. The proposed study will assess the timing and
location of subsistence use and would be necessary to develop PME measures with regard to the
timing of activities, particularly during Project construction.
4.4.1.7 Methodology
Community subsistence surveys have been performed throughout the state of Alaska for many
years; they are both well-accepted and cost-effective means of understanding subsistence use of
fish and game resources.
ADFG Division of Subsistence will conduct this study using standard Division methodology
involving systematic household surveys conducted by community-based survey technicians in
cooperation with Division subsistence resource specialists.
The study design will be guided by the research principles outlined in the Alaska Federation of
Natives Guidelines for Research 10 and by the National Science Foundation, Office of Polar
Programs in its Principles for the Conduct of Research in the Arctic 11, as well as the Alaska
confidentiality statute (AS 16.05.815). These principles stress community approval of research
designs, informed consent, anonymity of study participants, community review of draft study
10 Alaska Federation of Natives. 2013. “Alaska Federation of Natives Guidelines for Research.” Alaska
Native Knowledge Network. Accessed June 6, 2020. http://www.ankn.uaf.edu/IKS/afnguide.html
11 National Science Foundation Interagency Social Science Task Force. 2018. “Principles for the Conduct
of Research in the Arctic.” Accessed June 6, 2020. https://www.nsf.gov/geo/opp/arctic/conduct.jsp
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findings, and the provision of study findings to each study community upon completion of the
research.
The primary method for collecting subsistence harvest and use information in this project will be
through a systematic household survey. Following receipt of comments at the scoping meeting
where the project is described to residents of the study communities, ADF&G will finalize the
survey instrument. The survey will be structured to collect demographic, resource harvest and
use, and other economic data that are comparable with information collected in other household
surveys in the study communities across Alaska and with data in the Community Subsistence
Information System (CSIS 12). During surveys, ADF&G researchers will ask respondents to
indicate the locations of their fishing, hunting, and gathering activities during the study year.
ADF&G uses a standard mapping method to conducting household surveys. Points are generally
used to mark harvest locations and polygons are used to indicate harvest effort areas, such as
areas searched while hunting caribou. Harvest locations and fishing, hunting, and gathering areas
are documented on iPads using the Collector application (ESRI, or Environmental Systems
Research Institute) customized for Division of Subsistence data collection needs.
Prior to beginning the household surveys, the ADF&G research team will hire and train local
research assistants (LRAs) in each study community to aid in the household survey
administration. Hiring an LRA is very important for the community. LRAs support community
involvement with the project and receive funds that provide local economic benefits.
After survey data have been analyzed by the Division of Subsistence Section lead researcher, a
public community review meeting in each study community will be held to present draft study
results at and create an opportunity for residents to provide feedback to be incorporated into the
final report. A final report will be published in ADF&G’s Subsistence Section Technical Paper
series, and copies of the technical paper and a summary document of the research findings will
be provided to the Cooperative, the study communities, local Tribes, and the Dillingham
ADF&G office.
The Cooperative intends to establish a data-sharing agreement with ADFG to permit data
transfer between ADFG and the Cooperative. ADFG Division of Subsistence maintains datasets
documenting subsistence use of species such as caribou from the MCH that are applicable to the
proposed subsistence study.
4.4.1.8 Proposed Deliverables and Schedule
The Cooperative will determine the study deliverables and schedule during consultation with
ADFG.
4.4.1.9 Level of Effort and Cost
The Cooperative will refine the level of effort and anticipated cost during consultation with
ADFG.
12 ADF&G CSIS: http://www.adfg.alaska.gov/sb/CSIS/.
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4.4.2 Section 106 Evaluation
Consistent with Section 106 consultation requirements, the goal of the study effort described in
this RSP is to determine if historic properties occur within the study area and assess the potential
effects of the Project on any such properties. A Finding of Effect and potential protection,
mitigation, and enhancement measures will be presented in the final license applications.
4.4.2.1 General Description of Proposed Study
The Project Area of Potential Effect (APE) will be defined in cooperation with all consulting
parties, including the Commission, the State Historic Preservation Office (SHPO), and Tribes
who have an interest in the project. Once a proposed APE is defined, the SHPO will concur in
writing prior to any field surveys or further analysis within the APE. The Commission will be
included on any correspondence with the SHPO regarding the APE. Final definition of the APE
will facilitate and focus subsequent cultural resource planning, literature review, and fieldwork.
Probability areas will be established prior to field survey, based on the locations of previously
recorded sites in the Tikchik Lake and Nuyakuk River area and other variables such as
topography, ethnographic and historical data, and biological information. GIS modeling and
reconnaissance level surveys will be used to define areas with a high probability to contain
cultural resources. Phase 1 identification level surveys including sub-surface testing and Phase II
evaluation efforts will be undertaken in areas considered to have higher probability for cultural
resources. Much of the Project is located on state lands and will require a State Cultural
Resources Investigation Permit.
We will develop a cultural resources sensitivity model for the Project. We will acquire digital
AHRS data from the Alaska Historic Resources Survey (AHRS) for known sites in the general
Project area for inclusion in our GIS system. Textual information from the AHRS will be used,
along with other sources, to build a context for the model. A literature review of ethnographic,
historical, and oral history data will identify cultural sites not yet listed in the AHRS. As
possible, information from these additional sources will be transformed into data files for
utilization in ArcGIS. GIS-compatible data files will be obtained from repositories such as the
Alaska State Geo-Spatial Data Clearinghouse. Additionally, available high resolution aerial
photographs of the Project area will be used to develop and potentially refine the predictive
model.
Using available data, we will define high and low cultural resource sensitivity areas within the
APE. These areas will be mapped using ArcGIS and will be defined and explained in an
accompanying text document. High sensitivity zones are considered to include:
•Areas with a slope equal to or less than 25%;
•Areas within 250 meters (m) of a historic trail;
•River valleys, lake, and river systems providing passes or portages across larger land
masses;
•Areas currently or historically within 250 m of fresh water, including elevated/fossil river
and lake terraces;
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•Lake and stream systems containing, or known to have contained, anadromous fish runs,
including a focus on barrier falls locations, and other freshwater lakes and streams;
•Caves and rock shelters;
•Ice patches or fossil ice patches; and
•Other areas identified through oral history research/sources.
Using the predictive model for guidance, we will develop a field methodology for:
•verification of known site locations in the APE, along with notation of any
discrepancies between the recorded and actual site coordinates;
•systematic on-the-ground survey of high sensitivity zones in the APE;
•a reconnaissance survey of a sample of low sensitivity zones in areas of direct,
indirect, and cumulative impact in the APE, with the location and acreage surveyed to
be determined in consultation with FERC and SHPO;
•documentation of newly discovered sites;
•recordation of site location characteristics as they may relate to the sensitivity model.
Draft and final reports will be prepared that meet contemporary professional standards and
follow the Alaska Office of History and Archaeology’s Standards and Guidelines for
investigating and reporting archaeological and historic properties in Alaska (Historic
Preservation Series Number II) and the Secretary of Interior’s Standards and Guidelines for
reports (FR Vol. 48, No. 190, pp. 44734-44737). The report will include formal
recommendations of National Register of Historic Places (National Register) eligibility for
FERC review, and subsequent review and concurrence by consulting parties. A Historic
Properties Management Plan (HPMP) will also be prepared for the Project.
The cultural resources study will also include an inventory and assessment of Traditional
Cultural Properties (TCPs). The requirement for identification of TCPs is included in 54 USC
302102-302108, Protection of Historic Properties (Federal Register, Volume 65, Number 239,
December 12, 2000). A TCP is eligible for inclusion in the National Register “because of its
association with cultural practices or beliefs of a living community” (Parker and King
1990). TCPs are historic properties and as such are subject to the same Section 106 process as
other archeological and historical sites. A TCP is a tangible property that meets one or more of
the four basic criteria set forth in the National Register regulations (54 USC 100101).
The APE for TCPs will be larger than the APE for archeological and historical sites and include
more of the general Project area. Its final boundaries will be determined in consultation with
tribal organizations and any other groups and individuals who may ascribe traditional cultural
significance to locations within the study area. Survey and inventory will be conducted on a
case-by-case basis whenever activities are identified that may affect TCPs.
4.4.2.2 Geographic Scope
Based on the current knowledge of the Project, the APE will, at a minimum, include the lands
enclosed by the proposed Project boundary, and lands or properties outside the Project boundary
where Project operation or other Project-related activities may cause changes in the character or
use of historic properties, if any historic properties exist. All areas that have a high probability of
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containing archeological resources that will be subject to ground-disturbing activities will be
surveyed. Consultation may also identify other areas that should be archaeologically surveyed.
4.4.2.3 Study Goals and Objectives
The goal of the study is to comply with Section 106 of the NHPA. Because it involves the
acquisition of a FERC license, the Project is a federal undertaking under Section 106 of the
NHPA. A cultural resource study report will be produced that presents information relative to the
scope and context of potential effects of the Project. This information will be used to analyze
Project impacts and propose protection, mitigation, and enhancement measures in the draft and
final license applications for the Project.
4.4.2.4 Relevant Resource Management Goals
For hydropower licensing actions, FERC typically complies with Section 106 by entering into a
Programmatic Agreement (PA) or Memorandum of Agreement (MOA) with the license
applicant, the Advisory Council on Historic Preservation, and the SHPO. This agreement is then
incorporated by reference into the Project license when it is issued. Because it is not always
possible for FERC to determine all of the effects of various activities that may occur over the
course of a license, the PA or MOA typically provides, and FERC typically requires as a license
condition, that the licensee develop and implement a HPMP that includes consideration and
appropriate management of effects on historic throughout the term of the license.
4.4.2.5 Existing Information and Need for Additional Information
The following information regarding Project area cultural resources comes from the AHRS and
the Nuyakuk PAD (NETC 2019). The Nuyakuk PAD also includes a discussion of the
prehistory and history of the Project region.
There are no reported AHRS sites within one mile of Nuyakuk Falls, although this is likely
because of a lack of previous survey. There are eight reported sites between the outlet of Tikchik
Lake and the Falls. These sites include a historic cabin, summer fish camps with semi-
subterranean houses, a reindeer camp, a portage around the rapids, and three sites for which there
is no information other than their location.
4.4.2.6 Project Nexus
The proposed Project could have several potential effects on historic properties within the APE.
The study plan described above is intended to provide sufficient information regarding the nature
of historic properties located in the APE so that potential effects can be adequately assessed.
Findings of Effect on historic properties in the APE will be included in the study report and
reviewed with consulting parties. Study information will aid in developing measures to be
proposed in the draft and final license applications to protect or minimize adverse effects on
historic properties.
4.4.2.7 Methodology
Cultural Resources Consultants, LLC (CRC), an Alaska-based cultural resources consulting firm,
will assist Nushagak Cooperative in complying with its obligations under the National Historic
Preservation Act (16 U.S.C. § 300101) as it applies to federally funded projects. Much of CRC’s
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work in researching and identifying cultural resources will follow the steps of the Section 106
process as outlined in 54 U.S.C.§ 36108. The Cooperative’s subconsultant will be primarily to
advise and assist Nushagak Cooperative, especially by providing adequate documentation to
support determinations, findings, and/or agreements under the Section 106 procedures. Such
documentation could include historic contexts, recommendations for findings of eligibility and
effect, draft agreement documents, data recovery or other mitigation (including monitoring)
plans, and a Historic Properties Management Plan (HPMP). The Cooperative’s subconsultant
will be responsible for:
•responding to project notifications,
•attending meetings,
•conducting literature reviews to identify known cultural resources within a project
study area,
•assisting in determining areas of potential effect,
•consulting with Tribal groups, local entities, and State and Federal agencies,
•conducting cultural resource field surveys,
•completing appropriate analyses, and
•preparing reports and other documents.
All services and products developed during the cultural resources study process will meet
industry standards, largely codified in the Secretary of the Interior’s Standards and Guidelines
for Archaeology and Historic Preservation, National Register Bulletins, the Office of History
and Archaeology Historic Preservation Series.
Methods for completing environmental documentation will include:
•a review of existing information;
•a field survey of the project area to identify and document potential historic properties
located within the defined study area or area of potential effects;
•draft, and final reports, including any determinations of eligibility and
recommendations on the project’s potential effects; and
•completion of a Historic Properties Management Plan.
The scope of any field activities will be determined after evaluating the project area’s potential
for known cultural resources and the proposed project description. The number of field
personnel and their technical expertise will be weighed against time and cost constraints to
provide the highest quality survey and subsequent analysis possible, while also maintaining the
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safety and health of personnel. The type of survey and testing used will be contingent on the
level of documentation needed to support the project moving forward.
Cultural resources surveys and reports will be accomplished or supervised by personnel who
meet the Secretary of the Interior’s Professional Qualification Standards (48 FR 4473 -
44739). The cultural resources subconsultant will comply with applicable laws and regulations
and will follow the Secretary of the Interior’s Standards and Guidelines for Archaeology and
Historic Preservation (48 FR 44716-18) and identification and testing procedures presented in
Guidelines for Evaluating and Registering Archaeological Properties (National Park Service
2000).
Identified archaeological and historic resources will be referenced to the project plans and in
GPS coordinates. Identified sites will be evaluated for historic significance and integrity using
established National Register eligibility criteria. The Cooperative’s subconsultant will obtain an
AHRS number from the Alaska Office of History and Archaeology (OHA) for any potentially
significant archaeological or historical property.
The Cooperative’s subconsultant will complete sufficient investigation and research on the
significance of such properties to support recommendations of National Register
eligibility. These recommendations will provide the basis for the agency’s determinations of
eligibility to be submitted to the State Historic Preservation Officer (SHPO) for
concurrence. Reports will meet contemporary professional standards and follow the OHA’s
Standards and Guidelines for investigating and reporting archaeological and historic properties
in Alaska (Historic Preservation Series Number 11) and the Secretary of Interior’s Standards
and Guidelines for Reports (FR Vol. 48, No. 190, pp. 44734-44737). A completed OHA Cultural
Resources Report Coversheet will be submitted with each report.
In the early phases of the Project, the Cooperative should receive delegation of consultation
authority from FERC. Consultation will then begin with interested parties, a cultural resources
working group will be created, and the APE will be defined. Consultations with Tribal
governments, Native organizations, the SHPO, and other interested parties will be initiated in the
early Spring of 2023 and will continue throughout the duration of the Project. Additional
interested consulting parties will be included as they are identified.
The proposed undertaking has the potential to affect historic properties near the powerhouse and
associated features. Additionally, construction of the intake, penstock, access road, airstrip, and
transmission line could also potentially disturb cultural sites that will be identified through
consultation, literature review, and field survey. Evaluations of National Register eligibility will
be required for any previously known and newly documented historical and archaeological sites.
The cultural resources expert will complete a draft report and draft HPMP after fieldwork is
completed. The report and HPMP will be disseminated to the Cooperative and consulting parties
for review. Following review, final drafts will be completed.
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4.4.2.8 Proposed Deliverables and Schedule
•Winter/Spring 2023:
Receive delegation of consultation authority from FERC
Consultation meetings as appropriate, including consultation on APE and
TCPs
Literature review
Determine permits needed
Letters to consulting parties
Establish cultural resources working group
Field survey planning.
Update study plan with any changes to Project design
Review background information and research
Establish survey strategy
Permitting, as required
•Summer/Fall 2023: conduct field studies and evaluation, as appropriate.
•Summer/Fall 2023: finish evaluations and begin draft report and DOEs
•December 2023: draft study report to consulting parties.
•Winter 2023/2024: consultation meetings to discuss Project, field findings, DOEs,
and address additional concerns.
•Spring 2024: prepare draft Historic Properties Management Plan for eligible
properties
•Summer 2024:
Finalize report based on field studies and consultation
Prepare Finding of Effect, as appropriate, for review, submittal and
concurrence to consulting parties.
Finalize Historic Properties Management Plan
4.4.2.9 Level of Effort and Cost
The study will be conducted over approximately two years’ time by a cultural resources expert.
The Cooperative estimates that the cost to conduct this study is approximately $175,000 -
$300,000.
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4.5 Recreation and Aesthetic Resources
4.5.1 Noise Study
FERC identified the need for a noise study after reviewing the PAD and identifying a gap
between information presented in the PAD and information needed to assess Project effects.
FERC provided the seven study request criteria to the Cooperative in a letter on January 23,
2020.
4.5.1.1 General Description of Proposed Study
The goal of this study is to characterize the existing ambient sound environment in the vicinity of
the proposed Project and estimate the potential impacts associated with construction and
operational activities.
4.5.1.2 Geographic Scope
The study will be conducted in the vicinity surrounding the Project facilities, including upriver to
Tikchik Lake, where Royal Coachmen lodge is located. Additional areas of study will include
the area of Wood-Tikchik State Park surrounding the proposed Project facilities, shown in Figure
4-25.
4.5.1.3 Study Goals and Objectives
The specific objectives of the study and subsequent report are to:
1.Define existing noise levels in identified sensitive wildlife habitat, recreation and cultural
areas within the Wood-Tikchik State Park including trails, the Royal Coachman Lodge,
fishing and hunting areas, and areas used for subsistence and other traditional cultural
practices.
2. Describe, through the use of sound models, the expected noise levels in the identified
sensitive areas during Project construction and operation.
3. Develop measures to avoid or lessen sound impacts during Project construction and
operation.
4.5.1.4 Relevant Resource Management Goals
Section 4(e) and 10(a) of the Federal Power Act require that the Commission give equal
consideration to all uses of the waterway on which a Project is located. When reviewing a
proposed action, the Commission must consider the environmental, recreational, fish and
wildlife, and other non-developmental values of the Project, as well as power generation and
other developmental values.
Project-generated noise during construction or operation, if not properly controlled, could have a
negative effect on wildlife and the public in the surrounding area; therefore, it is important to
understand the existing ambient noise levels in the Project vicinity and possible noise effects
from Project-related activities. Ensuring that potential measures associated with minimizing
noise impacts are analyzed is relevant to the Commission’s public interest determination.
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Figure 4-25. Proposed Noise Study Area.
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4.5.1.5 Existing Information and Need for Additional Information
During scoping, ADNR, Division of Parks and Outdoor Recreation and the owner of the Royal
Coachman Lodge (a fishing outfitter located about 3 miles upstream of the Project site) raised
concerns about Project-generated noise during construction and operation disrupting wildlife and
visitor uses within Wood-Tikchik State Park and at the lodge. No information is included in the
PAD regarding ambient noise levels from which to gauge potential adverse effects of Project-
generated noise on existing uses.
4.5.1.6 Project Nexus
Construction is planned to take place over a 2-year period and would include the use of noise-
generating equipment to carry out activities such as drilling, boring, blasting, and compaction. In
addition, the Cooperative proposes to construct an airstrip that would fly in equipment, materials,
and personnel during construction and continue to be used for Project maintenance. Each of
these sources of noise has the potential to disrupt wildlife and their uses of adjoining habitats or
degrade visitor recreation and cultural experiences and practices. An understanding of ambient
noise levels and projected noise generation is needed to assess how Project-generated noise may
affect these uses and to identify potential mitigation measures.
4.5.1.7 Methodology
A systematic sound study should be conducted to characterize the existing ambient sound
environment in the vicinity of the proposed Project and estimate the potential noise effects from
construction, operation, and maintenance of the proposed. The study should include the
following steps:
1.Review the most current Project description, operating and construction equipment
rosters, construction schedules, and construction methods to identify the types of
excavation or blasting expected to occur and where Project noise is likely to be heard by
the public;
2.Identify the type and expected frequency of maintenance activities that would generate
noise in the Project vicinity (e.g., helicopter or airplane use);
3. Identify sensitive noise receptor areas (i.e., wildlife habitat, recreation and cultural areas)
where sound data needs to be collected. Note: these noise receptor areas will be
established in collaboration with the aforementioned resource agencies and Tribal entities
in advance of study implementation. This collaboration will occur in the early spring of
2023, at the latest.
4. Collect ambient sound level measurements at the identified noise receptor sites and
document observations of perceived and identifiable sources of sound contributing to
ambient sound levels at these sites;
5.Use an acoustic model to predict sound levels during Project construction, operation, and
maintenance at the noise receptor sites, estimated in A-weighted decibels (dBA), and
indicate the duration of these sound levels;
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6. Superimpose predicted sound level isopleths or “sound contours” on aerial photographs
or maps of the Project area and include specific sound level predictions at the selected
measurement locations; and
7.Develop measures to avoid or lessen Project-generated sound effects.
The study should be developed in consultation with the ADNR, Division of Parks and Outdoor
Recreation; ADFG; local outfitters; and Native Alaskan tribes that use the Project area for
subsistence or other traditional cultural practices.
These methods are consistent with sound analyses used by applicants and licensees and relied
upon by Commission staff in other hydroelectric licensing proceedings.
4.5.1.8 Proposed Deliverables and Schedule
The study will be conducted between spring and fall 2023. The results of the study will be
synthesized in the Project’s ISR and USR filings. The findings will be presented to stakeholder at
the ISR and USR meetings.
4.5.1.9 Level of Effort and Cost
The Cooperative intends to retain a recreation and aesthetics expert once the Study Plan has been
finalized. The anticipated cost for the noise study is estimated to be about $45,000.
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4.5.2 Recreation Inventory by Season
4.5.2.1 General Description of Proposed Study
Section 4.8 of the PAD described recreational use in the Project vicinity, which includes skiing,
off-road vehicle use, boating, sightseeing, hiking, hunting, and fishing, among other uses. It is
expected that the volume of recreational use in the area immediately surrounding the river
infrastructure is low, due to the remote location of the proposed Project. The proposed Project is
located within Wood-Tikchik State Park. The Cooperative proposes to inventory recreational use
of the Project vicinity by season, so that any potential Project impacts (both positive and
negative) can be identified, and any necessary mitigation measures can be developed.
4.5.2.2 Geographic Scope
The recreation inventory will focus on use in the area immediately around the river infrastructure
(intake, tunnel, powerhouse, etc.). It is anticipated that recreational use within this area generally
consists of boating, fishing, hunting and potential use of the portage trail around Nuyakuk Falls,
flight/sightseeing, and hiking.
The geographic scope of the recreation study area will span from ½ mile upstream of the
proposed Project intake to 1 mile downstream of the proposed Project tailrace. Recreational use
survey areas will include Dillingham and each of the outlying villages on the proposed Project
transmission corridor (Figure 4-26).
4.5.2.3 Study Goals and Objectives
The goal of the study is to inventory and quantify the type and volume of recreational use by
season in the vicinity surrounding the proposed Project facilities on the Nuyakuk River.
4.5.2.4 Relevant Resource Management Goals
The proposed Project is located within Wood-Tikchik State Park, managed by ADNR. The
purpose of Wood-Tikchik State Park is described in the legislation establishing the park (AS
41.21.160):
“The primary purposes of creating the Wood-Tikchik State Park are to protect the area’s fish and
wildlife breeding and support systems and to preserve the continued use of the area for
subsistence and recreational activities. The state park is also created to protect the area’s
recreational and scenic resources.”
Therefore, understanding any potential Project impacts (positive or negative) to recreation within
Wood-Tikchik State Park near proposed Project infrastructure is essential for ensuring that
ADNR is able to manage and protect resources within the Park.
4.5.2.5 Existing Information and Need for Additional Information
The PAD summarized existing recreational use in Wood-Tikchik State Park, but the specific
activities and volume of recreational use in the immediate Project vicinity that may be impacted
either positively or negatively by Project development is unknown. FERC will need site-specific
recreational use information for the Environmental Assessment (EA) of the proposed Project.
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Figure 4-26. Recreation Study Area
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4.5.2.6 Project Nexus
Construction and operation of the proposed Project may impact recreational use of the area
surrounding the Project facilities. Site-specific recreational use information may be used to
develop mitigation measures for Project construction and operation, if necessary.
4.5.2.7 Methodology
The Cooperative will collaboratively conduct a comprehensive recreational survey to be
employed in Dillingham and the same 4 villages outlined in the subsistence survey in Section
4.4.1 (Koliganek, New Stuyahok, Ekwok and Aleknagik). Beginning in 2022, the Cooperative
will develop an online portal by which seasonal (4 times per year), recreational surveys will be
submitted. This portal will both allow for any individual with internet access to fill-out the
survey and allow for the Cooperative to effectively organize and convey all data collected. The
portal will be developed and advertised in advance of the first set of surveys, to be conducted in
July 2023 (see Section 4.5.2.8). Contacts on the existing Project licensing contact list will be
invited to submit survey responses via the online portal. The Cooperative will also invite
participants to submit survey responses via social media outlets and the Project licensing
website. Surveys will begin in the Spring of 2023 and continue through the winter of 2023/2024.
It is understood that supplemental methods to the online portal will be necessary to reach a
robust enough data set to make conclusive determinations related to potential recreational
impacts associated with Project development. As such, a series of supplemental survey
distribution methods will be utilized to access as many interested individuals in these
communities as possible. Supplemental distribution methods will include:
•Seasonal village site visits by the Cooperative to conduct surveys
•Mailing of surveys to public individuals with instructions on mailing back to the
Cooperative
•Phone calls by the Cooperative to conduct surveys
•Distribution of a survey package at local meeting places with instructions on mailing
back to the Cooperative
The aforementioned seasonal site visits will be used to advertise the availability of the surveys,
solicit input and receive individual and village specific requests for the appropriate way to
distribute surveys to them (mail, phone calls, etc.) The Cooperative representatives have solid
contacts in all of the proposed survey villages and will work directly with these individuals to
select the appropriate locations for the site vists.
While it is anticipated that comments received on the PSP will include requested
additions/modifications to the proposed survey, survey focus will be placed on the following:
•Name
•Location
•Number of people in household participating various recreational activities in the
household
•Perceived primary benefits to the Nuyakuk Falls
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o Recreationally
o Aesthetically
o Other?
•Primary recreational activities conducted (each season) near proposed Project
infrastructure on the Nuyakuk River:
o Hunting
Species
Number of days
o Fishing
Species
Number of days
o Trapping
Species
Length of time the trap line in place (if applicable)
o Gathering
What?
Number of times
o Flight Seeing
Departure location
Any landing spots other than departure location
Primary areas of visual focus
o Boating
Float trips
Motorized boat trips
o Hiking
o Other?
•Number of times household has utilized the “Portage Trail” during the season the survey
pertains to
o Used for hiking?
o Portage a boat?
o Other?
•Overall number of recreational trips in the Project area per year, length of the average trip
and primary recreational activities during each trip
It is notable that the surveys conducted by the Cooperative will be supplemented by on-site
opportunistic recreation observations by natural resource study personnel, regardless of
discipline. All individuals conducting studies near the proposed Project location at Nuyakuk
Falls will be briefed prior to departing on recreational data to collect and will record any
recreational activities they observe while on-site.
The Cooperative is currently in the process of retaining a technically-specific recreation
subconsultant to conduct the survey work. While the logistical specifics of the surveys will be
finalized with the consultant’s input, the Cooperative is committed to conducting as
comprehensive of a survey process as possible. Appropriate days/times will be selected to get as
much participation as possible
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Once all comments on the PSP are reviewed and incorporated (where appropriate), the
Cooperative will develop a recreational survey data sheet template to be provided with the RSP.
This data sheet (once finalized) would be used for both the online portal and any supplemental
survey sheets utilized for in-person or versions distributed via mail to ensure synonymous data
collection regardless of the response option used.
4.5.2.8 Proposed Deliverables and Schedule
The study will be conducted seasonally throughout 2023. Results from the seasonal surveys will
be provided in the Project’s ISR and supplemented in the USR with additional detail along with a
comprehensive impact assessment related to all four study periods. The findings will be
presented to stakeholder at the ISR and USR meetings. The surveys will be conducted as
follows:
•Survey Schedule:
o July 2023
o October 2023
o January 2024
o April 2024
4.5.2.9 Level of Effort and Cost
The Cooperative intends to retain a recreation expert once the Study Plan has been finalized.
The estimated cost to complete this study is approximately $100,000 - $200,000.
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4.6
4.6.1
Environmental Justice Study
General Description of Proposed Study
In accordance with the issuance of FERC’s Equity Action Plan (FERC, 2022), the Cooperative
proposes to conduct an Environmental Justice (EJ) Study to determine if development of the
proposed Project would affect communities that identify as environmental justice communities.
The Cooperative plans to utilize standard methodology provided by FERC to conduct the study.
4.6.2 Geographic Scope
The Cooperative proposes to study potential Project impacts on environmental justice
communities within 5 miles of the proposed Project, including any potential impacts associated
with transmission upgrades (Figure 4-27).
4.6.3 Study Goals and Objectives
The proposed EJ Study has five objectives:
1) to identify presence of environmental justice communities that may be affected by
the licensing of the Project, including the construction of the Project, and identify
outreach strategies to engage the identified environmental justice communities in
the licensing process, if present;
2) to identify the presence of non-English speaking populations that may be affected
by the Project and identify outreach strategies to engage non-English speaking
populations in the licensing process, if present;
3) to discuss effects of licensing the Project on any identified environmental justice
communities and identify any effects that are disproportionately high and adverse;
4)to identify mitigation measures to avoid or minimize project effects on
environmental-justice communities; and
5) to identify sensitive receptor locations within the project area and identify
potential effects and measures taken to avoid or minimize the effects to such
locations if they are present.
4.6.4 Relevant Resource Management Goals
Executive Order 14008, Tackling the Climate Crisis at Home and Abroad, and Executive Order
12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-
Income Populations, as amended, require federal agencies to consider if impacts on human
health or the environment would be disproportionately high and adverse for environmental
justice communities in the surrounding community resulting from the programs, policies, or
activities of federal agencies.
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Figure 4-27. Geographic scope of Environmental Justice study.
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Further, Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal
consideration to all uses of the waterway on which a project is located, and what conditions
should be placed on any license that may be issued. In making its license decision, the
Commission must equally consider the environmental, recreational, fish and wildlife, and other
non-developmental values of the project, as well as power and developmental values.
4.6.5 Existing Information and Need for Additional Information
The information necessary to conduct an identification of environmental justice communities
near the Project is available through the U.S. Census Bureau’s American Community Survey;
however, such information must be aggregated and compared in order to make determinations
about the presence of environmental justice communities within the Project area. The nature of
effects of the Project on any communities present would need to be determined through
consultation with the communities.
4.6.6 Project Nexus
Project construction, operation, and maintenance has the potential to affect human health or the
environment in environmental justice communities. Examples of resource impacts may include,
but are not necessarily limited to, project-related effects on: erosion or sedimentation of private
properties; groundwater or other drinking water sources; subsistence fishing, hunting, or plant
gathering; access for recreation; housing or industries of importance to environmental justice
communities; and construction-or operation-related air quality, noise, and traffic.
4.6.7 Methodology
The Cooperative will use the methodology that FERC recommends for collecting environmental
justice data for hydroelectric projects. This methodology has been successfully employed on a
number of projects in the licensing process and is consistent with guidance from the
Environmental Protection Agency’s Promising Practices for EJ Methodologies in NEPA
Reviews (EPA 2016). The Cooperative will prepare an Environmental Justice Study Report that
provides the following:
a)A table of racial, ethnic, and poverty statistics for each state, borough, native regional
corporation, and census block group (may only exist for census tract) within the geographic
scope of analysis. For the Project, the geographic scope of analysis is all areas within 5
miles of the proposed Project boundary. The table will include the following information
from the U.S. Census Bureau’s most recently available American Community Survey 5-
Year Estimates for each state, native regional corporation, borough, and block group
(wholly or partially) within the geographic scope of analysis:
a. Total population;
b.Total population of each racial and ethnic group (i.e., White Alone Not Hispanic,
Black or African American, American Indian and Alaska Native, Asian, Native
Hawaiian and Other Pacific Islander, some other race, two or more races, Hispanic
or Latino origin [of any race]) (count for each group);
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c.Minority population including individuals of Hispanic or Latino origin as a
percentage of total population;13 and
d.Total population below poverty level as a percentage.14
The data will be collected from the most recent American Community Survey files available, using
table #B03002 for race and ethnicity data and table #B17017 for low- income households. An
example table is provided below (Table 4-9).
Table 4-9. Environmental Justice Data Table Example.
RACE AND ETHNICITY DATA
LOW-
INCOME
DATA
Geography Total
Population
(count)
White
Alone
Not
Hispanic
(count)
African
American
(count)
Native
American/
Alaska
Native
(count)
Asian
(count)
Native
Hawaiian
& Other
Pacific
Islander
(count)
Some
Other
Race
(count)
Two or
More
Races
(count)
Hispanic
or
Latino
(count)
Total
Minority
(%)
Below
Poverty
Level (%)
State
Native
Regional
Corporation
County or
Borough
Census
Tract X,
Block Group
X
b)Identification of environmental justice populations by block group, using the data obtained
in response to part a above, by applying the following methods included in EPA’s
Promising Practices for EJ Methodologies in NEPA Reviews (2016).
i.To identify environmental justice communities based on the presence of
minority populations, the Cooperative will use the “50-percent” and the
“meaningfully greater” analysis methods. To use the “50-percent” analysis
method, the Cooperative will determine whether the total percent minority
population of any block group in the affected area exceeds 50-percent. To use
the “meaningfully greater” analysis, the Cooperative will determine whether
any affected block group affected is 10-percent greater than the minority
13 To calculate the percent total minority population, subtract the percentage of “White Alone Not
Hispanic” from 100 percent for any given area.
14 To calculate percentage of total population below poverty level, divide the total households below the
poverty level by the total number of households and multiply by 100.
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population percent in the native regional corporation using the following
process:
1.Calculate the percent minority in the reference population (native
regional corporation);
2.To the reference population’s percent minority, add 10-percent (i.e.,
multiply the percent minority in the reference population by 1.1); and
3.This new percentage is the threshold that a block group’s percent
minority would need to exceed to qualify as an environmental justice
community under the meaningfully greater analysis method.
ii.To identify environmental justice communities based on the presence of low-
income populations, use the “low-income threshold criteria” method. To use
the “low-income threshold criteria,” the percent of the population below the
poverty level in the identified block group must be equal to or greater than
that of the reference population (native regional corporation).
c)A map showing the Project boundary and location(s) of any proposed Project- related
construction in relation to any identified environmental justice communities within the
geographic scope. Denote on the map if the block group is identified as an environmental
justice community based on the presence of minority population, low-income population,
or both.
d) A discussion of anticipated Project-related effects on any environmental justice
communities for all resources where there is a potential nexus between the effect and the
environmental justice community. For any identified effects, the Cooperative also
describe whether or not any of the effects would be disproportionately high and adverse.
e)If environmental justice communities are present, the Cooperative will provide a
description of public outreach efforts regarding the Project, including:
i.a summary of any outreach to environmental justice communities conducted
prior to filing the application (include the date, time, and location of any
public meetings beyond those required by the regulations);
ii. a summary of comments received from members of environmental justice
communities or organizations representing the communities;
iii.a description of information provided to environmental justice communities;
and
iv. planned future outreach activities and methods specific to working with the
identified communities.
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f)A description of any mitigation measures proposed to avoid and/or minimize Project
effects on environmental justice communities.
g) Identification of any non-English speaking groups, within the geographic scope of
analysis, that would be affected by the Project (regardless of whether the group is part of
an identified environmental justice community). The Cooperative will describe previous
and planned efforts to identify and communicate with these non-English speaking groups
and identify and describe any measures that proposed to avoid and minimize any Project-
related effects non-English speaking groups.
h) Because new construction is proposed, identification of sensitive receptor locations (e.g.,
schools, day care centers, hospitals, etc.) within the geographic scope of analysis. The
Cooperative will show these locations on the map generated in step c. In the study report,
the Cooperative will provide a table that includes their distances from Project facilities
and any Project-related effects on these locations, including measures taken to avoid or
minimize Project-related effects.
This study will be conducted in consultation with Project licensing stakeholders, including Tribal
organizations and the Cultural Resource study team.
4.6.8 Proposed Deliverables and Schedule
The EJ study, if included in FERC’s Study Plan Determination, will be conducted in 2023. The
results of the EJ study, including maps, tables, and analyses described in Section 4.6.7 will be
documented in the Initial Study Report. The results of the study will be presented to stakeholders
at the Initial Study Report Meeting which is anticipated to occur in Spring 2024.
4.6.9 Level of Effort and Cost
The EJ study is primarily a desktop analysis and is anticipated to cost between $50,000 – 75,000.
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4.7 Supplemental Study – Economic Decision Support Tool
Given the Cooperative’s desire to evaluate the feasibility of this Project from all perspectives, we
have elected to develop an economic analysis tool that will assist in informing the potential
economic impact of the project (positive and negative) over the duration of its operations. To
date, an abundance of collaboration with the ARWG and its associated work on the Life Cycle
Model will allow for the two to inform each other and create a comprehensive tool through
which, a variety of operational and natural resource scenarios can be run.
4.7.1 General Description of Proposed Study
The economic analysis tool, hereafter referred to as the economic Decision Support Tool or
eDST, considers both: 1) economic impact of developing the run-of-river hydropower project
and the impact on the Sockeye and Chinook fisheries, and 2) an electricity base rate model that
would enable the Cooperative to explore different cost differentials between current diesel
generation and with the run-of-river with diesel backup approach. The eDST will accept
information from the river flow/climate model in terms of the impact over the 50-year life of the
run-of-river hydro generation system and the aquatic fisheries lifecycle model to capture the
economic impact from changes in sport fishing, commercial fishing, subsistence fishing and
escapement.
4.7.2 Geographic Scope
The Project will be on the Nuyakuk branch of the Nushagak River. From the Project site, the
Nuyakuk River runs approximately 40 miles before converging with the Nushagak River, which
continues to Bristol Bay. Therefore, the economic analysis focuses on economic values specific
to the Nuyakuk. Specifically, the eDST focuses on the Chinook and Sockeye species to be
consistent with the life cycle model analyses for this area.
4.7.3 Existing Information and Need for Additional Information
There are various inputs into the eDST, including diesel and hydropower costs, retail electricity
consumption, river flow, and fish numbers.
Economic Costs:
Diesel generation costs were provided by the Cooperative. Related breakdowns for labor,
maintenance, and administrative are captured in the calculations. Inputs related to powerhouse
consumption, line losses, etc. that contribute to total required generation calculations are also
captured.
Project costs include construction spend plan (e.g., equipment, labor, and permitting) and
operational period estimates (e.g., insurance rates, taxes, and repairs). Other inputs within the
eDST capture estimated grant numbers and general overhead.
Electricity Demand:
Community electricity consumption values (in kWh) are included in the eDST. Values for
Dillingham and Aleknagik provided by the Cooperative are incorporated into the eDST, and
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placeholders for other community consumption data (e.g., Koliganek, Ekwok/New Stuyahok,
and Levelock) can be used/updated as needed.
River Flow Values:
Monthly river flow values for the Nuyakuk River above the Project are available from 1953 to
present. Summary values based on this historical record are used as inputs in the eDST. Annual
changes to river flow currently use climate change projections from Wobus et al. (2015) to
reflect future changes expected in the area. These values can be changed based on insights from
the hydro/climate model.
Fish Values:
Escapement values for the Nuyakuk were recorded using tower data from 2003 through 2006.
More recent values will be estimated by back-calculating proportions based on Nushagak
escapement values.
Other key input in the eDST are the relative proportion of Sockeye and Chinook from the
Nuyakak that contribute to commercial, sport, subsistence, and escapement activities. Currently,
placeholder values are used in the eDST, but require review and update.
4.7.4 Methodology
eDST Engine/Spreadsheet Tool:
The eDST spreadsheet tool (i.e., engine) contains a number of spreadsheets. The most important
sheets are the Read Me, Assumptions, Annual Diesel and Hydro Costs, Diesel and Hydro
Monthly, Fisheries – Annual, and River flow Worksheets. There are also several background
sheets with information that drive the data within the model, and include data provided by the
Cooperative such as Diesel Generator Costs, Diesel Other Production Costs, Diesel Loan
Amortization, Diesel Depreciation, Overhaul Cost Comparisons, Demand Assumptions, Hydro
Assumptions, River flow, and Administration. Most of the vital information has been moved to
the Assumptions worksheet.
The Assumption worksheet drives the economic impact and the electricity rate making analyses.
The worksheet contains input cells (in yellow) that drive consumption by community and the
start date for each community. There is a section for assumptions about diesel generation costs
along with various options and opportunities to adjust assumptions especially fuel cost values
used in the analyses. This section also has assumptions to drive the river flow calculations, such
as the diversion limits per month, the baseline river flow values by month in cubic feet per
second, and the flow rate of change associated with climate change. There is a section with
assumptions for the powerhouse construction costs along with the additional transmission costs
associated with the Project and the Project spend plan. Another section provides assumptions for
Proejct operations including operations interest rates, internal powerhouse consumption, and
repairs. A section on other costs includes Operating Margin and G&A as well as the BCA period
and Economic Impact Multipliers. There is a section for the assumption about baseline fisheries
for Sockeye and Chinook.
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The Diesel and Hydro monthly worksheet contains the baseline diesel model and the run-of-river
Project model. The diesel baseline is driven primarily by the consumption of Dillingham and the
five villages. Generation is calculated by adding back distribution losses and diesel powerhouse
consumption costs. Costs are driven by diesel fuel, labor, and repairs. Costs that are not driven
by monthly operations are only included in Annual Diesel and Hydro Costs worksheet.
The Project calculates electricity production based on the river flow assumed by month and
allowed diversion. If hydro generation doesn’t meet consumption needs, the diesel generators
feed the rest of consumption. Run-of-river electricity generation removes the consumption of the
powerhouse before determining if the diesel generators need to be turned on. Diesel generation,
if needed, requires remaining consumption be met and adds on distribution losses and diesel
powerhouse consumption to determine total generation. Costs for diesel generation are based on
fuel costs, repairs, amortization of new diesel generator loans, and other production costs which
are primarily based labor. The hydro model is primarily based on amortization of the loans on
the powerhouse and transmission lines along with fixed and variable operation and maintenance
and other production costs.
The Annual Diesel and Hydro Costs worksheet summarizes the annual costs in the monthly
worksheet and adds costs like G&A and Operating Margin. The Annual Diesel and Hydro Costs
are summarized into two different types: Cash and Net Operating Costs. The cash outlays
indicate the costs the Cooperative are incurring during a year while the Net Operating Costs
smooths out the Cash Costs with depreciation of the powerhouse and amortization of major
overhauls for both the Diesel and Hydro. Major hydro repairs are amortized over 13 years, Major
Diesel Overhauls occurs over three years and minor diesel overhauls occur over 18 months. The
Net Operating Margin would be basis for rate making for the Cooperative.
The River Flow worksheet provides a space for inputs from the river flow working group.
Currently, it is based on the average river flow in each month and the change in river flow by
month based a climate change model. The idea is the output of the future river flow model can be
put into this sheet and the output of the sheet can be put into the monthly hydro and diesel
worksheet.
The Fisheries worksheet provides an annual breakdown for both Sockeye and Chinook based on
assumptions about the initial fish entering the Nuyakuk. For each species, the worksheet
indicates how much of the annual fishery is taken by commercial, sport, and subsistence fishing.
There is a separate section for the baseline and one for the impact of implementing the Project.
The eDST assumes that subsistence farming will not be impacted because the escapement from
the Project will be designed to ensure minimal flow that protect these needs.
eDST Graphical User Interface:
To facilitate exploration of these scenarios, a front-end graphical user interface (GUI) will be
developed. Specifically, the GUI will enable the users to select between different climate
conditions, economic costs, and diversion limits. These inputs would then be read into the eDST
engine and the associated outputs from the latter would then be visualized within the GUI (see
mock-up image below; Figure 4-27). We anticipate building the GUI using the RShiny applet
capabilities within R, an open-source software.
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Figure 4-27. Example GUI output.
During the construction of the eDST, sensitivity analyses can also be run through the eDST to
ensure that the economic outputs function across expected ranges (of fish, river flows, etc.).
More importantly, the GUI would allow stakeholders to evaluate the impact of different
assumptions that will change outputs. Final selection of relevant outputs to visualize will be done
in collaboration with the stakeholders. The RShiny code can be easily updated to reflect
stakeholder priorities.
5.0 STUDY SCHEDULE AND PROCESS
As required by 18 CFR §5.15, the Cooperative will prepare and file with FERC annual progress
reports, file an ISR, and hold an ISR Meeting with stakeholders and FERC staff to discuss the
initial study results. Upon completion of the study program, the Cooperative will prepare and file
a USR and convene an associated USR Meeting to discuss the final study results.
Each proposed study schedule has been detailed in its respective subsection of Section 4.0. All
study reports will be filed with FERC in electronic format. Annual progress reports, the ISR, and
USR will be filed with FERC in electronic format. Licensing Participants will be notified via
email of the availability of reports and any associated information, along with information about
accessing and downloading the information.
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Standards. Amended as of April 6, 2018. Register 226, July 2018. Available at:
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ADFG (Alaska Department of Fish and Game (ADFG). 2006. Freshwater Fish Inventory Project FSN06:
2006 Nushagak-Mulchatna Drainage Inventory of Fish Community Distribution. Survey Dates
August 2-August 22, 2006. Obtained Online at:
http://www.adfg.alaska.gov/sf/reports/FishSurveys/rptProjectDetails.cfm?projectID=108.
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ADFG (Alaska Department of Fish and Game (ADFG). 2018. Using a Drone to ‘Recover’ Tagged Coho
Salmon. Alaska Fish and Wildlife News. Obtained Online at:
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Accessed April 9, 2020.
ADFG (Alaska Department of Fish and Game). 2020. Fish Count Data Search for the Nuyakuk River,
2003-2006. Online at: https://adfg.alaska.gov/sf/FishCounts/index.cfm?ADFG=main.home
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ADFG 2019. Caribou Species Profile, Alaska Department of Fish and Game, Juneau, AK. Online at:
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T. 2009. Assessing reservoir operations risk under climate change. Water Resources Research,
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FERC No. 14873 Revised Study Plan
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APPENDIX A:
PAD Comment Responses
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-1 March 2020
Table 1. Comments received on the Pre-Application Document (PAD) for the Nuyakuk River Hydroelectric Project (P-14873) and Nushagak
Cooperative's responses.
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
1 ADFG
3.3.2: Nuyakuk
Falls Diversion
& Intake
The concrete gravity diversion structure above the falls requires
careful study. Its effects on both upstream and downstream
movement of fish will have to be evaluated. The diversion
structure may also create some new slow-water habitat.
The PAD states that the diversion and intake geometry will
depend upon further studies. The design of the intake and
associated structures should minimize the likelihood of fish
entrainment, particularly of out-migrating salmon smolt.
The Cooperative agrees with ADFG’s statement
that the proposed intake will require careful
study. To accomplish this, the Cooperative has
proposed a study titled “Fish Entrainment and
Impingement Study” (PSP Section 4.1.3) to
assess the potential for fish entrainment and
impingement at the proposed Project intake. One
of the primary goals of the proposed study is to
inform the intake design to minimize
entrainment of juvenile salmonids in the
proposed Project intake and maximize survival
within the Project area.
2 ADFG 3.3.6: Tailrace
False attraction of fish to the tailrace is always a concern,
particularly for waterbodies with migrating salmon. ADF&G is
supportive of a design that reduces tailrace velocities and
considers fish exclusion barriers at the tailrace.
The Cooperative agrees that false attraction of
fish to the proposed Project tailrace is a concern.
The Cooperative has proposed a study titled
“Assessment of False Attraction at the Tailrace
Fish Barrier” (PSP Section 4.1.4). The primary
goal of the study is to evaluate performance of
the proposed tailrace location and design to
demonstrate which operational alternatives
minimize/eliminate attraction for returning
adults.
3 ADFG
4.4.6: Potential
Adverse Effects
to Aquatic
Resources
This section and Table 4-9 correctly identify some of the
potential adverse effects, such as delayed or prohibited upstream
migration of fish and mortality to upstream migrating fish.
However, potential adverse effects to downstream migrating
fish are not mentioned. Mortality of downstream migrating fish
may increase, due either to intake impingement, penstock
entrainment or to delays or blockage caused by the concrete
diversion structure. Downstream fish migration pathways may
be altered due to the decrease in flow; this could potentially
concentrate fish and lead to blockage and delays resulting in
increased predation and mortality.
The Cooperative agrees that entrainment and
impingement of fish is of concern. The
Cooperative has proposed a study titled “Fish
Entrainment and Impingement Study” (PSP
Section 4.1.3) to investigate the potential
impacts to downstream migrating fish and
inform proposed Project design. See also the
Cooperative’s response to Comment No. 1.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-2 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
4 ADFG
4.8.3.1:
Subsistence
Uses
Data collected by ADF&G shows that the proposed project area
was heavily used for subsistence hunting and fishing activities
by residents of Koliganek and New Stuyahok, at least for the
year the study was conducted, 2005. To understand possible
project effects, this data should be updated; we elaborate on the
collection of data on subsistence use in the Study Requests
section of this document.
The Cooperative agrees with ADFG’s
perspective that subsistence data for the area
surrounding the proposed Project should be
collected as part of the Project licensing study
program. The Cooperative has proposed to
collaborate with ADFG on a “Subsistence
Study” (PSP Section 4.4.1) in order to collect
updated subsistence use data for the study area.
5 ADFG
5.2.2: Water
Resources
(Potential
Studies)
Three potential studies are listed in this section: 1) water quality
and water temperature assessment, 2) hydrologic data
collection, and 3) sediment transport assessment and modeling.
Because the topics of these studies have a direct impact on fish
resources, ADF&G is supportive of all three of these studies and
will work with the applicant to ensure that they are carried out
in a way that ensure the quality and relevance of the data
collected to inform the decision-making process.
The Cooperative appreciates ADFG’s comment
and looks forward to collaborating with ADFG
throughout the study program.
6 ADFG
5.2.3: Fish and
Aquatic
Resources
(Potential
Studies)
Three potential studies are listed in this section: 1) fish species
seasonal distribution and abundance, 2) bathymetric modeling
(i.e. two-dimensional modeling) of Nuyakuk Falls, and 3)
Nuyakuk Falls fish passage evaluation and modeling. Each of
these studies is essential to understanding how salmon and other
fish pass through the Falls and possible project effects. We will
elaborate on each of these in the Study Requests section of this
document. Additionally, a study of entrainment mortality,
particularly for juvenile salmonids, is necessary to quantify
potential project impacts.
The Cooperative appreciates ADFG’s comment
and has proposed studies to address all of the
potential resource impacts ADFG lists here.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-3 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
7 ADFG
5.2.4: Wildlife
and Botanical
Resources
(Potential
Studies)
Four potential studies are listed in this section: 1) wildlife
presence, distribution and migratory assessments, 2) botanical
presence and distribution evaluation, 3) invasive weed
assessment, and 4) rare, threatened and endangered species
assessment. The first proposal is essential to provide site-
specific information for the evaluation of wildlife issues related
to the project. In particular, the project area is a calving area for
the Mulchatna Caribou Herd. The construction of power lines
through the area would create linear disturbances and activity
that may affect caribou movement patterns, survival of caribou
neonates, and caribou predation.
For studies numbers 2) and 3) we will defer to other resource
agencies with more pertinent expertise. We will work closely
with the applicant to ensure that the studies provide the
information needed for our decision-making purposes.
The Cooperative appreciates this comment and
agrees that conducting a caribou study is
necessary. The Cooperative has proposed to
conduct a study titled “Caribou Migration
Evaluation” (PSP Section 4.3.2) to investigate the
use of the proposed Project area by caribou
throughout their migratory period(s).
8 AK
SHPO
4.10: Cultural
and Tribal
Resources
Our office recommends revisiting the analysis needs under the
National Environmental Policy Act (NEPA) as the term
‘cultural resources’ is not synonymous with ‘historic
properties’. NEPA cultural resources impact analysis needs to
account for impacts to all cultural resources, whereas review
under Section 106 of the National Historic Preservation Act
only requires assessing effects to historic properties, as defined
in 36 CFR 800.16(1)(1), which are those properties that are
eligible for listing in the National Register of Historic Places.
The Cooperative appreciates the comment and
will ensure that correct terminology pertaining
to cultural resources and historic properties are
used in Project licensing documents going
forward. The Cooperative intends to retain a
cultural resources expert to conduct the cultural
resources impact analysis under NEPA. The
expert will also conduct the Section 106
Evaluation of the Area of Potential Effects
(APE).
9 AK
SHPO
4.10: Cultural
and Tribal
Resources
Our office looks forward to the initiation of Section 106 and
future consultation regarding the area of potential effects and
the proposed level of effort regarding the identification of
historic properties for the undertaking.
The Cooperative appreciates the comment and
looks forward to consulting with AK SHPO
regarding these important resources.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-4 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
10 AK
SHPO
4.10: Cultural
and Tribal
Resources
The PAD appropriately discusses the importance of consultation
to the Section 106 process and the document lists federal and
state agencies, Tribes, and the State Historic Preservation Office
as consulting parties. However, consulting parties should also
include local governments and other interested parties as
defined in 36 CFR 800.2(c).
The Cooperative appreciates the comment. The
Cooperative inadvertently neglected to mention
local governments and other interested parties in
this section of the PAD. However, the
Cooperative has been consulting with local
governments and other interested parties as
listed in 36 CFR 800.2 and plans to continue this
consultation throughout the licensing process.
11 AK
SHPO
4.10.2:
Ethnographic
and Historical
Overview
We recommend revising Section 4.10.2 Ethnographic and
Historical Overview for clarity through consistent use of terms
such as Tradition and Culture and by synthesizing the
information to create one chronology with multiple lines of
evidence.
The Cooperative appreciates the comment from
AK SHPO. The Cooperative does not plan to
revise the PAD, but all future Project licensing
documents will utilize the correct terminology
pertaining to historical, cultural, and tribal
resources.
12 AK
SHPO
4.10: Cultural
and Tribal
Resources
Our office recommends execution of a Programmatic
Agreement to assist the applicant with compliance under
Section 106 and the Alaska Historic Preservation Act regarding
the construction, operation, and eventual closure of the project.
The PAD current recommends only an Historic Properties
Management Plan (HPMP), but stand-alone management plans
have proven difficult to implement. Any agreement document
and/or management plan used to implement an agreement for
the purposes of Section 106 or the Alaska Historic Preservation
Act should be created in consultation with consulting parties.
The Cooperative appreciates the comment from
AK SHPO. The Cooperative intends to develop
the appropriate plans and/or agreement
document as required by Section 106 and the
Alaska Historic Preservation Act in consultation
with the consulting parties. We will be bringing
on a Cultural Resource expert to guide this
process.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-5 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
13 NMFS 3.0: Project
Description
The proposed Nuyakuk Hydroelectric Project will be located on
the Nuyakuk River at a cascade approximately five river miles
downstream from the Tikchik Lake outlet. The Tikchik Lake
drains the northern Wood River Mountains, a 1,544 square mile
watershed. Alaska Statutes (AS § 41.21.167(e)) allows this
project to be constructed within Wood-Tikchik State Park
boundary. The Project would divert water out of the river above
Nuyakuk Falls, pass it through a tunnel(s) to a powerhouse
located at the base of Nuyakuk Falls. The water will be returned
to the river via the tailrace at the base of Nuyakuk Falls.
Nuyakuk Falls is a ½-mile long cascade with 26 feet of
elevation change. From the Project site, the Nuyakuk River runs
approximately 40 miles before converging with the Nushagak
River, which continues to Bristol Bay. As outlined in the
November 14, 2019 Additional Information Request (AIR)
response, the proposed powerhouse would contain two Kaplan-
style reaction turbine generating units. The rated capacity on
each unit would be approximately 5 MW, for a total of 10 MW.
The combined maximum design flow is approximately 7,550
cfs. The PAD states a minimum flow of 1,000 cfs will be left in
the river for other in-river uses, however AS § 41.21.167(e)
states the project must maintain at least 70%of the daily
upstream water flow of an affected river along the natural
course of the river. This maximum designed flow represents the
75% exceedance flow rate for the months of June, July and
August. The PAD states the proposed project will be located at
Nuyakuk Falls, however, it is technically a half mile-long
cascade. Nuyakuk Falls and Nuyakuk cascade refer to the same
river reach in this document.
The Cooperative appreciates NMFS’s comment
regarding the proposed Project description.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-6 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
14 NMFS n/a
Our statutory responsibilities in this matter are codified under
our authorities pursuant to the Fish and Wildlife Coordination
Act (16 U.S.C. § 661 et seq.), which requires that the federal
action agency consult and give considerable weight to the
comments of federal and state resource agencies; the
Magnuson-Stevens Fishery Conservation and Management Act
(16 USC §
1855(b)) and its implementing regulations (50 CFR § 600.920),
which requires consultation between the federal action agency
and the National Marine Fisheries Service for projects that
affect essential fish habitat; and the Federal Power Act (16
U.S.C. §§803 and 811), for the protection of anadromous fish
resources and their habitat affected by the licensing, operation
and maintenance of hydroelectric projects.
The Cooperative appreciates NMFS’s comment
and looks forward to consulting with NMFS
throughout the Project licensing process.
15 NMFS n/a
NOAA’s National Marine Fisheries Service is a trustee for
coastal and living marine resources, including commercial and
recreational fisheries; diadromous species; marine mammals,
and marine, estuarine, and coastal habitat systems. Our work is
guided by two core mandates: ensure the productivity and
sustainability of fisheries and fishing communities, and recover
and conserve protected resources through reliance on the best
available science. Coastal riverine habitat systems, including
rivers such as the Nuyakuk, provide an integral component of
ecological functions for the larger marine environment. Species
such as Sockeye salmon
(Oncorhynchus nerka), Chinook salmon (O. tshawytscha), Coho
salmon (O. kisutch), Chum salmon (O. keta), pink salmon (O.
gorbuscha) rely on the Nuyakuk River for refuge, spawning,
rearing and nursery habitat.
The Cooperative appreciates NMFS’s comment
and looks forward to consulting with NMFS
regarding NOAA trust resources throughout the
Project licensing process.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-7 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
16 NMFS Contact List
(NOI)
Please remove Susan Walker, Kate Savage, and Thomas Meyer
from your contact list. We will file a separate notice to the
Commission to update the Mailing List. Communication with
our agency should continue through the following contacts:
Regional Administrator
National Oceanic and Atmospheric Administration National
Marine Fisheries Service
Alaska Region
PO Box 21668
Juneau, AK 99802
Sean Eagan
National Oceanic and Atmospheric Administration National
Marine Fisheries Service
Alaska Region
PO Box 21668
Juneau, AK 99802
907-586-7345
Sean.Eagan@noaa.gov
The Cooperative appreciates NMFS’s comment
and has made the corresponding changes to the
Project contact list.
17 NMFS 3.3: Project
Facilities
The second paragraph of this section, page 23, indicates that the
“combined maximum designed flow is the 75% exceedance
flow rate for the months of June, July and August, less 1,000 cfs
for instream uses.” Appendix B has the monthly flow duration
curves showing the 75% exceedance to be ~12,000, 10,000, and
7,500 cfs, respectively, for the months of June through August.
This volume of water removed is not consistent with Alaska
Statute (AS § 41.21.167(e)), which states “(2) maintains at least
70 percent of the daily upstream water flow of an affected river
along the natural course of the river”. If 70% is left in the river
even in June on many days only 3,600 cfs will be run through
the turbines which are being designed with 7,550 cfs of
capacity.
The Cooperative appreciates this comment. The
Cooperative plans to undertake a number of
studies to inform Project feasibility and design
specifics. The engineering configurations
proposed in the PAD may be modified based on
the results of field and feasibility studies in order
to meet regulatory requirements. It is anticipated
that instream flow requirements will be
developed based on the results of field studies.
The Cooperative is interested in displacing as
much diesel fuel generation as possible, even if
generation in lower flow months is diminished
due to complying with instream flow
regulations.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-8 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
18 NMFS
3.3.2: Nuyakuk
Falls Diversion
& Intake
The applicant proposed to complete two-dimensional river
hydraulic modeling for approximately 1,000 linear feet above
the falls to aid in development of the intake diversion hydraulic
and structural design. Our Study Request 3, objective (e),
supports the need for three dimensional computational fluid
dynamics (CFD) modelling to evaluate flows vectors under a
range of river and operation conditions.
This section describes the need for an inclined bar-screen at the
intakes to divert debris and ice. The openings between the bars
are proposed as 1 to 3 inches. These racks would be oriented
parallel to the flow to increase sweeping velocities to promote
debris and ice removal. Further, the Additional Information
Request response submitted by the applicant (November 14,
2019) provides a conceptual design of the proposed facility. We
note the concrete groin has the potential to span half the river’s
width or more.
Adult salmon migrating to the upstream lake habitat for
spawning, and juvenile salmon emigrating to the ocean need to
safely pass the project intakes. Diverting the first 7,550 cfs
above a minimum 1,000 cfs bypass flow, as proposed, would
have significant consequences for migratory fish, including
salmon. Maintaining 70% of the natural flow in the river would
significantly reduce effects on salmon. The Project should be
designed and operated to avoid impingement and entrainment of
these migrating fish. This may require smaller rack spacing and
larger screen surface area to manage intake flows and sweeping
velocities. It may also require a screen orientation at a specific
angle to the river flow to encourage movement along the screen
face. These same considerations apply to ice management.
Frazil ice, and to a lesser extent breakup and anchor ice, has the
potential to damage the bar rack and reduce intake flow, and
affect the overall operation of the Project. Damaged racks or
impaired project operations could influence the ability to safely
[Comment 18 continues on next page]
The Cooperative appreciates NMFS’s comment,
and has proposed several studies to address
these concerns:
• Nuyakuk Falls Fish Passage Study
(PSP Section 4.1.2)
• Fish Entrainment and Impingement
Study (PSP Section 4.1.3)
• Ice Processes Assessment (PSP Section
4.2.3)
As mentioned in each of the aforementioned
proposed studies sections in the PSP, the
Cooperative looks forward to working with
NMFS on the development of the appropriate
methods and analytical tools to adequately
assess potential impacts (positive and negative)
from Project construction and operation.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-9 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
move fish past the project structure.
Features designed to prevent ice damage are important to ensure
proper project operations. Our Study Request 3, objective (e),
for a 3-D modeling above the falls informed by the 2-D model
throughout the project affected area will inform the intake
screen design and help to meet this goal of protecting migrating
salmon.
19 NMFS
3.3.3:
Conveyance
Tunnels
The November 14th AIR response depicts twin 16 foot tunnels
leading to the powerhouse. This would seem more practical than
the larger single tunnel presented in the PAD.
The Cooperative appreciates NMFS’s comment.
Project design is still in development and will be
informed by Project feasibility studies. The PSP
describes the Project configuration as twin 18-
foot tunnels. This may be refined based on field
studies and ongoing engineering design work.
20 NMFS 3.3.5:
Powerhouse
The PAD indicates three vertical shaft Kaplan-type turbines are
proposed for the project. The November 14th AIR response
states two turbine units each rated at a capacity of 5,000KW.
We request analysis of this turbine type on outmigrating smolt
at 26-feet of head versus other turbine models. January through
March flows averaged approximately ⅕ of summer flows in the
last seven years. Climate change could further alter this
proportion (see Future Flows, Study Request 5). We
recommend investigating whether turbines of different sizes
might be the most efficient way to optimize winter power
production.
The Cooperative appreciates NMFS’s comment.
Project design is still in development and will be
informed by field and Project feasibility studies.
The Cooperative plans to assess optimal power
production the proposed turbine configuration.
The Cooperative has proposed a study titled
“Fish Entrainment and Impingement Study” that
will investigate potential impacts on
outmigrating juvenile salmonids.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-10 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
21 NMFS 3.3.6: Tailrace
The proposed tailrace outlet design is intended to reduce
velocities relative to the natural river velocities in the discharge
zone. This design feature will help prevent the false attraction of
anadromous fish to the tailrace. This section include the
potential for evaluation of other measures to meet this goal,
such as a vertical picket barriers or other such fish barrier type.
We support the inclusion of design features and operations to
prevent the false attraction of migrating anadromous fish at the
tailrace. Migrating fish need to reach their spawning habitat
safely and in a timely manner. The proposed actions will
support this goal.
The Cooperative appreciates this comment. The
Cooperative has proposed to conduct a study
titled “Assessment of False Attraction at the
Fish Tailrace Barrier” (PSP Section 4.1.3). This
study will provide data used to inform tailrace
design in order to minimize the potential for
false attraction of fish to the Project tailrace.
22 NMFS
3.3.7:
Switchyard/
Transmission
Lines
A straight transmission line from Nuyakuk Falls directly to
Koliganek and then a second line directly to Stuyahok would
appear to minimize the miles of new line that need to be
constructed and the environmental disturbance. We assume that
there are terrane or land ownership consideration that went into
the displayed longer route (AIR Fig 3-3).
The Cooperative appreciates this comment, and
is currently refining Project design, including
the transmission line route. The conceptual
design displayed in the PAD and PAD AIR may
be refined, and in the final design the
Cooperative will seek to reduce environmental
disturbance while balancing other considerations
such as land ownership. Further, during the
initial feasibility layout of the transmission line,
it was determined that the longer route proposed,
along ridgelines would cumulatively minimize
the overall impact of Project development by
avoiding numerous wetland areas utilized by a
variety of wildlife and botanical species.
23 NMFS
3.3.8: Proposed
Construction
and
Development
Schedule
Many aspects of the mobilization and construction have the
potential to affect anadromous species migration and spawning
activity. We recommend consideration of erosion and sediment
control, timing of in-water activity, hazardous materials control,
and invasive species management for each step of the
construction and development planning and implementation.
The Cooperative appreciates this comment and
agrees with NMFS that Project construction
schedules and methods should be planned to
minimize environmental disturbance, including
anadromous species migration and spawning
activity.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-11 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
24 NMFS
Figure 3-10:
Mean Daily
Discharge
We note the use of the full data range from 1953 to present to
create the flow duration curve for summer months. It appears
USGS gage #1530200 was not operated most years from
November through early April from 1953 to 2013. We
recommend the applianc[t] describe how the flow duration
curve was developed for the winter months.
Climate change is impacting hydrologic patterns across the
nation. Bristol Bay watershed has already seen an increase of
3.7 °F in air temperature and an increase of 13 % in annual
precipitation from 1969 to 2018 (Thoman 2019). Further,
increasing precipitation is projected in the project area within
even the early period of the license.(Leppi 2014; Wobus 2015).
The greatest increases are expected in winter and summer
months (USGCRP 2018), and in this watershed, increasing
temperatures are projected to lead to multiple freshets, or pulses
of flow, during the winter (Wobus 2015). A flow duration curve
based on a more precise data set that reflects current conditions
and trends would better inform the development of the project,
project operations, and mitigation measures. We recommend in
our Change Analysis (Study Request 4) to evaluate the flow
data for more recent trends in the data from the Nuyakuk USGS
gage. The results may influence the project proposal, project
capacity and production, and mitigation measures.
The Cooperative appreciates NMFS’s comment.
The Cooperative used the available winter flow
data at USGS gage #1530200 from 1953 to 2017
(54 years of available mean daily discharge
data). It is notable that available daily mean
winter flow records prior to 2014 were qualified
as “estimated” data. The Cooperative queried
the USGS via email to determine the basis for
estimating winter flow records prior to 2014 and
received a response from Chad W. Smith on
March 2, 2020:
Bob,
Historically discharge records have been
estimated at this site when ice formation affects
the stage discharge relationship. These estimates
were based on a combination of climate data,
physical discharge measurements, and trends of
the stage hydrograph. Advances in the
equipment used to make discharge
measurements and winter access to the site in
recent years have indicated that much of the
winter period is not adversely affected by
ice. Prior to this new information about winter
ice affects we would estimate the daily
discharge to be slightly less than what the
computed "ice affected" record would be. This
resulted in a fairly accurate estimated record.
The Cooperative believes Mr. Smith’s response
confirms that the USGS was actively gaging the
site through the winter on the pre-2014 data
sets. The USGS had to qualify the streamflow
record as “estimated” because their
instrumentation was affected by ice and
therefore stage/discharge readings were not
taken directly from the
instrumentation. [Comment 24 response
continues on next page]
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-12 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
Also, despite a substantial period of estimated
winter flow data, these flow data were slightly
reduced to create an accurate daily flow
record. The Cooperative is confident that the
winter flow data from USGS gage #1530200 is
the most accurate and reliable to generate flow
duration curves.
25 NMFS 4.1.2: Climate
Planning for new hydro projects has in the past relied on the
assumption that future air temperature and precipitation patterns
would be the same as those in the past. Given the increasing
certainty of global climate change, this assumption is no longer
valid given the current level of scientific certainty of climate
change (Milly 2008; Viers and Rheinheimer 2011). Further,
long range planning for hydroelectric project operations
depends on large-scale, long-term climate predictions. However,
for the multi-decadal period of the license, it is important to
assess how these variables will change due to trends and natural
variability, but also due to climate change. With needs to predict
both quantity and timing of precipitation and temperature in an
uncertain future, planning for new projects should analyze long-
term (multi-decadal) climate and hydrology datasets and assess
downscaled climate projections. Such an analysis has become
generally accepted practice in the hydropower industry
worldwide.
[Comment 25 continues on next page]
The Cooperative appreciates NMFS’s comment.
The Cooperative has proposed a robust study
program to be conducted during the Project
licensing process. However, the climate change
studies proposed by NMFS do not meet the
criteria for identifying a nexus between the
proposed Project construction or operations and
effects (direct, indirect, or cumulative) on the
resource to be studied. FERC has been
consistent in their treatment of similar requests
for studies in hydropower licensing (FERC
2009a, 2009b, 2009c, 2009d, 2011a, 2011b,
2013, 2016).
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-13 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
From an environmental standpoint, failing to consider climate
change trends for southwest Alaska can result in not capitalizing
on the opportunities for both hydropower planning and fish,
given the projections of increasing precipitation, and in design
of fish passage and operating conditions that are unrealistic for
the range of future flows. This is in line with recent literature
that highlights opportunities to design and operate hydropower
projects for sustainability of both power production and the
riverine environment (Brown et al. 2015; Poff et al. 2016).
These flows relate to diverse resources as recreation, aesthetics,
subsistence, and tourism, among others. From an economic
standpoint, not accounting for climate change can result in less
reliable electrical generation, more diesel fuel consumption,
higher energy costs, and other negative factors.
We recommend the applicant evaluate how anticipated changes
in temperature and precipitation may be expected to impact
project operations and operational efficiency of the proposed
hydropower project. A basis for this assessment can be derived
from state specific information generated by the U.S. Global
Change Research Program (Chapin 2014; USGCRP 2018) and
publications based on global climate models used in that report.
26 NMFS
4.4.3: Federal
and State
Designated
Habitat
The Nuyakuk River, including Nuyakuk Falls, is designated
Essential Fish Habitat for five species of salmon (NPFMC
2018). The Little King Salmon River enters the Nuyakuk just
below the Tikchik Lake outlet and adds to the affected area. The
Little King Salmon River supports Chinook and coho salmon
(ADFG 1994). A second unnamed stream enters the Nuyakuk
from the south about one mile above the fall and also supports
coho salmon. It is not clear that the watersheds of either of these
two streams is included in the applicant’s 1,544 square mile
watershed assessment.
The Cooperative appreciates NMFS’s comment.
We will review our previously conducted
watershed assessment to verify all relevant
tributaries are accounted for in our calculation.
We will modify the overall square mileage
number based on this assessment, if applicable.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-14 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
27 NMFS
4.4.4.1: Fish
Passage
Barriers
We agree that determining at what flows the falls are and are
not a barrier for each species needs further assessment
(Upstream Fish Passage, Study 2).
The Cooperative appreciates NMFS’s comment.
The Cooperative has proposed to conduct a
study titled “Nuyakuk Falls Fish Passage Study”
(PSP Section 4.1.2) to investigate the
relationship between river flow levels and
upstream and downstream fish migration.
28 NMFS
4.4.4.2:
Sediment, Ice,
and
Geomorphology
We agree with most aspects of this assessment, however, the
statement “the area immediately above and below Nuyakuk
Falls consistently remains ice free” needs verification. It is not
clear whether the ice free zone above the falls extend to the
intake facility all winter. It should be clarified whether frazil ice
will form as the river water emerges from under the iced over
section. If so, that frazil ice may adhere to the intake structure.
See our Ice Processes Assessment, Study 6.
The Cooperative appreciates NMFS’s comment,
and has proposed to conduct a study titled “Ice
Processes Assessment” (PSP Section 4.2.3) to
gain a better understanding of ice formation in
the Project area and potential impacts to Project
facilities.
29 NMFS 4.4.5: Instream
Flows
The short bypass reach is not “almost wholly falls” as the
gradient averages only 1% and could contain some areas with
habitat value. Our Study Request 1, Fish Distribution, objective
(d), addresses this need to understand what fish habitat and
processes happen in the Nuyakuk cascade.
The Cooperative appreciates NMFS’s comment
and agrees that Nuyakuk Falls (cascade) requires
study during the Project licensing process. To
address this, the Cooperative has proposed to
conduct the following studies to investigate fish
distribution and habitat availability in the falls:
• Fish Species Abundance and
Distribution Near the Project Area (PSP
Section 4.1.1)
• Nuyakuk Falls Fish Passage Study
(PSP Section 4.1.2)
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-15 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
30 NMFS 4.4.6 Potential
Adverse Effects
Table 4-9 identifies the potential adverse impacts related to fish
and aquatic resources. We note that in-water work has the
potential to result in long-term and permanent impacts on
spawning and rearing habitat, as well as the short term impacts
identified. The scope and scale of impacts depends on the in-
water activity.
We concur that bypass of a portion of the river flow around the
Nuyakuk Falls during operations may impede fish movement
during their migration. Evaluating this potential impact on
migrating salmon is a priority for our agency, and is considered
in our Upstream Fish Passage, Study 2.
The Cooperative appreciates NMFS’s comment
and agrees that impacts to migrating salmon
need to be assessed during Project licensing. To
accomplish this, the Cooperative has proposed
to conduct a study titled “Nuyakuk Falls Fish
Passage Study (PSP Section 4.1.2).
31 NMFS
5.0 Preliminary
Issues and
Study List
We support the development of environmentally sound,
renewable energy that helps communities reduce their reliance
on diesel. As indicated in this section of the PAD, a number of
data gaps that require evaluation to assess baseline conditions
and potential project related impacts. Data from these studies
will support the development of protection, mitigation and
enhancement measures that address identified project related
impacts. Attachment 2 of this document provides our detailed
study requests per 18 CFR § 5.9(b).
The Cooperative appreciates NMFS’s comment
and agrees that a robust study program is
essential during the Project licensing process.
The Cooperative has proposed to conduct a total
of 13 studies designed to evaluate potential
impacts (both positive and negative) to natural
resources due to proposed Project construction
and operation.
32 NMFS
PAD Section
5.3 Relevant
Comprehensive
Plans
We recommend inclusion as a comprehensive plan the Strategic
Conservation Action Plan for Southwest Alaska Watershed.
This action plan was developed by the Southwest Alaska
Salmon Habitat Partnership and updated in 2017. We filed this
document with the Commission as a comprehensive plan on
November 21, 2019 (accession # 20191121-5157). We also
recommend Nushagak River Watershed Traditional Use Area
Conservation Plan by the Nushagak-Mulchatna Watershed
Council, which we plan to file on the record.
The Cooperative appreciates this comment.
33 UTBB n/a What is the estimated average annual generation capacity of the
Project (e.g., is it 72,800 MWh or 55,300 MWh)?
Project design and specifications are still
conceptual and evolving based on ongoing
analysis. The current average annual generation
capacity is estimated to be 58,900 MWh.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-16 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
34 UTBB n/a
How much energy is needed for the fish processing and
packaging efforts in the summer versus the heating and
electricity needs in the villages?
The Cooperative appreciates this question from
UTBB. The Cooperative expects more than half
of the load from the Project to be utilized for
fish processing during the summer. Using 2019
as an example, over 3 MW were utilized for
processing during the commercial fishing
season. Heating and electricity demands will
obviously increase as a result of the Project, not
only supplying Dillingham but also the outlying
villages. Seasonal considerations related to
processing needs and peak times for heating
needs will be a driver in overall demand.
35 UTBB n/a
Will there just be a single bore tunnel arrangement for the 2
conveyance pipes to the powerhouse? How long and how far
underground will it be?
Project design and specifications are still
conceptual at this time, and it is unknown
whether there will be a single or double tunnel
bore arrangement for the 2 conveyance pipes to
the powerhouse. Preliminary geotechnical
studies will inform the Project’s engineering
design. Preliminary Project design consists of a
total tunnel length of approximately 750 ft. The
tunnel(s) will be approximately 20-30 ft below
ground at the edge of the water in the forebay
above Nuyakuk Falls. The tunnel depth will
increase as it travels under the nearby hill and
decrease closer to the powerhouse due to above-
ground topography.
36 UTBB n/a Will there be 2 or 3 Kaplan turbines in the powerhouse? Project design and specifications are still
conceptual at this time, but preliminary design
includes 2 Kaplan units in the powerhouse.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-17 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
37 UTBB n/a What is the amount of flow that will be diverted to the intake
structure every month of the year?
The Cooperative appreciates UTBB’s question.
At this time, the amount of flow diverted to the
intake structure during each month of the year is
unknown. Field studies, site-specific field gages,
and agency consultation will guide instream
flow requirements for this portion of the
Nuyakuk River. Additionally, the Cooperative
will be pursuing a water right with ADNR that
will prescribe the volume of water that can be
diverted through the proposed Project
throughout the year.
38 UTBB n/a Where will the gravel source be located for the runway and road
construction?
The Cooperative is in the process of identifying
sources for various materials necessary for
Project construction. Sources for gravel and
other necessary materials will be documented as
the information becomes available.
39 UTBB n/a
How will the winter ice and low flow conditions, the potential
for ice dams, and high flows during Spring breakup impact the
operation of the diversion structure? How will ice and debris
issues be mitigated from impacting the intake on the river bank?
Will antifreeze be used in winter through the intake structure to
avoid ice buildup?
The Cooperative appreciates UTBB’s question.
The Cooperative has proposed to conduct a
study titled “Ice Processes Assessment” (PSP
Section 4.2.3) in order to gather information
about ice formation in the Project vicinity and in
the Project intake structure. The information
from this study will be used to guide Project
design to minimize any potential issues that may
be caused by ice formation.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-18 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
40 UTBB n/a
What are the plans for the construction man camp and will it be
used in the winter months? How many people will be needed for
the construction phase? Will locals have hiring preference?
The Cooperative is in the process of planning
the construction of the man camp. The
construction man camp will be addressed when
the FERC license is received. The amount of
man power for this Project will ultimately be
defined by the final design and need for various
disciplines. During the construction phase, work
will be ongoing through the year. The
Cooperative has already hired locals for some of
the logistical work and will continue this
throughout the Project. The Cooperative plans
to have a man camp set up for the studies,
including two cabins and 3 docks. The study
work will be on-going throughout the year
during the study process.
41 UTBB n/a
When will construction of transmission lines occur, how many
streams and acres of wetlands will need to be crossed during
construction, and what environmental impacts will there be
during the construction of the transmission lines?
The Cooperative appreciates UTBB’s question.
At this time, it is unknown exactly when Project
transmission lines will be constructed. A refined
Project construction schedule will be developed
upon receiving the FERC operating license and
all associated land use permits from requisite
state agencies. At this time, detailed mapping of
wetlands has not been conducted in the proposed
Project vicinity. The Cooperative has proposed
to conduct a study titled “Botanical and
Wetlands Survey” (PSP Section 4.3.1) that will
quantify the type and acreage of wetlands and
streams within the proposed Project boundary,
which includes all transmission line corridors.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-19 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
42 UTBB n/a
What will be the barging challenges on the Nuyakuk River to
bring in heavy equipment and turbines to the site? In the
Scoping Meeting it was stated that there are navigational issues
near the project site (e.g., only a small 18’ boat can reach the
site).
The Cooperative appreciates UTBB’s question
and recognizes that there are logistical
challenges to undertaking construction in this
remote location. The Cooperative is currently
working to identify the best possible means and
methods of mobilizing equipment and turbines
to the site. As more information becomes
available, the Cooperative will provide these
details in Project licensing documents and at
public meetings.
43 UTBB n/a
What is the design of and how long will it take to construct the
diversion structure or groyne? Will a cofferdam be used for the
construction of the groyne? How long will the cofferdam be in
place? How will the construction of the groyne impact in- and
out-migrating salmon?
Project design and specifications are still
conceptual at this time, and exact details
regarding the design of the diversion structure
and concrete groin are not complete. It is
anticipated that a cofferdam will be placed for
construction of the concrete groin, but details
regarding the length and timing of cofferdam
use have not been developed. The Cooperative
recognizes that any in-water work has the
potential to impact salmonids. The Cooperative
intends to consult with agencies to determine the
appropriate timing for in-water work in order to
minimize impacts to in-and out-migrating
salmon.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-20 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
44 UTBB n/a
What are the maintenance requirements for the power plant and
transmission lines? Will the power plant need to be shut down
annually, if so for how long?
Project design specifications will be refined
throughout the licensing process. These
refinements will ultimately define the
maintenance process for all Project
infrastructure. Generally speaking and with the
understanding that this plan could be modified,
there will likely be an annual maintenance
outage associated with the low flow/power
output period during which, all standard
maintenance activities will take place. Unless
anomalous conditions occur, regular shutdowns
aside from this period are not anticipated at this
time.
45 UTBB n/a What other federal and state permits will be needed for the
project?
The Cooperative has begun the formal process
of consulting with federal and state agencies to
identify permits that will be needed to conduct
the feasibility studies associated with Project
licensing. Assuming the Project receives a
license, a similar collaborative process will
occur to ensure that all federal and state permits
are secured for the construction and operation of
the Project.
46 UTBB n/a How long will the project provide hydroelectric power to the
villages (e.g., 20, 50, 100 years)?
The Cooperative intends to obtain a 40-year
license from FERC for Project operation, which
is the standard length of license for projects of
this size. Similar projects in Alaska have
demonstrated their ability to provide a reliable
source of renewable power for 100+ years and
are still operating. Every expectation is that this
Project would operate with a similar life
expectancy.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-21 March 2020
Comment
No. Agency PAD
Section
PAD Comment Cooperative’s Response
47 UTBB n/a What are the decommissioning plans for the hydroelectric
power plant?
Currently, the Cooperative has not developed
decommissioning plans. In the event that the
Project requires decommissioning, the
Cooperative will create decommissioning plans
in consultation with federal, state, and local
agencies that meet strict FERC guidelines and
all relevant environmental regulations.
48 UTBB n/a
What are other electricity needs besides the villages along the
transmission line corridors (e.g., Aleknagik landfill, Float Plane
Road, and Johnny Tugatuk Road) that could benefit from the
Project?
In addition to Dillingham and the outlying
villages, the Cooperative plans to provide to the
Aleknagik Landfill, Float Plane Road, and
Johnny Tugatuk Road. At this time, we also
anticipate providing power to the new fish
processing being developed by Levelock Tribal.
49 UTBB n/a
When will an economic feasibility study be conducted and how
will the Nushagak Cooperative fund this Project (e.g., through
funds from the State of Alaska, federal funds and/or bank
financing)?
The Cooperative appreciates UTBB’s question.
The Cooperative is currently refining Project
economic feasibility studies. The Cooperative is
pursuing a variety of funding sources to assist
with the development of the proposed Project,
including federal, state, and other sources of
funding. As Project funding is established, the
Cooperative will provide funding details in
Project licensing documents and at public
meetings.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. August 2022
APPENDIX B:
PAD Comments and Study Requests Filed with FERC
Nuyakuk River Hydroelectric Project
FERC No. 14873 PAD Comment Responses
Nushagak Cooperative, Inc. A-22 March 2020
REFERENCES
FERC (Federal Energy Regulatory Commission). 2009a. Study Plan Determination for the Lake
Powell Pipeline Project (P-12966). January 2009.
FERC. 2009b. Study Plan Determination for the Yuba-Bear Drum-Spaulding Project (P-2310, P-
2266). February 2009.
FERC. 2009c. Study Plan Determination for the Toledo Bend Project (P-2305). August 2009.
FERC. 2009d. Study Plan Determination for the Merced Project (P-2179). September 2009.
FERC. 2011a. Study Plan Determination for the Yuba River Project (P-2246). September 2011.
FERC. 2011b. Study Plan Determination for the Don Pedro Hydroelectric Project (P-2299).
December 2011.
FERC. 2013. Study Plan Determination for the Susitna-Watana Hydroelectric Project (P-14241).
February 2013.
FERC. 2016. Study Plan Determination for the La Grange Hydroelectric Project (P-14581). May
2016.
Department of Fish and Game
Division of Sport Fish
Research & Technical Services
333 Raspberry Road
Anchorage, Alaska 99518-1565
Main: 907.267.2294
Fax: 907.267.2422
February 4, 2020
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Subject: Nuyakuk River (P-14873-001) Hydroelectric Project
Comments and Study Requests
Dear Ms. Bose:
On November 8, 2019, the Federal Energy Regulatory Commission (FERC) published notice
soliciting comments and study requests for the Nuyakuk River Hydroelectric Project (FERC
No. 14873). The Alaska Department of Fish and Game (ADF&G) has reviewed the Pre-
Application Document submitted by Nushagak Cooperative, Inc. and offers the attached
comments and study requests.
If you have any questions, please contact me at (907) 267-2836. Thank you for your
consideration.
Sincerely,
Kevin Keith
FERC Hydropower Coordinator
Alaska Department of Fish and Game
(907) 267-2836
Cc: J. Klein, ADF&G S. Graziano, ADF&G
T. Sands, ADF&G R. Himschoot, NCI
J. Head, ADF&G B. Armstrong, NCI
J. Dye, ADF&G C. Warnock, MJA
L. Borden, ADF&G C. Sauvageau, MJA
T. Rinaldi, ADF&G L. Johnson, MJA
L. Watine, ADF&G E. Benolkin, USFWS
R. Dublin, ADF&G S. Eagan, NMFS
M. Marie, ADF&G J. Kolberg, FERC
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
Comments and Study Requests
1
COMMENTS ON THE PRE-APPLICATION DOCUMENT (PAD)
As part of the greater Bristol Bay watershed, the Nuyakuk River supports one of the world’s most
productive salmon fisheries. The planning of any development in this region must be carried out with
a careful eye to how that activity, in this case the construction and operation of a hydropower facility,
may affect salmon populations, salmon habitat, and the communities that depend on salmon resources.
In addition, assessment of other (non-salmon) fish species, as well as the wildlife in the project area,
will also be needed.
Section 3.3.2 Nuyakuk Falls Diversion & Intake
The concrete gravity diversion structure above the falls requires careful study. Its effects on both
upstream and downstream movement of fish will have to be evaluated. The diversion structure may
also create some new slow-water habitat.
The PAD states that the diversion and intake geometry will depend upon further studies. The design
of the intake and associated structures should minimize the likelihood of fish entrainment, particularly
of out-migrating salmon smolt.
Section 3.3.6 Tailrace
False attraction of fish to the tailrace is always a concern, particularly for waterbodies with migrating
salmon. ADF&G is supportive of a design that reduces tailrace velocities and considers fish exclusion
barriers at the tailrace.
Section 4.4.6 Potential Adverse Effects to Aquatic Resources
This section and Table 4-9 correctly identify some of the potential adverse effects, such as delayed or
prohibited upstream migration of fish and mortality to upstream migrating fish. However, potential
adverse effects to downstream migrating fish are not mentioned. Mortality of downstream migrating
fish may increase, due either to intake impingement, penstock entrainment or to delays or blockage
caused by the concrete diversion structure. Downstream fish migration pathways may be altered due
to the decrease in flow; this could potentially concentrate fish and lead to blockage and delays resulting
in increased predation and mortality.
Section 4.8.3.1 Subsistence Uses
Data collected by ADF&G shows that the proposed project area was heavily used for subsistence
hunting and fishing activities by residents of Koliganek and New Stuyahok, at least for the year the
study was conducted, 2005. To understand possible project effects, this data should be updated; we
elaborate on the collection of data on subsistence use in the Study Requests section of this document.
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
Comments and Study Requests
2
Section 5.2.2 Water Resources (Potential Studies)
Three potential studies are listed in this section: 1) water quality and water temperature assessment, 2)
hydrologic data collection, and 3) sediment transport assessment and modeling. Because the topics of
these studies have a direct impact on fish resources, ADF&G is supportive of all three of these studies
and will work with the applicant to ensure that they are carried out in a way that ensure the quality and
relevance of the data collected to inform the decision-making process.
Section 5.2.3 Fish and Aquatic Resources (Potential Studies)
Three potential studies are listed in this section: 1) fish species seasonal distribution and abundance,
2) bathymetric modeling (i.e. two-dimensional modeling) of Nuyakuk Falls, and 3) Nuyakuk Falls fish
passage evaluation and modeling. Each of these studies is essential to understanding how salmon and
other fish pass through the Falls and possible project effects. We will elaborate on each of these in the
Study Requests section of this document. Additionally, a study of entrainment mortality, particularly
for juvenile salmonids, is necessary to quantify potential project impacts.
Section 5.2.4 Wildlife and Botanical Resources (Potential Studies)
Four potential studies are listed in this section: 1) wildlife presence, distribution and migratory
assessments, 2) botanical presence and distribution evaluation, 3) invasive weed assessment, and 4)
rare, threatened and endangered species assessment. The first proposal is essential to provide site-
specific information for the evaluation of wildlife issues related to the project. In particular, the project
area is a calving area for the Mulchatna Caribou Herd. The construction of power lines through the
area would create linear disturbances and activity that may affect caribou movement patterns, survival
of caribou neonates, and caribou predation.
For studies numbers 2) and 3) we will defer to other resource agencies with more pertinent expertise.
We will work closely with the applicant to ensure that the studies provide the information needed for
our decision-making purposes.
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
Comments and Study Requests
3
STUDY REQUEST #1: Fish Species Seasonal Distribution and Abundance near the Project Site
§5.9(b)(1) — Describe the goals and objectives of each study proposal and the information to be
obtained.
Goal:
The goals of this study are to better understand fish timing and use of the project area.
Objectives:
1.Estimate the run timing for all five species of Pacific salmon (Chinook, coho, sockeye, chum,
and pink salmon), for both their spawning migration up the Nuyakuk Falls and for the smolt
migration down the Nuyakuk Falls.
2.Estimate the magnitude and seasonality of resident fish use of Nuyakuk Falls by both juveniles
and adults.
§5.9(b)(2) — If applicable, explain the relevant resource management goals of the agencies or
Indian tribes with jurisdiction over the resource to be studied.
The Fish and Game Act requires the Alaska Department of Fish and Game (ADF&G) to, among other
responsibilities, “…manage, protect, maintain, improve, and extend the fish, game and aquatic plant
resources of the state in the interest of the economy and general well-being of the state” (AS
16.05.020).
ADF&G – Division of Sport Fish Mission is “to protect and improve the state’s recreational and
fisheries resources”. According to the 2015-2020 Division of Sport Fish Strategic Plan, the
management priority is to manage Alaska’s recreational fisheries for sustained yield and recreational
angler satisfaction that is centered on an area-based management system. The division’s fish habitat
program is directed at protecting and restoring fish habitats for the benefit of fish and current and
future recreational anglers.
§5.9(b)(3) — If the requester is not a resource agency, explain any relevant public interest
considerations in regard to the proposed study.
Not applicable, requestor is a resource agency.
§5.9(b)(4) — Describe existing information concerning the subject of the study proposal, and the
need for additional information.
ADF&G ran a counting tower on the Nuyakuk River from 1959 to 1988 and from 1995 to 2006. The
tower counts provide good information on the magnitude and timing of the adult sockeye salmon
spawning migration. However, we do not have good information on the magnitude and timing of the
spawning migrations for the other four salmon species (Chinook, coho, chum, and pink salmon). Nor
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
Comments and Study Requests
4
do we have information on the magnitudes and timing of the smolt migration at the project site for any
of the five Pacific salmon species.
ADF&G conducted a fish inventory of the Nuyakuk River in August of 2006. This inventory provides
of list of those species that may be present at the project site in August. It does not address which
species use the falls, either as habitat or as a migration corridor, and at what times of years those
species may use the falls. Additional studies are needed to answer these questions.
§5.9(b)(5) — Explain any nexus between project operations and effects (direct, indirect, and/or
cumulative) on the resource to be studied, and how the study results would inform the development
of license requirements.
Project construction and operation has the potential to affect fish populations in a number of ways.
Reduced flows in the bypass reach will decrease the amount of habitat. If flows in the bypass reach
are too low, fish migration will be seriously impeded or even blocked. Tailrace flows can be a source
of attraction for fish migrating up-river and may reduce migration success (particularly for adult
salmon). The concrete barrier and intake structure above the falls are both potential sources of
mortality for all fish species. Alteration of water velocity within the bypass reach may affect fish
habitat and fish behavior in the falls.
The proposed studies of fish seasonal abundance and distribution will be necessary to develop
protection, mitigation, and enhancement (PME) measures in terms of required flows in the bypass
reach, design and operation of the intake structure and concrete diversion structure, and tailrace design.
§5.8(b)(6) — Explain how any proposed study methodology (including any preferred data collection
and analysis techniques, or objectively quantified information, and a schedule including
appropriate field seasons(s) and the duration) is consistent with generally accepted practice in the
scientific community or, as appropriate, considers relevant tribal values and knowledge.
Some combination of fish capture techniques will likely be needed to meet the objectives (e.g. a
counting tower for adult salmon, incline plan traps for juvenile salmon, radio tags, electrofishing, etc.).
We will work with the applicant to design studies that will provide information needed to inform our
decision-making process.
§5.9(b)(7) — Describe considerations of level of effort and cost, as applicable, and why any
proposed alternative studies would not be sufficient to meet the stated information needs.
Level of effort and cost will be considered as the studies are designed. There are no proposed
alternatives.
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
Comments and Study Requests
5
STUDY REQUEST #2: Two-Dimensional Hydrodynamic (Bathymetric) Modeling of Nuyakuk Falls
§5.9(b)(1) — Describe the goals and objectives of each study proposal and the information to be
obtained.
Goal:
The goal of this study is to provide two-dimensional hydrodynamic results for evaluation of the
proposed project structures and operational flow scenarios on upstream and downstream fish passage
and use of the falls by resident species.
Objectives:
1. Collect detailed survey data of sufficient coverage and resolution over the entire Nuyakuk Falls
area for use in a two-dimensional hydrodynamic model.
2. Select appropriate hydrodynamic modeling software for study conditions to achieve model
stability and accurate representation of the computational domain and hydraulic conditions.
3. Select appropriate range of flows for model calibration.
4. Calibrate the model and run simulations for evaluation of alternative project designs and
operation scenarios for upstream and downstream fish passage and use of the falls by resident
fish species.
§5.9(b)(2) — If applicable, explain the relevant resource management goals of the agencies or
Indian tribes with jurisdiction over the resource to be studied.
The Fish and Game Act requires ADF&G to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the interest of
the economy and general well-being of the state” (AS 16.05.020).
ADF&G – Division of Sport Fish Mission is “to protect and improve the state’s recreational and
fisheries resources”. According to the 2015-2020 Division of Sport Fish Strategic Plan, the
management priority is to manage Alaska’s recreational fisheries for sustained yield and recreational
angler satisfaction that is centered on an area-based management system. The division’s fish habitat
program is directed at protecting and restoring fish habitats for the benefit of fish and current and
future recreational anglers.
§5.9(b)(3) — If the requester is not a resource agency, explain any relevant public interest
considerations in regard to the proposed study.
Not applicable, requestor is a resource agency.
§5.9(b)(4) — Describe existing information concerning the subject of the study proposal, and the
need for additional information.
To our knowledge, there is no detailed information on river depths and velocities throughout the falls
reach. A two-dimensional hydrodynamic model of the falls reach is needed to provide the level of
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
Comments and Study Requests
6
detail necessary to fully inform stakeholders of the effects of project construction and operation on
fish passage and habitat use.
§5.9(b)(5) — Explain any nexus between project operations and effects (direct, indirect, and/or
cumulative) on the resource to be studied, and how the study results would inform the development
of license requirements.
Project operation will lower the amount of water flowing down the falls because a certain quantity of
water will be diverted through the penstock. If low flows though the falls prevent migration during
critical time periods (for example, during the adult salmon spawning migration), fish populations will
be seriously impacted. An accurate two-dimensional hydrodynamic model is needed to simulate the
complex hydraulic features of the Nuyakuk Falls. Model results will allow simulation of alternative
project designs under varying operational scenarios to evaluate fish passage and fish habitat use at
different times of the year and to develop PME measures. We expect flows down the falls to be an
important issue for evaluation during the licensing process.
§5.8(b)(6) — Explain how any proposed study methodology (including any preferred data collection
and analysis techniques, or objectively quantified information, and a schedule including
appropriate field seasons(s) and the duration) is consistent with generally accepted practice in the
scientific community or, as appropriate, considers relevant tribal values and knowledge.
Two-dimensional hydrodynamic models require spatially explicit bathymetry. A combination of state -
of-the-art surveying techniques will be needed to acquire sufficient coverage and resolution needed
for modeling purposes (of LiDAR, total station survey, etc.) In-river surveys of the falls should be
completed when flows are at their annual minimum (between March 15 and April 15). This time period
is assumed to also coincide with lowest biological activity in the falls. As fish migrate upstream
through the falls, they must navigate a series of ledges and obstacles; this migration requires specific
hydraulic conditions in terms of velocity and depth. Ideally, an extensive survey of the falls to measure
water velocity, water depth and height of each ledge would be carried out when flows in the river
approach their lowest levels; however, we recognize the difficulties and safety issues of conducting
field work during winter conditions and will work with the applicant to develop field work tasks and
schedules with safety concerns fully considered.
§5.9(b)(7) — Describe considerations of level of effort and cost, as applicable, and why any
proposed alternative studies would not be sufficient to meet the stated information needs.
ADF&G will work with the applicant to develop a plan to survey the falls reach and develop a
bathymetric map that meets stakeholders needs. The level of effort and cost will be determined by the
methodology that is ultimately used but is expected to be comparable to that of similar FERC projects
of this size. There are no proposed alternative studies.
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
Comments and Study Requests
7
STUDY REQUEST #3: Nuyakuk Falls Fish Passage Evaluation and Modeling
§5.9(b)(1) — Describe the goals and objectives of each study proposal and the information to be
obtained.
Goal:
The goals of this study are to determine what flow levels through Nuyakuk Falls are necessary to
maintain fish passage (upstream and downstream).
Objectives:
1.Identify key locations in the falls that may restrict upstream fish passage at low water flows.
2.Identify flow levels at which fish will be unable to migrate upstream past the falls.
3.Assess downstream smolt migration and identify potential impingement, obstruction or delay
issues that may occur with project instream structures and/or operations.
4.Identify flow levels at which upstream adult salmon migration will be so constrained as to
increase mortality.
§5.9(b)(2) — If applicable, explain the relevant resource management goals of the agencies or
Indian tribes with jurisdiction over the resource to be studied.
The Fish and Game Act requires ADF&G to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the interest of
the economy and general well-being of the state” (AS 16.05.020).
ADF&G – Division of Sport Fish Mission is “to protect and improve the state’s recreational and
fisheries resources”. According to the 2015-2020 Division of Sport Fish Strategic Plan, the
management priority is to manage Alaska’s recreational fisheries for sustained yield and recreational
angler satisfaction that is centered on an area-based management system. The division’s fish habitat
program is directed at protecting and restoring fish habitats for the benefit of fish and current and
future recreational anglers.
§5.9(b)(3) — If the requester is not a resource agency, explain any relevant public interest
considerations in regard to the proposed study.
Not applicable, requestor is a resource agency.
§5.9(b)(4) — Describe existing information concerning the subject of the study proposal, and the
need for additional information.
To meet the objectives of this study, hydrodynamic modeling results from Study Request #2 will need
to be combined with fish swimming and jumping criteria. Information needs include: 1) identification
of target fish species and their swimming and jumping criteria, 2) identification of the key locations
that may limit fish upstream and downstream passage over the range of operation scenarios, 3)
assessment of downstream smolt migration and potential impingement, obstruction, and delay issues
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
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due to project structures and operations, and 4) assessment of factors that may affect adult salmon
passage over a range of operational flows.
§5.9(b)(5) — Explain any nexus between project operations and effects (direct, indirect, and/or
cumulative) on the resource to be studied, and how the study results would inform the development
of license requirements.
Project operation will lower the amount of water flowing down the falls because a certain quantity of
water will be diverted through the penstock. If low flows though the falls prevent migration during
critical time periods (for example, during the adult salmon spawning migration), fish populations could
be seriously impacted. A thorough evaluation of fish passage (upstream and downstream) at alternative
operation scenarios over the period of fish activity is needed to develop PME measures. We expect
flows down the falls to be an important issue for evaluation during the licensing process.
§5.8(b)(6) — Explain how any proposed study methodology (including any preferred data collection
and analysis techniques, or objectively quantified information, and a schedule including
appropriate field seasons(s) and the duration) is consistent with generally accepted practice in the
scientific community or, as appropriate, considers relevant tribal values and knowledge.
Some combination of a hydrodynamic model, a hydrologic time series, and on-site surveys will be
necessary to meet the objectives. We will work with the applicant to design studies that will provide
the necessary data to inform our decision-making process.
§5.9(b)(7) — Describe considerations of level of effort and cost, as applicable, and why any
proposed alternative studies would not be sufficient to meet the stated information needs.
Level of effort, schedules and cost will be considered as details of the studies are designed. There are
no proposed alternative studies.
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
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STUDY REQUEST #4: Fish Entrainment and Impingement Study
§5.9(b)(1) — Describe the goals and objectives of each study proposal and the information to be
obtained.
Goal:
The goals of this study are to conduct a desktop study to estimate fish injury and mortality due to
entrainment and impingement, and to investigate alternatives to reduce these impacts.
Objectives:
1. Conduct a literature review of fish impacts with Kaplan-style reaction turbines as proposed for
the project. The focus of the review should be on sockeye salmon smolt, but the other four
salmon species and juvenile resident species should also be considered.
2. Conduct a literature review of different methods of preventing fish impingement and
entrainment, with an emphasis on sockeye salmon smolt.
3. Conduct a literature review and modeling analysis of different designs for the proposed
concrete groin diversion structure, with an emphasis on effective upstream and downstream
passage of fish at all flow levels.
§5.9(b)(2) — If applicable, explain the relevant resource management goals of the agencies or
Indian tribes with jurisdiction over the resource to be studied.
The Fish and Game Act requires ADF&G to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the interest of
the economy and general well-being of the state” (AS 16.05.020).
ADF&G – Division of Sport Fish Mission is “to protect and improve the state’s recreational and
fisheries resources”. According to the 2015-2020 Division of Sport Fish Strategic Plan, the
management priority is to manage Alaska’s recreational fisheries for sustained yield and recreational
angler satisfaction that is centered on an area-based management system. The division’s fish habitat
program is directed at protecting and restoring fish habitats for the benefit of fish and current and
future recreational anglers.
§5.9(b)(3) — If the requester is not a resource agency, explain any relevant public interest
considerations in regard to the proposed study.
Not applicable, requestor is a resource agency.
§5.9(b)(4) — Describe existing information concerning the subject of the study proposal, and the
need for additional information.
This is envisioned as a desk-top study to gather the existing and relevant information on the
mechanisms of fish entrainment and entrainment mortality. Sockeye salmon smolt are emphasized
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
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because of the large annual out-migration, on the order of millions of smolts per year. Impingement
and entrainment of other species are concerns as well.
§5.9(b)(5) — Explain any nexus between project operations and effects (direct, indirect, and/or
cumulative) on the resource to be studied, and how the study results would inform the development
of license requirements.
Project construction and operation have a high potential to cause fish impingement and entrainment
and resulting injury or mortality. The concrete groin diversion structure, as proposed, may increase
fish mortality by forcing a large percentage of out-migrating fish down the penstock and through the
turbines. Understanding the mechanisms of fish impingement and entrainment and evaluation of
alternative project designs will provide essential information on design capabilities and risks needed
to develop appropriate PME measures. Evaluations of the design specifications for the inlet and groin
diversion structure will be critical issues of the license process.
§5.8(b)(6) — Explain how any proposed study methodology (including any preferred data collection
and analysis techniques, or objectively quantified information, and a schedule including
appropriate field seasons(s) and the duration) is consistent with generally accepted practice in the
scientific community or, as appropriate, considers relevant tribal values and knowledge.
A thorough literature review is generally a key part of any scientific study.
§5.9(b)(7) — Describe considerations of level of effort and cost, as applicable, and why any
proposed alternative studies would not be sufficient to meet the stated information needs.
Level of effort and cost will be considered as the studies are designed. There are no proposed
alternative studies.
Nuyakuk River Hydroelectric Project FERC No. P-14873 February 4, 2020
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STUDY REQUEST #5: Subsistence Survey
§5.9(b)(1) — Describe the goals and objectives of each study proposal and the information to be
obtained.
Goal:
The goal of this study is to document traditional and contemporary subsistence harvest and use in the
project area in order to provide a basis for impact assessment, avoidance, minimization, and
development of PME measures and to provide the information that will serve as the basis for
compliance with FERC’s National Environmental Policy Act (NEPA) analysis for the project license.
Objectives:
1.Conduct a subsistence harvest survey for the community of Koliganek.
2.Conduct a subsistence harvest survey for the community of New Stuyahok.
§5.9(b)(2) — If applicable, explain the relevant resource management goals of the agencies or
Indian tribes with jurisdiction over the resource to be studied.
The Fish and Game Act requires ADF&G to, among other responsibilities, “…manage, protect,
maintain, improve, and extend the fish, game and aquatic plant resources of the state in the interest of
the economy and general well-being of the state” (AS 16.05.020).
ADF&G – Division of Subsistence Mission is “to scientifically gather, quantify, evaluate, and report
about customary and traditional uses of Alaska’s fish and wildlife resources”. One of the core services
of the division is to assist fisheries and wildlife managers in preparing management plans to ensure
information on customary and traditional uses and fish and wildlife harvests is incorporated.
§5.9(b)(3) — If the requester is not a resource agency, explain any relevant public interest
considerations in regard to the proposed study.
Not applicable, requestor is a resource agency.
§5.9(b)(4) — Describe existing information concerning the subject of the study proposal, and the
need for additional information.
Subsistence surveys were carried out in the vicinity of the project in 2005.1 That data is now fifteen
years old and should be updated to more accurately reflect contemporary subsistence harvest and use
patterns. In particular, subsistence harvest surveys for the communities of Koliganek and New
Stuyahok would provide the necessary information to determine potential effects of the proposed
project.
1 See T.M. Krieg, D.L. Holen, and D. Koster. 2009. Subsistence harvests and uses of wild resources in Igiugig,
Kokhanok, Koliganek, Levelock, and New Stuyahok, Alaska, 2005. Alaska Department of Fish and Game, Division of
Subsistence. Technical Paper No. 322, Dillingham.
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§5.9(b)(5) — Explain any nexus between project operations and effects (direct, indirect, and/or
cumulative) on the resource to be studied, and how the study results would inform the development
of license requirements.
Residents of Koliganek and New Stuyahok use the project area for subsistence hunting, fishing and
gathering. Project construction and operation could lead to impacts on subsistence use of the project
area. The proposed study will assess the timing and location of subsistence use and would be necessary
to develop PME measures with regard to the timing of activities, particularly during project
construction.
§5.8(b)(6) — Explain how any proposed study methodology (including any preferred data collection
and analysis techniques, or objectively quantified information, and a schedule including
appropriate field seasons(s) and the duration) is consistent with generally accepted practice in the
scientific community or, as appropriate, considers relevant tribal values and knowledge.
Community subsistence surveys have been performed throughout the state of Alaska for many years;
they are both well-accepted and cost-effective means of understanding subsistence use of fish and
game resources.
ADF&G Division of Subsistence will conduct this study using standard Division methodology
involving systematic household surveys conducted by community-based survey technicians in
cooperation with Division subsistence resource specialists. Specific methods include:
• Development of a survey instrument to produce updated comprehensive baseline information
about subsistence hunting, fishing, and gathering and other topics that address subsistence
needs and are compatible with information collected in past household interviews.
• Community consultation to identify community liaisons and seek study support.
• Household surveys to record the following information: 1) demographic information; 2)
involvement in use, harvest, and sharing of fish, wildlife, and wild plants in their study year;
3) estimate of amount of resources harvested in their study year; 4) information about
employment and cash income; 5) assessments of changes in subsistence harvest and use
patterns based on data available from past study years; and 6) location of fishing, hunting, and
gathering activities in their study year.
§5.9(b)(7) — Describe considerations of level of effort and cost, as applicable, and why any
proposed alternative studies would not be sufficient to meet the stated information needs.
Level of effort and cost will be considered as the studies are designed. There are no proposed
alternative studies.
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, DC 20426
January 23, 2020
OFFICE OF ENERGY PROJECTS
Project No. 14873-001- Alaska
Nuyakuk River Hydroelectric Project
Nushagak Electric & Telephone
Cooperative, Inc.
VIA FERC Service
Bobby Armstrong
Nushagak Electric & Telephone Cooperative, Inc.
PO Box 350
Dillingham, AK 99576
Reference: Study Requests
Dear Mr. Armstrong:
After reviewing the Pre-Application Document (PAD) for the Nuyakuk River
Hydroelectric Project, staff have determined that a noise study is likely needed. The
study request is discussed in the enclosed Schedule A.
Please include in your proposed study plan a master schedule that includes the
estimated start and completion date of all field studies, when progress reports will be
filed, who will receive the reports and in what format, and the filing date of the initial
study report. All studies, including field work should be initiated and completed during
the first study season, and the study reports should be filed as a complete package to
avoid piecemeal review. Finally, if you are likely to propose any plans for measures to
mitigate project impacts, drafts of those plans should be filed with the initial study report.
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If you have any questions, please contact Julia Kolberg at (202) 502-8261, or via
e-mail at Julia.Kolberg@ferc.gov.
Sincerely,
David Turner, Chief
Northwest Branch
Division of Hydropower Licensing
Enclosure: Schedule A
Schedule A
Project No. 14873-001
STUDY REQUESTS
After reviewing the information in the PAD, we have identified a gap between the
information in the PAD and the information needed to assess project effects. As required
in section 5.9 of the Commission’s regulations we have addressed the seven study request
criteria for each of the study requests that follow.
Noise Study
Criterion (1) – Describe the goals and objectives of each study proposal and the
information to be obtained.
The goal of this study is to characterize the existing ambient sound environment in
the vicinity of the proposed project and estimate the potential impacts associated with
construction and operational activities. The specific objectives of the study and
subsequent report are to:
(1) Define existing noise levels in identified sensitive wildlife habitat, recreation and
cultural areas within the Wood-Tikchik State Park including trails, the Royal
Coachman Lodge, fishing and hunting areas, and areas used for subsistence and
other traditional cultural practices.
(2) Describe, through the use of sound models, the expected noise levels in the
identified sensitive areas during project construction and operation.
(3) Develop measures to avoid or lessen sound impacts during project construction
and operation.
Criterion (2) – If applicable, explain the relevant resource management goals of the
agencies or Indian tribes with jurisdiction over the resource to be studied.
Not applicable.
Criterion (3) – if the requester is not a resource agency, explain any relevant public
interest considerations in regard to the proposed study.
Section 4(e) and 10(a) of the Federal Power Act require that the Commission give
equal consideration to all uses of the waterway on which a project is located. When
reviewing a proposed action, the Commission must consider the environmental,
recreational, fish and wildlife, and other non-developmental values of the project, as well
as power generation and other developmental values.
Project-generated noise during construction or operation, if not properly
controlled, could have a negative effect on wildlife and the public in the surrounding
area; therefore, it is important to understand the existing ambient noise levels in the
project vicinity and possible noise effects from project-related activities. Ensuring that
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potential measures associated with minimizing noise impacts are analyzed is relevant to
the Commission’s public interest determination.
Criterion (4) – Describe existing information concerning the subject of the study
proposal, and the need for additional information.
During scoping, the Alaska DNR, Division of Parks and Outdoor Recreation and
the owner of the Royal Coachman Lodge (a fishing outfitter located about 3 miles
upstream of the project site) raised concerns about project-generated noise during
construction and operation disrupting wildlife and visitor uses within Wood-Tikchik State
Park and at the lodge. No information is included in the PAD regarding ambient noise
levels from which to gauge potential adverse effects of project-generated noise on
existing uses.
Criterion (5) - Explain any nexus between project operations and effects (direct,
indirect, and/or cumulative) on the resource to be studied, and how the study results
would inform the development of license requirements.
Construction is planned to take place over a 2-year period and would include the
use of noise-generating equipment to carry out activities such as drilling, boring, blasting,
and compaction. In addition, you propose to construct an airstrip that would fly in
equipment, materials, and personnel during construction and continue to be used for
project maintenance. Each of these sources of noise has the potential to disrupt wildlife
and their uses of adjoining habitats or degrade visitor recreation and cultural experiences
and practices. An understanding of ambient noise levels and projected noise generation
is needed to assess how project-generated noise may affect these uses and to identify
potential mitigation measures.
Criterion (6) – Explain how any proposed study methodology (including any preferred
data collection and analysis techniques, or objectively quantified information, and a
schedule including appropriate field season(s) and the duration is consistent with
generally accepted practice in the scientific community or, as appropriate, considers
relevant tribal values and knowledge.
A systematic sound study should be conducted to characterize the existing ambient
sound environment in the vicinity of the proposed project and estimate the potential noise
effects from construction, operation, and maintenance of the proposed. The study should
include the following steps:
(1) Review the most current project description, operating and construction
equipment rosters, construction schedules, and construction methods to identify
the types of excavation or blasting expected to occur and where project noise is
likely to be heard by the public;
(2) Identify the type and expected frequency of maintenance activities that would
generate noise in the project vicinity (e.g., helicopter or airplane use);
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(3) Identify sensitive noise receptor areas (i.e., wildlife habitat, recreation and cultural
areas) where sound data needs to be collected;
(4) Collect ambient sound level measurements at the identified noise receptor sites
and document observations of perceived and identifiable sources of sound
contributing to ambient sound levels at these sites;
(5) Use an acoustic model to predict sound levels during project construction,
operation, and maintenance at the noise receptor sites, estimated in A-weighted
decibels (dBA), and indicate the duration of these sound levels;
(6) Superimpose predicted sound level isopleths or “sound contours” on aerial
photographs or maps of the project area and include specific sound level
predictions at the selected measurement locations; and
(7) Develop measures to avoid or lessen project-generated sound effects.
The study should be developed in consultation with the Alaska Department of Natural
Resources, Division of Parks and Outdoor Recreation; Alaska Department of Fish and
Game; local outfitters; and Native Alaskan tribes that use the project area for subsistence
or other traditional cultural practices. The initial Study Report should include study
results, data analysis, a description of field investigation activities and methods, and
documentation of consultation with the above-named stakeholders.
These methods are consistent with sound analyses used by applicants and licensees
and relied upon by Commission staff in other hydroelectric licensing proceedings.
Criterion (7) – Describe considerations of level of effort and cost, as applicable,
and why any proposed alternative studies would not be sufficient to meet the stated
information needs.
The anticipated cost for the noise study is estimated to be about $45,000.
February 4, 2020
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
RE: Comments on the Pre-Application Document and Study Requests for the Nuyakuk River
Hydroelectric Project (P-14873)
Dear Secretary Bose:
On November 8, 2019, Federal Energy Regulatory Commission issued a Notice of Intent to file a
license application and filing of the Pre-Application Document (PAD) for the above referenced
proposed project. The PAD contains information about the Nuyakuk Project and the
environmental resources potentially affected by the project. We are providing the attached
comments on the PAD and Scoping Document, and submitting study requests as part of the
Integrated Licensing Process.
The stated purpose of the proposed Nuyakuk Hydroelectric Project is to support fish processing
and packaging efforts in the local villages, as well as to reduce the reliance on diesel-powered
generation. The project would transition six communities from diesel generation to hydroelectric
generation. This will drastically reduce the cost of power for each household and provide
generation to power salmon processing and other industries. This energy cost savings will
support employment in towns with high unemployment. With the affected communities paying
as much as $8 per gallon for diesel, this project has the potential to offset more than $1 million
dollars annually.
This project purpose is consistent with our agency mission to support resilient ecosystems,
communities and economies. We support the development of safe, climate resilient, renewable
energy that includes hydropower generation. However, hydropower development can
compromise the habitat and sustainability of migratory fish such as salmon; fish upon which the
local communities rely. In waterways such as the Nuyakuk River, which support a significant
portion of Bristol Bay sockeye salmon and four other salmon species, the impacts of energy
development can directly affect fish and habitat. Protection of migratory fish and their habitat
warrant equal consideration to energy generation throughout the licensing proceedings. This
project is consistent with Strategic Conservation Action Plan for Southwest Alaska Watershed
which was accepted as a comprehensive plan. Therefore, measures to protect fish and their
habitat should be considered integral components of the Nuyakuk River Hydroelectric Project
design. Close coordination with us and other state and federal resource agencies will facilitate
the review and design process. Specifically, the future flows study request is integral to several
2
studies and informing the design and operation of the proposed project. NOAA Fisheries and its
NOAA climate science partners are available and willing to discuss the details of the climate and
flow studies to ensure its value for all parties.
Please contact Sean Eagan sean.eagan@noaa.gov or by phone at 907-586-7345 if you have any
questions.
Sincerely,
Robert D. Mecum
Deputy Regional Administrator
Alaska Region
Attachment 1: National Marine Fisheries Service’s Comments on Nushagak Cooperative’s Pre-
Application Document and Scoping Documents for the Proposed Nuyakuk Hydroelectric Project
(P-14873)
Attachment 2: National Marine Fisheries Service's Study Requests for the Nuyakuk Project
(FERC No. P-14873)
3
Attachment 1:
National Marine Fisheries Service’s Comments on Nushagak Cooperative’s Pre-
Application Document and Scoping Documents for the Proposed Nuyakuk Hydroelectric
Project (P-14873)
January 3, 2020
1.Project Description
The proposed Nuyakuk Hydroelectric Project will be located on the Nuyakuk River at a cascade
approximately five river miles downstream from the Tikchik Lake outlet. The Tikchik Lake
drains the northern Wood River Mountains, a 1,544 square mile watershed. Alaska Statutes (AS
§ 41.21.167(e)) allows this project to be constructed within Wood-Tikchik State Park boundary.
The Project would divert water out of the river above Nuyakuk Falls, pass it through a tunnel(s)
to a powerhouse located at the base of Nuyakuk Falls. The water will be returned to the river via
the tailrace at the base of Nuyakuk Falls. Nuyakuk Falls is a ½-mile long cascade with 26 feet of
elevation change. From the Project site, the Nuyakuk River runs approximately 40 miles before
converging with the Nushagak River, which continues to Bristol Bay. As outlined in the
November 14, 2019 Additional Information Request (AIR) response, the proposed powerhouse
would contain two Kaplan-style reaction turbine generating units. The rated capacity on each
unit would be approximately 5 MW, for a total of 10 MW. The combined maximum design flow
is approximately 7,550 cfs. The PAD states a minimum f low of 1,000 cfs will be left in the river
for other in-river uses, however AS § 41.21.167(e) states the project must maintain at least 70%
of the daily upstream water flow of an affected river along the natural course of the river. This
maximum designed flow represents the 75% exceedance flow rate for the months of June, July
and August. The PAD states the proposed project will be located at Nuyakuk Falls, however, it is
technically a half mile-long cascade. Nuyakuk Falls and Nuyakuk cascade refer to the same river
reach in this document.
2.Federal Statutory Requirements
Our statutory responsibilities in this matter are codified under our authorities pursuant to the Fish
and Wildlife Coordination Act (16 U.S.C. § 661 et seq.), which requires that the federal action
agency consult and give considerable weight to the comments of federal and state resource
agencies; the Magnuson -Stevens Fishery Conservation and Management Act (16 USC §
1855(b)) and its implementing regulations (50 CFR § 600.920), which requires consultation
between the federal action agency and the National Marine Fisheries Service for projects that
affect essential fish habitat; and the Federal Power Act (16 U.S.C. §§803 and 811), for the
protection of anadromous fish resources and their habitat affected by the licensing, operation and
maintenance of hydroelectric projects.
3.NOAA Trust Resources
NOAA’s National Marine Fisheries Service is a trustee for coastal and living marine resources,
including commercial and recreational fisheries; diadromous species; marine mammals, and
marine, estuarine, and coastal habitat systems. Our work is guided by two core mandates: ensure
the productivity and sustainability of fisheries and fishing communities, and recover and
conserve protected resources through reliance on the best available science. Coastal riverine
4
habitat systems, including rivers such as the Nuyakuk, provide an integral component of
ecological functions for the larger marine environment. Species such as Sockeye salmon
(Oncorhynchus nerka), Chinook salmon (O. tshawytscha), Coho salmon (O. kisutch), Chum
salmon (O. keta), pink salmon (O. gorbuscha) rely on the Nuyakuk River for refuge, spawning,
rearing and nursery habitat.
4.Contact List
Please remove Susan Walker, Kate Savage, and Thomas Meyer from your contact list. We will
file a separate notice to the Commission to update the Mailing List. Communication with our
agency should continue through the following contacts:
Regional Administrator
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
Alaska Region
PO Box 21668
Juneau, AK 99802
Sean Eagan
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
Alaska Region
PO Box 21668
Juneau, AK 99802
907-586-7345
Sean.Eagan@noaa.gov
5.Comments on the Pre-Application Document
We offer the following comments based on our review of the PAD submitted by Nushagak
Cooperative, Inc. for the proposed Nuyakuk Hydroelectric Project.
PAD Section 3.3 Project Facilities
The second paragraph of this section, page 23, indicates that the “combined maximum designed
flow is the 75% exceedance flow rate for the months of June, July and August, less 1,000 cfs for
instream uses.” Appendix B has the monthly flow duration curves showing the 75% exceedance
to be ~12,000, 10,000, and 7,500 cfs, respectively, for the months of June through August.
This volume of water removed is not consistent with Alaska Statute (AS § 41.21.167(e)), which
states “(2) maintains at least 70 percent of the daily upstream water flow of an affected river
along the natural course of the river”. If 70% is left in the river even in June on many days only
3,600 cfs will be run through the turbines which are being designed with 7,550 cfs of capacity.
PAD Section 3.3.2 Nuyakuk Falls Diversion & Intake
The applicant proposed to complete two-dimensional river hydraulic modeling for approximately
1,000 linear feet above the falls to aid in development of the intake diversion hydraulic and
structural design. Our Study Request 3, objective (e), supports the need for three dimensional
5
computational fluid dynamics (CFD) modelling to evaluate flows vectors under a range of river
and operation conditions.
This section describes the need for an inclined bar-screen at the intakes to divert debris and ice.
The openings between the bars are proposed as 1 to 3 inches. These racks would be oriented
parallel to the flow to increase sweeping velocities to promote debris and ice removal. Further,
the Additional Information Request response submitted by the applicant (November 14, 2019)
provides a conceptual design of the proposed facility. We note the concrete groin has the
potential to span half the river’s width or more.
Adult salmon migrating to the upstream lake habitat for spawning, and juvenile salmon
emigrating to the ocean need to safely pass the project intakes. Diverting the first 7,550 cfs above
a minimum 1,000 cfs bypass flow, as proposed, would have significant consequences for
migratory fish, including salmon. Maintaining 70% of the natural flow in the river would
significantly reduce effects on salmon. The Project should be designed and operated to avoid
impingement and entrainment of these migrating fish. This may require smaller rack spacing and
larger screen surface area to manage intake flows and sweeping velocities. It may also require a
screen orientation at a specific angle to the river flow to encourage movement along the screen
face. These same considerations apply to ice management. Frazil ice, and to a lesser extent
breakup and anchor ice, has the potential to damage the bar rack and reduce intake flow, and
affect the overall operation of the Project. Damaged racks or impaired project operations could
influence the ability to safely move fish past the project structure. Features designed to prevent
ice damage are important to ensure proper project operations. Our Study Request 3, objective (e),
for a 3-D modeling above the falls informed by the 2-D model throughout the project affected
area will inform the intake screen design and help to meet this goal of protecting migrating
salmon.
PAD Section 3.3.3 Conveyance Tunnels
The November 14th AIR response depicts twin 16 foot tunnels leading to the powerhouse. This
would seem more practical than the larger single tunnel presented in the PAD.
PAD Section 3.3.5 Powerhouse
The PAD indicates three vertical shaft Kaplan-type turbines are proposed for the project. The
November 14th AIR response states two turbine units each rated at a capacity of 5,000KW. We
request analysis of this turbine type on outmigrating smolt at 26-feet of head versus other turbine
models. January through March flows averaged approximately ⅕ of summer flows in the last
seven years. Climate change could further alter this proportion (see Future Flows, Study Request
5). We recommend investigating whether turbines of different sizes might be the most efficient
way to optimize winter power production.
PAD Section 3.3.6 Tailrace
The proposed tailrace outlet design is intended to reduce velocities relative to the natural river
velocities in the discharge zone. This design feature will help prevent the false attraction of
anadromous fish to the tailrace. This section include the potential for evaluation of other
measures to meet this goal, such as a vertical picket barriers or other such fish barrier type.
6
We support the inclusion of design features and operations to prevent the false attraction of
migrating anadromous fish at the tailrace. Migrating fish need to reach their spawning habitat
safely and in a timely manner. The proposed actions will support this goal.
PAD Section 3.3.7 Switchyard / Transmission lines
A straight transmission line from Nuyakuk Falls directly to Koliganek and then a second line
directly to Stuyahok would appear to minimize the miles of new line that need to be constructed
and the environmental disturbance. We assume that there are terrane or land ownership
consideration that went into the displayed longer route (AIR Fig 3-3).
PAD Section 3.3.8 Proposed Construction and Development Schedule
Many aspects of the mobilization and construction have the potential to affect anadromous
species migration and spawning activity. We recommend consideration of erosion and sediment
control, timing of in-water activity, hazardous materials control, and invasive species
management for each step of the construction and development planning and implementation.
PAD Figure 3-10, Mean Daily Discharge
We note the use of the full data range from 1953 to present to create the flow duration curve for
summer months. It appears USGS gage #1530200 was not operated most years from November
through early April from 1953 to 2013. We recommend the appliance describe how the flow
duration curve was developed for the winter months.
Climate change is impacting hydrologic patterns across the nation. Bristol Bay watershed has
already seen an increase of 3.7 °F in air temperature and an increase of 13 % in annual
precipitation from 1969 to 2018 (Thoman 2019). Further, increasing precipitation is projected in
the project area within even the early period of the license.(Leppi 2014; Wobus 2015). The
greatest increases are expected in winter and summer months (USGCRP 2018), and in this
watershed, increasing temperatures are projected to lead to multiple freshets, or pulses of flow,
during the winter (Wobus 2015). A flow duration curve based on a more precise data set that
reflects current conditions and trends would better inform the development of the project, project
operations, and mitigation measures. We recommend in our Change Analysis (Study Request 4)
to evaluate the flow data for more recent trends in the data from the Nuyakuk USGS gage. The
results may influence the project proposal, project capacity and production, and mitigation
measures.
PAD Section 4.1.2 Climate
Planning for new hydro projects has in the past relied on the assumption that future air
temperature and precipitation patterns would be the same as those in the past. Given the
increasing certainty of global climate change, this assumption is no longer valid given the current
level of scientific certainty of climate change (Milly 2008; Viers and Rheinheimer 2011).
Further, long range planning for hydroelectric project operations depends on large-scale, long-
term climate predictions. However, for the multi-decadal period of the license, it is important to
assess how these variables will change due to trends and natural variability, but also due to
climate change. With needs to predict both quantity and timing of precipitation and temperature
in an uncertain future, planning for new projects should analyze long-term (multi-decadal)
7
climate and hydrology datasets and assess downscaled climate projections. Such an analysis has
become generally accepted practice in the hydropower industry worldwide.
From an environmental standpoint, failing to consider climate change trends for southwest
Alaska can result in not capitalizing on the opportunities for both hydropower planning and fish,
given the projections of increasing precipitation, and in design of fish passage and operating
conditions that are unrealistic for the range of future flows. This is in line with recent literature
that highlights opportunities to design and operate hydropower projects for sustainability of both
power production and the riverine environment (Brown et al. 2015; Poff et al. 2016). These
flows relate to diverse resources as recreation, aesthetics, subsistence, and tourism, among
others. From an economic standpoint, not accounting for climate change can result in less
reliable electrical generation, more diesel fuel consumption, higher energy costs, and other
negative factors.
We recommend the applicant evaluate how anticipated changes in temperature and precipitation
may be expected to impact project operations and operational efficiency of the proposed
hydropower project. A basis for this assessment can be derived from state specific information
generated by the U.S. Global Change Research Program (Chapin 2014; USGCRP 2018) and
publications based on global climate models used in that report.
PAD Section 4.4.3 Federal and State Designated Habitat
The Nuyakuk River, including Nuyakuk Falls, is designated Essential Fish Habitat for five
species of salmon (NPFMC 2018). The Little King Salmon River enters the Nuyakuk just below
the Tikchik Lake outlet and adds to the affected area. The Little King Salmon River supports
Chinook and coho salmon (ADFG 1994). A second unnamed stream enters the Nuyakuk from
the south about one mile above the fall and also supports coho salmon. It is not clear that the
watersheds of either of these two streams is included in the applicant’s 1,544 square mile
watershed assessment.
PAD Section 4.4.4.1 Fish Passage Barriers
We agree that determining at what flows the falls are and are not a barrier for each species needs
further assessment (Upstream Fish Passage, Study 2).
PAD Section 4.4.4.2 Sediment, Ice and Geomorphology
We agree with most aspects of this assessment, however, the statement “the area immediately
above and below Nuyakuk Falls consistently remains ice free” needs verification. It is not clear
whether the ice free zone above the falls extend to the intake facility all winter . It should be
clarified whether frazil ice will form as the river water emerges from under the iced over section.
If so, that frazil ice may adhere to the intake structure. See our Ice Processes Assessment, Study
6.
PAD Section 4.4.5 Instream Flows
The short bypass reach is not “almost wholly falls” as the gradient averages only 1% and could
contain some areas with habitat value. Our Study Request 1,Fish Distribution, objective (d),
addresses this need to understand what fish habitat and processes happen in the Nuyakuk
cascade.
8
PAD Section 4.4.6 Potential Adverse Effects
Table 4-9 identifies the potential adverse impacts related to fish and aquatic resources. We note
that in-water work has the potential to result in long-term and permanent impacts on spawning
and rearing habitat, as well as the short term impacts identified. The scope and scale of impacts
depends on the in-water activity.
We concur that bypass of a portion of the river flow around the Nuyakuk Falls during operations
may impede fish movement during their migration. Evaluating this potential impact on migrating
salmon is a priority for our agency, and is considered in our Upstream Fish Passage, Study 2.
PAD Section 5.0 Preliminary Issues and Study List
We support the development of environmentally sound, renewable energy that helps
communities reduce their reliance on diesel. As indicated in this section of the PAD, a number of
data gaps that require evaluation to assess baseline conditions and potential project related
impacts. Data from these studies will support the development of protection, mitigation and
enhancement measures that address identified project related impacts. Attachment 2 of this
document provides our detailed study requests per 18 CFR § 5.9(b).
PAD Section 5.3 Relevant Comprehensive Plans
We recommend inclusion as a comprehensive plan the Strategic Conservation Action Plan for
Southwest Alaska Watershed. This action plan was developed by the Southwest Alaska Salmon
Habitat Partnership and updated in 2017. We filed this document with the Commission as a
comprehensive plan on November 21, 2019 (accession # 20191121-5157). We also recommend
Nushagak River Watershed Traditional Use Area Conservation Plan by the Nushagak-
Mulchatna Watershed Council, which we plan to file on the record.
6.Comments on FERC’s Scoping Document 1
SD1 Section 3.1 No-Action Alternative
We concur with the stated purpose of the no-action alternative for establishing the baseline
condition. The Nushagak Cooperative’s proposal for the Nuyakuk Project is an entirely new
project. This presents a favorable opportunity to establish baseline conditions without previous
development impacts influencing the river environment or the fish habitat. Our study requests,
Attachment #2 are derived from this circumstance.
SD1 Section 3.2.2 Proposed Project Operation
The PAD states “a minimum instream flow of 1,000 cfs will be provided through the bypassed
reach, while the remainder of the available flow will be passed through the powerhouse.” This is
in conflict with the Alaska Statute AS § 41.21.167(e) allowing this to be built in the state park,
but requiring the utility to leave 70% of the flow in the river.
SD1 Section 3.2.3 Proposed Environmental Measures
The section only identifies protection measures for terrestrial resources. The PAD and additional
information request response include proposed measures for fisheries resources that includes a
minimum flow in the bypass reach, barrier fencing at the tailrace, and a concrete water diversion
9
groin to deflect upstream migrating adult salmon away from the intakes. These features all need
evaluation for their potential merit.
In addition to screening other measures should be investigated to keep smolt away from the
intakes. Smolt of the five salmon species vary in size and swimming ability, and smolt size
varies within a species based on the amount of time they have reared in fresh water. Keeping the
smallest smolt out of the intake will be challenging. It would be preferable to explore methods to
move the majority of smolt to river left and away from the intake.
SD1 Section 4.1 Cumulative Effects
The project will reasonably result in foreseeable future actions. The addition of >100 miles of
transmission lines may result in improved access to undeveloped and pristine habitats. Also, the
reliable and low cost electricity may result in additional settlement at existing villages.
Inexpensive power could make mining more viable, and this would affect water quality, fisheries
and habitat.
SD1 Section 4.2.2 Resource Issues, Aquatic Resources, Fisheries
Project operations will affect the movement of juvenile salmon during their out migration. This
list of resource issues should include effects of the project diversion structure and reduced flows
in the bypassed reach during project operation on downstream fish passage.
Effects of the project diversion and intake structures and reduced flows in the bypassed on fish
passage should include success of passage past the project area as well as the potential for delay
during adult upstream migration (e.g., how long it takes to pass the project area).
This project is highly unlikely to affect water temperatures. There is no impoundment and the
water will pass through the tunnel, penstock and turbines in less than a minute.
SD1 Section 5.0 Proposed Studies
We support the identified studies in Table 1 for Water Quality and Quantity, and Fisheries
Resources. We offer additional recommended studies in Requested Studies below.
SD1 Section 9.0 Plans
Please include the Nushagak River Watershed Traditional Use Area Conservation Plan by the
Nushagak-Mulchatna Watershed Council in the list of plans.
10
Attachment 2
National Marine Fisheries Service's Study Requests for the Nuyakuk Project (FERC No. P-
14873)
February 3, 2020
The National Oceanic and Atmospheric Administration’s, National Marine Fisheries Service
hereby files these seven study request for additional information and study with the Federal
Energy Regulatory Commission for Dillingham Cooperative’s (Applicant) Nuyakuk River
Project (P-14873) in Alaska.
We recommend the following seven studies be conducted during the study phase of the
relicensing activity. Each study is supported using the Commission's study plan criteria 18 CFR
5.9(b). Several of these studies compliment data gaps identified by the Nushagak Cooperative in
the Pre-Application Document (PAD). Information derived from each of these studies will
inform the decision process during this licensing action.
Study 1: Fish Distribution, Timing of Migration, and Abundance
Study 2: Upstream Fish Passage through Nuyakuk Falls
Study 3: Downstream Passage and Intake Design
Study 4: Flow Duration Curve Change Analysis
Study 5: Future River Flows and Water Temperatures
Study 6: Ice Processes Assessment
Study 7: Assessment of False Attraction at the Tailrace Fish Barrier
11
Study Request 1
Fish Distribution, Timing of Migration, and Abundance
Background
The PAD indicates 24 fish species are present in the larger Nushagak Watershed, approximately
11 of which are anadromous. Not all 11 species will pass Nuyakuk Falls or even be in the
Nuyakuk River. Determining the timing of upstream and downstream migration and estimating
the approximate run size of each anadromous species will inform the decision process for
developing protection measures. There is extensive data on the presence of sockeye salmon
especially on the lower stretches of Nuyakuk River (Brennan et al. 2019). The Alaska
Department of Fish and Game (ADF&G) counting tower has data on returning sockeye from
1959-1988 and then from 1995-2006. The Fisheries Research Institute (now called Alaska
Salmon Center) at University of Washington has collected data on a variety of species in Wood
Tikchik State Park and the Nushagak Watershed since the 1940s.
Content of Study Request (18 CFR § 5.9 (b))
1.§ 5.9 (b): 1.0 Goals and Objectives of Request
The goal of this study is to determine which anadromous species are present in the Nuyakuk
River in the five miles between Tikchik Lake and the bottom of Nuyakuk falls, the timing of
returning adult and outmigrating smolt of each anadromous species. Four objectives are:
a.Determine which anadromous species exist above Nuyakuk falls.
b.Determine run timing for the returning adults and outmigrating smolts. This
assessment could be based on previous work in other Bristol Bay rivers with similar
characteristics (e.g., drainage area, lake size, elevation). It is important to have
migration timing dates from several years on each species to evaluate inter-annual
variation.
c.Determine the relative run size of each anadromous species passing above the falls.
The study should incorporate historical data (such as the ADF&G counting tower), as
well as present day data.
d.Determine if any other lifecycle process/stages, besides migration, occur in the
project’s boundary (micro-habitat considerations).
i.Are there pools that function as holding areas within the cascade where fish
rest between burst of energy to make it through successive difficult cascades?
ii.How close is the nearest red and rearing area to the top of the falls?
iii.Are there any areas within the cascade reach that potentially support spawning
(overlap with Study 2, criteria 6, step b)?
iv.Do redds exist in the proposed area for the tailrace, intake structure, or groin?
12
2. § 5.9 (b): 2.0 Resource Management Goals
The relevant resource management goals are captured in the NOAA Fisheries Strategic Plan
for 2019-2022 (NOAA 2019a) and the Strategic Conservation Action Plan for Southwest
Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy oceans which
support healthy populations of marine species and sustainable commercial and recreational
fisheries. Our involvement is supported by mandates under the Fish and Wildlife
Coordination Act and Magnuson-Stevens Fishery Conservation and Management Act.
Section 18 authority of the Federal Power Act (16 U.S.C.§ 811) allows the Department of
Commerce to either prescribe fishways at the project or to reserve its prescriptive authority.
3. § 5.9 (b): 3.0 Relevant Public Interest Considerations
The requestor, the National Marine Fisheries Service, is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
4. § 5.9 (b): 4.0 Existing Information and Need for Additional Information
Data are available about fish presence/absence in the Nuyakuk River from both ADF&G and
Fisheries Resource Institute at University of Washington. The ADF&G counting tower has
data on sockeye escapement from 1959-1988 and then from 1995-2006.The counting station
is located approximately twenty miles downriver of the project. Data also exists at the same
institutions on the timing of returning adults of some species.
For addressing the smolt outmigration timing question, information from the outlet of other
large lake at a similar elevation in the Bristol Bay watersheds would be useful. Data being
collected on the Kvichak River during the springs of 2020 and 2021 should be taken into
account (Igiugig, P-13511). Particular attention should be paid to the start of smolt
outmigration which is often prior to breakup, however, this time period has rarely been
studied. The smolt which have a predisposition to emigrate earliest may actually be the most
important ones to protect, as that is the adaptive trait they may need as the trends of climate
change progress.
Most studies have focused on sockeye, with much less focus on Chinook, coho, chum and
pink salmon. Until studies indicate differently, we consider all five species present in the
Nuyakuk River with substantial runs. While Dillingham’s canneries currently process
primarily sockeye and pink, it should not be assumed that only those species will be
processing throughout the 50-year license. We need to know the timing of migration for
every anadromous species and design the intake and tailrace to avoid harm to any of the
species.
The PAD implies that fish pass through the cascade as quickly as possible. This may not be
the case. The slower sections of the ½ mile long reach should be investigated for spawning,
rearing or holding areas. These areas could be critical for passage as fish likely do not make
it up a ½ mile long cascade in a single expenditure of energy.
13
5.§ 5.9 (b): 5.0 Nexus Between Project Operations and Effects on the Resource Studie d,
and How the Study Results would Inform the Development of License Requirements
The proposed project will affect the volume of water flowing through the Nuyakuk cascades.
Therefore, the project will directly affect the habitat characteristics that suppor t anadromous
fish migration through this river reach. Different species have different sustained and burst
swimming speeds, and require different habitat characteristics to pass successfully through a
cascade or up a falls. Knowing which fish species are present and when will inform the
quantity of water necessary to ensure suitable habitat function during the salmon migration
periods. Some of these fish will swim through Tikchik and Nuyakuk Lakes to spawning areas
in tributary streams many miles away, therefor, delaying adults a week or two below the falls
could lead to a decrease in spawning success with implications on the productivity.
The project intake could entrain and impinge smolt outmigrating to the ocean. This
represents new hazards created by the project. It will be important to understand the chance
of blade strike or other injuries if fish pass through the turbines. Without knowing which
smolt species are likely to be present, there is no efficient way to design fish screens or other
physical deterrents to entrainment, and no means for evaluating blade strike probability.
Also, lifecycle and behavioral characteristics vary among species. The intake screen design
and behavioral deterrents need to consider these differences.
An improved understanding of which species pass at which times, and how they use the
cascade will be critical for determining how much water must be left in the river during
migration periods, and the design of mitigation measures.
6.§ 5.9 (b): 6.0 Consistence with Generally Accepted Practice
Determining species presence, migratory timing, and abundance is standard practice for new
hydropower development and licensing actions. This data helps identify potential project
impacts and the baseline condition. Site specific monitoring should be completed seasonally
over at least two years as fish runs vary greatly among years. Current data should be
collected to supplement any older data sets.
Standard fish inventory methods such as fish towers, fish wheels, acoustic counts, mark-
recapture and snorkel surveys are common practice for adult escapement. Minnow traps,
acoustic counts, and video coupled with artificial intelligence for enumerating fish are used
to count outmigrating smolts. We support all these methods and looks forward to discussion
on specifics in technical work group meetings.
Environmental DNA (eDNA) is a new method that might be a cost effect method for
presence and abundance. We encourage the fisheries working group to consider this method
especially to learn more about rare species.
Objectives (a), (b), and (c) do not need to happen in the falls reach. The safer work areas well
above the cascade would yield the same species, migration timing, and abundance estimates.
Study d does need to happen in or close to the cascade. We understand that it will not be
possible to study every part of the cascade.
14
7.§ 5.9 (b): 7.0 Considerations of Level of Effort and Cost
The required effort is commensurate with the size of the project and the requirements of an
original license. The stated purpose of this project is to power canneries that process multiple
species of anadromous fish. We are seeing with the collapse of the Pacific Cod fishery, a
once thriving industry. Even though the Dillingham canneries process primarily sockeye and
pink today, they may be reliant on another species during the 50-year license term.
Anadromous fish counting methods require surveys for migrating fish at the proper time of
the year. This may require automated methods and personnel staying on site for extended
periods that cover the adult and juvenile migration season. We recommend some
combination of automation and people on the ground as automated systems often need
human intervention. Two years of data may provide the applicant with a reasonably defined
timing window and a robust estimate of abundance for most species; for one or two species
more targeted methods would need to extend into a third year. Additionally, unanticipated
problems often cause the first year of fish surveys to be less informative. ADF&G has proven
effective at fish studies on the Nuyakuk and Nushagak rivers over the several decades and we
will work closely with them and other interested parties to determine the best methods and
the level of effort required.
15
Study Request 2
Upstream Fish Passage through Nuyakuk Falls
Background
Pacific salmon and other fish species are able to migrate up the fall with flows from 15,000 to
4,000 cfs (July – October typical flows). The applicant proposed leaving a minimum of 1,000 cfs
in the river reach between the project intake and tailrace. River flow conditions are critical to
supporting fish migration, and other ecological functions. No data exists to indicate the proposed
bypass base flow will provide safe, timely, and effective passage for returning adult salmon and
maintain the channel characteristics and baseline aquatic connectivity. Therefore, it is imperative
that the applicant determine which species can pass up the cascade at which flows. We
recommend the applicant complete a study to assess the relationship between river discharge and
the accessibility of habitat for migrating fish. Data collected during this study will inform
recommendations for optimal instream flow requirements for fish passage during different
seasons of the year.
Content of Study Request (18 CFR § 5.9 (b))
1.§ 5.9 (b): 1.0 Goals and Objectives of Request
The goal of this study is to determine an appropriate flow regime that will protect
anadromous fish migratory habitat in the bypass reach between project intake and tailrace.
The objectives of this study are:
a.Document zone of passage habitat characteristics within the bypass reach.
b.Assess the effects of proposed project instream flows on the wetted area and optimal
passage habitat for target species.
c.Determine optimal and minimal flows to maintain migratory habitat in the bypass
reach. The target fish species used to evaluate habitat value should include all
diadromous species that pass through the cascade (see Study Request 1).
2.§ 5.9 (b): 2.0 Resource Management
The relevant resource management goals are captured in the NOAA Fisheries Strategic Plan
for 2019-2022 (NOAA 2019a) and the Strategic Conservation Action Plan for Southwest
Alaska (SASHP 2017). Identified in NOAA’s Strategic Plan is the long-term goal of healthy
oceans that support healthy populations of marine species and sustainable commercial and
recreational fisheries. Our involvement is also supported by mandates under the Fish and
Wildlife Coordination Act and Magnuson-Stevens Fishery Conservation and Management
Act.
Furthermore, Section 18 authority of the Federal Power Act (FPA) allows the Department of
Commerce either to prescribe fishways at the Project or to reserve its prescriptive author ity.
16
3. § 5.9 (b): 3.0 Relevant Public Interest Considerations
The requestor, the National Marine Fisheries Service, is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
4. § 5.9 (b): 4.0 Existing Information and Need for Additional Information
Presently, there are no data available relating adult passage suitability through the cascade to
river flow for any of the five salmon species through the cascade. Data generated by this
study request does not currently exist. We know that the cascade drops 26 feet over a half
mile reach. Some salmon, pass through the falls at flows between 4,000 cfs and 15,000 cfs
5. § 5.9 (b): 5.0 Nexus Between Project Operations and Effects on the Resource Studied,
and How the Study Results would Inform the Development of License Requirements
The Nuyakuk River supports sockeye, Chinook, chum, coho and pink salmon, and a few
additional anadromous fish. These Bristol Bay salmon stocks have evolved to reach suitable
spawning/rearing habitat to complete their life cycle with natural river conditions. Their
migration behavior is adapted to a variable hydrograph both within the year and between
years. These natural conditions form the baseline condition.
The proposed project will divert substantial flow from a critical reach in the Nuyakuk River
where returning adult salmon are challenged by a series of cascades and small falls. This
represents a direct project related impact on valuable public trust resources. Presently, there
are no data to indicate how that change in flow conditions will affect fish migration. Absent
site specific data, we are unable to determine the scope of impacts on migrat ion behavior
and the need for mitigation measures. The requested study characterizing the relationship
between flow and passage suitability in the bypassed reach is needed to establish baseline;
evaluate potential effects (e.g., delay, stranding) of project operations on migration of adult
and juvenile salmon in the proposed bypass reach; and inform the development of protection
measures for fisheries resources.
6. § 5.9 (b): 6.0 Consistency with Generally Accepted Practi ce
Bypass flow habitat assessments are commonly employed in developing instream flow
requirements intended to mitigate project related impacts on aquatic resources and their
habitat. Given the length of the bypassed reach (0.5 miles) and the millions of culturally and
commercially important fish known to pass through the reach (sockeye, Chinook, coho,
chum and pink salmon), a combination of field measurements, modeling, and professional
judgement should be used. At a minimum, the study design should involve modeling wetted
perimeter, depth and velocity data within a range of flows along cross sections located in the
reach of river between the intake and the tailrace. Cross section locations should be assessed
on site to select the most informative locations. This information then should be synthesized
to quantify habitat suitability (using mutually agreed upon Habitat Suitability Index curves)
of each flow, as appropriate, and for target species/life stages identified by the resource
agencies. Habitat modeling using Physical Habitat Simulation Modeling System’s one-
dimensional modeling is a possible method.
17
We recommend the following tasks to meet the goals of this study request:
a.Complete a detailed survey of channel bathymetry from 1,000 feet above the intake to
100 feet below the tailrace. Use sufficient point cloud coverage to produce 1 foot
contours. This channel bathymetry could be obtained with water-penetrating green
light LIDAR. We recommend using green LIDAR at two flows to assess the precision
of the technology used at different water depths.
b.Identify the channel bottom substrate to the extent possible: bedrock, boulder, large
cobble, or gravels to assess potential spawning areas and channel permanence.
c.Install pressure transducer at the two boundary cross sections (1,000 feet above and
below the falls) and check them approximately every two weeks. The transducers
should be maintained in place until flows from approximately 1,500 - 15,000 cfs have
been recorded. This data will be used for model calibration.
d.Develop a two-dimensional physical flow model to assess velocities and depths
throughout the cascade at a range of flows.
i.Boundary conditions cross sections should be set up 1000 feet above and
below the falls.
ii.There should be sufficient detail for the model to determine water depths to
within 6 inches and velocities to within 2 feet/sec through the cascade at
discharges from the minimum proposed instream flow to 50th percentile flow
in the highest month.
iii.Calibrate the model using the boundary stage measurements and two flows:
one within 10% of the lowest flow at the USGS gage in the 2021 - 2022 water
years; one approximately the 50th percentile flow for the highest flow month
(July).
iv.Validate the model at two flows: Measure velocity and depth throughout the
cascade to validate the model. This could be done by attaching a floating
acoustic Doppler current profiler (ACDP) vessel to a fixed line strung across
the cascade. In general, these lines should be spaced 300 feet apart, but in
sections with consistent bathymetry they could be more spread out. Validate at
one flow which is the least amount of water the applicant is requesting to
leave in the river mid-winter; validate a second time at the mean late summer
flow the applicant plans to leave in the river when adults sockeye return. We
recommend the applicant receive prior agreement from the resources agencies
that the target validation flows are acceptable to all parties.
e.Run model simulations at 1000 cfs, 2000 cfs, 4000 cfs, 8000 cfs and the 2-year return
flow (or bank-full flow). If it comes to debating the minimum flows for the license,
the resources agencies may ask for another simulation.
f.Analyze the ability of each target species to swim through the cascade given their
swimming/jumping abilities in peer reviewed literature during each model simulation.
18
g.Analyze whether any current spawning areas will be inaccessible to fish or whether
any holding pools will become disconnected from the main flow during each
simulation.
h.Velocity and depth measurements can be completed from an unmanned watercraft
with a ADCP moved across multiple fixed lines strung perpendicular to the channel.
Any methods used should consider safety first.
7.§ 5.9 (b): 7.0 Considerations of Level of Effort and Cost
This effort may require a three-person team to make four trips to the site. An initial multiday
trip to fix the lines perpendicular to the cascade, followed by additional shorter trips. An
ACDP remote vessel cost approximately $25,000 or could be rented. We are open to
discussing alternatives that meet the objectives to the stated levels of precision. The cost and
level of effort of this study is commensurate with a project being proposed on a river that
has an average return of 370,000 sockeye in addition to four other returning salmon species.
19
Study Request 3
Downstream Passage and Intake Design
Background
The Nuyakuk River supports a regionally important commercial, subsistence, and recreational
fisheries run of sockeye salmon, as well as the four other Pacific salmon species and other
anadromous species. In order for these runs to continue, juvenile life stages must pass
downstream unharmed. The applicant must demonstrate that the proposed project will neither
impinge nor entrain smolts at the project intakes. The proposed project will need to incorporate
design features that support safe, timely and effective passage past the project works. We
recommend referring to our agency’s design criteria f or screening intakes (NMFS 2011) to
evaluate design features for the proposed action.
The proposed intake structure as described in the PAD and the applicant’s additional information
request response (accession # 20191114-5100) illustrates a 100-foot wide intake associated with
a concrete groin. While the concrete groin is shown to have a sluice gate, there are no defined
measures for preventing the migration delay, entrainment, or impingement of juvenile Pacific
salmon. We are also concerned that this groin may exacerbate frazil ice development near the
intake. As a newly proposed project, the applicant has the opportunity to incorporate design
features that protect juvenile pacific salmon that are critical to sustenance harvest, and are
commercially and recreationally valuable in this region.
The applicant proposes to complete a two-dimensional river hydraulic model for approximately
1,000 linear feet above the Nuyakuk Falls to aid in proper development of the intake diversion
hydraulic and structural design (see study request 2). Complex flow fields can occur upstream of
the entrance to powerhouse intakes. With respect to downstream fish passage, it is imperative to
understand the direction and magnitude of flow fields that are upstream of the turbine intakes in
order to inform license conditions that may improve downstream passage. In addition, three-
dimensional CFD modeling can be used to identify where and during what operational
circumstances excessive velocities occur at the turbine intakes – a project-related effect that can
lead to entrainment or impingement related injury or mortality to downstream migrating fish.
Three-dimensional CFD modeling is a precursor to downstream fish passage concept designs, as
water velocities and flow directionality are an important component to guiding fish towards a
safe downstream passage.
The screened intake is the most critical design element of this project and is extremely important
for protecting the salmon run. If the applicants contends that some smolt can pass through the
turbine with neither blade strike nor other injuries, we recommend they provide examples from
studies from other existing similar with similar turbines.
Intake structure icing has created significant issues for the Tazimina Project; we encourage the
applicant to contact Iliamna Newhalen Nondalton Electric Cooperative, Inc. (INNEC) to discuss
icing with their operators and designers.
20
Content of Study Request (18 CFR § 5.9 (b))
1. § 5.9 (b): 1.0 Goals and Objectives of Request
The goal of this study request is to evaluate conceptual alternatives in concert with the CFD
modeling, for design features that protect outmigrating salmon smolt. The study objects
include:
a. Complete a literature search of intake designs with and without designated bypasses
that mitigate entrainment of salmon smolt in areas subject to frazil ice. Evaluate
physical exclusion measures.
b. Complete a literature search of any behavioral or upstream measures that would move
the majority of smolt to river left away from the intake. Evaluate behavioral exclusion
measures.
c. Propose multiple project intake designs with screens, and with and without designated
bypass facilities based on other functioning hydropower intakes to eliminate or
minimize entrainment of smolt and address frazil ice.
d. Do a feasibility analysis and select an intake design in consultation with the resources
agencies.
e. Obtain bathymetry data sufficient for 1-foot contour intervals or 15% of the average
river depth at 2,000 cfs, whichever value provides more precision. The area covered
should be the top of the falls to three river widths above the intake structure. The
bathymetry data collected during the Upstream Passage Study Request 2 may be
sufficient.
f. Develop a CFD model that simulates three-dimensional flow from the top of the falls
to three river widths above the intake facility. At a minimum, the modeling output
should produce velocity, turbulence, and water depth for each cell in the mesh. The
modeling domain shall be of sufficient size and mesh to characterize the hydraulic
environment. The final product from this objective is a series of layered drawings that
show velocity magnitudes at intake flows that have been agreed upon by the resource
agencies and the applicant. Run simulations at the following flows:
i. River flow vectors in the intake vicinity at full powerhouse capacity plus
proposed minimum flow (1,000 cfs) in the river;
ii. River flow vectors in the intake vicinity at 50% powerhouse capacity, and
proposed minimum flow (1,000 cfs) in the river;
iii. River flow vectors in the intake vicinity at 80% exceedance on the existing
April through November flow duration curve and 70% of the flow left in the
river. Most climate models predict higher flows in May and October. This will
not change the total range of flow analyzed.
iv. The CFD modeling should also be conducted for at least these ten operation
modes for the selected intake design. If these CFD model results indicate
substantial entrainment during smolt outmigration, we may ask the applicant
to consider another intake/screen design. The results will demonstrate
21
velocities and flow orientations at the intake. If the 80% exceedance flow is
substantially the same in two months, it may not be necessary to model both
flows.
v.This CFD model must also be calibrated with existing conditions. We will
work with the applicant to agree on specific methods and standards.
g.Use the CFD model to simulate how the velocities into the selected intake structure
will be less than the sweep (perpendicular velocities) allowing smolt to be washed
downstream rather than impinged on the intake screen surface. Please refer to our fish
passage design criteria (NMFS 2011).
h.Field test a scaled down screen and intake exclusion device and place it in the river
and run it with pumps for a trial winter and spring to assess the potential for ice
development. Tagged smolt could be evaluated to see which ones manage to avoid
the intake. If the full-scale sized screen ices up the first or second winter, diesel cost
for six communities will mount quickly.
2.§ 5.9 (b): 2.0 Resource Management Goals
The relevant resource management goals are captured in the NOAA Fisheries Strategic
Plan for 2019-2022 (NOAA 2019b) and the Strategic Conservation Action Plan for
Southwest Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy
oceans that support healthy populations of marine species and sustainable commercial
and recreational fisheries. Our involvement is also supported by mandates under the Fish
and Wildlife Coordination Act and Magnuson-Stevens Fishery Conservation and
Management Act.
Section 18 authority of the Federal Power Act (16 U.S.C.§ 811) allows the Department of
Commerce either to prescribe fishways at the Project or to reserve its prescriptive
authority.
3.§ 5.9 (b): 3.0 Relevant Public Interest Considerations
The requestor, the National Marine Fisheries Service, is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
4.§ 5.9 (b): 4.0 Existing Information and Need for Additional Information
An extensive record is available pertaining to downstream passage of juvenile salmon.
However, the site specific conditions need documentation to develop the appropriate
screen design. The influence of ice in this part of the country needs consideration as well.
Presently there are no data to address the flow field in the project area. The proposed
volume of water withdrawal and the project’s remoteness make this project unique. This
project may also experience a wider range of mid-winter and spring temperatures than
more inland projects. Temperature that can fluctuate between above freezing to negative
10° Fahrenheit in the same week greatly complicates understanding ice formation at
intakes. The applicant has not provided a functional design of the intake at the proposed
facility.
22
5. § 5.9 (b): 5.0 Nexus Between Project Operations and Effects on the Resource Studied,
and How the Study Results would Inform the Development of License Requirements
The proposed project intake will affect migratory fish as they move through the project
area. Outmigrating smolt are susceptible to injury or death via entrainment and
impingement – a direct nexus to project-related effects. If fish protection measures are
not considered during design, the potential project related mortality will have a direct
effect on fish populations by reducing population size and capacity for future
reproduction and population growth. Results of this study are essential for a complete
understanding of the project’s effects to downstream migrating juvenile salmon. Data
derived from this study will contribute to the development of an administrative record in
support of the Commission’s licensing process and mitigation opportunities.
Data from this CFD model objective of this study will also be crucial to the Ice Processes
Assessment (Study Request 6).
6. § 5.9 (b): 6.0 Consistency with Generally Accepted Practice
This study request will require a review of existing downstream fish passage technologies
that meet our fish passage design guidelines (NMFS 2011) for intake screening and
downstream fish passage structures. This work will also consist of conceptual
engineering designs of fish passage protection alternatives that include physical screening
of fish to minimize entrainment, and relative velocities directing fish to the downstream
passage. The applicant should develop downstream fish passage alternatives for the
project based upon current guidelines (NMFS 2011) The options being studied, the depth
and breadth of the conceptual design, the need to combine with the requested CFD
modeling, should be agreed upon with the resource agencies in a study plan prior to
conducting the study.
Three-dimensional CFD modeling is a common analysis at hydroelectric projects around
the nation. Example from the northeast region where these models were developed
include the Holyoke (P-2004), Brunswick (P-2284), Shawmut (P-2322), Milford (P-
2534), and Weston (P-2325) Projects. We would expect to consult with the applicant and
other resource agencies to determine the appropriate area and flows modeled. Given the
large number of ways that output from these models can be presented and the near
infinite number of flows that could potentially be modeled, we would expect to consult
with the licensee to reach agreed upon modeling efforts and scenarios to be examined.
Fish passage engineering alternative studies are an established and a typical means to
evaluate options in the decision making process. This type of assessment has been used
by the Commission in many licensing proceedings to support decisions at hydro projects
during licensing.
23
7.§ 5.9 (b): 7.0 Considerations of Level of Effort and Cost
The level of effort and cost is commensurate with a project the size of the Nuyakuk
Project and the likely 50-year license term. Subsistence harvest of salmon provides a
significant portion of these communities’ diet and processing fish is the main economic
driver for several of the downstream communities. The expense to understand the effects
on outmigrating smolt and protecting this valuable resource is reasonable. No alternatives
were proposed. Objective (a) through (e) will likely take a year and involve meeting with
the resource agencies multiple times. Objectives (f) and (g) may take an additional 6
months. The cost of developing, running, and testing a CFD model is variable. If the first
runs suggests a different design needs to consideration, this will take more time.
Proactive communication with resource agencies will reduce the cost and iterative effort.
Objective (h) will take approximately one year to design, fabricate, and install, and then
need testing during a winter/spring season.
24
Study Request 4
Flow Duration Curve Change Analysis
Background
Published studies indicate shifting climate conditions for Bristol Bay watershed over the next
century as a result of climate change (Wobus 2015). During the term of any new license for this
project, Southwest Alaska will experience increasing temperatures and increasing annual
precipitation (Walsh 2018). The resulting changes in environmental conditions during the next
30-50 years will influence project operations, scope and scale of project related impacts, and the
effectiveness of mitigation measures (e.g., fish passage). This study will help identify trends in
flow conditions to provide a forward-looking evaluation of the flow duration curve. Data from
this study can be used to inform the licensing process with specific application to project design,
operation and fish protection measures. The applicant suggested this study, or a very similar one,
during the November 18, 2019 project kickoff meeting.
Content of Study Request (18 CFR § 5.9 (b))
1.§ 5.9 (b): 1.0 Goals and Objectives of Request
The goal of the study is to evaluate changes in the flow duration curve for the Nuyakuk River
that have happened during the 67-year USGS 15302000 gage record. This study request will
not analyze climate projections or future flows. The objectives of this study are:
a.Determine if flow pattern observable for the USGS Nuyakuk River gage record
exhibit stationarity as hydrologist assumed for decades, or if there is a statistically
significant trend (Milly 2008) consistent with other gage records in Northern climates
where a change analysis has been completed.
b.Use the appropriate data to inform the development of climate resilient license
articles. This is a statistical study using peer reviewed existing USGS flow data.
2.§ 5.9 (b): 2.0 Resource Management Goals
The relevant resource management goals are captured in the NOAA Fisheries Strategic Plan
for 2019-2022 (NOAA 2019b) and the Strategic Conservation Action Plan for Southwest
Alaska (SASHP 2017). Identified in NOAA’s strategic plan is the long-term goal of healthy
oceans that support healthy populations of marine species and sustainable commercial and
recreational fisheries. Our involvement is also supported by mandates under the Fish and
Wildlife Coordination Act and Magnuson-Stevens Fishery Conservation and Management
Act.
3.§ 5.9 (b): 3.0 Relevant Public Interest Considerations
The requestor, the National Marine Fisheries Service, is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
25
4.§ 5.9 (b): 4.0 Existing Information and Need for Additional Informatio n
The existing flow duration curve relies on methods developed prior to our cur rent
understanding of climate, especially that rainfall and temperature are variable between years
and months, but overall tied to a static horizontal line (stationarity). The analysis that will
indicate if stationarity (Milly 2008) exists at the Nuyakuk gage. This evaluation has not been
completed for this USGS gage record. This analysis may only apply to the months in the
sufficient hydrograph data are available.
5.§ 5.9 (b): 5.0 Nexus Between Project Operations and Effects on the Resource Studied,
and How the Study Results would Inform the Development of License Requirements
River flow and its seasonal patterns directly influence project design and operations, and
mitigation measures intended to protect public trust resources. As this is a new project
development, the applicant should consider the changing environmental conditions on which
their project is dependent for successful operation. As flow patterns change, changes in
project operations often occur. The Bradley Lake Project (P-8221) licensee decided to stop
diverting water on November 1 based on records from the historical record. Historical data
indicated no flow worthy of diversion during mid-winter. In 2019, both November and
December saw 1,000’s of acre feet flow down Battle Creek as large precipitation events
arrived primarily as rain. Likewise, project operations influence the behavior of migrating
fish within the project area. The information collected by this study would support the
analysis of direct and cumulative effects of the proposed project on migratory fish and aid in
the development of any necessary license articles regarding measures to achieve fish passage.
If this watershed runoff pattern is non-stationary, then design consideration, operations
models and license articles should be flexible enough to deal with change.
6.§ 5.9 (b): 6.0 Consistency with Generally Accepted Practice
Studies should use current literature, existing data from the USGS gage (USGS No.
15302000), and standard practices accepted by the scientific community. A change analysis
is a standard Bureau of Reclamation analysis method. Many utilities with hydropower
projects are employing it for their decision making processes.
7.§ 5.9 (b): 7.0 Considerations of Level of Effort and Cost
All the data necessary to complete this study are available. The analysis could be completed
within two to four months. The level of effort and cost is commensurate with the proposed
project size and the likely license term. No alternatives have been proposed.
26
Study Request 5
Future River Flows and Water Temperatures
Background
An understanding of future flows and stream temperatures is necessary to inform the design of
project infrastructure, including fish passage protection measures, and project operations. The
best available science indicates temperature, precipitation, and stream flows will increase in the
Bristol Bay region, and much of south central Alaska (IPCC 2018; Walsh 2014; Walsh 2018).
Thus, higher stream flows and volume are likely within the project area during the prospective
license term. Peer-reviewed, publicly available downscaled climate model projections have been
developed for this region. These model projections should be analyzed to support flow analysis
for this project. We request that the existing peer reviewed climate model predictions be used to
model future discharges and water temperatures for the Nuyakuk River, in accordance with peer-
reviewed published methods and generally accepted practice as described below. This
information will inform the development of license articles guiding operation and maintenance,
including mitigation measures, as well as the development of a climate resilient project design.
The Nuyakuk River supports a commercial, subsistence and recreational sockeye fishery, as well
as the four other Pacific salmon species. These species rely on these riverine systems for refuge,
spawning, rearing and nursery habitat. The Nuyakuk River and Tikchik Lake supports the second
largest sockeye run in the world; second only to the Kvichak River and Lake Iliamna. Adult
sockeye pass through the Nuyakuk cascade to spawn in the lakes above. Smolts pass back down
the cascade on route to the ocean to mature. Furthermore, the timing of adult escapement and
smolt outmigration is keyed to water temperature, which is strongly affected by air temperature
(Mauger et al. 2016) and projected to change with increasing air temperature.
Many of the climate change effects described below have likely impacts on salmonids (Leppi
2014; Wobus 2015). Given that increased flows are projected by the five member ensemble of
global climate models (GCM) best fitted for Alaska, these increases provide opportunities to
benefit both the hydropower generation and fish management and protection. Therefore, it is
critical to have estimates of future flows and stream temperatures to assess the combined effects
of the project and climate on these trust resources. This study is at the core of producing more
evenly distributed year-around hydropower generation, while at the same time protecting and
maintaining this salmon fishery. This is in line with recent literature that highlights opportunities
to design and operate hydropower projects for sustainability of both power production and the
riverine environment (Brown et al. 2015; Poff et al. 2016). Thus, our study request will identify
forward looking, climate resilient outcomes for hydropower development and fisheries.
Trends in the Region
We included published literature and first hand observations from 2019 for the Bristol Bay
Watershed. Documented trends include (Thoman 2019):
• Increase of 3.7º F in air temperature in the Bristol Bay region, 1969-2018
• Increase of 13 percent increase in annual total precipitation in Bristol Bay Region, 1969-
2018
27
•Lowest sea ice extent in Bering Sea in February 2019 in last 170 years
•Nearby King Salmon had 26 record warm daily temperatures and a single record low
from 2014-2018
Bristol Bay has rarely frozen in the last decade; people and animals used walk or sled to the
nearby islands mid-winter on a regular basis (Markoff 2019).
Nuyakuk Watershed Hydrology
The proposed project will be located on the Nuyakuk River at a cascade approximately five river
miles downstream from the Tikchik Lake outlet which drains the northern Wood River
Mountains, a 1,544 square mile watershed. The watershed contains six large lakes which
comprise 12 percent of the land area. An additional 50 percent of the watershed is below 1000
feet in elevation. While the highest peak is over 5,000 feet, the vast majority of the watershed is
below 3,000 feet in elevation. There are no significant glaciers; permanent snowfield make up
less than 1% of the watershed. The proposed project would divert water out of the river above
Nuyakuk Falls, pass it through a tunnel(s) to a powerhouse located at the base of Nuyakuk Falls.
Nuyakuk Falls is a ½ mile long cascade with only 28 feet of elevation change. Below the project
site, the Nuyakuk River meanders and braids 40 miles before converging with the Nushagak
River, which flows to Bristol Bay. The Nuyakuk watershed drains the west side of the Nushagak
River basin. The Koktuli River, another tributary to the Nushagak that was modeled in a project
discussed below, drains from the east side of the Nushagak.
There is a 67-year USGS gage record at Tikchik Lake outlet for spring through early fall flows
and a shorter, more intermittent, record for winter flows. The lowest mean daily winter flows this
decade are approximately 2,000 cfs, with the flows dropping below 1,500 cfs during two winters.
A broad, snowmelt-driven peak arrives in early June and remains through mid-August. The flow
typically remains above 10,000 cfs for two months with a peak flow between 15,000 and 22,000
cfs. Half of the Octobers in the last decade have had a second peak over 10,000 cfs lasting days
to two weeks. The Nuyakuk River hydrograph is not flashy, because it has six large upstream
lakes.
Relevant Climate Studies
Future River Flows and Water Temperatures study request would employ the data from an
existing peer-reviewed ensemble of downscaled GCMs (Walsh 2018; Wobus 2015) and use a
hydrologic model to project mean monthly (at a minimum) or daily Nuyakuk River discharges
and stream temperature. The Wobus and Walsh climate projections, each based on five state of
the art models developed for the Intergovernmental Panel on Climate Change (IPCC), provide
mean monthly precipitation and air temperatures in the Nushagak watershed during the license
term. They project a range of plausible future scenarios.
Recent peer-reviewed studies have described the changes projected by the most recent
generations of IPCC models. Wobus et al (2015) used downscaled climate data to assess flow
changes in other parts of the Nushagak basin, finding large changes in monthly temperature and
precipitation projected based on five global climate models (Figure 1). Furthermore, numerous
high flow events (green and red lines) would be expected throughout the winter (Figure 2).
Leppi et al (2014) linked climate scenarios from GCMs and habitat models for the Chuitna River
28
basin in south central Alaska and used this in a coho salmon population model to assess how
projected climate change could affect survival at each freshwater life stage and, in turn,
production of coho salmon smolts. Relevant for the Nuyakuk basin, this study finds a significant
increase in peak discharge, temperature and other stream variables at several points in the salmon
migration and development period.
Figure 1. Monthly Changes in future temperature and precipitation projected for five GCMs (Figure 3 in
Wobus et al. 2018).
29
Figure 2. Changes in Hydrograph for Upper Talarik Creek Gage Site in 2100, for Lowest and Highest
Temperature Scenarios. Note the loss of the spring pulse (freshet) in both future climate simulations.
(Figure 6 in Wobus 2015). Talarik Creek is on the east side of the Nushagak River drainage, while
Nuyakuk is on the west side. While the two are 70 of miles from each other, the Nuyakuk has higher
mountains in its headwaters and the watersheds are different in other ways, so while the results provide an
estimate, they cannot replace analysis of the Nuyakuk basin.
Content of Study Request (18 CFR § 5.9 (b))
1.§ 5.9 (b): 1.0 Goals and Objectives of Request
The goals and objectives of this study are to determine mean flows and water temperature
during the term of the license, at least at a monthly time scale, and daily if feasible. Details of
the recommended study are provided in the Generally Accepted Practices section below.
NOAA Fisheries and its NOAA climate science partners are available and willing to discuss
the details of the climate and flow studies to ensure its value for all parties. We assume a 50-
year license will be issued, and total development time will be 8 years, so evaluate 2027 to
2077. The objectives of this study are:
1.Use existing climate projections (Walsh 2018; Wobus 2015) to model and predict
Nuyakuk River flow and temperatures during the license term. These should be done
at least at a monthly time scale and daily if feasible.
2.Use this information to determine the future timing of returning adult salmon and
when water will be needed in the river (license conditions) to support fish passage up
the falls. This information will inform the Upstream Passage (Study Request 2) and
Tailrace False Attraction (Study Request 7).
3.Use this information to project timing of outmigrating smolt. This information will
inform the Ice Process (Study Request 6) and Intake Design (Study Request 3).
30
4. Use future flow information to inform turbine sizing and maximize winter , spring and
fall energy production.
5. Use future flow information to inform project design and operation including tunnel
design, groin design and any attempt to mesh winter hydropower with other electric
generation facilities to meet domestic winter power demands of the six communities.
2. § 5.9 (b): 2.0 Resource Management Goals
The relevant resource management goals are captured in the NOAA Fisheries Strategic Plan
for 2019-2022 (NOAA 2019b) and the Strategic Conservation Action Plan for Southwest
Alaska (SASHP 2017). Identified in this plan is the long-term goal of healthy oceans support
healthy populations of marine species and sustainable commercial and recreational fisheries.
Our involvement is also supported by mandates under the Fish and Wildlife Coordination
Act and Magnuson-Stevens Fishery Conservation and Management Act.
3. § 5.9 (b): 3.0 Relevant Public Interest Considerations
The requestor, the National Marine Fisheries Service, is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
4. § 5.9 (b): 4.0 Existing Information and Need for Additional Information
Existing, baseline flows in the Nuyakuk River are likely to change in the coming decades due
to the effects of climate change. The climate-induced changes to baseline conditions will
interact with the project diversion of substantial flow from a this critical Nuyakuk Falls reach
where migrating fish are challenged by a series of cascades and falls. Thus the project related
changes to the baseline condition will interact with the effects of climate change.
Information exists for the support of this study request. Walsh 2018, in a project at the
University of Alaska, have recently published downscaled monthly climate data for Alaska
that includes this region. A hydrologic model of future flows exists for the Koktuli River
(Wobus 2015), a tributary of the Nushagak, that could be adapted for the Nuyakuk. Wobus
(2015) developed projections of air temperature and precipitation for the upper Nushagak and
Kvichak rivers; they do not project flows or temperature in the Nuyakuk River. Several
studies have documented climate induced changes in flows and stream temperature in other
areas of southcentral (Leppi 2014; Winfree 2014). The methods from these studies could be
replicated. The steps and data available to complete the analyses are described below at the
end of this study request.
Projected future daily flow values would better inform the project design and license review
process than projected future monthly flows. For example, knowing the projected average
March flow in the Nuyakuk will be 3,000 cfs, is less useful than knowing most days in
March the flow will be between 2,200 and 2,600, but a two-day rain on snow event causing
8,000 cfs is likely (figure 2), and in the last week of March flows will average 3,200 cfs
caused by the onset of spring melt.
31
5.§ 5.9 (b): 5.0 Nexus Between Project Operations and Effects o n the Resource Studied,
and How the Study Results would Inform the Development of License Requirements
The proposed project will affect the volume of water flowing through the Nuyakuk cascades.
Therefore, the project will directly affect the habitat characteristics that support anadromous
fish migration through this ½ mile river reach. Different species have different sustained and
burst swimming speeds, and require different habitat characteristics to successfully pass
through a cascade or up a falls. Projections of a range of flow volumes at different times of
the year will inform the quantity of water necessary to ensure suitable habitat function during
the salmon migration periods. Because some of these fish will swim through Nuyakuk Lake
to spawning areas in tributary streams many miles away, delaying adults a week or two
below the falls could lead to a decreased spawning success.
Thus, results of this Future Flows Study are essential for a complete understanding of the
combined effect of the project and climate change effects on salmon migrating upstream as
adults and downstream as juveniles, and these results support each of the other studies that
use flow. Developing the requested data at the onset will also help limit the need for
revisiting project design features, including mitigation measures, as future environmental
conditions change.
The Nuyakuk project proposes to remove different amounts of water from the Nuyakuk
River at different times of the year. The timing and volume of flows are projected to change
due to climate warming. During some time periods this could have a significant effect on
salmon productivity such as during smolt outmigration. However, given that overall flows
are projected to increase, operations could be designed, and conditioned in the license, to
maintain appropriate fish passage protection measures. This study will help estimate how
much water will be available for power generation in each month during the license term. It
will provide the flow analysis to indicate how salmon migration timing (both upstream and
downstream) will change due to water temperature changes. Finally, it will contribute to the
Ice Processes (Study 6).
River flow and its seasonal patterns directly influence project operations and mitigation
measures intended to protect aquatic resources. As flow patterns change, changes in project
operations often occur. Likewise, project operations influence the behavior of migrating fish
within the project area. The information collected by this study would support the analysis of
direct and cumulative effects of the proposed project on migratory fish and aid in the
development of any necessary license articles regarding measures to achieve fish passage.
6.§ 5.9 (b): 6.0 Consistency with Generally Accepted Practice
It has become generally accepted practice to consider climate change among planners and
designers of dams for hydropower and water supply. The best available science now includes
the presently observed and projected future impacts of climate change on water r esources, as
demonstrated by Congress directing the Secretary of Interior, via the Secure Water Act, to
coordinate with NOAA and its programs to ensure access to the best available information on
climate change [Secure Water Act (§) 9503 (c)] Some examples:
32
•Non-federal water managers and planners incorporate the risks of climate change in their
long-range planning. The Water Utility Climate Alliance (WUCA), twelve of the Nation's
largest water providers, was formed to provide leadership and collaboration on climate
change issues affecting the country's water agencies, most of which also generate
hydropower. WUCA and its member cities advocate the use of climate projections. They
include a set of case studies of how climate change is shifting water utility planning
(Stratus_Consulting_and_Denver_Water 2015) and producing actionable climate
information for utility modeling applications (Vogel et al. 2015). Globally, a number of
peer-reviewed studies were published on use of climate projections in hydropower
planning, including (Cherry et al. 2010; Hamlet et al. 2013; Lee 2016; Taner 2017) in the
U.S. and in Northern Europe (Finger et al. 2012; Frigon 2007).
•The American Society of Civil Engineers (ASCE) recommended the use of climate
change in in design criteria. The ASCE recently reissued a policy statement in 2018,
indicating a growing need for engineers to incorporate future climate change into project
design criteria (http://www.asce.org/issues-and-advocacy/public-policy/policy-statement-
360---impact -of-climate-change).
•The U.S. Bureau of Reclamation and Army Corps of Engineers both use climate
projections in their long range operations planning and design, including hydropower
generation, flood control, and water supply. These agencies jointly commissioned and
released a report that identifies the needs of local, state, and federal water management
agencies for climate change information and tools to support long-term planning (Brekke
2009). Reclamation and a consortium of agencies funded downscaled hydrologic
projections for use in planning for reservoirs and hydropower operations
(Bureau_of_Reclamation 2009) which were then subsequently updated for the next
generation of IPCC global climate models (Brekke 2013), and continue to be updated as
the science of downscaling and bias correction has advanced (Pierce 2014; Pierce et al.
2015).
The downscaled projections we recommend using (see Proposed Study below) follow in this
tradition, based on the same IPCC global climate models. In particular, the University of
Alaska Fairbanks’ Alaska Climate Research Center (http://akclimate.org/) has produced the
Scenarios Network for Alaska and Arctic Planning (SNAP, https://www.snap.uaf.edu).
In its July 18, 2014, Order rejecting the National Marine Fisheries Service and the Center for
Water Advocacy’s requests for rehearing of the formal study dispute determination regarding
Susitna, “as climate change modeling continues to advance, it may eventually yield data and
knowledge that can and should be used to formulate license requirements that respond to
environmental effects caused by climate change.” That time has come. Another generation of
IPCC models has shown consistency with previous IPCC and U.S. National Climate
Assessment analysis, while also providing more detailed and relevant information for natural
resource planners. Downscaled climate projections datasets developed for Alaska (Walsh
2018) and elsewhere are being used in the design and operational planning for hydropower.
33
Proposed study
We request a study similar to the future flow and temperature analyses in (Wobus 2015),
(Leppi 2014), and (Mauger et al. 2016). The steps and data available to do these analyses, are
described below. New climate modeling is not needed. Rather, we request analyses of
existing, publicly available and peer-reviewed datasets (Walsh 2018), using peer-reviewed
and generally accepted practices, as described in those articles and cites therein. The basic
analysis needed is to move from GCM outputs to predicted flows and water temperatures
from a hydrologic model for the Nuyakuk River specifically.
(Walsh 2018) is the peer-reviewed publication that presents the methods and related data
from the Scenarios Network for Alaska and Arctic Planning (SNAP), which is available for
download at this website: https://www.snap.uaf.edu. Their product provides monthly values
of projected future air temperature and precipitation. Monthly values are the minimum
needed for analyses of future flows, but may average out changes. Wobus et al (2015)
generated daily values, and thus were able to discern shorter time scale features in river
flows. If technically feasible and available for the Nuyakuk River, this daily scale is
preferable. If by the time this study is executed, a daily downscaled product is available from
SNAP or by a researcher such as Dr. Wobus (Lynker Technologies), that would be
preferable. Furthermore, a dynamically downscaled product for all of Alaska may be
available soon. Both Walsh 2018 and Wobus 2015 provide good discussions of the choices
involved in downscaling and their choices of GCMs.
a. We recommend use of the Walsh 2018 dataset, an existing, peer-reviewed and
publicly available monthly downscaled climate projection dataset, and related data
from the Scenarios Network for Alaska and Arctic Planning
(https://www.snap.uaf.edu/Project for Alaska). This dataset is based on the latest
IPCC generation of global climate models, and along with related data is available for
download at https://www.snap.uaf.edu/. The Walsh product analyzed the over 35
GCMs to assess which five best represent climates in Alaska as a whole. See (Lader
2017) or (Bieniek et al. 2015) for a more detailed description of the downscaling
model procedure and an evaluation against historical temperature and precipitation
data. Wobus 2015 selected five GCMs, including most of the same GCMs as Walsh
2018, to best represent the climate for the Bristol Bay region.
If a daily product becomes available, that would be preferable because of the finer
time scale changes that daily analyses would detect. Below, where monthly is used,
daily is meant if that product becomes available.
b. Monthly predicted temperatures and precipitation should be analyzed for the first 1/3
of the license, 2027 – 2045; the middle 1/3, 2045-2062; and the final third 2062 to
2077 for the Nuyakuk watershed. This will allow consideration of flow trends over
the period, and potentially different operations as projected conditions change.
c. An accepted hydrologic model should be used to translate these downscaled climate
outputs (precipitation/temperature) into other hydroclimate variables (evaporation,
soil percolation, surface runoff) and ultimately the timing and volume of runoff into
the Nuyakuk River, and stream temperatures. We recommend a hydrologic model
34
such as the MIKE/SHE MIKE 11 modeling system which was used by Wobus et al
(2015) in the upper Nushagak watersed.
The MIKE SHE system (Graham DN 2005) is a fully distributed, parameter
integrated, hydrologic code that simulates the flow of water within and among surface
water, groundwater, and the unsaturated zone. Atmospheric conditions, including
precipitation, air temperature, and evapotranspiration drive continuous flows within
the hydrologic system. A modified degree-day snowmelt method, the code simulates
snow accumulation if air temperatures fall below a freezing threshold (typically 0°F),
and it also simulates snowmelt processes including evaporation (sublimation and wet-
snow evaporation), rain-on-snow, changes in wet and dry snow storage, and
refreezing of wet snow. The Wobus et al (2014) effort, they also implemented a heat
balance algorithm to simulate stream temperatures (Loinaz et al. 2013). The
hydrologic models then projects monthly (or daily) water temperatures based on
predicted air temperature and the relative river contributions from surface water
versus groundwater sources versus snowfields sources.
d.The potential climate change effects should be summarized in a Climate and Flows
Technical Report. This technical report should include a description of the
assumptions made, models used, and other background information. The report will
provide interpretation and guidance on the science knowledge developed, in order to
translate them into useable knowledge, through syntheses and translational products
developed to address the hydropower, water, and fisher habitat needs. Additionally,
this report will include an analysis of the impacts of projections on the project nexus,
and hydropower facilities. The report will include an electronic supplement that
makes the data used in this study available for the use of other studies.
7.§ 5.9 (b): 7.0 Considerations of Level of Effort and Cost
This study can be completed in six months because climate projections for the region
already exist. It will then be ready as input to other studies. The cost is reasonable
considering the PAD estimated that $1,000,000 annually in diesel cost could be avoided
once this project comes online. Correctly sizing turbine and designing them for maximum
efficiency at the flows expected during the license term could change the unit efficiency
by ten percent. Producing daily projected flows and temperatures, compared to monthly,
will increase the cost and time required slightly, but not significantly.
35
Study Request 6
Ice Processes Assessment
Background
The PAD states that Nuyakuk Falls normally remains ice free. The intake upstream of the falls
needs to be specifically designed to prevent icing as ice tends to adhere to any exposed surface
put in the river. Tazimina Falls Hydropower Project (P-11316) is 110 miles away at a similar
elevation. Icing of the intake, caused primarily by frazil ice, was a majo r problem during the first
decade of operation. In 2018, the screen bars were retrofitted to minimize frazil ice clogs. That
system is not designed for smolt exclusion. We anticipate similar issues at the Nuyakuk site
especially given the expectation for exclusion screens.
Ice processes in large rivers are complex. Based on the temperatures in Dillingham during the
first week of 2020 (Figure 1). Icing on the proposed structure would be expected. The Nuyakuk
Falls is 280 feet higher in elevation and 40 miles farther inland than Dillingham, both of which
would suggest the site was colder than Dillingham.
Figure 3. Weather graph for the City of Dillingham demonstrating temperatures for January 2 through 8,
2020.
Frazil ice forms when water emerges from underneath a layer of ice cover and contacts very cold
air. The water becomes super cooled quickly and forms frazil ice. Cold water will emerge from
under a layer of ice cover directly above the intake. Anchor ice forms on the bottom of r ivers by
ice crystals adhering to cobbles and gravel and then floating these particles to the surface. If
small chunks of this ice get into penstock it could damage to hydropower facility.
Climates studies for Bristol Bay (Osterkamp and Gosink 1983) indicate that temperature may
alternate above and below freezing perhaps all winter and through the Spring (April - May). This
rising and falling of temperature around the freezing point could greatly complicate frazil ice
development. Operators at existing northern facilities know that certain sets of actions need to be
taken mid-winter and others during spring breakup to keep their moving mechanism ice free. A
poorly designed facility combined with alternating deep freeze/thaw conditions could require an
operator to be present all winter.
36
Content of Study Request (18 CFR § 5.9 (b))
1. § 5.9 (b): 1.0 Goals and Objectives of Request
Computational Flow Dynamic studies, intake velocities and fish exclusion devices can all
become compromised and/or ineffective once frazil ice, anchor ice, shore ice or ice jams start
to form. For the structures to effectively intake water and simultaneously exclude juvenile
salmon, the intakes must remain clear. Salmon smolt outmigration begins just before ice melt
out in and continue through June. The month the fish exclusion devices must be most
effective is when the ice conditions may be most challenging. The goal of this study is to
evaluate winter conditions to determine how likely frazil and other types of ice is to form at
various times during the year. Three objectives are:
a. Obtain a clearer understanding of the amount of icing that has happened above
Nuyakuk Falls during the last 20 years from satellite or overflight images.
b. Complete a literature search of other facilities and determine which climatic
conditions (temperatures, relative humidity, wind) cause the most challenges.
Compare this to the Future Flows and Temperature study results to determine how
frequently icing problems are likely to develop.
c. Obtain videos from remote cameras during two winters to better understand frazil ice
production processes and spring breakup. Determine if lake ice eddies out in front of
the proposed intake.
2. § 5.9 (b): 2.0 Resource Management Goals
The relevant resource management goals are captured in the NOAA Fisheries strategic Plan
for 2019-2022 (NOAA 2019b) and the Strategic Conservation Action Plan for Southwest
Alaska (SASHP 2017). Identified in NOAA’s strategic plan is the long-term goal of healthy
oceans that support healthy populations of marine species and sustainable commercial and
recreational fisheries. Our involvement is also supported by mandates under the Fish and
Wildlife Coordination Act and Magnuson-Stevens Fishery Conservation and Management
Act.
3. § 5.9 (b): 3.0 Relevant Public Interest Considerations
The requestor, the National Marine Fisheries Service, is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
4. § 5.9 (b): 4.0 Existing Information and Need for Additional Information
Satellite imagery does exist for this area and periods of extreme cold usually occur during
cloud free weeks. These conditions providing excellent images (https://www.sentinel-
hub.com/explore/eobrowser ). Studies exist on the rate of frazil ice formation based on air
temperature, wind speeds and the degree of mixing in the water column (Osterkamp and
Gosink 1983).
37
Ice studies were conducted for the Susitana-Watana project (P-14241) and may have been
conducted for the Tazimina project (P-11316) and Igiugig project (P-13511). Information
from these studies may inform the study plan development.
We recommend the applicant obtain additional information and follow these steps to
complete the study analysis:
1.Obtain satellite imagery for the previous 20 years to quantitatively determine the extent
of ice free water above the falls during different periods of cold temperature patterns.
Weekly or more frequent images November through April would be useful.
2.Create a model based on this information of likely times of year and weather scenarios
that would create frazil ice in the area above the falls.
3.Obtain video or frequent still images at the falls during two winters to better understand
the processes of frazil ice formation and spring breakup. We would expect the first year
that images would start when ice forms on Tikchik Lake and go through mid-April. The
subsequent year could have a narrower time window, once a crosswalk is developed
between average daily temperatures and ice formation. Additionally we recommend
video from a remote camera during ice breakup to understand the size of icebergs that
arrive at the falls. A remote camera, attached to a bank of batteries or solar panel could be
put in place before breakup and removed after.
4.Collect frazil ice information in the Dillingham area during the two study winters. Use
this information to develop a link between frazil ice near Dillingham and frazil ice at the
cascade.
5.Visit Nuyakuk Falls during crucial periods to confirm the strength of the link between
frazil ice formation in the Nushagak in Dillingham and frazil ice at Nuyakuk Falls.
6.Do a literature search of other hydropower facilities with fish exclusion devices in above
55 degrees north. Particularly focus on projects close to the coast where large swings in
temperature mid-winter are common.
5.§ 5.9 (b): 5.0 Nexus Between Project Operations and Effects on the Resource Studied,
and How the Study Results would Inform the Development of License Requirements
The Nuyakuk River supports one of the largest sockeye salmon runs in the world. Any
development creates a risk of reducing the salmon run. This study will help ensure that the
designed infrastructure will function during Bristol Bay’s tough winter environment. Further,
this data will support the development of license articles regarding project operations and
maintenance to ensure the facility generates the power these communities need year -around;
and support the development of mitigation measures to ensure the resources these
communities depend on will remain sustainable.
38
6.§ 5.9 (b): 6.0 Consistency with Generally Accepted Practice
The information gathering described above will support generally accepted practices for
evaluating ice conditions at a new hydropower facility. The study should use existing
scientific protocol for analyzing the collected data.
7.§ 5.9 (b): 7.0 Considerations of Level of Effort and Cost
The only on the ground effort is the annual placement and removal of cameras. The level of
effort/cost is small compared to the value of potentially lost energy due to iced over intake
structure.
39
Study Request 7
Assessment of False Attraction at the Tailrace Fish Barrier
Background
Hydropower project operations can result in false attraction to project works, resulting in
migration delay and loss of productivity. The Nuyakuk Cascades are approximately half way
through a migration of close to 100 miles for some salmon species. Understanding how the
various solutions for preventing false attraction to tailrace discharge will inform t he project
design and licensing process, and lead to more effective and cost efficient mitigation measures
for protecting aquatic resources.
False attraction to a dead end is energetically costly for upstream migrating fish. Adult salmon
have a limited window to reach natal spawning habitat, including habitat above Tikchik and
Nuyakuk Lakes. Therefore, any delay has consequences for the productivity of a salmon run.
Once the tailrace is constructed, fish will choose between trying to go up the tailrace or up the
cascades. Fish clue into velocity, temperature, turbulence, turbidity, olfactory signals and other
sensory clues when deciding which route to take up a river. In an ideal situation very few
returning adults of any species would be attracted to the tailrace. If fish stay in a holding pattern
below the tailrace for days or weeks, it could lower their chance of successful spawning. The
assessment of false attraction will evaluate the potential for delay at the tailrace and the need for
alternative design features to minimize this effect.
In addition to fish returning to an unfamiliar spatial flow patterns at the tailrace, flow volumes
and flow velocities as climate change trends progress may cause flows during migration seasons
to change. Hydrograph peak August flow could be lower as there is no snow melting, and mean
October flows could be much higher. These study requests are interdependent.
Content of Study Request (18 CFR § 5.9 (b))
1.§ 5.9 (b): 1.0 Goals and Objectives of Request
The goal of this request is to evaluate the performance of proposed tailrace location and
design to demonstrate which alternatives do not attract returning adults. The study objects
include:
a.Complete a literature search of tailrace designs with and without fish barriers that
mitigate the false attraction by salmon. This is focused on physical structures to keep
fish out.
b.Propose multiple project tailrace designs/locations with and without barriers based on
other functioning hydropower tailraces that minimize both salmon attraction to the
tailrace area and salmons ability to get through the tailrace barrier.
c.Do a feasibility analysis and select a tailrace design/location in consultation with the
resources agencies. Indicate the percentage of the flow the project will leave in the
river during the months when salmon return as determined by Study Request 1.
d.Use the two dimensional model developed in the Study Request 2 (Upstream
Passage) to demonstrate why the majority of fish will be attracted to one of the three
cascades at the lower end of the falls rather than to the tailrace. For each month where
40
a significant proportion (more than 10% of the run) of a species of concern has
traditionally returned, run the model at the 20% exceedance flow and the 80%
exceedance flow combined with the hydropower facility:
i.operating at 100% capacity and leaving the remaining flow or 1000 cfs,
whichever is greater;
ii.removing 30% of the flow and leaving 70% in the river (current state law);
iii.removing 50% of the flow and leaving 50%;
iv.removing 70% of the flow and leaving 30%.
v.This will potentially generate 20+ scenarios to model, many of which will be
similar. Work with the resource agencies to agree on a set flow/diversion
amounts that represent the range of river conditions and operational plans
during the time adult salmon return.
e.If the model indicates a significant attraction to the tailrace, identify the
conditions below the tailrace will be unfavorable to adult salmon searching for a
different route upriver.
f.Demonstrate that a physical barrier will safely keep fish out of the tailrace.
2.§ 5.9 (b): 2.0 Resource Management Goals
The relevant resource management goals are captured in the NOAA Fisheries Strategic Plan for
2019-2022 (NOAA 2019a) and the Strategic Conservation Action Plan for Southwest Alaska
(SASHP 2017). Identified in NOAA’s strategic plan is the long-term goal of healthy oceans that
support healthy populations of marine species and sustainable commercial and recreational
fisheries. Our involvement is supported by mandates under the Fish and Wildlife Coordination
Act and Magnuson-Stevens Fishery Conservation and Management Act.
3.§ 5.9 (b): 3.0 Relevant Public Interest Considerations
The requestor, the National Marine Fisheries Service, is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
4.§ 5.9 (b): 4.0 Existing Information and Need for Additional Information
At this time, no information about velocities, depths, or turbulence exists in the vicinity of the
proposed tailrace. This study request will fill this information void and allow the applicant and
resource agencies to quantify the risk of a false attraction. Data are accessible to address this
study request. Guidelines exist for tailrace infrastructure designs that do not allow fish to pass
and where the fish do not physically injure themselves while trying to pass (NMFS 2011).
Project studies and literature support an understanding of the functionally of p hysical barriers.
This study will create a bibliography of the effectiveness of various tailrace designs, and then
facilitate the Nuyakuk design for a structure that will meet project goals while protecting a
regionally valuable public trust resource.
41
5. § 5.9 (b): 5.0 Nexus Between Project Operations and Effects on the Resource Studied,
and How the Study Results would Inform the Development of License Requirements
Hydropower project operations can result in false attraction to project works, resulting in
migration delay and loss of productivity. The proposed project represents a new, anthropo genic
impact in an otherwise pristine salmon river. The Nuyakuk Cascades ar e approximately half way
through a migration of close to 100 miles for some salmon species. Understanding how the
various solutions for preventing false attraction to tailrace discharge will inform the project
design and licensing process, and lead to more effective and cost efficient mitigation measures
for protecting aquatic resources.
6. § 5.9 (b): 6.0 Consistency with Generally Accepted Practice
Ensuring that the tailrace does not create a false attractant is generally accepted practice for new
hydropower projects. We anticipate all scientifically accepted practices to be implemented for
the completion of this study.
7. § 5.9 (b): 7.0 Considerations of Level of Effort and Cost
The cost of completing a literature search and evaluating various tailrace designs is reasonable.
The literature search should be completed before the tailrace is designed. Completing the
literature search and using this information to inform design decisions should take several
months to a year. The cost of this study is commensurate with a project of this size, and located
in a valuable natural resource area.
42
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Tuesday, February 4, 2020
Julia Kolberg,
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Submitted via FERC online
Re: Nuyakuk River Hydroelectric Project (P-14873-001)
Nushagak Cooperative Inc. submitted a FERC Pre-Application Document for the Nuyakuk
River Hydroelectric Project (P-14873) on October 7, 2019. And FERC sent out Scoping
Document 1 to interested parties on November 8, 2019. Based on a review of these
documents, I respectfully submit the following questions on behalf of the United Tribes of
Bristol Bay.
General Design and Construction Concerns
•What is the estimated average annual generation capacity of the Project (e.g., is it 72,800
MWh or 55,300 MWh)?
•How much energy is needed for the fish processing and packaging efforts in the summer
versus the heating and electricity needs in the villages?
•Will there just be a single bore tunnel arrangement for the 2 conveyance pipes to the
powerhouse? How long and how far underground will it be?
•Will there be 2 or 3 Kaplan turbines in the powerhouse?
•What is the amount of flow that will be diverted to the intake structure every month of
the year?
•Where will the gravel source be located for the runway and road construction?
•How will the winter ice and low flow conditions, the potential for ice dams, and high
flows during Spring breakup impact the operation of the diversion structure? How will ice
and debris issues be mitigated from impacting the intake on the river bank? Will antifreeze
be used in winter through the intake structure to avoid ice buildup?
•What are the plans for the construction man camp and will it be used in the winter
months? How many people will be needed for the construction phase? Will locals have
hiring preference?
•When will construction of transmission lines occur, how many streams and acres of
wetlands will need to be crossed during construction, and what environmental impacts will
there be during the construction of the transmission lines?
•What will be the barging challenges on the Nuyakuk River to bring in heavy equipment
and turbines to the site? In the Scoping Meeting it was stated that there are navigational
issues near the project site (e.g., only a small 18’ boat can reach the site).
•What is the design of and how long will it take to construct the diversion structure or
groyne? Will a cofferdam be used for the construction of the groyne? How long will the
cofferdam be in place? How will the construction of the groyne impact in- and out-
migrating salmon?
UTBB Headquarters:
P.O. Box 1252
Dillingham, AK 99576
Phone: 907-842-1687
Fax: 907-842-1853
UTBB Member Tribes:
Nondalton Tribal Council
P.O. Box 49
Nondalton, AK 99640
Ph/Fax: 907-294-2257/ 907-294-2271
New Stuyahok Traditional Council
P.O. Box 49
New Stuyahok, AK 99636
Ph./Fax: 907-693-3173/ 907-693-3179
Levelock Village Council
P.O. Box 70
Levelock, Alaska 99625
Ph/Fax: 907-596-3434 / 907-596-3462
Curyung Tribal Council
P.O. Box 216
Dillingham, Alaska 99576
Ph/Fax: 907-842-2384 / 907-842-4510
Ekuk Village Council
P.O. Box 530
Dillingham, Alaska 99576
Ph/Fax: 907-842-3842 / 907-842-3843
Manokotak Village Council
P.O. Box 169
Manokotak, Alaska 99628
Ph/Fax: 907-289-2067 / 907-289-1235
New Koliganek Village Council
P.O. Box 5057
Koliganek, Alaska 99576
Ph/Fax: 907-596-3434 / 907-596-3462
Traditional Council of Togiak
P.O. Box 310
Togiak, Alaska 99678
Telephone: 907-493-5003
Fax: 907-493-5005
Clarks Point Village Council
P.O. Box 90
Clark’s Point, Alaska 99569
Ph/Fax: 907-236-1427 / 907-236-1428
Twin Hills Village Council
P.O. Box TW
Twin Hills, Alaska 99576
Ph/Fax: 907-525-4821 / 907-525-4822
Aleknagik Traditional Council
P.O. Box 115
Aleknagik, AK 99555
Ph/Fax: 907-842-2080 / 907-842-2081
Portage Creek Village Council
1327 E. 72nd Unit B
Anchorage, AK 99518
Ph/Fax: 907-277-1105 / 907-277-1104
Chignik Lake Traditional Council
P.O. Box 33
Chignik Lake, AK 99548
Ph/Fax: 907-845-2212 / 907-845-2217
Pilot Point Tribal Council
PO Box 449
Pilot Point, AK 99649
Ph/Fax: 907-797-2208 / 907-797-2258
Pedro Bay Village Council
PO Box 47020
Pedro Bay, AK 99647
Ph/Fax: 907-850-2225 / 907-850-2221
2
•What are the maintenance requirements for the power plant and transmission lines? Will the power plant
need to be shut down annually, if so for how long?
Miscellaneous Concerns
•What other federal and state permits will be needed for the project?
•How long will the project provide hydroelectric power to the villages (e.g., 20, 50, 100 years)?
•What are the decommissioning plans for the hydroelectric power plant?
•What are other electricity needs besides the villages along the transmission line corridors (e.g., Aleknagik
landfill, Float Plane Road, and Johnny Tugatuk Road) that could benefit from the Project?
•When will an economic feasibility study be conducted and how will the Nushagak Cooperative fund this
Project (e.g., through funds from the State of Alaska, federal funds and/or bank financing)?
Tuesday, February 4, 2020
Julia Kolberg,
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Submitted via FERC online
Re: Study Plan Requests for the Nuyakuk River Hydroelectric Project
(Docket # P-14873-001)
Submitted by United Tribes of Bristol Bay
ENGINEERING FEASIBILITY STUDY PLAN
GOALS AND OBJECTIVES
The goal of the engineering feasibility study is to determine the suitability of the site for
the construction of the infrastructure related to the Nuyakuk River Hydroelectric Project
(Project). Field surveys, bathymetric and topographic mapping will determine the
feasibility of constructing the various Project infrastructure in relation to biological and
physical site conditions. For example, the surveys for bathymetric data and topography
are needed for the hydraulic modeling of specific tunnel designs and generator capacities.
Developing the specific engineering designs of the proposed diversion and intake
structures, project buildings, access roads, airstrip, and transmission lines will need site
specific geotechnical data.
Objectives include the need for geologic borings to define the site bedrock unit
characteristics and a soil survey for proper engineering design and construction plans of
the buildings and underground tunnels (e.g., is the bedrock competent enough for the
conveyance tunnel). The study objectives should also include an evaluation of the
seismicity potential at the site and groundwater conditions that might be impacted during
the construction and operation phases.
RELEVANT RESOURCE MANAGEMENT GOALS
The Project site is designated as a Natural Area in the Wood Tikchik State Park (WTSP)
Management Plan (2002) and the purpose of this Natural Area is to provide for moderate
to low impact, clustered or dispersed forms of recreation, and managed as relatively
undeveloped and undisturbed areas. Therefore the Project needs to provide flow and
sediment regimes that closely mimic natural flows and geomorphological processes as
much as it is biologically and technically feasible, which will then optimize conditions
downstream for aquatic biota life cycles.
UTBB Headquarters:
P.O. Box 1252
Dillingham, AK 99576
Phone: 907-842-1687
Fax: 907-842-1853
UTBB Member Tribes:
Nondalton Tribal Council
P.O. Box 49
Nondalton, AK 99640
Ph/Fax: 907-294-2257/ 907-294-2271
New Stuyahok Traditional Council
P.O. Box 49
New Stuyahok, AK 99636
Ph./Fax: 907-693-3173/ 907-693-3179
Levelock Village Council
P.O. Box 70
Levelock, Alaska 99625
Ph/Fax: 907-596-3434 / 907-596-3462
Curyung Tribal Council
P.O. Box 216
Dillingham, Alaska 99576
Ph/Fax: 907-842-2384 / 907-842-4510
Ekuk Village Council
P.O. Box 530
Dillingham, Alaska 99576
Ph/Fax: 907-842-3842 / 907-842-3843
Manokotak Village Council
P.O. Box 169
Manokotak, Alaska 99628
Ph/Fax: 907-289-2067 / 907-289-1235
New Koliganek Village Council
P.O. Box 5057
Koliganek, Alaska 99576
Ph/Fax: 907-596-3434 / 907-596-3462
Traditional Council of Togiak
P.O. Box 310
Togiak, Alaska 99678
Telephone: 907-493-5003
Fax: 907-493-5005
Clarks Point Village Council
P.O. Box 90
Clark’s Point, Alaska 99569
Ph/Fax: 907-236-1427 / 907-236-1428
Twin Hills Village Council
P.O. Box TW
Twin Hills, Alaska 99576
Ph/Fax: 907-525-4821 / 907-525-4822
Aleknagik Traditional Council
P.O. Box 115
Aleknagik, AK 99555
Ph/Fax: 907-842-2080 / 907-842-2081
Portage Creek Village Council
1327 E. 72nd Unit B
Anchorage, AK 99518
Ph/Fax: 907-277-1105 / 907-277-1104
Chignik Lake Traditional Council
P.O. Box 33
Chignik Lake, AK 99548
Ph/Fax: 907-845-2212 / 907-845-2217
Pilot Point Tribal Council
PO Box 449
Pilot Point, AK 99649
Ph/Fax: 907-797-2208 / 907-797-2258
Pedro Bay Village Council
PO Box 47020
Pedro Bay, AK 99647
Ph/Fax: 907-850-2225 / 907-850-2221
2
According to the WTSP Management Plan any development in the Park shall be sited, designed, and
constructed to minimize impacts upon the natural environment and the area's
scenic quality. And facilities developed in the vicinity of salmon streams and other areas of ecological
importance should plan to mitigate any problem stemming from over-use or other visitor activities. The
WTSP Management Plan states that developments in such areas will only be considered if there is
evidence that the environment will not suffer significant adverse effects.
RELEVANT PUBLIC INTEREST CONSIDERATIONS
It is important that the Project protects and conserves the area's fish and wildlife populations; provides for
the continued use of the area for traditional subsistence and recreational purposes; and to protect the area's
recreational and scenic resources.
DESCRIBE EXISTING INFORMATION AND NEED FOR ADDITIONAL INFORMATION
Limited geotechnical information was collected at the site during summer 2018. Engineers were on site to
look at potential infrastructure locations and collected limited bathymetric survey and water quality data.
Therefore additional topographic, bathymetric, and geotechnical surveys are required at the site to
properly design the diversion structure, conveyance tunnels, tailrace, the access roads, and airstrip.
EXPLAIN THE NEXUS BETWEEN PROJECT OPERATIONS AND EFFECTS ON THE
RESOURCES TO BE STUDIED
The geotechnical information will determine the site design for the Project’s infrastructure.
EXPLAIN HOW ANY PROPOSED STUDY METHODOLOGY IS CONSISTENT WITH
GENERALLY ACCEPTED PRACTICE
Methods for the geotechnical surveys should follow USGS procedures and the field results can be
evaluated with GIS tools to produce site specific maps on bathymetry, topography, soil types and bedrock
geology. For example, acoustic bathymetry surveys often use multi-beam sonar or acoustic device system
to collect stream depth. The Acoustic Doppler Current Profiler (ADCP) are used to measure water
velocity by transmitting sound waves which are reflected off sediment and other materials in the water.
Data collected from ADCPs can then be used for bathymetric maps.
DESCRIBE LEVEL OF EFFORT AND COSTS
A field engineer/geologist with surveying background and a field technician will be needed for the
development of the field study plan, conducting the field work, and post data-collection evaluation using
GIS tools to produce site-specific maps showing the topographic and bathymetric elevations, soil and
bedrock types. An estimated cost for this task is $100,000.
FLOW AND SEDIMENT STUDY PLAN
GOALS AND OBJECTIVES
The goal is to understand the flows necessary for fish passage near the Project, how the Project will alter
sediment transport, and to understand the water quantity, peak flows, and design flows required for the
3
hydroelectric power operation. This information will also determine the exact size and type of
turbine/generator, switchgear, transmissions facilities and other electrical equipment.
It is important that the Project mimics the flow and sediment regimes which provide for the maintenance
and enhancement of channel structure and habitat for aquatic- and riparian-dependent species near the
Nuyakuk Falls. The Project needs to maintain instream flows sufficient to create and sustain riparian,
aquatic, and wetland habitats and to retain patterns of sediment transport crucial to spawning gravels.
Therefore the study needs to determine flows that would alter the route of spawning-gravel-sized
sediments near the project site and that support the riparian and aquatic habitats in the anadromous
habitats near the site.
The objectives are to determine how the outflows from the tailrace will alter spawning gravel size and
sediment transport and what will be the effects from the groyne, or diversion structure, on sediment
transport. The study will need to determine what flows would maintain floodplain characteristics,
determine the area of available aquatic habitat for different species and life stages at different base flows,
and determine how the Project will affect stream morphology and aquatic habitat characteristics.
RELEVANT RESOURCE MANAGEMENT GOALS
The Project should follow the WTSP Management Plan (2002) and maintain and restore the sediment
regime under which aquatic ecosystems evolved. Important elements of the sediment regime include
timing, volume, rate, and characteristic of sediment input, storage, and transport. Since so little of the Park
has experienced habitat disturbance, management of Park resources is a matter of conserving existing
habitat values and ensuring that those values are not lost or degraded. Habitat protection was a central
purpose of the Alaska State Legislature when it established the Park. And according to the Nushagak
River Watershed Traditional Use Area Conservation Plan (2012) any project, including this Project,
should reserve adequate water flow under existing laws for in-stream flow reservations.
RELEVANT PUBLIC INTEREST CONSIDERATIONS
The State of Alaska through ADF&G holds an instream flow reservation for the Nuyakuk River that
ranges between 1,600 and 2,700 cubic feet per second (cfs) during the low flow period in winter. The
Project plans to remove 30% of the flow therefore there will barely be between ~500-900 cfs remaining in
the river. So the amount of water diverted to the powerhouse may not be enough to efficiently produce
electricity, during the critical winter months when the villages need a lot of power for the electricity and
heating needs in their homes.
DESCRIBE EXISTING INFORMATION AND NEED FOR ADDITIONAL INFORMATION
There is a long-term USGS stream gauging station approximately 4 miles upstream of the Project, but
there are 4 major tributaries between the USGS gauging station and the Nuyakuk Falls that contribute
additional flow to the Nuyakuk River. Therefore site specific flow measurements should be collected by
setting up a gauging station upstream and downstream of the Project. Instruments at the gauging stations
should include the ability to measure water height, discharge, water chemistry, and water temperature.
Conducting an on-site physical habitat assessment survey will help us to understand current gravel and
substrates above and below the Project site. The study should define the substrate composition (gravel,
cobbles, boulders, etc.), the riparian vegetation, channel morphology type using the Rosgen classification
system, and should measure the average stream gradient above and below the Project.
4
EXPLAIN THE NEXUS BETWEEN PROJECT OPERATIONS AND EFFECTS ON THE
RESOURCES TO BE STUDIED
The environmental baseline data should be analyzed for the potential impacts due to the construction,
operation and maintenance phases to determine how the Project will alter flow and sediment regimes in
the Nuyakuk River. The flow and sediment regime changes caused by the Project may result in changes
to the physical structure and function of the aquatic and riparian ecosystems and the distribution and
abundance of aquatic and riparian species. Therefore the flow studies need to determine how the
diversion structure, or groyne, will alter the magnitude, frequency and timing of peak flow events, reduce
base flows, and change the sediment regime. This is important because if the sediment transport processes
are altered it may change the spawning gravels present near the site.
The timing, magnitude, duration, and spatial distribution of peak, high and low flows must be protected.
Therefore we need multi-year water depth and flow data to better forecast the flow of the river during all
seasons above and below the Project. The peak flows will be altered by the diversion structure that will
be installed above the Nuyakuk Falls. The flows being discharged from the tailrace will also be different
from the natural background flows below the Falls. Therefore an instream flow study is needed to
understand the flow needed to maintain the seasonal migration patterns of resident and anadromous fish
and the depths and velocities critical for spawning habitats near the Project.
Mean monthly flow in Table 1 of the Preliminary Permit show low flow values occurring in the months of
December through April and range from 1690-3220 cfs. Therefore, it is important to determine how will
these low flows impact the efficiency of the hydroelectric output because these are the coldest and darkest
months and are when the villages are using the most diesel fuel for heating and electricity.
EXPLAIN HOW ANY PROPOSED STUDY METHODOLOGY IS CONSISTENT WITH
GENERALLY ACCEPTED PRACTICE
A stream gage is a structure installed beside a stream or river that contains equipment that measures and
records the water level (called gage height or stage) of the stream. Streamflow (also called discharge) is
computed from measured water levels using a site-specific relation (called a stage-discharge rating curve)
developed from onsite water level and streamflow measurements. The relation between stream stage and
discharge is determined, and a stage-discharge relation (rating) is developed to calculate streamflow for
each recorded stream stage (Rantz et al., 1982). These data are used to calculate the daily mean discharge
for each day at a site. All measurements should be made according to standard USGS procedures (Rantz et
al., 1982; Sauer and Turnipseed, 2010; and Turnipseed and Sauer, 2010).
Physical stream assessment protocols should follow the U.S. Army Corps of Engineers and the U.S.
Environmental Protection Agency guidance document: Physical Stream Assessment - A Review of
Selected Protocols for Use in the Clean Water Act Section 404 Program (September 2004). This
document outlines procedures to define the physical (geomorphological and habitat variables) to assess
stream bank erosion, a stream’s hydraulics and geometry, bank stability, and the pool to riffle percentage
in a stream reach.
DESCRIBE LEVEL OF EFFORT AND COSTS
A hydrologist and a field technician will be needed to develop a comprehensive flow and sediment field
study plan, collect, analyze, and summarize the stream flow and physical stream assessment data.
Logistical costs will include commercial airline flights to Dillingham, helicopter support to transport field
crew to the Project site, room and board during field work, and monthly site visits. The estimated monthly
5
labor requirements for on-site visits would be approximately 40 hours/month for a hydrologist and a
technician. Estimated annual costs are $150,000.
6
FISH SURVEY STUDY PLAN
GOALS AND OBJECTIVES
The goal is to gather presence/absence information, abundance and fish habitat information, to understand
the life stages, life history and distribution for all resident and anadromous species upstream and
downstream of the Nuyakuk Falls Hydroelectric Project.
Objectives of the fish surveys include a biological description including physical descriptions, geographic
distributions, average and record sizes, age and growth characteristics, food habits, predator and prey
dynamics, and use and value to humans. The fish survey should evaluate when the different species use
the Nuyakuk Falls for migration and how their migration changes relative to seasonal flows. The fish
surveys should include a general description of life history phases and description of migratory behavior
for each phase.
The study should identify habitat requirements for each life phase including reproductive, early life, and
adult stage. The habitat assessment should map the percentage of pools versus riffles upstream and
downstream of the Project. It is also important to determine the water depth, velocity, cover and substrate
preferences for the different life stages particularly with respect to seasonal changes in the hydrograph,
and under different climate scenarios.
The survey needs to determine what is the temporal and spatial distribution of each species and life stages.
It needs to evaluate how the diversion structure, or groyne, which could change the behavior and
migration patterns of fish up and down that stretch of river. This is particularly important because the
groyne will change water flows, as a function of stage height. Data needs to be collected on the
abundance for all the anadromous and resident fish species that migrate upstream and downstream of the
Nuyakuk Falls. The study should evaluate the seasonal timing and the timing of the migration relative to
the seasonal hydrograph.
RELEVANT RESOURCE MANAGEMENT GOALS
The Wood Tikchik State Park (WTSP) Management Plan (2002) goals include the protection of the fish
and wildlife resources of the Park, including management of natural habitats and support systems.
Objectives of the WTSP Management Plan include establishing habitat management practices through
consultation and cooperative agreements with the Alaska Department of Fish and Game (ADF&G) to
protect salmon spawning grounds, resident fish populations, critical habitats and distributions of wildlife
populations.
According to the WTSP Management Plan there are extensive spawning grounds located along the
western half of Nuyakuk Lake and the Nuyakuk River outlet. And five species of Pacific salmon [chinook
(king), sockeye (red), coho (silver), pink, and chum] spawn in the Tikchik Lakes systems. ADF&G
estimates that the Park’s waters contribute a significant share of the Bristol Bay commercial sockeye
salmon fishery. Escapement into the Wood and Nuyakuk Rivers often constitutes 20 percent or more of
the total annual Bristol Bay sockeye escapement. The sockeye salmon also play a significant role in the
sport and subsistence fishery in the Park.
Freshwater resident fish are generally prolific throughout the area near the Project. Rainbow trout,
grayling, lake trout, Arctic char, and Dolly Varden abound. Northern pike of good size offer fishing
variety in several of the lakes. According to the WTSP Management Plan the present angling pressure is
estimated to be on the order of 2,000 to 3,000 angler days annually in the Tikchik River system.
7
RELEVANT PUBLIC INTEREST CONSIDERATIONS
The requestor of the study is the United Tribes of Bristol Bay (UTBB), which is a tribal consortium
working to protect the traditional Yup’ik, Dena’ina, and Alutiiq ways of life in Bristol Bay that depend on
the sustainable harvest of the watershed’s renewable resources, most notably Bristol Bay’s wild salmon.
UTBB requests that the surveys be multi-seasonal over at least a 2 year time period. This is important
because there is substantial year to year variation in the hydrograph and we know that fish passage up and
down the Falls changes under different seasonality and magnitudes of the hydrograph. The analyses
should also include scenarios that explore potential hydrograph variations under climate change scenarios.
The survey needs to take into account that thousands of pink salmon are known to spawn above the Falls
on even numbered years; to identify the presence and abundance of both anadromous and resident fish
species because of the subsistence value; and because rainbow trout, grayling and lake trout are known to
move up and down the Nuyakuk Falls through out the year.
DESCRIBE EXISTING INFORMATION AND NEED FOR ADDITIONAL INFORMATION
Extensive fish surveys need to be site specific as defined in the Goals and Objectives Section of this plan
since there has been no site specific fish surveys conducted at the site.
EXPLAIN THE NEXUS BETWEEN PROJECT OPERATIONS AND EFFECTS ON THE
RESOURCES TO BE STUDIES
The Project needs to understand how diverting flow with the groyne structure will impact the aquatic
habitat and the migration routes through the Falls. The Project need to estimate the direct fish mortality or
injury due to turbine entrainment, impingement, or reentry into the powerhouse via the tailrace under
different flow conditions, and an evaluation of the potential delayed mortality downstream (e.g., for
juveniles).
The design of the intake structure and groyne needs to take into consideration how the they will change
the current relationship between the seasonal flow regimes and adult fish migration (e.g., will the groyne
create back eddies and potentially slow the migration of juvenile fish). Reduction of fish mortality can be
accomplished by reducing the flows at the intake and by using fish screens (e.g., Pelton Round Butte
Screens which can be used in flows greater than 5,000 cfs).
The Project needs to ensure that there will be no low flow migration inhibition affects or affects to adult
upstream migration through bathymetric and hydrologic models. The models should estimate flow impacts
on adult fish migration under current conditions and to understand the impacts of reduced flow on juvenile
and adult resident and anadromous fish. The Project also needs to evaluate how the flow of the water at
the tailrace channel into the river will be dissipated so that it is not going to cause a false attraction and
confuse the fish to hang out in this area because of the increased flow and increased water volume.
EXPLAIN HOW ANY PROPOSED STUDY METHODOLOGY IS CONSISTENT WITH
GENERALLY ACCEPTED PRACTICE
The recommended methodology to resolve the migration timings and routes through the Falls is by using a
Dual frequency IDentification SONar (Didson) Acoustic Camera. The Didson technology is used by
ADF&G for detecting fish in rivers and was developed at the University of Washington. This method can
be used to count adult fish migrating up the Falls, smolts and fry moving down the Falls, and what routes
they take across
8
different seasons and under different water stages. This methodology could be supplemented with the use
of aerial drone footage and/or using an underwater video camera.
Field surveys are needed because there is very little site specific data. The surveys will define fish species
composition, distribution, presence/absence, and life history by using acceptable field methods to meet the
study objectives. Sampling methods must conform to the conditions of ADF&G regulations to ensure
minimal risk to aquatic life. Survey methods and timing are subject to restrictions and protocol
requirements identified by ADNR and ADF&G Fish Habitat Permits, or other regulatory requirements.
DESCRIBE LEVEL OF EFFORT AND COSTS
Fish biologists and field technicians will be required to develop the comprehensive field study plan,
conduct the field work, evaluate the survey results, and write up a draft and final summary report. Field
equipment and supplies that will need to be purchased include the Didson hydroacoustic equipment and
other video equipment such as an underwater video camera and drone. The logistical costs include airline
tickets to reach Dillingham, helicopter support to transport the field crew to the site, and room and board
during the field work. An annual estimated cost for this survey is $300,000.
9
WATER QUALITY STUDY PLAN
GOALS AND OBJECTIVES
The goal is to collect baseline water quality data to identify Project effects on water temperature, turbidity,
dissolved oxygen and other parameters which may have adverse effects to the function of the aquatic
ecosystem and detrimental change in habitat for aquatic species.
The objectives are to collect background water quality data (e.g., water temperature, turbidity, suspended
sediment, dissolved oxygen, dissolved gas, nutrients, and pH) for 2 continuous years at monitoring sites
above and below the Falls. It is important that the water quality and the flow rate after the Project is
operating will remain within the range that maintains the biological, physical, and chemical integrity of
the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic
and riparian communities.
RELEVANT RESOURCE MANAGEMENT GOALS
The Project needs to operate and mimic natural processes to the greatest extent possible
because the objective of the Wood Tikchik State Park Management Plan (2002) is to protect and conserve
the area's fish and wildlife populations; provide for the continued use of the area for traditional subsistence
and recreational purposes; and to protect the area's recreational and scenic resources. The Nushagak River
Watershed Traditional Use Area Conservation Plan (2012) states that it is important to monitor and
maintain water quality standards that protect wild salmon and other fish throughout the watershed.
RELEVANT PUBLIC INTEREST CONSIDERATIONS
The Project needs to maintain water quality to a degree that provides for stable and productive ecosystems
(i.e., timing and character of temperature, dissolved oxygen, sediments and nutrients) to support the
current healthy aquatic ecosystem and the important wild salmon fishery in this watershed. The Project
needs to mimic natural processes to the greatest extent feasible to reestablish proper function after the
construction phase and during the operation phase.
DESCRIBE EXISTING INFORMATION AND NEED FOR ADDITIONAL INFORMATION
Very limited water quality has been collected and the Project may alter water temperature, dissolved
oxygen concentrations, and other water quality parameters and consequently degrade aquatic habitats
downstream. Therefore it is important to collect environmental baseline data for background water quality
conditions. Once the plant is operational it will be important to monitor the temperature of the water after
it flows through the Powerhouse and after it is discharged at the tailrace. The water discharged in the
tailrace channel may also change the dissolved oxygen values and therefore should be monitored because
a change in the oxygenation of the water could impact the fish.
It is important to integrate the water quality study results with the flow study and fish surveys to determine
what effects on-going water temperature regimes and water quality outflows have on the aquatic habitat
and fish species. This integrated study should identify the life history stage and levels in the food web
most sensitive to changes in water temperature, and to identify where the movement or migration of fish is
affected by project effects to temperature.
10
EXPLAIN THE NEXUS BETWEEN PROJECT OPERATIONS AND EFFECTS ON THE
RESOURCES TO BE STUDIED
The operation of the the diversion structure, hydroelectric powerhouse, and water discharged into the
Nuyakuk River at the tailrace will change the water quality and therefore water quality parameters need to
be monitored before and during the construction and operation of the Project.
EXPLAIN HOW ANY PROPOSED STUDY METHODOLOGY IS CONSISTENT WITH
GENERALLY ACCEPTED PRACTICE
Water quality protocols for the collection of field parameters and surface water samples should follow
USGS protocols that are described in the National Field Manual for the Collection of Water Quality Data
and the Water Quality Sampling by the USGS-Standard Protocols and Procedures (2010). These
documents include the methods and protocols for sampling surface water, methods for processing water
quality samples for analysis, and methods for measuring field parameters. The water quality parameters
collected should include the 6 most important indicators of water quality (e.g., temperature, dissolved
oxygen, pH, conductivity, total dissolved solids, and suspended nutrients).
DESCRIBE LEVEL OF EFFORT AND COSTS
A water quality specialist/hydrologist and a field technician will be required to develop the field study
plan, to conduct the field work, to evaluate the water quality results, and write up a draft and final
summary report. Field equipment and supplies needed include a multi-parameter water quality meter,
sample vials, miscellaneous field and office supplies. The logistical costs include airline tickets to reach
Dillingham, helicopter support to transport the field crew to the site, and room and board during the field
work. An annual estimated cost for this survey is $50,000.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. August 2022
APPENDIX C:
Nexus Between the Project and Fish Populations, by Proposed Fish Study
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. C-1 August 2022
1. Appendix C – Nexus Between the Project and Fish Populations, by Proposed Fish Study
The potential for the Project to impact the fish community and aquatic habitats in the Project vicinity will be evaluated with the six studies
proposed in Section 4. This appendix provides the foundation that was used for study development. The first section, Project Nexus Statements
characterize the connections from Project-related changes to potential impacts and identifies the questions that the studies will address, as well
as likely monitoring and adaptive management that may be required once the Project is operating. The second section is a list of specific
hypotheses that will be addressed through implementation of the empirical and modeling studies. These will be synthesized with the Integrated
Risk Assessment to provide a comprehensive assessment of potential Project impacts of the fish community and aquatic habitats in the vicinity
of the Project. 2. C1. Project Nexus Statements
Primary Nexus: Project operations will divert river water through the powerhouse and return it to the river below the Falls Reach via a tailrace,
so fish habitat will be affected via decreased flow through the Falls. Regional climate will determine the flow and temperature of water entering
the Project Area and may affect operations (due to flow changes) or have effects on fish (due to flow and water temperature changes).
Secondary Nexus: Physical Project components (e.g., groin, intake, tailrace) will replace existing fish habitat with flow control structures
upstream and downstream of the Falls thereby altering habitat characteristics at those locations.
Note: Each Nexus statement (1a through 4a) below is written with the preface of “Project structure and/or operations may have a potential
effect on, e.g., 1a Upstream passage behavior and survival of fish through the Falls Reach”, etc.
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Table 1. Nuyakuk River Hydroelectric Project Nexus with Aquatic Habitats and Functions: Potential Impacts on the Timing, Distribution, and
Overall Success of Fish Moving Upstream and Downstream Through the Falls Reach (defined as the river reach from the point of proposed
intake to the downstream end of the pool adjacent to the proposed tailrace). This Nexus relates to downstream passage via powerhouse
entrainment or the Falls Reach in Nexus #2a, and stranding/trapping in Nexus #3a.
Project Nexus #1a Upstream passage, behavior and survival of fish through the Falls Reach
Structural/Operational
Source of Impact
River flow will be diverted above the Falls proper and through the powerhouse at a variable rate. Some river
habitat will be replaced with water conveyance structures.
Conditions/Habitats
Affected
Upstream passage conditions and habitats within the Falls Reach of the Nuyakuk River.
Potential changes in
conditions/habitats
Will reduce the quantity of river flow and distribution of flow through the Falls Reach and alter the
depth/velocity distributions and the quantity and composition of habitats suitable for upstream passage.
Potential effects on fish 3.Changes in depth, velocity and habitat composition may impair or improve upstream fish passage
conditions (variable by species and size) compared to baseline and affect their behavior. Reduction in
pathways or passage opportunities may affect the timing and distribution of migrating fish and/or
reduce numbers of fish upstream of the Project. An increase in pathways or passage opportunities may
also affect temporal distribution of migrating fish and increased numbers of fish upstream of the Project.
4.Reduced total aquatic habitat available for upstream passage may increase fish density and respective
density dependent ecological effects (e.g., predation, injury, stress).
5.There may be interactive effects between future climate change and flow conditions, including reduced
or increased flow overall and during specific seasons. Must consider potential interactive effects
between increased temperatures and passage metrics.
Metrics and criteria to
evaluate the change to
habitat and fish passage
1.Metric - Depth and velocity output from 2D modeling under different flow conditions, With and Without-
Project.
Criteria - Established depth, swimming speed and jumping criteria will be linked to outputs from 2D
modeling to spatially determine areas of suitable/unsuitable passage under different flow conditions.
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Will generate probability distributions of migration pathways (scale TBD; e.g., ranked according to highly
likely, likely, possible, unlikely).
2.Metric - Passage success and pathways under different flows, With and Without-Project.
Criteria - Comparisons between 2D model predictions and empirical data (measures of passage success
and identification of pathways).
Comparison between 2D model predictions for attraction and empirical staging times and locations to
evaluate potential delay due to conditions in the Falls Reach.
Potential ancillary information on fallback/dropback rate, size frequency distribution of run, temporal
distribution, incidence of injury/mortality, and others (Related to Nexus 4a).
3.Metric - 2D model predictions linked with Habitat Suitability Criteria (HSC) (e.g., adult holding; adult
jumping/plunge pool area), With and Without-Project.
Criteria – Comparison of suitable upstream passage related habitat quantities under different flow
conditions.
4.Metric – Fish density in pathways, With and Without-Project.
Criteria – Comparison of modeled fish density in pathways under different flow conditions.
5.Metric – Survival to spawning for fish successfully passing the Falls Reach, With and Without-Project.
Criteria – Compare probability distributions of latent/pre-spawn mortality.
Comparison Basis:
-With and Without-Project hydrologic conditions as predicted from 2-D model. Potential for flow field
changes to affect behavior of fishes depending on the proportion of flow through the Falls Reach.
-Probability distributions of suitable passage metrics and habitat conditions. If probabilities are similar or
higher between With and Without-Project operations, then likely no effect.
-Comparison of likelihood estimates of successful passage based on simulations.
-For Sockeye and Chinook salmon, probabilities can be linked to the appropriate Life Cycle model to
determine upstream related Project effects on individuals and population.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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Operational Considerations Timing and quantity of flow through the Project may be adjusted to minimize risk of negative effects.
Engineered manipulations of passage routes could alter flow patterns and direct flows to improve passage
conditions within pathways.
Monitoring and Adaptive
Management
Flow based assessments and observations. With-Project evaluation of flow pathways. Assessment of fish
passage by observation or trapping in the Falls Reach (movement, jumping, aggregations, predation, pre-
spawn mortalities, injuries). Assessment of habitat composition and connectiveness, incidence of fish-
unfriendly conditions.
Project Nexus #1b Downstream passage and behavior of fish through the Falls Reach
Structural/Operational
Source of Impact
River flow will be diverted above the Falls proper and through the powerhouse at a variable rate. Some river
habitat will be replaced with water conveyance structures.
Conditions/Habitats
Affected
Downstream passage conditions and habitats within the Falls Reach of the Nuyakuk River. A new
downstream passage route will be available through the Project. A proposed groin upstream of the intake
and a tailrace downstream of the powerhouse would change flow fields along the left bank of the river
(facing downstream)
Potential changes in
conditions/habitats
Will reduce the quantity of river flow and distribution of flow through the Falls Reach and alter the
depth/velocity distributions within pathways used for downstream passage, and the quantity and
composition of habitats suitable for downstream passage. Proposed groin adjacent to the intake and a
tailrace downstream of the powerhouse could create eddy conditions or change other flow field
characteristics.
Potential effects on fish 1.Changes in depth, velocity and habitat composition may impair or improve downstream fish passage
conditions. Migration pathways may change and affect passage run timing (seasonally and diurnally) and
distribution.
2.Reduced total aquatic habitat available for downstream passage may increase fish density and respective
density dependent ecological effects (e.g., predation, injury, stress).
3.Changed hydraulic conditions (e.g., eddy) could delay small fish (e.g., salmon fry or parr) or modify their
diurnal timing of passage.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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4.There may be interactive effects between future climate change and flow conditions, including reduced
or increased flow overall and during specific seasons. Consider interactive effect between increased
temperatures and passage metrics.
Metrics and criteria to
evaluate the change to
habitat and fish passage
1.Metric – Depth, velocity habitat output from 2D modeling under different flow, With and Without-Project.
Criteria – Comparison of particle travel times under different flow conditions, Without and With-Project –
(assumes passive downstream migration) and compare potential injury risk areas;
Assess depth/velocity matrices and drop features within the Falls Reach to identify and compare potential
injury risk areas (With and Without-Project).
2.Metric - Estimates of downstream passage timing through the Falls Reach.
Criteria – Compare peak number per day and trends past a location above and below the Project;
3.Metric - Vertical and horizontal distribution of downstream migrating fishes in the vicinity of the intake.
Criteria – Comparison of relative distribution, Without and With-Project. Modeled flow field
characterization may provide inferences to fish distribution.
4.Metric – Fish density in pathways, With and Without-Project.
Criteria – Comparison of modeled fish density in pathways under different flow distribution.
Comparison Basis:
-With and Without-Project hydrologic conditions as predicted from 2-D model. Potential for flow field
changes to affect behavior of fishes depending on the proportion flow through the Falls Reach.
-Probability distribution of suitable downstream passage metrics and habitat conditions. If the
probabilities are similar or higher between baseline and operations, then likely no effect.
-Comparison of likelihood estimates of successful passage based on simulations.
-For Sockeye and Chinook salmon, probabilities can be linked to Life Cycle model to determine
downstream related Project effects on individuals and population.
Operational Considerations Timing and amounts of flow through the Project may be adjusted to minimize risk of negative effects.
Engineered manipulations of passage routes could alter flow patterns and direct flows to improve passage
conditions within pathways. Selection of fish friendly turbines will affect passage success through the
Project.
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FERC No. 14873 Revised Study Plan
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Monitoring and Adaptive
Management
Flow based assessments and observations. With-Project evaluation of flow conditions and pathways.
Assessment of fish passage by observation or trapping in the Falls Reach (movement, aggregations,
predation, injuries). Assessment of habitat composition and connectiveness, incidence of fish-unfriendly
conditions. Monitoring of route-specific and overall timing and passage survival. Monitoring for fish delay
associated with groin eddy or tailrace. Predator (fish, avian, mammalian) distribution and abundance.
Project Nexus #1c Rearing habitat in the Falls Reach
Structural/Operational
Source of Impact
River flow will be diverted above the Falls proper and through the powerhouse at a variable rate. Some river
habitat will be replaced with water conveyance structures.
Conditions/Habitats
Affected
Rearing habitat (areas for refuge, feeding, holding, moving) for fish within the Falls Reach of the Nuyakuk
River.
Potential changes in
conditions/habitats
Will reduce the quantity of river flow and distribution of flow through the Falls Reach and alter the
depth/velocity distributions within rearing habitats, and the quantity and composition of habitats suitable
for rearing. Channel configuration, substrate composition, and the composition and configuration of rearing
habitat below the Falls proper could be modified. Anticipate seasonal changes associated with operations.
Potential effects on fish 1.Changes in depth/velocity may reduce or increase the total quantity of rearing habitat (as defined by
depth/velocity suitability indices) in the Falls Reach. Reduced total aquatic habitat may increase fish
density and respective density dependent ecological effects (e.g., feeding opportunity, predation, injury,
stress).
2.Changes in habitat below the Falls proper may affect a prime feeding area for resident fish.
3.There may be interactive effects between future climate change and flow conditions, including reduced
or increased flow overall and during specific seasons. Consider interactive effect between increased
temperatures and respective metrics.
Metrics and criteria to
evaluate the change to
habitat and fish passage
1.Metric - Depth and velocity output from 2D modeling under different flow conditions, With and Without-
Project.
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Criteria – Comparison of the quantity, composition, and distribution of rearing habitat (e.g., # pools, tail
outs) for fish using Habitat Suitability Criteria (HSC) values derived from the 2D model to define the area
of habitat under different flow conditions, by different species.
Probability distribution of available rearing habitats, With and Without-Project. If the probabilities are
similar or higher between baseline and operations, then likely no effect. For Sockeye and Chinook
salmon, probabilities could be linked to Life Cycle model to determine the effect of rearing habitat
changes in the Falls Reach on individuals and the population as related to Project operations.
Metric – Distribution and relative abundance of resident fish below the Falls proper.
Criteria – Seasonal distribution and relative abundance changes, With and Without-Project.
Comparison Basis:
- With and Without-Project hydrologic conditions as predicted from 2-D model. Potential for flow field
changes to effect behavior of fishes depending on the proportion flow through the Falls Reach.
- Probability distribution of suitable habitat rearing conditions. If the probabilities are similar or higher
between baseline and operations, then likely no effect.
- For Sockeye and Chinook salmon, probabilities can be linked to Life Cycle model to determine
downstream related Project effects on individuals and population.
Operational Considerations Timing and quantities of flow through the Project may be adjusted to minimize risk of negative effects to
habitat in the Falls Reach.
Monitoring and Adaptive
Management
Flow based assessments and observations. With-Project evaluation of flow conditions and pathways.
Assessment of habitat use by observation or trapping in the Falls Reach (refuge, feeding, holding, moving,
aggregations, predation). Assessment of habitat composition and connectiveness, incidence of fish-
unfriendly conditions (e.g., trapping or stranding areas; development of predator (fish, avian, mammalian)
stations).
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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Table 2. Nuyakuk River Hydroelectric Project Nexus with Aquatic Habitats and Functions: Potential Direct and/or Indirect Mortality of
downstream moving Fish Due to passing via the powerhouse (entrainment) or the Falls Reach. Relates to stranding/trapping in Nexus 3a.
Project Nexus 2a Downstream passage and survival. Fish may pass downstream through the powerhouse (entrainment) or
through the Falls Reach.
Structural/Operational
Source of Impact
River flow will be diverted above the Falls proper and through the powerhouse at a variable rate. Some river
habitat will be replaced with water conveyance structures.
Conditions/Habitats
Affected
Downstream passage conditions and habitats within the Falls Reach of the Nuyakuk River. A new
downstream passage route will be available.
Potential changes in
conditions/habitats
Will reduce the quantity of river flow and distribution through the Falls Reach and alter the depth/velocity
distributions within pathways used for downstream passage, and the quantity and composition of habitats
suitable for downstream passage in the Falls Reach.
Potential effects on fish 1. Changes in depth, velocity and habitat composition may impair or improve downstream fish passage
conditions through the Falls Reach compared to baseline. For example, slower velocities and shallower
depths may improve survival rates through the reach (less turbulence and potential abrasion, injury). In
contrast, lower velocities and depths may predispose fish to lower survival due to predation. Also, an
increase of rearing habitats (pools) within the Falls Reach could increase predation risk for downstream
migrating salmon.
2. Migration pathways may change and total aquatic habitat available may decrease in the Falls to affect
passage survival and respective density dependent ecological effects (e.g., predation, injury, stress).
3. Passage through the Project will offer novel conditions that may result in differential survival and injury
as compared to the Falls Reach. Fish survival and physical condition could be affected by abrasion from
concrete infrastructure, impingement on gates and screens, strikes with turbines, and predation in or
adjacent to the tailrace structure. Differential injury or stress on fish between the routes may
potentially cause a higher, latent mortality for route-specific fish after leaving the Project Area.
4. There may be interactive effects between future climate change and flow conditions, including reduced
or increased flow overall and during specific seasons. Increased temperature from climate change and
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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expansion of predator (fish, avian, mammalian) habitat could increase predation rates of small
fishes/lifestages. Consider interactive effect between increased temperatures and passage metrics.
Metrics and criteria to
evaluate the change to
habitat and fish passage 1.Metric – Depth, velocity and habitat output from 2D modeling under different flow conditions, With and
Without-Project.
Criteria – Proportions of flow through the Project and the Falls Reach, pathways and areas of
suitable/unsuitable passage, particle travel times;
2.Metric – Literature derived estimates of powerhouse passage survival effected by impingement, fish-
friendly turbines, and predation in the tailrace.
Criteria – Comparison with empirically derived estimates of survival;
3.Metric - Estimates of empirically derived downstream survival through the Falls Reach.
Criteria – Comparison of rates of downstream passage survival between powerhouse and Falls Reach fish,
Without and With-Project.
4.Metric – Proportional rate of injury for fish passing the Falls, With and Without-Project, and incidence of
injury through the powerhouse.
Criteria – Compare estimates of injury rate of fish passing through the powerhouse and Falls.
Comparison Basis:
- Probability distributions of suitable passage metrics and habitat conditions. If probabilities are similar or
higher between With and Without-Project operations, then likely no effect. Comparative analysis of
predicted injury and mortality between Falls, With and Without-Project, and through Project routes.
-Probabilities can be linked to Life Cycle model to determine upstream related Project effects on
individuals and population.
Operational Considerations Turbine type, flow distribution across routes and timing, engineering design (gates, screens, tailrace) for
higher passage survival in the Falls Reach
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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Monitoring and Adaptive
Management
Flow based assessments and observations. With-Project evaluation of flow conditions and pathways.
Observation of habitat use by fish in the Falls Reach (moving, aggregations). Assessment of habitat
composition and connectiveness, incidence of fish-unfriendly conditions. Predator (fish, avian, mammalian)
distribution and abundance.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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Table 3. Nuyakuk River Hydroelectric Project Nexus with Aquatic Habitats and Functions: Potential Stranding or Trapping of Fishing the Falls
proper, and potential dewatering or scouring of spawning habitat below the Falls and tailrace. Due to Rapid Flow Reductions (Down-
ramping). Relates to migration pathways and total habitat in Nexus 1b, suitable conditions for rearing in Nexus 1c, and direct/indirect
mortality in Nexus 2a.
Project Nexus 3a Pathways for movement. Potential stranding or trapping of fishes in the Falls Reach
Structural/Operational
Source of Impact
River flow will be diverted above the Falls proper and through the powerhouse at a variable rate. Some river
habitat will be replaced with water conveyance structures.
Conditions/Habitats
Affected
Rearing habitats and passage corridors within the Falls Reach of the Nuyakuk River.
Potential changes in
conditions/habitats
Rapid changes in flow operations may result in rapid decreases or increases in flow through the Falls Reach.
Some fringe habitats/corridors may become dewatered stranding fish, or as water recedes fish may be
trapped in small, isolated pools.
Potential effects on fish 1. Rapid flow changes may render fringe habitats/corridors dewatered or partially dewatered resulting in
potential stranding and/or trapping of small fish such as (e.g., salmon fry).
Metrics and criteria to
evaluate the change to
habitat and fish passage
1. Metric - Review of bathymetry and depth and velocity output from 2D modeling to identify areas with a
high likelihood for getting disconnected from flow (e.g., perched depressions; gently sloping lateral
margins; complex lateral habitats with widely variable topography).
Criteria - Evaluate and compare stranding and trapping potential by running different operational
ramping rate scenarios and seeing how identified risk areas respond in terms of the timing to
disconnection, trapping and stranding, and the total areas affected. Quantify and characterize
identified areas as high or low likelihood. High concern area is characterized as areas that are perched
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and highly sensitive to flow changes; low concern areas have depressions that only become
disconnected under extremely low flow conditions.
2.Metric – modeled rate of mortality for fish stranded/trapped.
Criteria - use life cycle model and a distribution of mortality rate for sensitivity analysis of
stranding/trapping under flow scenarios.
Comparison Basis:
-Comparison of (a) total trapping/stranding area (m2) under With and Without-Project operations, and
(b) modeled mortality estimates With and Without-Project based on different down-ramping rates.
-Results linked to life cycle model as source of influence on juvenile/smolt/fry survival rates through the
Falls Reach.
Operational Considerations Rate of change in flow directed through the turbines. Sequence and timing of turbine start up and shut
down.
Monitoring and Adaptive
Management
With-Project monitoring of topography of the Falls proper to identify specific locations for fish stranding and
or trapping low flow condition. Monitor program during downstream fish migration during; conduct post –
flow change monitoring of areas at risk to see if any trapping or stranding has occurred.
Project Nexus #3b Spawning habitat below Falls and tailrace. Potential for dewatering or scouring.
Structural/Operational
Source of Impact
Operational changes in flow rate and distribution through the powerhouse and the Falls Reach.
Conditions/Habitats
Affected
Potential spawning habitats downstream of the Falls and tailrace.
Potential changes in
conditions/habitats
Changes in operations may result in decreases or increases in flow through the Falls Reach. Decreases may
result in some fringe habitats used for spawning (if present) to become dewatered. Rapid increases may
result in some scouring of these areas. Water flow, water elevation, river channel configuration, and
distribution of substrate composition may create suitable spawning habitat in new locations.
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Potential effects on fish 1. Flow reductions may render fringe spawning habitats dewatered or partially dewatered resulting in
potential egg desiccation or reduced embryo survival (reduced intragravel velocities).
2. Rapid flow increases may scour redds and dislodge eggs/embryos.
3. Suitable habitat for spawning may be created by new hydraulic conditions of the Project.
4. There may be interactive effects between future climate change and flow conditions, including reduced
or increased flow overall and during specific seasons. Consider interactive effect between increased
temperatures and passage metrics.
Metrics and criteria to
evaluate the change to
habitat and fish passage
1. Metric – Evaluate2D model flow field and water elevations below the Falls and tailrace over several
operational scenarios including different ramping rates, to determine whether and extent to which
potential spawning areas might be affected (dewatered, scoured etc.).
Criteria – Identify flow field and elevation changes may result in potentially erosive or dewatering
conditions, or the development of new suitable spawning locations.
2. Metric - Observations and demarcation of spawning gravel distributions downstream of the Falls proper,
including within and downstream of the proposed tailrace. If possible, collect substrate samples to
verify size classes present.
Criteria - If spawning observed, review output form 2D model to define areas where potential changes
in operational flows could dewater or scour redds. Relate potential impact area to potential for fish
incubation effects based on estimates of redds/square meter and embryo per redd estimates obtained
from the literature.
Comparison Basis:
- Comparison of (a) area of spawning/incubation habitat under With and Without-Project operations, and
(b) potential effects to embryo mortality under With and Without-Project operations.
- Results linked to life cycle model as source of influence on juvenile/smolt/fry survival rates through the
Falls Reach.
Operational Considerations Timing and sequence of turbine start up and shut off. Rate of change of intake flow through the
powerhouse.
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Monitoring and Adaptive
Management
With-Project observational monitoring for redds for the area downstream of the Falls proper to downstream
of the tailrace. The area of interest may modify depending on shifts in channel in substrate because of
Project operations.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
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Table 4. Nuyakuk River Hydroelectric Project Nexus with Aquatic Habitats and Functions: Potential migration delay and injury may result in
the delayed passage timing and/or latent mortality of fish moving upstream due to false attraction to the tailrace or changes in habitat
below the Falls proper. Relates to upstream moving fish in Nexus 1a.
Project Nexus #4a Timing, behavior, and passage routes of upstream moving fish entering the Falls proper.
Structural/Operational
Source of Impact
Operational changes in flow rate and distribution through the powerhouse/tailrace and the Falls Reach.
Some river habitat will be replaced with water conveyance structures.
Conditions/Habitats
Affected
Flow field and the proportion of flow coming through the Falls Reach and tailrace. Channel configuration
and habitats below the Falls proper could be modified.
Potential changes in
conditions/habitats
Project operations will result in a higher proportion of flow in the tailrace compared to the Falls Reach
tailout and may change the flow field, channel configuration, and water depths/velocity below the Falls
proper. The composition, configuration, connectivity, and suitability of holding/staging/migration/ascension
habitats downstream of the Falls proper and tailrace may change.
Potential effects on fish 1.Changes in holding/staging/migration/ascension habitats below the Falls proper may become less
suitable or connected and result in delayed passage through the Falls or higher rates of injury.
Anadromous migrants may have higher rate of latent mortality prior to spawning. Resident migrants
may arrive later or not at all to destinations associated with their life history.
2.Upstream migrating fish may be attracted to the predominant flow of the impassible route of the
tailrace and thereby be delayed in finding the migration pathway into the Falls proper or subject to
higher rates of injury.
3.Adult salmon attracted to turbine discharge into the tailrace could be injured jumping at draft tubes or
other structures.
4.Fish may expend additional energy related to 1) the alteration of holding /staging/migration/ascension
habitat immediately below the Falls proper or 2) time and effort being falsely attracted to the tailrace
and result in premature mortality.
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Metrics and criteria to
evaluate the change to
habitat.
1.Metric - Depth and velocity output from 2D modeling under different flow conditions (With and
Without-Project).
Criteria - Identification and assessment of potential changes to holding/staging/migration/ascension
habitats (quantity, composition and flow characteristics) and the effect on migration into the Falls proper.
2.Metric – Assessment of the mixing of flow fields from the tailrace and Falls Reach. May provide an
indication of potential for and severity of false attraction to the tailrace.
Criteria - Depth and velocity vector values can be compared to standards developed by NMFS for fish
passage at hydropower facilities.
3.Metric - Observations or telemetric data of numbers and timing of fish holding/milling/searching
immediately downstream of the Falls proper and tailrace compared to numbers successfully passing the
Falls Reach (i.e., above the Project).
Criteria – A relative increase in the number of fish below the Falls proper compared to the number
passing the Falls proper may indicate a delay in passage timing. Fish holding/milling for extended time at
locations further downstream With-Project.
4.Metric - Ratio of number migrants upstream versus downstream of the Falls Reach, With and Without-
Project.
Criteria – A decrease in ratio would indicate fewer migrants are successfully passing the Falls Reach.
5.Metric – Observed rate of injury or mortality of fish below the Falls proper and tailrace. Observation of
migration jumping at unpassable structures.
Criteria – Observed higher incidence of injury or mortality With-Project may indicate unsuitable habitat
conditions. Information gleaned from analysis can be parameterized into Life cycle model as a mortality
factor.
6.Metric – use life cycle model analyses to address the potential energy expenditure effect (#4).
Criteria – Assess the potential quantity of delay time that would cause latent pre-spawn mortality in
migrating salmon due the additional energy used during the delay.
Comparison Basis:
-Rates of injury, delay, milling compared to expected values.
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Operational Considerations Engineered modifications to tailrace outflow, rerouting of flow from turbines, physical methods to prevent
fish from entering the tailrace
Monitoring and Adaptive
Management
Monitoring of fish behavior at tailrace and in the holding pool downstream of the Falls. Estimates of injury
and mortality in the tailrace. Monitoring of passage success.
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3.C2. Hypothesis Statements
Null Hypothesis Alternative Hypothesis Example Values Example Metric
Comparative metrics for pre- and With-Project conditions, given natural variability. The
metrics for Hypotheses 2,3,4,5,7 are intended for sensitivity analysis with the Life Cycle
Model to ascertain the magnitude to which these relations may be important in the risk
analysis. However, this does not exclude the potential need for validation of the
relationships that are demonstrated to be sensitive to change and form the basis of
collecting the necessary empirical data for the Nuyakuk (e.g., tower counts of adults and
hydroacoustic counts of juveniles for salmon). Blue shade indicates a sequence which
potentially leads to reduced long term production and sustainability of the population.
DIRECT Effect - H1N. The
probability of upstream
passage success through
the Falls will be similar.
Life Cycle Transition 1.
Metric(s) 1a2
H1A1. The probability of upstream passage success
through the Falls will be significantly lower under With-
Project conditions relative to Without-Project.
Without-Project = 0.90
With-Project = 0.80
Probability of upstream
passage success through
the Falls (from a
calibrated fish passage
model). A lower
probability can result in
a decreased population.
H1A2. The probability of upstream passage success through
the Falls will be significantly higher under With-Project
conditions relative to Without-Project.
Without-Project = 0.90
With-Project = 1.0
DIRECT Effect - H2N. The
ratio of upstream-Project
to downstream-Project
adult migrants will be
similar. Life Cycle
Transition 1. Metric(s)
4a4
H2A1. The ratio of upstream-Project to downstream-
Project adult migrants will be significantly lower (i.e.,
relative decrease in spawners upstream the Project) under
With-Project conditions relative to Without-Project.
Without-Project = 0.90
(9:10)
With-Project = 0.80
(8:10)
Number of adult
migrants upstream-
Project and
downstream-Project. A
lower ratio can indicate
a lower passage success
and can result in a
decreased population.
H2A2. The ratio of upstream-Project to downstream-
Project adult migrants will be significantly higher (i.e.,
relative increase in spawners upstream the Project) under
With-Project conditions relative to Without-Project.
Without-Project = 0.90
(9:10)
With-Project = 1.0
(10:10)
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INDIRECT Effect - H3N.
The ratio of upstream-
Project juvenile migrants
to upstream-Project adult
migrants will be similar.
Life Cycle Transition 2.
Metric(s) 1b2, 4a4
H3A1. The ratio of upstream-Project juvenile migrants to
upstream-Project adult migrants will be significantly lower
(i.e., relative increase in adult delayed mortality through
the Project) under With-Project conditions relative to
Without-Project.
Without-Project =
100.0 (100:1)
With-Project = 50.0
(50:1)
Number of juvenile
migrants upstream-
Project and number of
adult migrants
upstream-Project. A
lower ratio can indicate
fewer successful
spawners and result in a
decreased population.
H3A2. The ratio of upstream-Project juvenile migrants to
upstream-Project adult migrants will be significantly higher
(i.e., relative decrease in adult delayed mortality through
the Project) under With-Project conditions relative to
Without-Project.
Without-Project =
100.0 (100:1)
With-Project = 150.0
(150:1)
DIRECT Effect - H4N. The
ratio of downstream-
Project juvenile migrants
to upstream-Project
juvenile migrants will be
similar. Life Cycle
Transition 3. Metric(s)
1b2
H4A1. Ratio of downstream-Project juvenile migrants to
upstream-Project juvenile migrants will be significantly
lower (i.e., relative decrease in juvenile outmigrants
downstream the Project).
Without-Project = 0.90
(9:10)
With-Project = 0.80
(8:10)
Number of juvenile
migrants downstream-
Project and upstream-
Project. A lower ratio
indicates lower survival
and can result in a
decreased population. H4A2. Ratio of downstream-Project juvenile migrants to
upstream-Project juvenile migrants will be significantly
higher (i.e., relative increase in juvenile outmigrants
downstream the Project).
Without-Project = 0.90
(9:10)
With-Project = 1.0
(10:10)
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. C-20 August 2022
INDIRECT Effect - H5N.
The ratio of downstream-
Project juvenile migrants
by brood year to
downstream-Project
returning adult migrants
by brood year, compared
to ratios observed in other
systems, will be similar.
Life Cycle Transition 4.
Metric(s) 1b2, 4a4
H5A1. The ratio of downstream-Project returning adult
migrants by brood year to downstream-Project juvenile
migrants by brood year, compared to ratios observed in
other systems, will be significantly higher (relative increase
of juvenile delayed mortality passing through the Project).
Without-Project = 0.10
(1:10)
With-Project = 0.05
(1:20)
Number of adult
migrants downstream-
Project and juvenile
migrants downstream-
Project and (brood
analysis). Higher ratio
indicates fewer adult
returns per juvenile and
may result in a
decreased population. H5A2. The ratio of downstream-Project returning adult
migrants by brood year to downstream-Project juvenile
migrants by brood year, compared to ratios observed in
other systems, will be significantly lower (i.e., relative
decrease of juvenile delayed mortality passing through the
Project).
Without-Project = 0.10
(1:10)
With-Project = 0.15
(1:7)
Direct Effect - H6N. The
quantity of suitable
rearing habitat in the Falls
Reach will be similar. Life
Cycle Transition 3.
Metric(s) 1c1
H6A1. The quantity of suitable rearing habitat in the Falls
Reach will be significantly lower under With-Project
conditions relative to Without-Project.
Without-Project = 1 ha
With-Project = 0.5 ha
Quantity (hectare) of
suitable rearing habitat
in the Falls Reach as
defined by depth and
velocity as index of
effect on survival. A
lower survival can result
in a decreased
population.
H6A2. The quantity of suitable rearing habitat in the Falls
Reach will be significantly higher under With-Project
conditions relative to Without-Project.
Without-Project = 1 ha
With-Project = 1.5 ha
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. C-21 August 2022
Direct Effect - H7N. The
survival of downstream
migrants through the Falls
Reach and the
powerhouse will be
similar. Life Cycle
Transition 3. Metric(s)
2a2, 2a3, 2a4
H7A1. Survival of downstream migrants through the
powerhouse (literature) will be significantly lower than
Without-Project through the Falls Reach (empirical).
Falls Reach = 95%
powerhouse = 85%
Proportion of
downstream migrants
surviving through the
powerhouse and Falls
Reach. A lower survival
can result in a
decreased population.
With-Project survival
through the
powerhouse may be
empirical.
H7A2. Survival of downstream migrants through the
powerhouse (literature) will be significantly higher than
Without-Project conditions through the Falls Reach
(empirical).
Falls Reach = 95%
powerhouse = 99%
Direct Effect - H8N. The
survival of downstream
migrants through the Falls
Reach and tail out will be
similar. Life Cycle
Transition 3. Metric(s)
2a3, 2a4
H8A1. Survival of downstream migrants through the Falls
Reach and tail out under With-Project conditions will be
significantly lower than Without-Project.
Without-Project = 95%
With-Project = 85%
Empirical proportion of
downstream migrants
surviving through the
Falls Reach and tail out.
A lower survival can
result in a decreased
population. This
comparison is
conducted if the Project
is built.
H8A2. Survival of downstream migrants through the Falls
Reach and tail out under With-Project conditions will be
significantly higher than Without-Project.
Without-Project = 95%
With-Project = 99%
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. C-22 August 2022
Direct Effect - H9N. The
risk of stranding/trapping
of small fish in the Falls
Reach will be similar Pre-
vs - Post Project. Life
Cycle Transition 3.
Metric(s) 3a1, 3a2
H9A1. The risk of stranding/trapping of small fish With-
Project will be significantly higher than Without-Project.
Without-Project = 0.5
With-Project = >0.6
Estimated risk will be
determined by channel
bathymetry/topography
in relation to flow
reduction associated
With-Project operations.
Will then look at range
of typical flow changes
over different time
periods Pre- and Post-
Project operations to
see to what extent
stranding/trapping may
occur within those
areas.
H9A2. The risk of stranding/trapping of small fish With-
Project will be significantly lower than Without-Project.
Without-Project = 0.5
With-Project = <0.4
Direct Effect - H10N. The
modeled total area of
potential dewatering or
erosion of spawning
habitat in the powerhouse
tailrace and Falls Reach
tail out will be similar. Life
Cycle Transition 3.
Metric(s) 3b1, 3b2
H10A1. The total area of potential dewatering or erosion
of spawning habitat will be significantly higher With- versus
Without-Project conditions.
Without-Project = 1 ha
With-Project = 1.5 ha
Modeled area of
potential dewatering or
erosion of spawning
habitat (defined by
suitability criteria) as an
index of effect on
juvenile production in
the powerhouse tailrace
and Falls Reach tail out.
Decreased spawning
habitat can result in
decreased production
and population.
H10A2. The total area of potential dewatering or erosion
of spawning habitat will be significantly lower With- versus
Without-Project conditions.
Without-Project = 1 ha
With-Project = 0.5 ha
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. C-23 August 2022
Direct and Indirect Effect -
H11N. The modeled flow
field (velocity vectors and
depth) in the Falls Reach
tail out will provide similar
upstream migration
attraction cues to current
conditions in the Falls
Reach. Life Cycle
Transition 1. Metric(s)
4a1, 4a2, 4a5
H11A1. With-Project water velocity vectors and depth in
the Falls Reach tail out will be significantly different and
result in poor upstream migration attraction cues into the
Falls Reach relative to Without-Project conditions.
Without-Project =
within criteria
With-Project = out of
criteria
Modeled water velocity
vectors and depth in the
Falls Reach tail out as an
indicator of passage
attraction flow. Pre-
and With-Project
suitability of water
velocity and depth in
ascension pathways
based on physical ability
and NMFS attraction
flow criteria compared
to tailrace flows.
Delayed migration can
result in increased
injury, pre-spawn
mortality, and a
decreased population.
H11A2. With-Project water velocity vectors and depth in
the Falls Reach tail out will be significantly different and
will result in better upstream migration attraction cues into
the Falls Reach relative to Without-Project conditions.
Without-Project =
within criteria
With-Project = out of
criteria
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. C-24 August 2022
Direct and Indirect Effect -
H12N. Residence times
(empirical) of upstream
migrants below the Falls
Reach will be similar. Life
Cycle Transition 1.
Metric(s) 4a3, 4a5
H12A1. Residence times of upstream migrants below the
Falls Reach will be significantly higher under Without-
versus With-Project conditions.
Without-Project = T
With-Project = 2T
Residence times
(empirical) below the
Falls Reach as an
indicator of false
attraction. Delayed
migration can result in
increased injury and
pre-spawn mortality,
and a decreased
population. Baseline
residence times to be
compared with With-
Project times during
monitoring period. This
comparison is
conducted if the Project
is built.
H12A2. Residence times of upstream migrants below the
Falls Reach With-Project will be similar to Without-Project.
Without-Project = T
With-Project = 0.5T
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. August 2022
APPENDIX D:
Proposed Study Plan Comment Responses (7/23/2021 Aquatics Resources Work
Group Technical Subcommittee Distribution)
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-1 August 2022
Table 1. Comments received on the Proposed Study Plan (PSP) for the Nuyakuk River Hydroelectric Project (P-14873) distributed to the Aquatics
Resources Technical Workgroup (ARWG) on July 23, 2021 and Nushagak Cooperative's responses.
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
1
ADFG
(Tim
Sands)
4.1.1.7 Methodology –
Adult Salmon
Migratory Behavior
Observation
I’m concerned that they think they can accomplish
this by surveys every five days weather depending.
I’m also concerned that they are married to these 3
zones. It may be much easier and safer to sample
or monitor migrations further away from the high
flow areas adjacent to the falls. I understand that
they want to monitor activity in that area but to
accomplish the stated goal of estimating timing
and number of fish they should consider finding
the place where that is easiest even if that is
outside of their defined zones. I suspect that closer
to the lake it may be easier. That is not to say they
shouldn’t still do surveys and try and determine
the migratory paths and all that.
The intention of visual observation surveys is to gain some
understanding of how the fish move through the falls and
what paths they are using: right, left or middle so
subsampling is an appropriate approach. However, to
capture the variable nature of the flows and subsequent
passage at this site, we have revised the study plan to
indicate that observations would occur every two to five
days weather and method depending.
With respect to sampling locations, our intent is to focus
on Zones 1-3 as the data collected there would be site-
specific and representative of the existing condition in the
proposed bypass reach. That said, we acknowledge that
additional site evaluation is necessary to determine
appropriate methods for this area, safety considerations
and whether collecting data a bit further upstream and/or
downstream of the Project area is necessary.
2
ADFG
(Tim
Sands)
4.1.1.7 Methodology –
Downstream Migrant
Trapping/Migration
Pattern Observations
I’m concerned that they will only run this
sampling for 72 hours during each survey week. I
can’t quite figure out when the survey weeks are.
Are they once a month? Once in the spring,
summer, fall and winter. I read through this whole
section and can’t figure it out. I’m not sure what
the timing is for the various species that will
outmigrate but it sure seems like a 72 hour
window a week a month will not categorize the
migratory timing by species very well.
Text was added to clarify the intent of operating migrant
traps throughout the salmon outmigration window and to
indicate that the 72 hour minimum could be achieved
through a combination of a number days a week and block
of hours each trap day.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-2 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
3
BBSRI
(Bryan
Nass)
2.0 Project Location
and Description
I recall that an economic feasibility assessment of
undetermined scope was proposed or considered at
some point. Am I missing something or is there a
separate document or source of information on this
aspect so that stakeholders can review the numbers
and assumptions? The only reference I found on
the website was a bullet in the FAQ doc.
An economic feasibility assessment will be ongoing
during the entirety of the study program process and a
financial assessment (benefits, impacts, plan for
development, etc.) will be incorporated into draft and final
license applications. As natural resource study results
come in and design elements are refined accordingly, the
financial assessment will evolve.
4
BBSRI
(Bryan
Nass)
2.3 Project Facilities
[regarding sentence: “The powerhouse is
conceptualized to contain two Kaplan-style
reaction turbine generating units to accommodate
a combined maximum design flow of
approximately 6,000 cfs divided evenly among the
units.”]
Fig 4-4 and 4-7 indicate diversions up to 7,551 as
based on the PAD. Likely not critical since it says
approximately, but recognize that some analyses
(like % diversion) are based on the 7,551 value.
The flow amount in the caption for Figure 4-4 is intended
to define the amount of flow in the river on the date the
aerial image was taken. Regardless and as the comment
recognizes, a substantial amount of design and analysis
will take place in the coming years to ultimately define the
amount of water that may be able to be diverted for power
production.
5
BBSRI
(Bryan
Nass)
2.3 Project Facilities
[regarding sentence: “This combined maximum
design flow between 55% and 80% of the average
flow rate for the months of June, July and August,
less a design specification of 1,000 cfs for
instream uses.”]
I am assuming this is not a regulatory
specification.
As noted in the prior comment response and the sentence
preceding the reference in the PSP, operational and flow
values are “conceptual” at this point. A substantial amount
of design and analysis will take place in the coming years
to ultimately define the amount of water that may be able
to be diverted for power production.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-3 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
6
BBSRI
(Bryan
Nass)
2.3.2 Nuyakuk Falls
Diversion & Intake
[“regarding sentence: The intake diversion would
move water from the southern portion of the river
above the falls into a drop shaft-type structure
connected with two 18-foot diameter tunnels.”]
Has modeling already been completed to
substantiate this statement? Otherwise, it is not
known what the flow field looks like.
At this point, all design elements are conceptualized and
based upon baseline surveying, site visits, historic
hydrology, etc. Substantia site-specific analysis will occur
in parallel with the natural resource study program and
ultimately define the specifics of the Project infrastructure.
7
BBSRI
(Bryan
Nass)
4.1 Aquatics/Fisheries
Resources
It would be good to decide when “falls” and
“reach” are capitalized, as in Falls reach, and make
it consistent throughout. Also, need consistency
for with and without Project (used as a condition.
With-Project, without-Project?), as in pre-Project
and post-Project (which I think are used in a
timeframe context). For some reason my find tool
is not finding them…
Thank you for this comment. The document has been
revised to have consistent conventions in these regards.
8
BBSRI
(Bryan
Nass)
4.1 Aquatics/Fisheries
Resources
“Water diversion would reduce flow and may
change habitat conditions through the
approximately 0.7 mile falls reach,”
As per Section 2.1
The stat from 2.1 may not be appropriate bc it
apparently starts at the physical intake and ends at
the physical tailrace. Therefore, I’ve changed this
according to the potential extent of hydraulic
influence as indicated in 4.1.1.2.
Based on the fish passage study area, the “falls”
area is approx. 1930 ft or 0.36 mi
The reach length issue has been resolved and the PSP
updated accordingly
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-4 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
9
BBSRI
(Bryan
Nass)
4.1 Aquatics/Fisheries
Resources
The 2D model extents do not cover the entirety of
the hydraulic extents of the Project (approx. 0.5 mi
up and dn of the falls as per the fish community
study). We think it should cover that whole area
to be able to understand the conditions that
upstream and downstream migrating salmon will
encounter as they approach the physical
Project. The hydraulics may provide cues
migrating fish that will influence where those fish
arrive with respect to the Project and the falls, and
thereby affect their interaction with the Project.
I updated the distances for the 2D model
according to the information in the Fish Pass
Study 4.1.2.2 updated by Dudley. However, if the
hydraulic extent is actually 1.36 mi (as in 4.1.1.2),
then it would be appropriate for the 2D model to
cover that. Note that the lidar covers 1.86 mi of
river.
The reach length issue has been resolved and the PSP
updated accordingly
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-5 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
10
BBSRI
(Bryan
Nass)
4.1.1 Characterization
of the Fish
Community and
Behavior Near the
Project Area
4.1.1.2 Geographic
Scope
[“regarding sentence: approximately 0.5 miles
upstream of the Nuyakuk Falls (the Falls) to an
area approximately 0.5 miles downstream of the
Falls, which includes the proposed tailrace area of
the Project (Figure 4-2). Based on current design,
this one-1.36 mile study area would account for
the entire area of potential flow alteration
associated with Project operations.”]
According to 4.1.2.2, the falls is 0.36 mi in length.
The extents of potential flow operation are
important to determining what the zone of
influence is for the Project as habitats may change
within it (i.e., the overall study area), and needs to
be consistent throughout the document.
The reach length issue has been resolved and the PSP
updated accordingly
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-6 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
11
BBSRI
(Bryan
Nass)
4.1.1 Characterization
of the Fish
Community and
Behavior Near the
Project Area
4.1.1.3 Study Goals
and Objectives
Potentially “new” predation in the form of
increased effort and new locations could arise as a
result of the Project. It would be prudent to
include some directed effort as part of this study to
determine the whereabouts of piscivores and the
extent to which they are eating smolts in the
spring. Are piscivores presently in the vicinity of
the intake and tailrace? Is the falls tailout a
location of relatively high abundance of
piscivores? Important locations: near-field of
intake, near-field of tailrace, in the falls, falls
tailouts.
Also see comment in the Mortality section of the
entrainment study.
There may be other forms of predation that this
study could document (avian, mammals)
This fish sampling study will be designed to evaluate
presence of piscivores in the study area under baseline
conditions through this study area and with a primary
focus on the intake, tailrace and the reach immediately
downstream of the falls. We do not anticipate being able
to documents predator abundance throughout the Falls
proper due to depth and velocity conditions but will
conduct sampling along the channel margins where it is
safe.
In addition, the 2-D model results will give us information
on potential habitat conditions throughout the project area
related to different flows. We can then review these
conditions and habitat suitability characteristics for key
piscivorous fishes to evaluate the potential of creating or
eliminating habitat for piscivores. In addition, we can
collect incidental observations of avian or mammalian
piscivores in the area. The text has been edited to clarify
these points.
12
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.1 General
Description of
Proposed Study
This is salmon centric, so should residents be
mentioned as this is a general description for the
study?
Text revised to note other fish species will be considered
as well.
13
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.1 General
Description of
Proposed Study
[regarding a new figure provided by Bryan Nass]
I recommend using this figure rather than the
original as it provides the metric of % diverted.
Agreed, figure modified accordingly.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-7 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
14
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.1 General
Description of
Proposed Study
[regarding title for Figure 4-4 which was edited by
Bryan Nass]
This data was analyzed on a daily basis
The figure caption has been revised to state “daily”.
15
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.2 Geographic
Scope
[regarding sentence: “The geographic focus of the
Fish Passage Evaluation will be from the upstream
hydraulic control of the Nuyakuk Falls
downstream approximately 0.35 miles to the base
of the falls.”]
Section 2.1 says it is 0.7 miles (?).
The reach length of the hydraulic modeling has been
resolved and the PSP updated accordingly. Text reads-The
geographic focus of the Fish Passage Evaluation will
extend from approximately 1,000 ft (0.19) above the upper
end of the Nuyakuk Falls to approximately 1,400 ft (0.27
mi) be from below the lower end of the falls; total length
of the study area is approximately 4,310 ft (0.82 mi.).
(Figure 46???)
Two figures have been added, one that depicts the Falls
reach and extent of 2D modeling, the second the extent of
the LiDAR coverage with the Falls reach (focus of
hydraulic modeling) highlighted and superimposed on that
coverage.
16
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.2 Geographic
Scope
This is where it might be beneficial to include the
extents of the LiDAR data.
The extent of the LiDAR data was intentionally in excess
of the bypass reach for the proposed Project. The goal
here was to be certain that we acquired all necessary
topographic and bathymetric data during the survey so the
need for additional LiDAR in the future would not be
required. A new figure has been inserted into the PSP
under the 2D Modeling section that displays the extent of
LiDAR coverage and the Falls reach that encompasses the
hydraulic modeling.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-8 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
17
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.6 Project Nexus
[regarding statement: “Diverted water would then
be discharged back into the natural channel
immediately below the falls resulting in a 0.34
mile bypass section that comprises the Nuyakuk
Falls reach.”]
Correct?
As noted above, the length of the bypass section has been
adjusted to 0.82 mi.
18
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.7 Methodology
May 2020 indicated above [regarding bathymetric
survey date]
Date adjusted here to May 2020 to correspond with other
date
19
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.7 Methodology
[regarding a new figure provided by Bryan Nass]
I recommend using this figure rather than the
original as it provides the metric of % diverted. I
added general periodicities for salmon to the
figure
Agreed, figure modified accordingly.
20
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.7 Methodology
[regarding Figures 4-9 and 4-10]
These are the exact same figure, so either we only
need one of them, or one scenario needs a new
figure.
Replaced second figure with proper one for downstream
migration
21
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.7 Methodology
Not critical, but, migration, operations, and
reduction are misspelled. On 4-12, the expected
change associated with climate is supposed to
indicate “downstream”.
Changes made to figure
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-9 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
22
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.7 Methodology
I must be missing something as I don’t see how
the figure illustrates habitat change, other than the
diversion…
Agree – figure deleted
23
BBSRI
(Bryan
Nass)
4.1 Aquatics/Fisheries
Resources
“Water diversion would reduce flow and may
change habitat conditions through the
approximately 0.7 mile falls reach,”
As per Section 2.1
The length was changed from 0.7 mi to 0.82 mi per the
Fish Passage Study. This was computed via GIS from the
top of the falls to below the tailrace and is therefore the
most accurate estimate. All length numbers are now
consistent between sections.
24
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.7 Methodology
Windows can only be validated by collection of
empirical data on individual fish passage events
over a range of flows. Without it, there is an
indeterminant level of risk that the modeling does
not characterize fish passage through the falls.
True, but doesn't forego the estimation of probabilities of
successful passage based on published swimming and
jumping capabilities compared with model generated values
within the Falls reach under different flow characteristics.
Telemetered data would serve as a validation step to see if
probability estimates were realistic.
25
BBSRI
(Bryan
Nass)
4.1.2 Nuyakuk Falls
Fish Passage Study
4.1.2.7 Methodology
This characterization of the evaluation is too
ambiguous for a reviewer to ascertain what the
steps are. Seems this should be a bit more specific
regarding what constitutes this evaluation in the
last step. How is the modeling going to provide an
evaluation? Probabilities of occurrence for a
qualitative range of dewatering? Please identify
specific data that can be used in the LCM and IRA
where risk will be classified.
Additional text was added to this section to more fully
explain the modeling process including the assessment of
potential stranding and trapping.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-10 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
26
BBSRI
(Bryan
Nass)
4.1.3 Fish
Entrainment and
Impingement Study
4.1.3.7 Methodology
[regarding sentence: “A two-dimensional
hydraulic model of Zones 1, 2, and 3 of the
Nuyakuk River will be developed under the Fish
Passage Study.”]
This statement conflicts with the shaded areas
representing the modeled area for this study, the
passage study, and the false attraction study. It
seems the modeled area does not equal all of zones
1,2,3. But we would like to see all of the zones
modeled in their entirety for reasons indicated
elsewhere.
As described in the Geographic Scope of the Nuyakuk
Falls Fish Passage Study (4.1.2.2), the 2D model will
encompass all three zones within the project area.
Additional text clarifications were added in the description
of the 2D model to affirm this coverage.
27
BBSRI
(Bryan
Nass)
4.1.3 Fish
Entrainment and
Impingement Study
4.1.3.7 Methodology
[regarding sentence: evaluate approach velocities
and approach angles in relation to primary fish
species swimming ability and behavior for various
intake designs and orientations.
Similar to the attraction study, this description
does not provide adequate information for the
reader to understand what the steps and criteria
are. As an example, what range in velocities and
angles would most certainly entrain and not
entrain a juvenile sockeye? 3 m/s at 45deg ? Is
this the concept or am I conceptualizing this
incorrectly?
The approach and sweeping velocity criteria will be
species-specific and will use NMFS criteria as guidelines
for protection. The velocities and approach angles that
result in sweeping velocity will likely vary with different
intake design configurations. These values will need to be
determined during the study once flow patterns, species
and design options are known.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-11 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
28
BBSRI
(Bryan
Nass)
4.1.3 Fish
Entrainment and
Impingement Study
4.1.3.7 Methodology
[regarding statement: “The overarching goal of the
literature review and hydraulic model evaluation is
to refine the preliminary design for the Nuyakuk
Project intake that minimizes potential fish
mortality and injury due to entrainment, and
impingement, and related fish mortality and
injury.”]
Minimizing the interaction that leads to lower
mortality and injury
We appreciate the comment but want to leave the focus on
finding the design that reduces mortality and injury
through the project. A focus on minimizing interaction
with the Project implies that we expect that turbine
passage has more potential for injury and mortality then
reduced flow conditions over the falls and I am not sure
we can assume that. By focusing on reduced mortality
and injury associated with passage through the Project we
are going to find a better design regardless of which route
is safer.
29
BBSRI
(Bryan
Nass)
4.1.3 Fish
Entrainment and
Impingement Study
4.1.3.7 Methodology
As discussed, I could not detect in the first two
references [EPRI 2997; FERC 1995] anything that
substantiates the statement – I took detailed notes
of content during my review. Specifically, I did
not see anything about using a modeled flow field
and hypothetical fish density to estimate
entrainment (but I would be intrigued to see a
paper that does). I was not able to obtain the
Winchell doc and would appreciate a copy to see
if it provides supporting information. The
credibility of this approach would be elevated if
you could cite actual FERC license documentation
for a Project that could be used as an example.
The text has been revised to clarify intent of citations. In
addition, a copy of the Winchell et al. document was
provided to Bryan Nass and can be made available to
others.
The following projects included FERC approved desk top
entrainment studies: Mason Dam Hydroelectric Project (P-
12686), Uniontown Hydroelectric Project (P-12958),
Overton Hydroelectric Project (P-13160), Emsworth Back
Channel Hydroelectric Project (P-13761), Montgomery
Locks and Dam Hydroelectric Project (P-13768), Evelyn
Hydroelectric Project (P-14799), Braddock Locks and
Dam hydroelectric project (P-13739), Allegheny Lock and
Dam 2 Hydroelectric Project (P-13755), and the
Emsworth Locks and Dam Hydroelectric Project (P-
13757).
30
BBSRI
(Bryan
Nass)
4.1.3 Fish
Entrainment and
Impingement Study
4.1.3.7 Methodology
I could not obtain this document and would
appreciate a copy.
[regarding: Coutant and Whitney 2000]
A copy of the Coutant and Whitney document was
provided to Bryan Nass and can be made available to
others.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-12 August 2022
31
BBSRI
(Bryan
Nass)
4.1.3 Fish
Entrainment and
Impingement Study
4.1.3.7 Methodology
For discussion with MLK. Turbine intake and
outfall flow fields have been shown to be
energetically beneficial locations for predators to
take other passing fish, especially juveniles, that
get concentrated in water diversion scenarios. For
example, consider a juvenile salmon that makes it
past the gauntlet at the intake, survives passage
through a turbine, and then is preyed upon by a
waiting Dolly Varden at the tailrace. Regardless
of the location in that route, the Project would
have indirectly increased vulnerability, increased
mortality, and thereby potentially decrease
survival of the population (short and longterm).
This relationship needs to be recognized and/or
incorporated into the assessment of Project
mortality. Similarly, changes in flow through the
falls reach could increase (or decrease) predation
on juvenile salmon in the falls proper and in the
falls tailouts.
Perhaps the quantitative predation is for the LCM,
but it seems the fish community study should be
addressing the distribution of predators, pre and
post Project, and provide the rationale. This study
may research how this phenomenon has developed
at other Projects.
Similarly, changes in flow through the falls reach
could increase (or decrease) predation on juvenile
salmon in the falls proper and in the falls tailouts.
Perhaps the quantitative aspect of this is for the
LCM, but it seems the fish community study
should be addressing the distribution of predators,
pre and post Project
We appreciate the comment. As stated in response to
comment 10, Fish sampling during the Fish Community
study will be designed to evaluate presence of piscivores
in the study area under baseline conditions through this
study area and with a primary focus on the intake, tailrace
and the reach immediately downstream of the falls.
The relationship between the Project and indirectly
mortality cannot be empirically determined before the
project is built. Once we have conducted the pilot testing
we may be able to evaluate mortality over the falls,
depending on our ability to collect fish above an capture a
substantial portion below. Given interannual variability of
outmigrant size and condition, the best empirical data on
this issue will come post-project through monitoring that
can inform adaptive management. Additionally, the LCM
will be able to incorporate sensitivity of losses to
predation on overall populations.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-13 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
32
BBSRI
(Bryan
Nass)
4.1.3 Fish
Entrainment and
Impingement Study
4.1.3.7 Methodology
For discussion with MLK. Relates to the prior
comment. This assumes that flow is proportionate
to entrainment, but it may be that smolts
disproportionately follow flow. It may be more
conservative to assume that any smolt that enters
the flow field (the draw of the intake) will be
entrained. A thorough sensitivity analysis will
evaluate this and other assumptions.
The text was modified to add behavior to the factors that
influence entrainment, I think this take us away from the
assumption that entrainment will be expected to be
proportional to flow.
33
BBSRI
(Bryan
Nass)
4.1.3 Fish
Entrainment and
Impingement Study
4.1.3.7 Methodology
For discussion with MLK. Relates to the prior two
comments. This assumes that smolts/fry normally
migrating at 5-17 kcfs survive at the same rate as
if they migrated at 1-10 kcfs (according to the base
case flow regime and timing). This relationship
might be evaluated with sensitivity analysis as
smolts tend to migrate with the freshet to be fast
and covert (and avoid predation).
We appreciate this comment and note that the entrainment
study is focused on first evaluating the potential to
minimize direct injury and mortality from the turbine and
project infrastructure design features.
If estimates/predictions of direct injury prove to be of
concern, collaborative study planning discussions
associated with year 2 efforts would take this into account
and a supplemental study to assess/predict indirect
mortality over the falls and through the project may be
deemed justified.
34
BBSRI
(Bryan
Nass)
4.1.4 Assessment of
False Attraction at the
Tailrace Fish Barrier
4.1.4.2 Geographic
Scope
[Regarding Figure 4-16, which shows the study
area]
Hatching should go up to/into the chutes to the
extent that habitat could change with respect to
attraction.
The figure has been modified to show the study area up to
the falls downstream chutes.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-14 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
35
BBSRI
(Bryan
Nass)
4.1.4 Assessment of
False Attraction at the
Tailrace Fish Barrier
4.1.4.7 Methodology
This characterization of the evaluation is too
ambiguous for a reviewer to ascertain what the
steps are. There are three metrics identified but no
indication of what or how comparisons are made,
and by what criteria. What constitutes potential
effectiveness? What are the conditions that
enhance attraction? As in the fish passage study,
perhaps provide an example. There are no cited
references provided to support the proposed
approach. Is this a newly conceived approach, or
has it been applied in a similar situation
previously? I suspect the former given the general
description provided, but if there is precedence, it
would be good to know.
Text has been added to help clarify the intent of the
comparative model approach and its acceptance by
regulatory agencies on another FERC project. Criteria
that are used to define effectiveness have not yet been
determined but will be built into the model in
collaboration with the ARWG.
36
BBSRI
(Bryan
Nass)
4.1.4 Assessment of
False Attraction at the
Tailrace Fish Barrier
4.1.4.7 Methodology
[regarding: “ecological, physical and operational
criteria”]
For example ?
Text was edited replacing “criteria” with characteristics
and several examples of the types of data are provided.
37
BBSRI
(Bryan
Nass)
6.0 References
It has been my experience in FERC hydro
processes that the references are made available to
the public should they wish to research particular
aspects. For my review, I was not able to obtain
several documents through public channels (some
require membership or to purchase). I won’t
advocate for establishing a repository bc I know it
is extra effort, but I will appreciate being provided
elusive docs. Thx.
We are happy to share reference documents cited in our
study plans and report at the request of reviewers.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-15 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
38
BBSRI
(Bryan
Nass)
Appendix C, H3N
Please keep the alternative hypotheses (A1, A2)
together (i.e., no orphans) The Cooperative appreciates the comment. This
formatting was corrected during document revision.
39
BBSRI
(Bryan
Nass)
Appendix C, H11N Please keep the alternative hypotheses (A1, A2)
together (i.e., no orphans)
The Cooperative appreciates the comment. This
formatting was corrected during document revision.
40
NMFS
(Sean
Eagan)
Section 2.4.1
Proposed Project
Operations
Sean Eagan wrote an email as follows: “The five
most recent hydrographs do not resemble that 60-
year average or even each other very well. I think
the PSP should have a diagram with the 10 most
recent hydrographs as 10 different color lines. We
need to help everyone understand how different
the flow is each year.”
Sean provided a series of 5 hydrographs for our
use or as an example in his email.
The scales on these are all over the board, but I'm
sure Chuck could display on one scale and make
it pretty. For the general public, I'm not a fan of
log scale.
Per our conversation with NMFS, we have added this
chart to the specified section.
41
UTBB
(Molly
Welker)
Introduction
An Executive Summary should be included to give
readers an overview of the entire document so that
the stakeholders do not have to read the entire
document to understand its purpose.
An email will accompany any draft distribution to the
stakeholders outlining the intent of every document
throughout the licensing process.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-16 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
42
UTBB
(Molly
Welker)
Section 4
Additional monitoring should be included during
the 6-7 months of winter to collect data on winter
base flows, winter water temperatures and ice
conditions, and to determine overwintering habitat
for juvenile salmon and resident fish near the
Project.
A stream gage will be installed on site with temperature
sensing equipment to document flow and water
temperatures throughout the winter. Further, remote
cameras will be installed to document ice conditions
throughout the winter.
43
UTBB
(Molly
Welker)
Section 4
More information should be included from other
projects in Alaskan or similar northern regions on
impacts to fish from concrete gravity diversion
structures (e.g., groin) and tailraces, and problems
with frazil ice on infrastructure (e.g., water intake
structure).
Per Section 4.2.3.7, “a literature review of existing
hydropower facilities in Alaska and other cold weather
environments to evaluate their methods for continued
winter operation in harsh environments” will be
conducted.
44
UTBB
(Molly
Welker)
Section 4
Thank you for including this appendix that
discusses the relationship between the Project and
fish behavior and habitat.
We appreciate the comment.
45
UTBB
(Molly
Welker)
Appendix C
The ADFG protocols for out-migration studies
should be considered in the PSP. I agree with
ADFG (i.e., Sands and Borden) comments on the
need for more than the minimum 72-hours for the
out-migration studies to accomplish the goals of
the PSP.
Unlike ADFG population or smolt abundance studies, this
study is not focused on estimating abundance. It is
focused on understanding the migratory patterns over time
and distribution of fish across the river channel so that we
can refine the design of the intake to minimize impacts to
these downstream migrants. Still, collecting sufficient
numbers of fish to be representative of the population will
be important, thus multiple methods may be used together
to best characterize fish distributions.
Text was added to clarify the intent of operating migrant
traps throughout the salmon outmigration window and to
indicate that the 72-hour minimum could be achieved
through a combination of a number days a week and block
of hours each trap day.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-17 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
46
NMFS
(Sean
Eagan)
2.3 Project Facilities
Page-9
Leave open the option of installing one Kaplan
turbine and one more modern fish friendly turbine.
During the peak of smolt out-migration, the
Kaplan turbine could be turned off (if smolt
mortality is unacceptable) and only the fish-
friendly turbine left generating power. The rest of
the year, they could run in tandem or only the
Kaplan turbine could spin if there is insufficient
flow for both. The text should reflect flexibility in
the turbine choice.
Design parameters for the facility will be evolving
throughout the study implementation and conceptual
design process.
47
NMFS
(Sean
Eagan)
2.3.2 Intake
Page-12
Consider heating a portion of the trash racks as the
groin could slow the water down and exacerbate
the icing on the metal bars. With climate change,
this may not be a problem, but it is simpler to add
heating elements at the start then to retrofit later.
Only a section of the trash rack would need to be
heated, as when de-icing is required, there will not
be much water being routed to the penstock.
Design parameters for the facility will be evolving
throughout the study implementation and conceptual
design process.
48
NMFS
(Sean
Eagan)
Figure 2-6
This figure leads the public to envision an overly
simplified hydrograph. A similar graph with 10
colored lines: one for each of the last 10 annual
hydrographs (2012-2021) would be more
informative. Everyone should be aware that
sometime the October hump is larger than the
June-July hump.
Per our conversation with NMFS, we have added this
chart to the specified section.
49
NMFS
(Sean
Eagan)
4.1.1.2 Geographic
Scope
NMFS is Okay with the ½ mile above and below
for the 2-d hydraulic model geographic scope.
Tagging of fish could happen outside of this short
section if necessary for logistics or safety. Clarify
the text so people understand some activities could
happen outside the 1.5 mile long modeled section.
Text added to clarify study related activities may occur
outside of the study area.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-18 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
50
NMFS
(Sean
Eagan)
4.1.1.3 Study goals
We should know if fish are being delayed below
the falls at some flows under natural conditions. If
the pre-project delays at 10,000 cfs are 36 hours
for the average fish, Nushagak Utility should not
be asked to keep that under 24 hours.
We appreciate the comment and agree baseline passage
behavior is important to understand. Because of the
uncertainty associated with methods for tracking fish
immediately downstream and through the falls study
question 3 was written broadly to address salmon
upstream passage migratory patterns and behavior. Text
was added to indicate what pattens/behaviors may be
assessed.
51
NMFS
(Sean
Eagan)
4.1.1.5 Existing Info
Fig 4-7
Anadromous waters catalog says five species of
salmon above the falls. Are there a substantial
number of pinks above the falls?
Fig 4-7 suggest you do not plan to look at pink
passage - NMFS is fine with this, but include some
information as to why. Such as “99% of pink
never approach the falls so this project is unlikely
to affect the pink population.”
We appreciate the comment and we agree that very few
pink salmon are likely to pass the falls under baseline
conditions, However, there is the possibility the with-
project flow conditions enhance Pink Salmon passage.
Thus, we would like to keep Pink Salmon on the list for
now. This can be revised if appropriate, based on
discussions with the AWRG prior to filing the Revised
Study Plan.
52
NMFS
(Sean
Eagan)
4.? Literature review
Fisheries Resources
Studies
This list is missing the University of Washington -
Alaska Salmon Program (the exact name has
changed a few times). This group has been
looking at Bristol Bay salmon life histories for
60+ years. Using as much salmon information
collected in the Bristol Bay region as possible, and
not rely on Oregon/Washington or even SE Alaska
salmon data, will be important if stakeholder
groups challenge the study results.
University of Washington-Alaska Salmon Program has
been added to the list.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-19 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
53
NMFS
(Sean
Eagan)
Candidate Fish
Sampling
Page 38
Is it important to sample fish during the large
October flow? This could coincide with a
significant Coho run.
The May to September schedule is specific to fish
collection, not adult observations. Further and per
collaboration/agreement amongst the ARWG, Coho were
not one of the target salmon species we are focusing on for
the LCM. The value of adult observation efforts would be
to understand baseline migration trends, and that would
depend on how long the Coho run goes, ice-in timing, and
whether or not we can collect information that would be
representative of the run. This will be discussed with
ADFG after the opportunity for a more detailed literature
review and if warranted, additional text may be
incorporated prior to filing of the RSP.
54
NMFS
(Sean
Eagan)
Adult Migratory
Behavior
Page 42
On page 38 it suggest only sampling the edges of
zone 2 for safety reasons. Here it suggest we will
understand adult routes through the middle of the
cascade. Once site visits have occurred, NMFS
would appreciate more details. Spatial telemetry
tracking of fish might work. Could several
receiver antennae be suspended on cables across
the cascade?
This should be in the Fish Passage study 4.1.2.
We appreciate the comment and will provide further detail
in the RSP once site visits have taken place.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-20 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
55
NMFS
(Sean
Eagan)
4.1.1.7
“Vertical and horizontal distribution of juveniles
could be evaluated and monitored in the intake
vicinity” This is very important and should be
stated as “will” happen.
Agreed, but that particular “could” is referring to the
method of evaluation that is at the end of that phrase
quoted. The study plan does indicate a focus on the intake
area as indicated with quote below, taken from the
Downstream Migrant Trapping/Migration Pattern
Observations section.
“Downstream migrant trapping may occur at several
locations in the Project area to account for spatial
variability; however, survey efforts will be focused in
Zone 1 near the proposed Project intake (Figure 4-3).”
56
NMFS
(Sean
Eagan)
Fish Passage study
Figure 4-5
How will we verify if our human guesses of where
fish hold are correct? These ovals are basketball
court or larger sized areas. What if the most
critical rest areas are actually much smaller, like 2
-10 m2 triangles downstream of boulders?
To the best of our ability, holding areas will be identified
during baseline conditions regardless of size. For the 2D
model we will look for habitats of specific depth and
velocity that are consistent with salmon holding
suitability. The zones on Figure 4-5 will not define where
we look for holding. This figure is intended to
demonstrate that a number of different pathways and
holding areas may be present in the Falls reach.
57
NMFS
(Sean
Eagan)
4.1.2.3 Goals
The water is flowing through the cascade fast
enough that juvenile fish and fry primarily go with
the flow. Juvenile max swim speed of 0.6 m/sec
seems to be no match for the current 3-5 m/sec.
The text should indicate that unlike adults,
juveniles do not pick a route through the cascade.
We agree with your comment under baseline conditions,
but are uncertain how the velocities will change under
with-Project conditions. Thus, we would like to reserve
making that judgement at this time.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-21 August 2022
58
NMFS
(Sean
Eagan)
4.1.2.3 Page 49
Salmon are adept at finding tiny pockets of slower
velocity to move upstream and reverse hydraulics
to propel their jumps up cascades/falls. It seems a
HEC-RAS 2-D model may be too coarse to
capture these micro areas that salmon rely on to
move up cascades. Please provide an example of
where a similar 2-D model has successfully
modeled salmon passage through a similarly
complex cascade.
The application of 2D modeling to assess passage
conditions for fish has been applied as early as 2006, in
Australia (Haeusler, T and Bevitt, R. (2007). Hydraulic
modelling of a fish barrier – Pinch Falls, Snowy River.
Snowy River Recovery: Snowy River Flow Response
Monitoring, NSW Department of Water and Energy) and
is currently being applied to the Skagit River as part of
relicensing studies being conducted by Seattle City Light.
The Australia study was completed in 2006 and employed
River2D modeling but was constrained by limited
bathymetric mapping due to dangerous conditions in field
surveys (LiDAR was not yet available). The SCL studies
are focused on the Gorge Bypass Reach of the Skagit
River and are using a 2D HEC-RAS model. The reach is
high gradient and contains large boulders and a number of
falls and cascades. There is some question as to whether
anadromous fish ever passed through this reach and the
modeling studies are one of the tools being used to assess
potential pathways under different flow conditions. The
study is relying on LiDAR coupled with some field
surveys to develop an initial topographic model. Pressure
transducers have been installed at key falls locations to
allow more detailed evaluation of localized hydraulic
features which will aid in model calibration. While the
results of this analysis are not complete, the application of
a 2D HEC-RAS model to assist in evaluating flow-
passage conditions in this very complex reach of the
Skagit River has been generally accepted by state and
federal resource agencies. For more information visit
Relicensing the Skagit Hydroelectric Project - City Light |
seattle.gov. You are correct that salmon rely on multiple
velocity cues that can be quite complex. The extent to
which the 2D HEC-RAS model will be able to capture and
accurately represent these areas will depend on the mesh
used and overall model calibration.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-22 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
59
NMFS
(Sean
Eagan)
4.1.2.5
All models should be calibrated and validated with
two different sets of data prior to being used for
predictions. Elaborate on the data that will be used
to calibrate and validate this 2D hydraulics model.
NMFS may be fine with one of the other five
proposed models, but they all need to be calibrated
and validated.
The 2D model will be calibrated using three sets of field
data as described in Section 4.1.2.7, Conduct Bathymetric
Mapping of Reach. The first set was collected coincident
with the LiDAR surveys. The second and third surveys
will be collected during high and medium flows,
tentatively scheduled for late June and mid-July. The July
survey will also be used to collect data useful for
hydraulic model calibration. For this, floating tracers (a
variety of objects can be used) will be deployed from a
boat in Zone 1 and monitored via drone-based
videography. These data will be post-processed to
determine the magnitude and direction of surface
velocities under a given flow condition. The model will be
calibrated using the water surface elevations surveyed near
each benchmark during the field surveys, and using the
direction and surface velocity information measured using
floating tracers. The calibrated model will then be used to
model passage conditions under different flows.
60
NMFS
(Sean
Eagan)
Table 4-2
Please obtain leaping and jumping capability and
body sizes from similar Bristol Bay sockeye and
Chinook populations. The sockeye that usually
seek a lake only 100 meters or so above sea level
may have lower jumping limits then other
populations.
As noted in Study 2.1, under Establish Species Swimming
and Leaping Criteria, “As part of this study, a combined
literature and internet search will be completed to compile
relevant information related to both swimming and leaping
capabilities of salmon. From this, a set of criteria will be
developed in collaboration with the stakeholders that will
be used in the modeling and passage evaluation.
Observational data on fish leaping behavior at the
Nuyakuk Falls area during the Characterization of the Fish
Community and Behavior Near the Project Area study and
anecdotal information (including videography) will be
included for consideration.”
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-23 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
61
NMFS
(Sean
Eagan)
Table 4-3 The PSP should not describe flying a helicopter
low over a cascade as safe.
Any designation of “safe” or “unsafe” has an implicit level
of relativity incorporated into it. Relative to foot-based
and/or any type of boat surveys, aerial imagery of the falls
area is a much safer option.
62
NMFS
(Sean
Eagan)
Fish Passage Study
page 59
Please describe the known accuracy of the LiDAR
data and how that was verified. The fact that it
cannot penetrate deeper than 20 feet is not a
problem. What is the accuracy on water less than
3 feet deep? How do bubbles or froth in a rapid
figure into that depth? What size boulder, or
bedrock outcrop, will be identified versus just
being missed?
Thanks for the comment. As described in Section 4.1.2.7,
“The survey and LiDAR acquisition occurred on May 14,
2020 using a Riegl VQ-880-GII mounted on a Cessna
Caravan (Quantum Spatial 2020). The survey consisted of
consecutive overlapping flight paths of a reach of the
Nuyakuk River that extended approximately 3,000 ft (0.57
mi)1 km upstream and 2,500 ft (0.47 mi)1 km downstream
from the upper and lower ends of the Fish Passsage Study
Area Falls reach, respectively (total of 9,810 ft or 1.86
mi). Aerial imagery was co-acquired using a PhaseOne
iXU-RS1000 digital camera that collected imagery in
three spectral bands (Red, Green and Blue). The LiDAR
allowed for laser penetration through the water column up
to a nominal depth of 20 ft (depending on water clarity,
bed surface reflectivity and turbulence) and in those areas
can accurately depict the bed topography of the channel
below the water surface. However, the Falls reach
contains substantial areas of highly turbulent water, and
mapping in those areas can be problematic and will
require post-processing of data using interpolative, nearest
neighbor computations. The extent to which these void
areas exist will be determined as part of the model
development process. These void areas and solutions for
addressing them will be discussed with the ARWG.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-24 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
63
NMFS
(Sean
Eagan)
Page 61 - use of the
model
For flows that actually occur during 2022 and
2023 it would be much more accurate to track a
dozen marked fish’s path through the cascade then
trust the model. The model should only be used
for low flows that did not happen in the July -
September adult migration window of 2022 nor of
2023. Would tracking the routes coho take through
the falls during low November flows be an analog
for the sockeye and Chinook? Most salmon take
the path of least resistance. I trust the sum logic of
several cohos’ routes up the cascade at 2,000 cfs
much more than a models route.
Thanks for the comment although we respectfully disagree
on two counts. First, assuming a dozen fish could be
successfully tracked through the reach for a given flow,
absent a hydraulic model you would have no or little
information on the hydraulic conditions that they
experienced (what caused them to select that pathway and
not others?), or how those conditions would change under
different flows, only that they made it The Project will
alter both the magnitude and timing of flows in the Falls
reach and without the development of a 2D hydraulic
model, it will be virtually impossible to evaluate and
render in a probabilistic manner what changes in the
hydraulics that will accompany those flow alterations will
have on upstream and downstream passage. Second, the
entire purpose of developing the model is so that passage
conditions can be reasonably defined over a wide range of
flows, not just low flows. The tracking of fish through the
Falls reach will be valuable in documenting whether
model predictions are valid and of course as part of project
monitoring, but it does not replace model development.
64
NMFS
(Sean
Eagan)
Fig 4-10 - mislabeled
This PSP labels this “Upstream Migration” (top
left) but seems to talk about downstream
migration. Also if the fish moved in the opposite
direction across the page to the upstream Fig 4-9
that would help the reader understand one was up
and the other down.
The figure has been modified to correctly display
downstream migration.
65
NMFS
(Sean
Eagan)
Fig 4-11
“Similar analysis would be applied under a
Climate Change scenario as a function of flow
changes”. This is hard for me to envision because
climate change is not one thing or one scenario.
The diversity of annual hydrographs under climate
change is likely to increase.
In general, we agree with your statement. This is the
primary reason we are so on board with conducting the
NMFS requested Future Flows Study.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-25 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
66
NMFS
(Sean
Eagan)
Fig 4-14
The Tennant Method should not be mentioned
even for comparison. This is the most productive
sockeye run on the planet. Tennant Method may
be appropriate for an urban stream with a dozen
coho, but it is too blunt a tool for this location and
this amazing resource.
The Tennant method is not being considered nor
mentioned for any of the Nuyakuk fish passage analysis.
The figure presented that shows the Tennant method was
for illustrative purposes only as referenced to a study
completed on Ward Creek, Alaska by Reiser et. al. 2006.
67
NMFS
(Sean
Eagan)
Page 65
“Likewise, fry occupying flat shallow water areas
may suddenly become stranded.”
Please clarify whether fry hanging out in shallow
areas of a cascade is common and if so at what
times a day. Some data suggest fry stay in the
main current to move downstream as quickly as
possible.
Because we do not yet know the bathymetry and velocities
of the Falls reach under with-Project conditions, and
because we are assuming the substrate is largely bedrock,
we are being conservative in thinking that there may be
slow, shallow water areas where fry enter and are trapped.
68
NMFS
(Sean
Eagan)
Table 4-4
Hunter 1992 is 30+ year old information collected
primarily in the lower 48. The study should get a
newer reference for ramping. Secondly, different
day and night ramping rates do not make sense in
the Nuyakuk when smolt are out migrating in 21+
hours of clear daylight.
Based on recent interaction with Alaska agencies on other
existing and proposed hydropower projects, Hunter 1992
is the standard typically utilized for setting ramping rates.
Moreover, the reference to Hunter (1992) was cited as an
“example” of ramping rate criteria that have been applied
elsewhere and does not negate consideration of other,
more local criteria if they exist. The Hunter (1992) report
compiled information from a number of studies
specifically designed to evaluate and test ramping rate
effects due to hydroelectric operations on salmonids. The
results of those studies are as germane today as they were
then.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-26 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
69
NMFS
(Sean
Eagan)
4.1.3.2 Entrainment
Study The entire width of the channel is important.
We agree that is will be important to understand the
distribution of downstream migrating fishes across the
channel, that is why data collection in Zone 1 is proposed
across a channel spanning transect. In addition, we are
very interested in fish and flow patterns and pathways
around the intake in comparison to what is and may be
happening on the far bank away from the intake.
70
NMFS
(Sean
Eagan)
4.1.3.3 Entrainment
Goals
How can anyone estimate the potential for
entrainment without knowing the details of the
intake and trash rack design?
As stated in the study goals and objectives, this study is
being conducted to inform design and placement of the
intake. The Cooperative will continue to advance the
conceptual design during the entirety of the study planning
process and utilize the most updated version of the intake
design for the purposes of analysis. Further, multiple
options will be looked at corresponding to potential
alterations to intake design.
We are striving to develop a design that minimizes
downstream mortality and injury to migrants. Thus, the
approach includes look at potential effects of alternatives
as well passage for fish bypassed through the Falls reach.
71
NMFS
(Sean
Eagan)
4.1.3.5 Existing info Projected future flows would be useful, if they are
available in sufficient time.
Depending on the status of our Future Flows Study, we
will incorporate relevant data into this analysis.
72
NMFS
(Sean
Eagan)
Flow routing and
hydraulic modeling
Page 72
The 2-D model will be useful for investigating the
effects of various groin length/angles. The studies
should also investigate if the groin may increase
ice cover and icing on the intake structure.
The groin will be considered as a part of this and other
assessments to inform its ultimate design and longevity.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-27 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
73
NMFS
(Sean
Eagan)
Entrainment
page 72
We will not really know entrainment or mortality
until after the project has been constructed and we
do tagging studies on fry. The intake structure and
turbines should be designed with flexible features
so adaptive management can happen if
entrainment and mortality are too high.
We appreciate the comment.
74
NMFS
(Sean
Eagan)
False Attraction
Page 77
“residual risk” should be explained.
The text has been reworked to clarify the objective of
looking for latent affect that results as a consequence of
false attraction.
75
NMFS
(Sean
Eagan)
Feasibility Evaluation
Page 79
“Specifically, for each month during which more
than 10% of the run of a species of concern has
traditionally returned, the model will be run at the
20% exceedance flow and the 80% exceedance
flow.”
This is a good concept, however, only use the last
10 years of salmon return data.
We appreciate this comment and the intent which we
interpret to be ‘to use the best existing data to inform
predictions re future conditions.’ To do so, we would want
to reserve our ability to review the existing data and then
consider the variation evident in flow record and pick the
period of record that captures the greatest variation to
improve our ability to make predictions,
76
NMFS
(Sean
Eagan)
4.1.5 Life Cycle
models
Do you have all agency/stake holder buy in on
only completing lifecycle models for two species
(Chinook and Sockeye)? Forty years from now
another species might be the economic driver of
the Bristol Bay fishery.
Through discussions with the ARWG, Sockeye Salmon
and Chinook Salmon were selected as the target species
for life cycle model development. This was in a large part
due to the existing data that can support model
development. We anticipate that these models will help
inform assessment of other species to some extent, for
example when migrations overlap.
Further, as part of the Integrated Risk Analysis qualitative
models will be developed for all five species of salmon
present in the basin. This will give us the ability to
compare both approaches and further assess potential
effects for species without life cycle models.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-28 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
77
NMFS
(Sean
Eagan)
4.1.5.3 Study goals
Page 81
“Quantify the risks” - This seems very similar to
the Integrated Risk Assessment study. We appreciate the comment.
78
NMFS
(Sean
Eagan)
4.1.5.3 LCM
Question 3c & 3e & 6
3c- If these lifecycle models focus on Chinook and
Sockeye, why are we discussing rearing habitat in
the falls?
3e - Stranding will be more effected by how the
project is operated then how it is constructed. Will
the license specify how it will be operated 40
years from now?
6 - Great question. Can a lifecycle model tell us
the amount of change in population dynamics
under future climates? Is it going to take into
account prey availability and predator abundance
in the Bering Sea?
3c- This concern is about potential for enhancing rearing
habitat for species that might prey on downstream
migrating salmon.
3e- The license will define operation with respect to fish
impacts through the term of the license, which likely will
be 40 years.
6-With future flow conditions incorporated into the 2D
model the LCM can predict population dynamics
associated with the Project. It will not be able to predict
changes outside of the Project effects described in this
PSP.
79
NMFS
(Sean
Eagan)
General LCM
question
How will the LCM deal with ocean conditions that
are more/less favorable for salmon growth? How
about more/less intense fishing pressure? How
about new warmer water prey species that eat
juvenile salmon and become more prevalent in the
new climate? Are these questions that a completed
LCM will be able to answer?
Similar to above the LCM will be able to predict
population level effects that are related to future modeled
flow conditions and Project-related effects only.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-29 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
80
NMFS
(Sean
Eagan)
4.2.2.3 Flow Duration
Curve - Goals
“Use data from existing general circulation models
in the region to inform the development of climate
resilient license articles”. This should NOT be a
goal of Flow Duration Curve Study. It should be a
goal of Future Flows Study or just a general part
of license development.
If non-stationarity is determined to be the case
during Flow Duration Curve Study, maybe a third
goal is to state the direction of change in each
season during the last two decades.
If the work can be completed in an office in 2 - 4
months with existing data, why is the price tag so
high?
Agreed. Goals of the Flow Duration Curve Study will be
updated.
At a minimum, a tertiary goal will be to assess stationarity
vs. non-stationarity of the existing, historical flow record
over the last two decades.
The cost to execute the Flow Duration Curve Study will
be re-assessed and updated if necessary
81
NMFS
(Sean
Eagan)
4.2.3.7 Ice processes
Page 99
The PSP says 2021 and 2022, but I think you
mean 2022 and 2023. Do a global search as
failing to update the year happens in several
places.
Agreed. All study dates will be updated to accurately
reflect the study seasons in which they will occur.
82
NMFS
(Sean
Eagan)
Integrated Risk
Assessment
Page 1
Objective one - What is the difference between a
fish population and a fish community?
A population is used to define a group of fish within the
same species, fish that can interbreed. A community is an
ecological term to describe the assemblage of different
fish species that live in the same waterbody/area.
83
NMFS
(Sean
Eagan)
Integrated Risk
Assessment-
Objective 2 -risk
sources
There are many risk sources out there for fish
populations especially in the ocean and they will
change as the climate changes. Are we just
looking a risk directly created by the project?
Yes.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-30 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
84
NMFS
(Sean
Eagan)
Integrated Risk
Assessment
Unlike the LCM study, will this be for a much
wider suite of target species? If that is correct,
state it up front.
The goal statement has been revised accordingly.
85
ADF&G
(Kevin
Keith)
4.1.1 –
Characterization of the
Fish Community and
Behavior Near the
Project Area
Section 4.1.1.3 “Study Goals and Objectives” lists
8 specific questions to be addressed. These are all
excellent questions, and answers to these questions
would go a long ways towards assessing risks to
aquatic resources associated with the project.
However, the methods proposed are mostly
insufficient to answer these questions. Details in
following comments.
We appreciate the comment.
86
ADF&G
(Kevin
Keith)
4.1.1 –
Characterization of the
Fish Community and
Behavior Near the
Project Area
Specific questions #1 and #2 in Section 4.1.1.3 are
“What fish species use the aquatic habitats in the
Project Area across seasons?” and “What is the
relative abundance of fishes in the Project Area
seasonally?” The Proposed Study Plan is unclear
about how often sampling will take place, but
states that, “each transect will be surveyed at least
once for each season.” It is unlikely that a single
sampling event per season will provide sufficient
information to confidently answer either of these
questions.
Additional detail was added to the fish collection methods.
This indicates that within Zones 1 and 3 a total of 10,
50m-wide transects will be sampled during each of three
sampling events and that given the deployment of multiple
methods it is expected that each sampling event will take
10 days to complete. In addition, opportunistic sampling
will occur in Zone 2 edge habitat during each event. This
will equate to more than 36 days of sampling throughout
the open water period. In addition, to fish collection,
downstream migrant traps will be operated throughout the
salmon outmigration period and observational data will be
collected on fish moving upstream through the project
throughout the salmon migration window. We are
confident that, in combination, these activities will allow
us to characterize fish use of habitats and relative fish
abundance in the Project Area well in excess of a more
simplistic fish occupancy type assessment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-31 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
87
ADF&G
(Kevin
Keith)
4.1.1 –
Characterization of the
Fish Community and
Behavior Near the
Project Area
Specific question #4 in Section 4.1.1.3 is “What is
the proportion of adult salmon that successfully
pass through the Falls Reach under baseline
conditions?” Neither the transect sampling, nor the
visual surveys for adult salmon (whether by drone,
or helicopter) are likely to answer this question. A
fairly substantial radio-tagging project is one
possible method to address this question.
Biotelemetry IS mentioned as a possible method,
but there are no specifics as to what the
biotelemetry study would look like.
Additional on-site evaluation of the specific effort needed
to adequately conduct a telemetry study will ultimately
define the specifics of this effort. It is anticipated that the
site visits needed will take place between PSP and RSP
filing and as such, further detail will be available for
review/comment in the RSP.
88
ADF&G
(Kevin
Keith)
4.1.1 –
Characterization of the
Fish Community and
Behavior Near the
Project Area
Specific question #6 in Section 4.1.1.3 is “What is
the baseline migration pattern for Sockeye and
Chinook Salmon passing downstream through the
Project Area?” I have two concerns with the
downstream migrant trapping. 1) Trapping only
near the proposed project intake would yield a
very incomplete assessment of outmigration. 2)
Trapping a minimum of 72 hours each week will
not provide any confidence in the assessment of a
baseline migration pattern; as ADF&G biologist
Lee Borden pointed out at our meeting (7/29/21)
smolt outmigration can be extremely concentrated
with the possibility of a majority of the migration
occurring in just a few days.
Text was added to clarify the intent of operating migrant
traps throughout the salmon outmigration window and to
indicate that the 72-hour minimum could be achieved
through a combination of a number days a week and block
of hours each trap.
In addition, as described in the PSP, once an on-site
evaluation is appropriate, we will be able to assess the
potential use of fixed sonar (DIDSON, ARIS) to support
the assessment of run timing and migratory patterns.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-32 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
89
ADF&G
(Kevin
Keith)
4.1.1 –
Characterization of the
Fish Community and
Behavior Near the
Project Area
Specific question #7 in Section 4.1.1.3 is “What is
the proportion of juvenile salmon that successfully
pass through the Falls Reach under baseline
conditions?” It does not appear that anything
proposed in the methods for downstream migrant
trapping will shed light on this question.
We agree with the intent and concept behind this comment
and will very likely add specific language to this section
upon conducting a site visit to evaluate appropriate
methods. The Cooperative intends to conduct these site
visits prior to the filing of the RSP which will allow
additional specifics to be incorporated into the study plan.
As ADFG is aware, there will be a similar opportunity to
review and comment on the RSP prior to FERC issuing its
Study Plan Determination. This type of iterative process
related to the development of specific methodologies is
consistent with the “typical” ILP and the collaborative
nature that we have established with the ARWG. We will
evaluate the potential for telemetry and/or mark-recapture
with juvenile outmigrants once access to the site is
appropriate. If these baseline data cannot be obtained at
this time the LCM can use a sensitivity analysis to
evaluation the critical nature of this parameters. The
potential Project impacts would be informed by the LCM.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (ARWG Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. D-33 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
90
ADF&G
(Kevin
Keith)
4.1.1 –
Characterization of the
Fish Community and
Behavior Near the
Project Area
Specific question #8 in Section 4.1.1.3 is “What is
the baseline condition of injury/mortality in
juvenile salmon passing the Falls proper?” This
seems like a very difficult question to answer, and
it is not clear how any of the proposed methods
would address it.
We agree with the intent and concept behind this comment
and will very likely add specific language to this section
upon conducting a site visit to evaluate appropriate
methods. The Cooperative intends to conduct these site
visits prior to the filing of the RSP which will allow
additional specifics to be incorporated into the study plan.
As ADFG is aware, there will be a similar opportunity to
review and comment on the RSP prior to FERC issuing its
Study Plan Determination. This type of iterative process
related to the development of specific methodologies is
consistent with the “typical” ILP and the collaborative
nature that we have established with the ARWG. We will
evaluate the potential for telemetry and/or mark-recapture
with juvenile outmigrants once access to the site is
appropriate. If these baseline data cannot be obtained at
this time the LCM can use a sensitivity analysis to
evaluation the critical nature of this parameters. The
potential Project impacts would be informed by the LCM.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. August 2022
APPENDIX E:
Proposed Study Plan Comment Responses (9/24/2021 Project Contact List
Distribution)
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-1 August 2022
Table 1. Comments received on the Proposed Study Plan (PSP) for the Nuyakuk River Hydroelectric Project (P-14873) distributed to the Project Contact
List on September 24, 2021 and Nushagak Cooperative's responses.
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
1
ADF&G
(Kevin
Keith)
4.1.1 – Characterization
of the Fish Community
and Behavior Near the
Project Area
ADF&G continues to be concerned with the lack of
specifics for this study. Area Management Biologist Lee
Borden sent you an e-mail earlier today; instead of
repeating his concerns, many of which I share, I will
include his e-mail below (see Comment Nos. 3-4).
Per conversations during PSP
development and during the scheduling
process for re-initiation of the ILP, site
visits with technical specialists in 2022
will assist greatly in defining the specific
methodologies to be employed. The
goal of the PSP was to comprehensively
list the methods that may be used
depending determinations made during
the aforementioned site visits. The
recent decision to re-initiate the ILP in
March of 2022 will allow for the
remainder of the year to be devoted to
these site visits and refinements to the
methodologies. Those refinements will
be incorporated into the RSP, distributed
for comment and filed with FERC well
in advance of the studies commencing in
2023.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-2 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
2
ADF&G
(Kevin
Keith)
4.4.1 – Subsistence
Study
ADF&G fully supports the study plan to conduct
subsistence surveys for the communities of Koliganek,
New Stuyahok, Ekwok, and Aleknagik using the same
methodologies that ADF&G has used in the past and
uses throughout the State so that data collected will be
comparable to previous subsistence surveys in the
Project Area. The text in the Proposed Study Plan seems
to imply that ADF&G will be sharing the cost of this
study. We would like to clarify that ADF&G does not
have any funds available for this study. We look forward
to working out an agreement with the Cooperative to
fund this study.
The Cooperative appreciates the
comment. The intent of the text was to
convey our willingness to work with
ADF&G on this study and realize
synergies related to data collection
efforts, where possible. We did not
mean to imply that any funding for this
project-specific assessment would come
from ADF&G. We apologize for any
confusion and will review the text and
modify accordingly.
3 ADF&G
(Lee Borden)
4.1 Aquatics/Fisheries
Resources Proposed
Studies
I am still unsure on what the “methods” of any of the
proposed studies would entail on the ground. Without
such methods outlined and detailed, there is nothing to
go on when determining the adequacy of the proposed
studies to answer questions and fulfill the data collection
objectives outlined in the project nexus document. The
concerns brought forth from myself, and others on the
ARWG regarding lack of adequate field time have not
been addressed. A more specific “methods” section with
detailed sampling schedules and proposed means of
capture etc. would provide for a starting point to base our
analysis of the adequacy of the proposed field work in
meeting stated project objectives.
Per conversations during PSP
development and during the scheduling
process for re-initiation of the ILP, site
visits with technical specialists in 2022
will assist greatly in defining the specific
methodologies to be employed. The
goal of the PSP was to comprehensively
list the methods that may be used
depending determinations made during
the aforementioned site visits. The
recent decision to re-initiate the ILP in
March of 2022 will allow for the
remainder of the year to be devoted to
these site visits and refinements to the
methodologies. Those refinements will
be incorporated into the RSP, distributed
for comment and filed with FERC well
in advance of the studies commencing in
2023.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-3 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
4 ADF&G
(Lee Borden)
4.1 Aquatics/Fisheries
Resources Proposed
Studies
From a Sport Fish Division perspective, the lack of
attention given to resident species and their use of the
bypass area as more than simply an area to be passed
through by anadromous species is a bit of a concern. The
falls themselves are a unique habitat feature that likely
influences all life stages of resident/anadromous species
present in the upper Nuyakuk. The Nuyakuk system is
somewhat ecologically distinct from the other tributaries
of the Nushagak and the falls play a big part in why.
Thinking of the falls as an area that functions solely as a
corridor for anadromous passage overlooks its
importance as a geographical feature that effects the
ecology of the drainage by providing many other
functions including but not limited to winter/spring
foraging, juvenile rearing, and spawning habitat.
Per the previous comment, we are
confident that the site visits and
associated additional dialogue that will
take place in 2022 will assist in
supplementing the study program with
additional resident fish species
information. The Cooperative open to
that dialogue and the potential for
additional resident fish species
investigation, if it is agreed that the site
warrants it.
5 ADF&G
(Lee Borden) General Comment
I’m looking forward to continuing to work with the
ARWG in further refining the PSP. Let me know if there
is any clarification needed for any of my comments or if
you’d like to discuss anything in more detail. Much
progress has been made, and I am optimistic that we can
get to a place where all stakeholders are satisfied with
the proposed studies.
We appreciate the comment and look
forward to continued consistent
collaboration throughout the process.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-4 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
6
Dan
Dunaway
(Stakeholder)
Water Quality/Project
Design
I am concerned for gas entrainment / supersaturation that
can be terribly detrimental to fish - causing gas bubble
disease. Basically it creates a “bends” type situation. I
believe turbines and operation of them has improved.
But I’d like reassurances.
If cavitation of the turbines is not an
issue, then TDG will generally not be an
issue. In fact, the TDG exiting a
powerhouse has been found to be
slightly less than the TDG entering the
powerhouse. However, if cavitation is an
issue, it can be minimized by venting or
injecting air into the turbines. Air
introduced into turbines becomes
dissolved in the water under high
pressure, and can increase TDG levels in
tailrace waters. There are other
approaches to minimize cavitation,
however, that doesn’t involve venting
(e.g., lowering the turbine centerline
relative to the tailwater; welding
overlays of cavitation resistant
materials). And finally, dissipation of
TDG levels through shallow water
turbulence is also a possibility, given the
somewhat long tailrace.
7
Dan
Dunaway
(Stakeholder)
2.3 Project Facilities
Groin: This structure really concerns me. Depending on
design and construction it could become a barrier to
migrating adults finally topping the falls. Further it may
act as a trap to out-migrating smolt or other species
holding them or herding them to the penstock intakes.
From the beginning, one of my greatest concerns has
been the potential effects on out-migrating smolt. The
earliest concepts had water drawn from well out into
Tikchik Lake where it was hoped smolts would not be
congregated. This current concept may require very
careful design and operation of the intakes as well.
We appreciate this concern. As part of
the study program and design evaluation,
we will assess the hydraulics near the
intake to fully assess the value/impact of
a groin.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-5 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
8
Dan
Dunaway
(Stakeholder)
4.1 Aquatics/Fisheries
Resources Proposed
Studies
Pink Salmon: I have long heard from Jeff Skrade,
former ADFG, Area Biologist for the Nushagak
Commercial Fishery, that the Nushagak / Nyuakuk pink
salmon have an unusually high fat content due to their
unusually long (for pinks) spawning migration and hence
are a premium among Alaskan pinks. I did not know
until this evening that some pinks spawn above the falls.
I suggest the following: 1) assess the number of pinks
spawning above the falls to evaluation the potential level
of concern; 2) if there are significant above falls
spawners, seriously conduct an LCM for pinks as well.
Typically pinks are not nearly as strong swimmers as
sockeye or chinook and may require design and
operation considerations. Given that these pinks go so far
and climb the falls they may be uniquely stronger too.
As part of our aforementioned site visits
and refinement process (PSP to RSP) in
2022, we plan on having additional
dialogue with the ARWG regarding pink
salmon utilization (access and numbers)
of areas above the falls.
9
Dan
Dunaway
(Stakeholder)
4.0 Proposed Studies
There was a comment from Mr Vermillion about how to
value the area as it is now: I believe there are methods
for establishing such values. I know some of the Federal
conservation units have discussed such concepts
extensively. Very likely someone with McMillan Jacobs
can knows of this or can find folks who do. It is my
hope that in final form (if built) will be of very moderate
impact to the area. Large cascades / falls like these are
naturally special places.
The Cooperative appreciates and shares
this perspective. While we are currently
in the phase of determining the project’s
overall feasibility, if the project is
deemed feasible, licensed and ultimately
constructed, the Cooperative will make
every effort to blend the project with the
existing landscape and make it as low-
profile as possible. In addition and
based on precedent, it is likely that a
series of mandates (via the FERC
license) will require these types of
design elements to minimize the impact
to the visual elements of the falls area.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-6 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
10
Dan
Dunaway
(Stakeholder)
4.4 Cultural Resources
Studies
I didn’t mention this at the meeting but providing for the
on-going traditional portage opportunity at this site will
be important. I think this has been recognized before too.
The Cooperative agrees and is
committed to maintaining a portage trail
through the area if the project is
constructed.
11 BBSRDA
(Andy Wink) General Comment
Bristol Bay Regional Seafood Development Association
(“BBRSDA”) represents 1,862 salmon driftnet permit
holders that harvest roughly 80 percent of the salmon
caught in Bristol Bay. Bristol Bay is the most productive
and most valuable salmon fishery in the world, typically
yielding over $250 million in ex-vessel value. As you
probably know, the commercial salmon industry is by far
the largest economic sector in the region. The livelihood
of these fishermen, their crew members, and many other
local residents depends on abundant and sustainable
salmon runs, which in turn depends upon preserving
critical salmon habitats.
A stance which the Cooperative has
never challenged, as our Board is
composed of the community members
that have strong ties to fishing as well as
our employees. The sustainability and
ex-vessel value of the fishery should also
take into account the changing landscape
of power generation costs and carbon
production during processing to be more
resilient and future-proof.
12 BBSRDA
(Andy Wink) General Comment
Lack of a Comprehensive, Independent Cost/Benefit
Study:
The Nushagak Electric & Telephone Cooperative
(NETC) and McMillen Jacobs have provided some
cursory details of what may be gained by replacing
diesel with hydro power, but there needs to be a
comprehensive analysis of potential costs and risks. It is
also critical that this report be independent or at least
peer reviewed to assure the data and assumptions made
are accurate and objective.
All of the independent review processes
you refer to in this comment are explicit
in the FERC licensing process. Not only
will FERC have consistent opportunity
to review and assess the viability of the
project from natural resource, design and
economic perspectives, all agencies,
interested technical experts and the
public are mandated the same
opportunities throughout the process. In
short, the type of review you refer to will
happen multiple times throughout the
study planning, data collection/analysis
and feasibility assessment processes.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-7 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
13 BBSRDA
(Andy Wink) General Comment
Lack of a Comprehensive, Independent Cost/Benefit
Study:
The Nushagak district, which is comprised of three main
river systems (Nushagak, Wood, and Igushik rivers), has
been the most productive river in Bristol Bay in recent
years. Harvests of sockeye salmon in the Nushagak
district averaged 15.5 million fish per year over the past
five years, worth an annual average of $23.0 million in
ex-vessel value. A brief review of available data
provided by Bristol Bay Science and Research Institute
(BBSRI) suggests that during the mid-2000s the
Nuyakuk river accounted for approximately 24 percent
of the Nushagak river’s sockeye salmon run and BBSRI
believes that older data may indicate an even higher
percentage. It is imperative that stakeholders know how
many salmon are migrating through the proposed project
area.
We appreciate the comment and believe
that the combination of the existing PSP
and the supplemental dialogue planned
for 2022 will facilitate the
implementation of the appropriate
fisheries studies to assess impacts
(positive and negative) from potential
project development and operations.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-8 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
14 BBSRDA
(Andy Wink) General Comment
Lack of a Comprehensive, Independent Cost/Benefit
Study:
This hydro project could also create additional stress on
Chinook salmon runs in the Nushagak river. Although
relatively few Chinook salmon are caught by commercial
fishermen in the Nushagak district, as compared to
sockeye, the health of local Chinook stocks has a direct
impact on fishing opportunities for (and harvest volume
of) sockeye salmon. It has already been a challenge for
fishery managers to a) accurately count incoming
Nushagak Chinook salmon and b) allow enough Chinook
to get up-river without limiting sockeye harvests too
much, but the Bristol Bay management plan requires
protection for Chinook runs. If the hydro project were to
depress already struggling (or inadequately counted)
Chinook runs, commercial (and recreational) sockeye
fishing opportunities in the entire Nushagak district may
be significantly restricted. The economic losses from
such a scenario would be very large and we believe this
worst-case scenario, as well as the potential impact on
Nuyakuk river salmon stocks, needs to be thoroughly
understood and communicated to stakeholders.
We appreciate the comment and believe
that the combination of the existing PSP
and the supplemental dialogue planned
for 2022 will facilitate the
implementation of the appropriate
fisheries studies to assess impacts
(positive and negative) from potential
project development and operations.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-9 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
15 BBSRDA
(Andy Wink) General Comment
Lack of an Alternative Options Study:
Hydro power is just one of several options to replace
diesel-generated power in Bristol Bay. Where is the
analysis of other alternatives? Wind, tidal, or even solar
power may prove to be competitive with a hydro project,
if not even more beneficial. Further, these options would
likely create less economic risk. Such a study should also
include a cost/benefit analysis of what might be gained
by reducing the need for power generation.
From a cost/benefit analysis perspective,
that type of evaluation is explicitly
required in the FERC licensing process
so that analysis would be part of any
Final License Application and FERC
will assess that C/B as part of their
NEPA process. We would be happy to
have a discussion with BBSRDA
regarding other options considered to
date, which include both hydropower
and wind projects. No other renewable
energy projects have appeared as
feasible for development as the Nuyakuk
Project.
16 BBSRDA
(Andy Wink) General Comment
Lack of an Alternative Options Study:
We are aware that previous research has been done on
alternative power options; however, it was not clear why
this hydro project had been selected as the best
alternative. We would recommend that previous studies
of alternatives be reviewed and communicated to
stakeholders, as well as updated where necessary.
As has been conveyed at multiple public
forums, the Cooperative has explored a
variety of other potential renewable
generation options over the past 10
years. We believe that this project
represents the most likely long-term
solution to our energy needs in the
region. That said, we would be more
than happy to further describe the other
alternatives that have been evaluated in
the past at upcoming public meetings.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-10 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
17 BBSRDA
(Andy Wink) General Comment
Lack of an Alternative Options Study:
Finally on this point, stakeholders must recognize that
we will probably see continued advances in power
generation technologies in coming years. A stress-test
ought to be performed on this hydro project, in the event
that better technologies become available in the next 20
years or beyond. Can the project be profitable within a
shorter time horizon?
We appreciate the comment. Based on
our assessments over the past few years
of other generation options, we believe
hydro in general and this project
specifically represents a potential
opportunity (based on the feasibility
assessment) to develop a long-term
operational mechanism for the region
that will substantially (if not wholly)
remove the need for fossil fuel
generation. It cannot be overstated that
substantial precedent now exists for
these type of hydro facilities to last well
over 100 years. That type of longevity
and reliability has to be accounted for in
any sort of cost/benefit analysis.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-11 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
18 BBSRDA
(Andy Wink) General Comment
Concerns about Assumptions and Ability to Meet the
“First-First” Resolution:
In our discussions with several people who have tracked
this proposed project closely, we have heard some
concerns about assumptions related to how much water
will need to be diverted to achieve the necessary power
generation targets. This assumption and others need
independent vetting before the project advances too far
and consumes any more funding. If more water needs to
be diverted to achieve project goals, what impact might
that have on assumptions about fish mortality?
The fundamental intent of the aquatics
study program is to define what level of
water withdrawal can be utilized without
substantial negative impact to the aquatic
environment. The Cooperative would
again like to alleviate any concerns
related to an assumption that once the
study plan is finalized, dialogue with
stakeholders will cease. Nothing could
be further from the truth. Once data is
collected, a collaborative and
comprehensive assessment of all data
results will ultimately lead to
conclusions on the feasibility of the
project. This is a lengthy process and to
put any statement related to the
feasibility of the project in advance of
data collection and assessment would be
presumptuous. It is the Cooperative’s
genuine intent to carry out the feasibility
assessment transparently and in the order
necessary to make quality conclusions.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-12 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
19 BBSRDA
(Andy Wink) General Comment
Concerns about Assumptions and Ability to Meet the
“First-First” Resolution:
Also, while we greatly appreciate NETC’s “Fish First”
resolution (No. 2017-30) that prioritizes fish resources,
the reality is that it can be very difficult to know if
there’s a problem until it is too late. We would request
further research into how such a goal will be achieved
(as well as funded); and to what extent other projects
have been successful in similar efforts. More commonly,
it would seem to us that monitoring efforts are not
successful in predicting negative impacts until they
become apparent, by which time it’s often too late to
mitigate the damage.
There is extensive precedent for both the
success of the process the Cooperative
has entered into here as well as the
adaptive management monitoring
protocol that would likely result if this
project is constructed. We would be
happy to provide you examples upon
request.
20 BBSRDA
(Andy Wink) General Comment
Finally, we would like to recommend that NETC wait to
file the proposed study plan with the Federal Energy
Regulatory Commission (FERC) until at least March
2022. As we have explained in this letter, many
important questions remain unanswered at this time.
Despite our concerns at this point, we believe that if
prudent steps are taken and stakeholders remain
committed to reducing the high cost of power generation
in Bristol Bay, such a goal can be achieved without
creating negative impacts to the local economy. Please
feel free to reach out to BBRSDA if there is a desire to
discuss the issues raised in this letter in greater detail.
Per our recent communication and based
on stakeholder input, the Cooperative
will be filing the PSP and re-entering the
formal FERC Integrated Licensing
Process (ILP) on March 1, 2022.
21 NMFS
(Sean Eagan)
Pg 5, Section 2.1
1,544 square miles is the contributing watershed at the
USGS gaging station and the lake outlet. Since the
proposed site is four miles downriver, the contributing
watershed should be slightly larger. This incorrect
watershed boundary is also graphically represented in
Fig 2-2. (This repeats a NMFS 1/3/2020 comment)
The Cooperative has re-calculated the
watershed area and modified this
information in the PSP.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-13 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
22 NMFS
(Sean Eagan)
Pg 14
Section 2.3.4 Project
Design
NMFS encourages the utility to consider having one of
the turbines be more smolt friendly than a Kaplan turbine
(Hogan 2014). This unit could be used during the peak of
smolt outmigration. 100% juvenile exclusion at the
intake of out-migrating juveniles is a worthy goal;
however, screen systems almost never achieve it. (This
repeats a NMFS 1/3/2020 comment)
We appreciate the comment. As NMFS
is aware, the design of the project will
evolve throughout the feasibility
assessment phase with ultimate
determinations related to certain
infrastructural components being made
during the final license application phase
(assuming the feasibility assessment is
favorable to project development). The
Cooperative is committed to continuing
collaboration with the stakeholders
throughout this process.
23 NMFS
(Sean Eagan) Pg 14
Section 2.3 - Groin
The groin has the potential to exacerbate ice buildup on
both the intake and the groin itself. It is generally a poor
idea to extend concrete into a river with discharges
exceeding 20,000 cfs. (This repeats a NMFS 1/3/2020
comment)
We appreciate the comment. As NMFS
is aware, the design of the project will
evolve throughout the feasibility
assessment phase with ultimate
determinations related to certain
infrastructural components being made
during the final license application phase
(assuming the feasibility assessment is
favorable to project development). The
Cooperative is committed to continuing
collaboration with the stakeholders
throughout this process.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-14 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
24 NMFS
(Sean Eagan) Pg 16
Section 2.4.1
“river diverted to the powerhouse ranges between 43%
and 87% of average river discharge” This new text is a
large deviation from Alaska Statutes (AS§ 41.21.167(e).
Whether or not this will allow the utility to still protect
anadromous fish has to do with how the fish are using
the falls reach during that time period of high
withdrawal. Eighty-five percent water diversion during
juvenile outmigration is very unlikely to allow enough
smolt to pass without injury to sustain the population.
As mentioned throughout the initial
ARWG meetings, the feasibility studies
that will be conducted 2022-2024 will
provide the capability to assess/model the
impact to priority fish species and life
stages. Assuming the project proves
feasible, this will allow for the necessary
collaborative dialogue to determine
appropriate diversion rates that limit the
impact to fisheries species.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-15 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
25 NMFS
(Sean Eagan)
Pg 17
Figure 2-6
It would be more informative to additionally display the
hydrographs from each of the last 10 years. That 65-year
average is based on more USGS “estimated” daily
averages than ture measurements and is misleading to the
public, the agencies, and the utility itself. Focusing on
more recent and precise data is actually likely to make
the project appear more likely to meet demand year
around. (This repeats a NMFS 1/3/2020 comment)
We will be using a 25-year period of
record rather than a 10-year period or the
entire period of record for the following
reasons:
• The USGS recommends using a
minimum period of record of 25-years to
develop annual exceedance probability
flood events such as the 100-year flood
where such data is available (Guidelines
for Determining Flood Flow Frequency,
Bulletin #17B); and
• A nonstationarity analysis of the period
of record has not yet be completed, so
the extent to which nonstationarities
occur within the hydrologic record is not
yet known. For this reason, using a
maximum period of record of 25 years
will help ensure that only those years
that are most reflective of today’s
hydrologic regime are used to develop
pea flow statistics.
NOTE: The Cooperative utilized Figure
2-6 to display publicly available, site
specific data from a government agency
(USGS) that has a rigorous QA/QC
publishing protocol. It was never the
intention to mislead any of the
stakeholders.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-16 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
26 NMFS
(Sean Eagan)
Pg 31
Section 4.1
Aquatics/Fisheries
Resources
NMFS fully supports #4 that speaks to delayed juvenile
mortality. Pracheil 2016 illustrates the effects of blade
strick or near blade strike to smolts of passing through a
turbine. The smolt can still be swimming just below the
tailrace, however, they may have sustained internal
injuries that will cause them to die in the next few days.
The Cooperative appreciates the
comment.
27 NMFS
(Sean Eagan)
Pg 32
Section 4.1.1
Characterize Fish
Community
Question 1a. Is this focused on just fish piscivores or
does it also refer to birds and mammal (such as bears and
gulls) that eat fish.
The intent of 1a. in this section is
referring to piscivorous fish.
28
NMFS
(Sean Eagan)
Pg 38
Table 4-1
NMFS appreciates this new table on life stage
periodicity. The table states that all juveniles from all
five salmon species start out migrating on April 1. That
date is very important to operational considerations and
keeping smolt away from the turbines. There is research
that protecting the leading edge of the outmigration
cohort is more important than protecting the tail and may
be starting earlier due to climate change(Sparks 2018).
●How accurate is that outmigration date for the
five species?
●With more sockeye going to sea after only 1
year in fresh water will that push their fresh
water departure date to later?
Will climate change move all dates to earlier? What
clues do juveniles use to decide to out migrate?
The initial periodicity table incorporated
into the PSP is based on existing
drainage-specific and regional data. A
substantial portion of the 2022-2024
aquatic feasibility studies will be devoted
to further specifying the site-specific
periodicities associated with priority
species and associated potential behavior
modifications that may occur as a result
of both climate change and potential
project implementation.
29 NMFS
(Sean Eagan)
Pg 39
Section 4.1.1.7
Will sampling only the two 50 edge meters of the 180-
meter wide river quantify out migrating juveniles?
Juvenile salmon tend to go down the middle river where
the current is fastest. In the reach below the falls, why
not sample all the way across? Is a human carriageway
similar to what USGS uses impossible to construct?
Site visits in 2022 will assist in any
necessary refinements to the study
program. It is notable with respect to
this specific topic, safety near the falls is
a key consideration near the falls area.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-17 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
30 NMFS
(Sean Eagan)
Pg 40
NMFS preference would be for the consultants to try
multiple fish sampling techniques and locations in 2022
and determine which methods are most effective in
consultation with the agencies. Then use just one or two
fish sampling methods in a repeatable scientific process
in 2023 and 2024. This would avoid the mismatch of
difficult to compare datasets that were produced during
the Susitna studies. Some of the 2022 data would be
useable in the analysis; however, the 2022 data would
primarily be used to determine the most effect methods.
With our now established plan for
conducting robust study seasons in 2023
and 2024, the Cooperative intends on
utilizing 2022 for a series of site visits
with technical consultants to determine
the appropriate methods to utilize during
the subsequent years. These additional
assessments will take place over the
summer of 2022 and we will then utilize
the fall/winter to collaborate with the
ARWG on methodologies for the
comprehensive studies in 2023 and 2024.
31 NMFS
(Sean Eagan)
Section 4.1.1.7 general
Achievable goals should be written down for fish habitat
use in Nuyakuk Falls zone 2. If it simply is not possible
to characterize habitat in this zone while ensuring human
safety, maybe this work should be discontinued after the
first season. Alternatively, perhaps it is possible in some
seasons but not others.
We appreciate the comment and share
the primary concern for safety. As
mentioned in the prior response, a focus
of 2022 will be to determine what
methods in the falls area are achievable.
32 NMFS
(Sean Eagan)
Pg 43
Adult Salmon
Migratory Behavior
The field-testing of biotelemetry described as an activity
for 2022 is exactly the same trial period concept that
NMFS is suggesting for the plethora of net types and fish
traps. Work out the best methods in 2022.
We appreciate the comment. See
previous two responses.
33 NMFS
(Sean Eagan) Pg 45
It is possible that juveniles begin out migrate during ice
breakup periods. The applicant needs to find some
method to quantify juvenile outmigration during this
time period even if the data is less precise then after
breakup.
We appreciate the comment and intend
on utilizing both site specific data and
existing regional data to determine what
amount (if any) juvenile outmigration is
occurring prior to break-up.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-18 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
34 NMFS
(Sean Eagan) Pg 46
“Hydro-acoustics and telemetry may be used for
juveniles …”. “These technologies will be evaluated
during field testing prior to study implementation.”
NMFS agree; the spring of 2022 should be a trial study
season, rather than year 1 of the two official years.
Deng 2017 discusses using tiny acoustic transmitters.
Per previous comment, our plan is to
utilize 2022 as a field testing year for
certain aquatic methods.
35 NMFS
(Sean Eagan) Pg 46 How will you determine if avian predation will increase
with project implementation?
Utilization of existing data from similar
projects along with the site-specific data
collected on site related to current avian
predation and flow patterns will be
utilized to assess potential impacts.
36 NMFS
(Sean Eagan)
Pg 47
Section 4.1.2. Fish
Passage Study
Fig 4-4
This new figure does graphically represent the utilities
intentions in terms of water withdrawal.
1)Presenting the 70-year average hydrograph is
misleading. Present the average hydrograph
from the last decade.
Eighty-five percent diversion at the height of juvenile
outmigration is unlikely to be acceptable to NMFS.
The Cooperative utilized publicly
available, site-specific data from a
government agency (USGS) that has a
rigorous QA/QC publishing protocol.
Our intent was not to be misleading. The
PSP has been supplemented to include an
average hydrograph from the past 25
years of mean daily flow data (see
response to Comment #25 for further
detail regarding the rationale for using 25
years rather than 10 years).
37 NMFS
(Sean Eagan)
Section 4.1.2 Fish
Passage Study
NMFS remains suspicious that a model of these complex
hydraulics will not do an adequate job of modeling the
future routes fish will use to pass through the falls. Fish
utilize micro hydraulic features to get through cascades
that will be smaller than the smallest modeling unit in the
2-D model. Fish also use 3-D hydraulics and the model
will not capture this. This is not to advocate for a 3-D
model; that could potentially be less accurate still.
Per substantial consultation with the
ARWG and genuine commitment from
the Cooperative, we plan on consistent
technical dialogue with the ARWG
throughout the remainder of the study
planning process and all of the data
collection, analysis and reporting phases.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-19 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
38 NMFS
(Sean Eagan)
Section 4.1.2 Fish
Passage Study
Once the model is constructed, how will it be calibrated
and verified? 2,000 c.f.s. does happen at times during
the year. (with drones) and perhaps find a remote method
to assess water depth and velocity during a wide variety
of flows?
On site data collection will assist in
calibrating/verifying the model’s
integrity. On-site data collection will
take place in 2023 and 2024. Additional
remote data collection may include
supplemental LiDAR during this period.
39 NMFS
(Sean Eagan)
Section 4.1.2.3
Telemetry is a more robust way to decipher the often-
used routes fish take through the falls. While more
difficult than the model, it would likely be more accurate.
We appreciate the comment.
40 NMFS
(Sean Eagan)
Page 50
Section 4.1.2.3
Objective 3, 4 also
Question 8
NMFS encourages the applicant to use a large battery for
peaking rather than drastic flow alterations especially
during smolt outmigration. Cordova, Kodiak and Homer
utilities have all recently installed larger batteries.
We appreciate the comment.
41 NMFS
(Sean Eagan) Pg 50 Question 6
The groin could delay downstream passage and keep
fish milling near the intakes, which is another reason to
try to avoid building groin.
We appreciate the comment. As NMFS
is aware, the design of the project will
evolve throughout the feasibility
assessment phase with ultimate
determinations related to certain
infrastructural components being made
during the final license application phase
(assuming the feasibility assessment is
favorable to project development). The
Cooperative is committed to continuing
collaboration with the stakeholders
throughout this process
42 NMFS
(Sean Eagan)
Pg 50 Question 9
While a valid question, NMFS will not support a tailrace
design with sufficient velocities to scour out redds. Such
velocity would be a fish attractant. Scour at the base of
the falls should be less than current, as this project does
not add water.
We appreciate the comment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-20 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
43 NMFS
(Sean Eagan)
Section 4.1.2.7
Methodology
Table 4.2
Use jumping and swimming speed data collected from
fish stocks in Alaska, and preferably on the West coast of
Alaska where the rivers are comparatively flat. (This
repeats a NMFS 1/3/2020 comment) Where was the data
in Fig 4-2 collected?
We appreciate the comment and will
collaborate with the ARWG to ensure
that the jumping and swimming speed
criteria we use are acceptable.
44 NMFS
(Sean Eagan)
Pg 58 Figure 4-10
While the science and mathematical calculations
supporting Figure 4-10 are likely correct, a half-mile
long cascade is very different. There will not likely be
any true vertical leap barriers, but the lack of areas for
rest may be problematic.
We appreciate the comment.
45 NMFS
(Sean Eagan)
Pg 60
“However, the Falls Reach contains substantial areas of
highly turbulent water, and mapping in those areas can
be problematic”. NMFS appreciate this acknowledgment,
however, these area with turbulence are the most critical.
Where there is laminar flow, it is highly likely the fish
can burst through it. Clearly identify areas of the Falls
reach where nearest neighbor computations were used.
The green LiDAR data collected in 2020
was a great first step in mapping the falls
area. Not only did it allow us to identify
the depth/contour characteristics of a
significant portion of the falls, it also
allowed us to identify those turbulent
areas you refer to in your comment. The
Cooperative intends on focusing on
additional site-specific mapping of these
areas either on the ground or by
supplemental LiDAR efforts at different
flows.
46 NMFS
(Sean Eagan)
Pg 61
NMFS supports the three pass method at different rive
stages for LIDAR. This should help identify areas where
the LIDAR is leading the modeler to incorrect
conclusions.
We appreciate the comment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-21 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
47 NMFS
(Sean Eagan)
Pg 62
Assess the 2-D hydraulics models capabilities in each of
these four area.
●water extent
●water depth
●water velocity
●metric of turbulence
NMFS is skeptical of the accuracy in the last two bullets.
We appreciate the comment and plan on
continuing to work with the ARWG
throughout the model development
process.
48 NMFS
(Sean Eagan)
Pg 64 Figure 4-13
Even though it is just an example, NMFS does not
support the Tennant Method. It is not based on the
swimming ability of fish. (This repeats an earlier NMFS
comment)
We appreciate the comment.
49 NMFS
(Sean Eagan)
Pg 69
Section 4.1.3
Fish Entrainment and
Impingement
A 3D model could work in the 1,000 feet upstream of the
falls and should be considered. Juveniles out migrate at
different water depths, and correctly understanding this
could lead to substantially less entrainment. Hydropower
intakes on the Columbia are put at specific depths to
avoid entrainment. I believe any of the hydraulic models
will work in this reach.
We appreciate the comment and plan on
continuing to work with the ARWG
throughout the model development
process.
50 NMFS
(Sean Eagan)
Fish Entrainment and
Impingement
Hydraulic models have a high probability of being highly
useful in reach 1 and reach 3. There is a slight chicken
and egg conflict, in that the model will be more
informative once the designs of several intakes have
been proposed. Without a basic intake design, this cannot
work.
As has been communicated and
consistent with other licensing processes,
refinements to the project design will
utilize study results and will take place in
parallel with study reporting. Biological
data will be used to inform both design
modifications and dialogue with
stakeholders so accurate conclusions
related to impacts (positive and negative)
can be assessed during the feasibility
studies process.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-22 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
51 NMFS
(Sean Eagan)
Pg 70 Point 4
With a higher percentage of sockeye salmon out
migrating after only 1 year in freshwater, make sure this
is factored into the swimming ability calculation and
screen size determination.
We appreciate the comment and will
include this in swimming ability
calculations and considerations.
52 NMFS
(Sean Eagan)
Pg 70 question 3
Juvenile mortality is closely tied to turbine selection and
rotation speed. Please show indirect and delayed
mortality rates based on recent data from some of the
newer fish friendly turbines in addition to Kaplan
turbines. The size, blade configuration and rotational
speed of a Kaplan turbine could change mortality.
Our project engineer has substantial
experience in evaluating and selecting
the appropriate turbine types for the site-
specific environmental and biological
considerations in place. A portion of the
feasibility study process will consist of
substantive dialogue between the ARWG
and the Cooperative related to biological,
hydrologic and hydraulic data and the
implications as it relates to project
design. As has been mentioned,
refinements to the project design will
utilize study results and will take place in
parallel with study reporting. Biological
data will be used to inform both design
modifications and dialogue with
stakeholders so accurate conclusions
related to impacts (positive and negative)
can be assessed during the feasibility
studies process.
53 NMFS
(Sean Eagan)
Pg 74
Juvenile mortality through the falls should be determined
through telemetry or mark recapture studies. Although
flows will be lower once the project starts this method is
far superior to desktop methods evaluation of juvenile
death.
We appreciate the comment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-23 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
54 NMFS
(Sean Eagan)
Pg 74
While desktop entrainment studies have been approved
in the past, NMFS questions the accuracy of many of
these studies. NMFS would like a full list of studies used
to reach the conclusions about entrainment mortality and
we will read them.
We have revised the PSP to include a list
of relevant entrainment studies.
55 NMFS
(Sean Eagan)
Section 4.1.4 False
Attraction
Pg 82
Determine the 20% and 80% monthly exceedances either
using the most recent 10 years of flow data, or use the
flow rates determined by the Future Flows Study. Do not
use pre 2000 flow data.
While we understand the desire to
utilized only post-2000 data, we have a
lengthy hydrologic record for this site.
We believe there is likely some merit
incorporating it into the overall
hydrologic assessment and look forward
to reaching collaborative conclusions
with the ARWG on how much of that
record to utilize for exceedance values.
56 NMFS
(Sean Eagan)
Pg 83
NMFS supports modeling the four operating scenarios at
the top of page 83 (nice range of impacts). If you want
NMFS to consider allowing the project to remove 87% of
the flow, model that 87% removal.
We appreciate the comment.
57 NMFS
(Sean Eagan)
Pg 86
Section 4.1.5
Life Cycle Models
•Give an example of a “management relevant
threshold for the metric that constitute “risk” to
help readers understand.
Does “current condition without project” = “baseline
condition”.
The current condition without the project
would be the “baseline condition”.
58 NMFS
(Sean Eagan)
PG 86
Section 4.1.5
How does 3b differ from 3d? How is “Impact
populations projections” different from “Impact the
population?” Is “downstream passage” different from
“downstream survival”? Remember 98% of your
audience is not familiar with these models.
We appreciate the feedback on technical
detail; we agree it is important to reach
the entire audience and will revise text to
be more specific before filing with
FERC.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-24 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
59 NMFS
(Sean Eagan)
Pg 87
Question 5
“How will climate change alter the Nuyakuk River flow
and temperature regime?” The Future Flows and
Temperatures Study will answer this question. It is
confusing to list it here also.
We appreciate the comment and have
removed the referenced text from this
section.
60 NMFS
(Sean Eagan)
Pg 88
I know stages can be divided lots of ways, but it seems
surviving/growing at sea is a stage, and “escaping” the
fishermen's nets is a stage. How does the model project
the fishing effort say 30 years in the future, which will be
a stressor? Will there be a process based model to look
at fish survival in the Pacific Ocean environment of the
future?
We can build the model to be more or
less refined as to what level of detail we
use for the life stage inputs. This will be
largely determined by what data we have
and project nexus. If fishing pressure
was thought to be potentially significant
to understanding Project Impacts, then in
the absence of data, the model could
address potential future losses to fishing
by incorporating some scaling factor or
sensitivity type iterations. Model
development and data inputs is expected
to be a collaborative effort with the
Aquatic Resources Working Group.
That said, we do not anticipate building a
model capable of predicting fish survival
in a future Pacific Ocean condition.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-25 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
61 NMFS
(Sean Eagan)
Pg 91
Is a “population level impact” and impact to Nuyakuk
Chinook population and a “Fishery level impact” mean
the fishermen catch fewer Chinook? Please give
examples to help those without fisheries degrees.
We appreciate the feedback on technical
detail; we agree it is important to reach
the entire audience and revise to be more
specific before filing with FERC. For
clarification a “fishery level impact”
would be an impact significant enough to
prevent the fishery from attaining their
goals and would also be a population
level impact. However, there are other
population level impacts that, for
example, may operate on a smaller or
more local scale and may not rise to the
level of fishery impact.
62 NMFS
(Sean Eagan)
Pg 94
If the project exits abeyance in Nov of 2021 future flows
and temperature information will not be available in Q1
and Q2. If we reinitiate in May of 2022 future flows
info may be available. If we can delay needing the
future flow data until fall of 2022, we will have it.
We appreciate the comment and as
communicated, the Cooperative intends
to exit FERC abeyance in March of
2022.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-26 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
63 NMFS
(Sean Eagan)
Pg 95
Section 4.1.6
Integrated risk
Assessment Study
How do you keep this from expanding into hundreds of
tables on 20+ species? At some point, your “expert”
panel gets tired and just starts throwing numbers in the
grid that are not based on much.
The comment is correct, it will not be
efficient or effective to conduct a risk
assessment for every species. We have
identified two alternatives that will allow
us to maintain an informative risk
assessment for all priority species.
1.Assess risk for species guilds,
groups of fish species/lifestages
that use similar habitat.
2.Using representative species to
cover a variety of habitat uses
as evidenced from the baseline
fish community study.
64 NMFS
(Sean Eagan)
Pg 95
Section 4.1.6
How do you get the right people in the room to make all
these qualitative judgements? Some “experts” may have
a lot of knowledge, but little credibility in the Dillingham
Borough. Others might be highly respected in
Dillingham and know three species inside and out, but
have a lower level of understanding of other species.
We have been very pleased with the
amount of combined site-specific and
regional technical knowledge that exists
with our ARWG. We are confident in
their knowledge base and ability to make
quality collaborative decisions.
65 NMFS
(Sean Eagan) Pg 103
Section 4.1
In table 4-7 Why is Maximum Risk value more
important than summing the risk across the row?
Risks are not additive and can’t offset
each other. For example, the impact to
10 percent of the spawning population
cannot be offset by a benefit to 10
percent of the juvenile outmigrants.
During study development we will work
with the AWRG to determine what
ranking system is appropriate.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Stakeholder Distribution Draft) Comment Responses
Nushagak Cooperative, Inc. E-27 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
66 NMFS
(Sean Eagan)
Pg 103
If you retain an expert panel with some members with
Traditional Ecological Knowledge (TEK), will you
compensate all panel members? As a society, we tend to
compensate people with knowledge from universities
and neglect to compensate the people with TEK
knowledge. Agency employees are more often
compensated by their respective agency and therefore the
project should not compensate them.
If the TEK is instituted, some form of
compensation for their time may be
considered.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. August 2022
APPENDIX F:
Proposed Study Plan Comments
Department of Fish and Game
Division of Sport Fish
Research & Technical Services
333 Raspberry Road
Anchorage, Alaska 99518-1565
Main: 907.267.2294
Fax: 907.267.2422
June 27, 2022
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Subject: Nuyakuk River (P-14873-001) Hydroelectric Project
Comments on Proposed Study Plan
Dear Ms. Bose:
On March 2, 2022, Nushagak Electric & Telephone Cooperative (Cooperative) filed a request
with the Federal Energy Regulatory Commission (FERC) to re-initiate the Integrated Licensing
Process (ILP) for the Nuyakuk River Hydroelectric Project (FERC No. 14873). At the same
time, the Cooperative filed a revised Proposed Study Plan for the project. On March 10, 2022,
FERC approved the Cooperative’s process plan and schedule, which included a deadline of June
30, 2022 for comments on the Proposed Study Plan (PSP).
The Alaska Department of Fish and Game has reviewed the March 2022 PSP and offers the
attached comments.
If you have any questions, please contact me at (907) 267-2836. Thank you for your
consideration.
Sincerely,
Kevin Keith
FERC Hydropower Coordinator
Alaska Department of Fish and Game
(907) 267-2836
Cc: J. Klein, ADF&G M. Marie, ADF&G C. Warnock, MJA
T. Sands, ADF&G R. Dublin, ADF&G L. Johnson, MJA
J. Dye, ADF&G B. Jones, ADF&G C. Sauvageau, MJA
L. Borden, ADF&G A.Kastning, ADF&G M. Keefe, KG
T. Rinaldi, ADF&G S. Eagan, NMFS D. Reiser, KG
J. Schamber, ADF&G J. Kolberg, FERC E. Benolkin, USFWS
Nuyakuk River Hydroelectric Project FERC No. P-14873 June 27, 2022
Comments on Proposed Study Plan
1
COMMENTS ON THE MARCH 2022 PROPOSED STUDY PLAN
The Proposed Study Plan that was filed in March of this year has some significant improvements from
the previous Proposed Study Plan that was filed before the Integrated Licensing Process for the project
went into abeyance in 2020. The Alaska Department of Fish and Game appreciates all the work that
was done on the refinement of the study plans during the abeyance period. We also appreciate the
extraordinary level of collaboration that the Nushagak Cooperative has had with the various
stakeholders on the Aquatics Resources Working Group in the development of the study plans.
Proposed Study 4.1.1 Fish Species Abundance and Distribution Near the Project Area
In general, we are supportive of the fish abundance and distribution study. The range of methods
(literature review, beach seines, minnow trapping, electrofishing, gill/trammel netting, environmental
DNA, visual surveys, incline plane/rotary screw traps, sonar, and radio/acoustic tags) should provide
a robust picture of fish presence near the project area. Consistent sampling from April through
September will be necessary to understand the seasonal use of the area and how project operation may
affect the various fish species.
Based on past research and general knowledge of the area, it is well-known that the five species of
Pacific salmon migrate up through the Falls as adults and back down through the Falls as juveniles.
Aerial surveys, either by helicopter or drone, are proposed to estimate the magnitude and timing of the
adult migration, and incline plane traps in combination with sonar are proposed to estimate the
magnitude, timing, and spatial distribution of the juvenile out-migration. The cross-channel
distribution of the juvenile out-migration should be studied near the proposed intake location in order
to understand what proportion of smolts may be subject to entrainment at the intake. It is essential that
both the adult and juvenile salmon studies are begun early enough in the season and continued long
enough to cover the complete time range of both upstream and downstream migration.
For the resident fish species (for example, Arctic grayling, rainbow trout, northern pike), it is less clear
how often, or even if, they move upstream and downstream through the Falls. This is an important
question because the project proposes to significantly decrease flows in the Falls during certain times
of the year. The proposed study may or may not be able to answer this question. In addition to the
proposed methods, we recommend the deployment of radio tags to better understand passage through
the Falls by resident fish species.
It is also possible that the Falls reach serves as an important food source for resident species,
particularly during the winter when it is usually the only part of the river not covered in ice. For this
reason, we recommend winter sampling in the open water just downstream of the Falls; underwater
camera systems would likely work well, but there may be other methods that would also be effective.
Nuyakuk River Hydroelectric Project FERC No. P-14873 June 27, 2022
Comments on Proposed Study Plan
2
Proposed Study 4.1.2 Nuyakuk Falls Fish Passage Study
The fish passage study is one of the most important studies in the Proposed Study Plan. This study
requires the collection of scientifically sound data and careful analysis in order to meaningfully inform
a decision-making process that is consistent with the protection of the fish resources of the Nuyakuk
River.
While we are supportive of the modeling approach for this study, as summarized in the Proposed Study
Plan, we do have some concerns. The applicant has proposed using LiDAR to collect the bathymetry
data that will be necessary; LiDAR seems like a safe and efficient way to map the topography of the
Nuyakuk Falls. However, it is our understanding that the LiDAR that has been collected at the site has
some very significant gaps throughout the study site, likely due to the turbulence of the Falls.
Comprehensive bathymetric data throughout the Falls is imperative to ensure high confidence in the
2D hydraulic model proposed for study analysis and ultimately for the decision-making process. We
encourage the applicant to carefully assess bathymetry results and consider alternative methods to
supplement the existing data as needed to ensure a robust dataset, particularly for any critical barriers
in the Falls that may be identified.
We expect the 2D hydraulic model to assess the lower thresholds of flows in the Falls that allow for
fish passage. We would note that there may be days in June and July when tens of thousands of sockeye
salmon migrate upstream through the Falls. So fish passage should not just be considered in terms of
the ability of a single fish to physically navigate up the Falls, but in terms of thousands of salmon per
hour to move efficiently up the Falls.
To supplement the 2D hydraulic model, we strongly recommend that aerial photos of the entire Falls
reach (either by means of a drone or a helicopter) be taken at different flow levels with an emphasis
on the lowest flows of the year. These photos would allow for a more robust assessment of the
possibility of fish passage at low flows than an assessment that relied solely on the 2D model.
Both Figure 4-3 and Figure 4-5 present the hydrograph of the Nuyakuk River. That is, they present
the average discharge for a given time period. As this study is developed, it will be more important to
consider the low flow events in the hydrological record (i.e. flows at the 90% or 95% exceedance
during different times of the year, particularly from April to October during salmon migration); those
are the times when hydropower operation would be most in conflict with fish passage.
Proposed Study 4.1.3 Fish Entrainment and Impingement Study
The proposed study of entrainment and impingement will combine a literature review with site-
specific hydrology and flow information. The literature review will include target fish species and
sizes and swimming velocities, intake and intake screen design considerations, approach and sweeping
Nuyakuk River Hydroelectric Project FERC No. P-14873 June 27, 2022
Comments on Proposed Study Plan
3
velocities, debris management, structural modifications, and entrainment deterrent systems. Site-
specific information will include a hydraulic model of the intake reach with consideration of the full
range of natural flows and project operation flows.
All five species of Pacific salmon will migrate upstream past the intake as adults and will migrate
downstream past the intake as smolt. We are particularly concerned that the groin may act as a funnel
for outmigrating smolt and that the groin will substantially increase the rate of impingement and/or
entrainment. We request that the entrainment study also consider design modifications to the groin
that would allow for smolt passage past the groin at the range of flows that occur during smolt
outmigration.
We are also concerned that the relevant fish entrainment study reports referenced are all for sites with
primarily warm water fisheries, and no anadromous salmon species. The literature review should be
expanded to include all hydroelectric projects in the Pacific Northwest with anadromous salmon
species and similar proposed design and operational characteristics.
Proposed Study 4.1.4 Assessment of False Attraction at the Tailrace Fish Barrier
The proposed study of false attraction to the tailrace will be essential to inform the final design of the
project. The scope and magnitude of the proposed study are appropriate for a project this size. One
part of the proposed study is, “A review of available information regarding tailrace designs at similar
hydroelectric facilities as well as protective engineering design criterion associated with minimizing
salmon false attraction and the potential for migration delay.” This review should include a careful
consideration of the various pitfalls of tailrace design and how this project would avoid them.
Proposed Study 4.2.2 Flow Duration Curve Assessment
ADF&G is supportive of the goals and methodology of this study. The utility of the study could be
increased fairly simply by presenting the results in terms of flow at the Nuyakuk Falls, rather than in
terms of flow at the outlet of Tikchik Lake. A streamgage was recently installed at the project location
and we expect an excellent correlation between the flows at the project and the flows upstream, where
there is a long-term record.
Proposed Study 4.3.2 Caribou Population Evaluation
The proposed study will evaluate the Mulchatna Caribou Herd (MCH) within Game Management
Units 17B and 17C (where the proposed hydroelectric project would be located). The objectives of the
proposed study are comprised of evaluations of population status and trends, health, habitat
assessment, and land use. Each of these evaluations is necessary. Furthermore, an evaluation of how
the proposed project would affect each of these elements is also necessary.
Nuyakuk River Hydroelectric Project FERC No. P-14873 June 27, 2022
Comments on Proposed Study Plan
4
As the Proposed Study Plan notes, “The Cooperative has initiated preliminary discussion with ADFG
to establish collaboration and mechanisms for data sharing.” We will continue to work with the
Cooperative so that the possible impacts from the proposed project on the MCH can be well
understood.
Proposed Study 4.4.1 Subsistence Study
In our Study Requests, which we filed with FERC on February 4, 2020, ADF&G requested a
Subsistence Study using standardized ADF&G methodologies. These methodologies are meant to
ensure the quality of the data collected and to maintain positive working relationships with local
communities. Use of these standard methodologies will also facilitate the interpretation of the data
collected. For these reasons, ADF&G is in agreement with the proposed Subsistence Study.
The study design will be guided by the research principles outlined in the Alaska Federation of Natives
Guidelines for Research 1 and by the National Science Foundation, Office of Polar Programs in its
Principles for the Conduct of Research in the Arctic 2, as well as the Alaska confidentiality statute (AS
16.05.815). These principles stress community approval of research designs, informed consent,
anonymity of study participants, community review of draft study findings, and the provision of study
findings to each study community upon completion of the research.
The primary method for collecting subsistence harvest and use information in this project will be
through a systematic household survey. Following receipt of comments at the scoping meeting where
the project is described to residents of the study communities, ADF&G will finalize the survey
instrument. The survey will be structured to collect demographic, resource harvest and use, and other
economic data that are comparable with information collected in other household surveys in the study
communities across Alaska and with data in the Community Subsistence Information System (CSIS 3).
During surveys, ADF&G researchers will ask respondents to indicate the locations of their fishing,
hunting, and gathering activities during the study year. ADF&G uses a standard mapping method to
conducting household surveys. Points are generally used to mark harvest locations and polygons are
used to indicate harvest effort areas, such as areas searched while hunting caribou. Harvest locations
and fishing, hunting, and gathering areas are documented on iPads using the Collector application
1. Alaska Federation of Natives. 2013. “Alaska Federation of Natives Guidelines for Research.” Alaska Native Knowledge
Network. Accessed June 6, 2020. http://www.ankn.uaf.edu/IKS/afnguide.html
2. National Science Foundation Interagency Social Science Task Force. 2018. “Principles for the Conduct of Research in
the Arctic.” Accessed June 6, 2020. https://www.nsf.gov/geo/opp/arctic/conduct.jsp
3.ADF&G CSIS: http://www.adfg.alaska.gov/sb/CSIS/.
Nuyakuk River Hydroelectric Project FERC No. P-14873 June 27, 2022
Comments on Proposed Study Plan
5
(ESRI, or Environmental Systems Research Institute) customized for Division of Subsistence data
collection needs.
Prior to beginning the household surveys, the ADF&G research team will hire and train local research
assistants (LRAs) in each study community to aid in the household survey administration. Hiring an
LRA is very important for the community. LRAs support community involvement with the project
and receive funds that provide local economic benefits.
After survey data have been analyzed by the Division of Subsistence Section lead researcher, a public
community review meeting in each study community will be held to present draft study results at and
create an opportunity for residents to provide feedback to be incorporated into the final report. A final
report will be published in ADF&G’s Subsistence Section Technical Paper series, and copies of the
technical paper and a summary document of the research findings will be provided to the funding
agency (the Cooperative), the study communities, local Tribes, and the Dillingham ADF&G office.
ADF&G requires and is requesting the Cooperative secure funding for this research. ADF&G has
had discussions with the Cooperative regarding these surveys and will continue to work closely with
them in an effort to ensure that subsistence use of the project area is well understood and ultimately
protected.
Department of Natural Resources
Division of Parks and Outdoor Recreation
Chugach/Southwest Area Parks
18620 Seward Hwy.
Anchorage, Alaska 99516
Main: 907.345.5014
June 29, 2022
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Subject: Nuyakuk River (P-14873-001) Hydroelectric Project
Comments on Proposed Study Plan
Dear Secretary Bose:
On March 2, 2022, Nushagak Electric & Telephone Cooperative (licensee) filed a request with the
Federal Energy Regulatory Commission to re-initiate the Integrated Licensing Process for the Nuyakuk
River Hydroelectric Project (FERC No. 14873). At the same time, the Cooperative filed a revised
Proposed Study Plan for the project. On March 10, 2022, FERC approved the Cooperative’s process plan
and schedule, which included a deadline of June 30, 2022, for comments on the Proposed Study Plan
(PSP). The Alaska Department of Natural Resources (DNR), Division of Parks and Outdoor Recreation
has reviewed the March 2022 PSP and offers the following comments.
The DNR regulates “fish and wildlife” resources as per section 10(j) of the Federal Powers Act. At the
recent public meeting the DNR identified initial study requests identified by the Wood-Tikchik State Park
Management Council, members of the public and stakeholders may not have met the FERC study criteria,
but that does not necessarily mean the topics are of less importance and should not be studied in a fruitful
manner as they are obviously important to community members.
Of specific importance and in no particular order:
1. Evaluate potential impacts to recreation, tourism and commercial businesses during research,
construction, and operation of the project
2. Evaluate potential impacts to scenic resources of the park during research, construction, and
operation of the project
3. Evaluate potential impacts to hunting access, harvest and effects to game species populations,
distribution, and subsequent changes to ADFG regulations during research, construction, and
operation of the project.
4. Evaluate potential impacts to subsistence use, access and harvest success during research,
construction, and operation of the project
5. Evaluate potential impacts of industrial development and human disturbance on the behavior,
survival, recruitment, and distribution of big game species including caribou, brown and black
bear, moose, and wolves, as well as small game and non-game species during research,
construction, and operation of the project
6. Evaluate potential impacts to migratory corridors of Mulchatna caribou. The annual seasonal
migration route runs perpendicular to proposed transmission route.
Of additional concern are water rights. The licensee does not have a valid application for water rights
because the application process requires the licensee to apply for land use access. The issues of access are
being worked out. We would like to make it clear that the licensee has been in contact with the DNR and
is working in good faith.
It is important to note that there will need to be a companion decision process for water rights that will
include public notice and requests to Nushagak Cooperative for studies. It is our opinion that it would be
better management of resources to include the studies above as part of the study plans under FERC. The
licensee can then include the results in a single report that all public entities have access to. It is in the
public interest that the licensee includes these studies. It is also in the public interest that these studies do
not hold up a future license due to delays in the water right process.
Thank you for your consideration.
Sincerely,
Ben Corwin
Park Superintendent
Chugach/Southwest Area
cc:
C. Reese, DNR M. Wedeking, DNR K. Wilson, DNR
C. Larson, WTSPMC W. Chaney, NETC J. Kolberg, FERC
C. Warnock, MJA L. Johnson, MJA
ANDY WINK, ANCHORAGE, AK.
The Bristol Bay Regional Seafood Development Association (BBRSDA) represents all commercial salmon
driftnet fishermen who operate fishing businesses in the Bristol Bay salmon fishery. Bristol Bay is home
to the world’s most valuable wild salmon fishery and is the region’s economic cornerstone. BBRSDA has
participated in the Aquatic Resources Working Group (ARWG) since 2021 to protect the interests of
commercial fishermen and ensure the project does not jeopardize Bristol Bay’s epic, natural salmon
runs.
BBRSDA fully recognizes the need for affordable power generation in Bristol Bay and we commend the
Nushagak Telephone & Electric Cooperative (NETC) for its proactive efforts to address this need.
However, in the interest of maintaining a robust commercial salmon fishery, we have several comments
about the Proposed Study Plan (PSP) pertaining to the following topics:
1. Defining the “Fish First” directive and ensuring data collection will provide adequate measures to
follow such a policy prior to project construction, as well as monitoring conditions during project
execution.
What is “Fish First?” In November 2017, the NETC Board of Directors adopted a “Fish First” directive
when evaluating any resource utilization. However, this resolution does not define how fishery
resources are to be protected or what an acceptable loss of fish populations may be. Although the Fish
First directive is a noble and reasonable filter for potential resource utilization projects, it is imperative
that it be more specifically defined so that data collection methods can provide useful tools for the
decision-making and public education process. Different people likely have varying definitions of what
they believe the “Fish First” directive means.
Further, it is concerning that the Proposed Study Plan (PSP) does not appear to have a clear and/or
adequate set of data collection methodologies for counting the volume of fish migrating through the
Nuyakuk Falls area. The PSP lays out a goal of developing a Life Cycle Model and Integrated Risk
Assessment tool; however, even the most sophisticated models are useless unless the input data is
sound. BBRSDA is concerned by the PSP document’s lack of a clearly articulated study plan directed at
enumerating fish passage in the project area and the lack of consensus by subject matter experts on the
ARWG regarding how to measure fish passage volume. In the opinion of BBRSDA, the PSP is too
ambiguous about how critical fish data will be collected in a reliable and consistent manner to inform
the LCM, IRA, and “Fish First” specifications – both for the purposes of baseline data and post-
construction monitoring.
Finally on this point, the PSP needs to put forth a specific data collection plan that will allow for reliable
projections about impacts on fish across varying levels of water flow. As this project will redirect river
water during periods of upriver migration, the declining flow through the Nuyakuk Falls could have a
substantial impact on the ability of adult salmon to migrate upriver to spawning beds/
2. Project assumptions regarding long-term demand patterns for electric power generation.
The proposed Nuyakuk Hydroelectic project assumes that for many decades to come, the demand for
electricity will follow the current pattern where load increases substantially during the late spring and
summer months coinciding with the salmon season. Shoreside processing plants consume large
amounts of power to process and freeze salmon. However, it is possible that in the future salmon
processing will shift offshore. In 2019, Northline Seafoods operated such a business in Bristol Bay where
the company froze whole-round salmon on a barge without ever needing to deliver the fish to a
shoreside facility. A storm destroyed that barge when a mooring buoy failed late in 2019, but Northline
founders are looking at options to restart similar operations. BBRSDA has investigated the Northline
whole-round approach and found it to have numerous compelling attributes over the current processing
model used in Bristol Bay.
While it is impossible to predict whether the offshore, whole-round approach will become the new
normal in Bristol Bay in decades to come, we believe it is prudent to point out that there is a reasonable
chance that the current processing model dominated by shoreside facilities may not survive for the next
50-100 years. Therefore, it is important to provide stakeholders with a clear sense of how a potential
shift in processing activity away from shoreside plants may impact the economics of the proposed
project. To what extent does this change the predicted cost per kilowatt? What effect would this shift
have on the project’s cost burden for other NETC customers?
Thank you for the opportunity to comment on this project. Sincerely,
Andy Wink
BBRSDA Executive Director
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, D. C. 20426
June 28, 2022
OFFICE OF ENERGY PROJECTS
Project No. 14873-001—Alaska
Nuyakuk River Hydroelectric Project
Nushagak Electric & Telephone
Cooperative, Inc.
VIA USPS First-Class Mail
Will Chaney
Nushagak Electric & Telephone Cooperative, Inc.
PO Box 350
Dillingham, AK 99576
Reference: Comments on Proposed Studies
Dear Mr. Chaney:
We have reviewed the updated proposed study plan for the Nuyakuk River
Hydroelectric Project filed on March 2, 2022. We are providing written comments
pursuant to section 5.12 of the Commission’s regulations. Our comments are provided in
the attached Schedule A. We remind Nushagak Electric & Telephone Cooperative, Inc. it
must file the revised study plan with the Commission by July 30, 2022.
If you have any questions, please contact Matt Cutlip at (503) 552-2762, or via
email at matt.cutlip@ferc.gov.
Sincerely,
David Turner, Chief
Northwest Branch
Division of Hydropower Licensing
Enclosure: Schedule A
Schedule B
aki4
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule A
1
COMMENTS ON PROPOSED STUDIES
Botanical and Wetlands Survey
1. Section 4.3.1.2 (Geographic Scope) of the proposed study plan states that field
data collection will be focused on the intake and powerhouse vicinity shown in Figure 2-
3, where the majority of impacts to terrestrial resources are expected to occur. Section
4.3.1.7 (Methodology, Study Component #2) states that a field vegetation survey and
delineation of wetlands and Waters of the U.S. will be conducted in the area where
project facilities are proposed for construction, but no additional details are provided as to
what area that includes.
In contrast to this geographic scope, the pre-application document states in Section
5.2.5 that, “An initial review of all existing information documenting wetland presence,
type and quantity in the Project area will culminate in an aerial and on-foot field survey
of wetland areas that will be potentially impacted by the Project. At this time, it is
anticipated that wetlands that would be potentially impacted (if any) would be primarily
associated with the construction and operation of the transmission line.”
Therefore, please clarify if any field vegetation surveys (wetland delineation,
mapping of BLM Alaska Special Status plant species and non-native plants) are planned
to be conducted along the project transmission line corridor as part of the Botanical and
Wetland Survey. The proposed transmission line corridor totals 135 miles, and
transmission line poles are to be installed at 400-ft. intervals, which would result in the
installation of approximately 1,782 poles, clearing of the right-of-way and associated
ground disturbance from pole installation and vehicular traffic. If no field surveys for
vegetation and wetlands are planned to be conducted in the transmission line corridor,
please explain how potential impacts to vegetation will be evaluated within this area.
Caribou Population Evaluation and Noise Study
2. Section 4.5.1.8 (Proposed Deliverables and Schedule) states that the noise study
will be conducted between spring and fall 2023. One of the purposes of the noise study is
to evaluate the effect of noise on caribou in the project area as described in Table 3-1.
The desktop portion of the caribou study is scheduled to be conducted from fall 2023
through fall 2024 (see Section 4.3.2.8), which includes evaluating Mulchatna caribou
herd (MCH) land use in the project area.
There appears to be a disconnect between the timing of the noise study and the
caribou study. We recommend revising the timing of these study plans so that sensitive
areas for caribou are identified and included in the noise study, rather than identified after
the noise study is completed. Preliminary MCH land use within GMU 17B and 17C,
including migration corridors, calving areas, and foraging patterns, should be available
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule A
2
based on surveys through 2022 for the purposes of identifying sensitive areas for the
noise study.
Noise Study
3.Section 4.5.1.7 (Methodology) of the proposed study plan states the study will be
“developed in consultation with the Alaska Department of Natural Resources (ADNR),
Division of Parks and Outdoor Recreation; Alaska Department of Fish and Game
(ADFG); local outfitters; and Native Alaskan tribes that use the Project area for
subsistence or other traditional cultural practices.” The proposed study also states the
study will “identify noise receptor areas (i.e. wildlife habitat, recreation, and cultural
areas) where sound data needs to be collected,” and, “collect ambient sound level
measurements at the identified noise receptor sites.” We recommend that the
Cooperative work with the stakeholders mentioned above to identify these noise receptor
areas and sites. Please provide a schedule and methods on how the Cooperative plans to
consult with the stakeholders listed on page 133 of the proposed study plan to identify
these noise receptors.
Subsistence Study
4.The proposed subsistence study plan lacks certain details that would help us
evaluate the proposed study. For example, the study plan mentions that the location of
fishing, hunting, and gathering activities will be collected during the surveys but does not
indicate that you would collect information on when (i.e., seasons) these activities are
conducted. Please include the survey instrument in the Revised Study Plan so that the
Commission and other stakeholders can thoroughly evaluate the study proposal. Also,
please make sure a question related to the timing and seasonality of subsistence activities
is included in the survey.
5.The proposed study plan states that the ADFG intends to assist the Cooperative
with the subsistence study. There are steps listed in how a comprehensive subsistence
survey is conducted on the ADFG Division of Subsistence website, but it is not clear if
you intend to follow these steps. Please indicate if you intend to follow the ADFG’s
survey guidelines, and if so, include them in your Revised Study Plan. Please include a
detailed methodology, including how the surveys will be conducted (door to door, mail,
online, etc.), who will conduct the surveys, how many surveys would take place per
community, and when they surveys will be conducted. Please also include how the
community liaisons will be involved in the study, how they would be identified, and
details on any other planned community consultation regarding the study. It is not clear
if you intend to conduct in-person interviews to supplement the survey. We recommend
that you include interviews with local users as recommended in ADFG’s methodology.
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule A
3
6. Section 4.4.1.3 (Study Goals and Objectives) of the proposed study plan states that
Levelock and Dillingham are key survey areas from a subsistence perspective. Under
Sections 4.4.1.5 (Existing Information and Need for Additional Information) and 4.4.1.6
(Project Nexus) you do not list Levelock Village or villages near Dillingham such as the
Village of Clark’s Point or Portage Creek Village. Please clarify which communities and
villages you plan to survey, and if you don’t plan to survey Levelock Village, the Village
of Clark’s Point, or the Portage Creek Village, please explain why.
Section 106 Cultural Resources Evaluation
7. The proposed Section 106 Evaluation study plan lacks certain details that would
help us evaluate the proposed study. For example, there is almost no information about
the survey methodology. The proposed study plan states, “probability areas will be
established prior to field survey, based on topographic features and the locations of
previously recorded sites. Pedestrian surveys will be conducted in areas considered to
have higher probability for cultural resources.” It is our understanding that no prior
surveys of the study area have been done. Consequently, how will existing information
factor into deciding which areas have a high probability to contain cultural resources?
You might consider modeling or reconnaissance level surveys to narrow the areas of high
probability that require surveys within the APE. Please describe the level of effort that
would be followed for the pedestrian surveys (e.g., percent of area to be covered, length
of transects, etc.).
8. Section 4.4.2.1 (General Description of Proposed Study) of the proposed study
plan states, “the APE will be defined in cooperation with all consulting parties.” Please
make sure you include the Commission, the Alaska State Historic Preservation Office
(Alaska SHPO), and Tribes who have an interest in the project, in the consultation
process. Once the proposed APE is defined, please request that the Alaska SHPO concur
with the APE, in writing, prior to conducting any field surveys or further analysis within
the APE and include the Commission on any correspondence with the SHPO regarding
the APE. Please revise the study plan to reflect this guidance.
9. Section 4.4.2.2 (Geographic Scope) of the proposed study plan states, “based on
the current knowledge of the Project, the cultural resources survey will focus on the
Powerhouse, Diversion & Intake structures, and the Conveyance Tunnels. The proposed
airstrip and access roads would also require archaeological survey. Consultation may also
identify other areas that should be archaeologically surveyed.” The APE should, at a
minimum, include the lands enclosed by the proposed project boundary and lands or
properties outside the project boundary where project operation or other project-related
activities may cause changes in the character or use of historic properties, if any historic
properties exist. All areas that have a high probability of containing archeological
resources that will be subject to ground-disturbing activities should be surveyed, such as
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule A
4
the project transmission line and portage trail. These areas should be included in the
APE.
10. Section 4.4.2.7 (Methodology) of the proposed study plan lists methods for
completing environmental documentation, including, “draft, and final reports, including
any determinations of eligibility and recommendations on the project’s potential effects,
if requested.” The use of the term “if requested” is confusing and misleading. Section
106 and the Commission’s regulations require that the application describe the identified
resources, determine their eligibility, complete an assessment of the effects on the
resources, and propose measures to address the effects. Please revise the study plan to
remove “if requested.”
11. Section 4.4.2.8 (Proposed Deliverables and Schedule) of the proposed study plan
lists, “writing a study plan in Winter/Spring 2023,” as a proposed deliverable. The study
plan should already be written and included in the proposed study plan document for
comment. Please explain what you mean by “write study plan” and “propose any
revisions to the study plan” in winter/spring 2023.
12. We remind you that certain details in the draft and final reports should be kept
confidential and filed with the Commission and other consulting parties as privileged,
non-public documents.
Recreation Inventory by Season
13. The proposed Recreation Inventory by Season study plan (recreation study) lacks
certain details that would help us evaluate the proposed study. For example, there is no
information about the survey methodology itself.
Section 4.5.2.7 (Methodology) of the proposed study plan states that “The
Cooperative will collaboratively conduct a comprehensive recreational survey to be
employed in Dillingham and the same 4 villages outlined in the subsistence survey in
Section 4.4.1 (Koliganek, New Stuyahok, Ekwok and Aleknagik). Beginning in 2022,
the Cooperative will develop an online portal by which seasonal (4 times per year),
recreational surveys will be submitted. Contacts on the existing Project licensing contact
list will be invited to submit survey responses via the online portal. The Cooperative will
also invite participants to submit survey responses via social media outlets and the
Project licensing website. Surveys will begin in the Spring of 2022 and continue through
the winter of 2022/2023.”
What kind of survey will be employed in Dillingham and the four villages? Is this
an in-person oral survey, written survey, or combination of the two? Are the surveys
going to be conducted at the same time as the subsistence surveys, to the same
participants? How are these participants being chosen and how many? If they are going to
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule A
5
be given to the same participants as the subsistence survey, how will you mitigate for
participant fatigue and interest? If the recreation surveys are not being deployed at the
same time as the subsistence surveys, please describe when the surveys would take place
(times throughout the day, weekends/weekdays, participants, etc.), who would be
conducting the surveys, how many surveys would take place per community (and how
this is determined), and how the surveys would be conducted (door to door, mail, online,
etc.). Please include this information in the Revised Study Plan. Please explain if the
online portal mentioned above is for the Cooperative’s organization of data or if it is a
public site for members of the public to visit and fill out the survey online? Please
provide more information on how the survey link will be marketed, for example which
social media outlets will be utilized and examples of social media groups that the survey
will be posted on. When will the online survey be available and open to the public? The
survey schedule listed under Section 4.5.2.8 (Proposed Deliverables and Schedule)
mentions surveys in January, April, July, and October 2023 but the above description
mentions spring of 2022 through winter of 2023. Please correct this discrepancy. In
addition, please explain why an online survey would not be available to the public
continuously throughout the study season as compared to the four months listed above.
Please update your proposed schedule as spring of 2022 has passed. Please include the
survey instrument in the Revised Study Plan so that the Commission and other
stakeholders can thoroughly evaluate the study proposal. It is unclear if you intend to
conduct in-person surveys as well as the online survey. Please clarify in the revised study
plan. If the online survey and in-person/mailed survey are different, please include both.
14. The proposed study plan states, “it is understood that supplemental methods to the
online portal may be necessary to reach a robust enough data set to make conclusive
determinations related to potential recreational impacts associated with Project
development. A series of supplemental survey distribution methods may be utilized to
access as many interested individuals in these communities as possible,” and then lists
these supplemental distribution methods. The identified supplemental distribution
methods include seasonal village site visits, mail-back surveys, and calling. What criteria
will be used to determine if these supplemental distribution methods will be implemented
and by when? How will the seasonal village site visits be different than the
comprehensive recreational survey planned to be employed in Dillingham and the 4
villages outlined in Section 4.5.2.7? How will members of the public be chosen to have a
survey mailed to them? Will the instructions also include postage and an envelope to
mail back the survey? How will phone numbers be selected to make survey calls
(randomized by what method, selected based on certain criteria, etc.)? What kinds of
local meeting places will the surveys be distributed at and how?
15. Please provide a figure showing the geographic scope of the area where the
recreation inventory will take place.
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule A
6
16. What protocols are planned to maximize participation in surveys through the
planned methodology and through the supplemental distribution methods?
17. The survey in the proposed study plan asks participants about usage of the portage
trail but does not ask about usage for all recreational activities. The survey should ask
about usage for all recreation activities, including number of recreation trips and length of
trips. The survey asks about primary recreational activities conducted near the proposed
project but should also ask about all recreational activities conducted in general near the
proposed project area and have the participant identify which is their primary activity.
Boating seems to be one of the most popular recreation activities in Wood-Tikchik State
Park; the PAD even mentions river floating as a highly popular activity and states that
one of the most popular river trips in the park is near the project where some boaters exit
the Park after Nuyakuk Falls, therefore using the existing portage trail. Please include
river floating/boating as one of the recreational activities listed in the survey; currently it
is not listed as an activity along with hunting, fishing, etc. As mentioned above, please
include the survey instrument in the Revised Study Plan so the Commission and other
stakeholders can thoroughly evaluate the study proposal.
Visual Aesthetics
18. Page 95 of the PAD states, “The proposed Project would be located on the
Nuyakuk River near Nuyakuk Falls. Project features would be visible to both
recreational users that float the river and subsistence users that navigate upriver to access
Tikchik Lake and the lower Tikchik River. The proposed transmission lines may also be
visible from various viewpoints in the surrounding area, such as some of the public use
sites identified in the Nushagak & Mulchatna Rivers Recreation Management Plan. It is
anticipated that Project vicinity aesthetic resources will be investigated as part of the
overall Project licensing study program.” Page 113 of the PAD states, “given the remote
location of the Project site, relatively limited recreational activity occurs in the area.
However, there are lodges located in the drainage upstream of the Project site. Both
guides associated with those lodges and other individuals fish for a variety of species in
the river near the Project site and utilize it as a transportation corridor for hunting
activities. Overland activities utilizing snowmobiles and ATVs also occur in the area
along with aerial sightseeing. Given these activities, a comprehensive visual and
recreational assessment of the Project area will occur with the intent of defining the
extent of the recreational activities that occur in the Project area and describing all of the
potential impacts associated with Project development and operations. The on-site data
collection component of this effort would likely be conducted primarily from the air.”
These statements indicated that you intended to develop and conduct a visual aesthetics
assessment as part of the study process. Yet a detailed study plan was not provided in the
proposed study plan. Please include a detailed aesthetic study plan in the revised study
plan. This plan should include a viewshed/landscape analysis that identifies key areas
where visitors would see the project and its facilities and assess how those views would
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule A
7
change following project construction. The analysis could include photo simulations of
representative sites before and after the project is constructed and should identify
measures that could reduce those effects (e.g., lighting, painting, landscaping, etc.).
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule B
8
SCHEDULE B
ADDITIONAL STUDY REQUEST
To assist Commission staff with its analysis under the National Environmental
Policy Act (NEPA), we recommend that Nushagak Electric and Telephone Cooperative
conduct an Environmental Justice Study (EJ Study) for the proposed Nuyakuk
Hydroelectric Project. Pursuant to section 5.9 of the Commission’s regulations we
address the seven study request criteria below.
Environmental Justice Study
Goals and Objectives
§5.9(b)(1) Describe the goals and objectives of each study proposal and the information
to be obtained.
The proposed EJ Study has five objectives: (1) to identify presence of
environmental justice communities that may be affected by the licensing of the Nuyakuk
Hydroelectric Project, including the construction of the project, and identify outreach
strategies to engage the identified environmental justice communities in the licensing
process, if present; (2) to identify the presence of non-English speaking populations that
may be affected by the project and identify outreach strategies to engage non-English
speaking populations in the licensing process, if present; (3) to discuss effects of
licensing the project on any identified environmental justice communities and identify
any effects that are disproportionately high and adverse; (4) to identify mitigation
measures to avoid or minimize project effects on environmental-justice communities; and
(5) to identify sensitive receptor locations within the project area and identify potential
effects and measures taken to avoid or minimize the effects to such locations, if they are
present.
Relevant Resource Management Goals and Public Interest Considerations
§5.9(b)(2) — If applicable, explain the relevant resource management goals of the
agencies or Indian tribes with jurisdiction over the resource to be studied.
Not applicable.
§5.9(b)(3) — If the requester is not a resource agency, explain any relevant public
interest considerations in regard to the proposed study.
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule B
9
Executive Order 14008, Tackling the Climate Crisis at Home and Abroad,1 and
Executive Order 12898, Federal Actions to Address Environmental Justice in Minority
Populations and Low Income Populations,2 as amended, require federal agencies to
consider if impacts on human health or the environment would be disproportionately high
and adverse for environmental justice communities in the surrounding community
resulting from the programs, policies, or activities of federal agencies.
Further, Sections 4(e) and 10(a) of the Federal Power Act require the Commission
to give equal consideration to all uses of the waterway on which a project is located, and
what conditions should be placed on any license that may be issued. In making its
license decision, the Commission must equally consider the environmental, recreational,
fish and wildlife, and other non-developmental values of the project, as well as power and
developmental values.
Existing Information and Need for Additional Information
§5.9(b)(4) Describe existing information concerning the subject of the study proposal,
and the need for additional information.
The information necessary to conduct an identification of environmental justice
communities near the project is available through the U.S. Census Bureau’s American
Community Survey; however, such information must be aggregated and compared in
order to make determinations about the presence of environmental justice communities
within the project area. The nature of effects of the project on any communities present
would need to be determined through consultation with the communities, and are
dependent on the applicant’s licensing proposal.
Project Nexus
§5.9(b)(5) Explain any nexus between project operations and effects (direct, indirect,
and/or cumulative) on the resource to be studied, and how the study results would inform
the development of license requirements.
Project construction, operation, and maintenance has the potential to affect human
health or the environment in environmental justice communities. Examples of resource
impacts may include, but are not necessarily limited to, project-related effects on: erosion
or sedimentation of private properties; groundwater or other drinking water sources;
subsistence fishing, hunting, or plant gathering; access for recreation; housing or
1 86 Fed. Reg. 7,619-7,633 (January 27, 2021).
2 59 Fed Reg. 7,629-7,633 (February 16, 1994).
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule B
10
industries of importance to environmental justice communities; and construction-or
operation-related air quality, noise, and traffic.
Proposed Methodology
§5.9(b)(6) Explain how any proposed study methodology (including any preferred data
collection and analysis techniques, or objectively quantified information, and a schedule
including appropriate field season(s) and the duration) is consistent with generally
accepted practice in the scientific community or, as appropriate, considers relevant tribal
values and knowledge.
Below, we provide the methodology that Commission staff has adopted for
collecting environmental justice data for hydroelectric projects. This methodology has
been successfully employed on a number of projects in the licensing process and is
consistent with guidance from the Environmental Protection Agency’s Promising
Practices for EJ Methodologies in NEPA Reviews (2016).3 Please prepare an
Environmental Justice Study Report that provides the following:
a)A table of racial, ethnic, and poverty statistics for each state, borough, native
regional corporation, and census block group (may only exist for census tract)
within the geographic scope of analysis. For the project, the geographic scope of
analysis is all areas within 5 miles of the project construction of the proposed
project boundary. The table should include the following information from the
U.S. Census Bureau’s most recently available American Community Survey 5-
Year Estimates for each state, native regional corporation, borough, and block
group (wholly or partially) within the geographic scope of analysis:
i.Total population;
ii.Total population of each racial and ethnic group (i.e., White Alone Not
Hispanic, Black or African American, American Indian and Alaska
Native, Asian, Native Hawaiian and Other Pacific Islander, some other
race, two or more races, Hispanic or Latino origin [of any race]) (count
for each group);
3 Available online at https://www.epa.gov/sites/default/files/2016-08/documents/
nepa_promising_practices_document_2016.pdf.
Field Code Changed
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule B
11
iii.Minority population including individuals of Hispanic or Latino origin
as a percentage of total population;4 and
iv.Total population below poverty level as a percentage.5
The data should be collected from the most recent American Community Survey files
available, using table #B03002 for race and ethnicity data and table #B17017 for low-
income households. A template table is provided below.
b)Identification of environmental justice populations by block group, using the data
obtained in response to part a above, by applying the following methods included
in EPA’s Promising Practices for EJ Methodologies in NEPA Reviews (2016).
i.To identify environmental justice communities based on the presence of
minority populations, use the “50-percent” and the “meaningfully
greater” analysis methods. To use the “50-percent” analysis method,
determine whether the total percent minority population of any block
group in the affected area exceeds 50-percent. To use the
“meaningfully greater” analysis, determine whether any affected block
group affected is 10-percent greater than the minority population
percent in the native regional corporation using the following process:
1.Calculate the percent minority in the reference population
(native regional corporation);
2.To the reference population’s percent minority, add
10-percent (i.e., multiply the percent minority in the reference
population by 1.1); and
3.This new percentage is the threshold that a block group’s
percent minority would need to exceed to qualify as an
environmental justice community under the meaningfully
greater analysis method.
4 To calculate the percent total minority population, subtract the percentage of
“White Alone Not Hispanic” from 100 percent for any given area.
5 To calculate percentage of total population below poverty level, divide the total
households below the poverty level by the total number of households and multiply by
100.
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule B
12
ii.To identify environmental justice communities based on the presence of
low-income populations, use the “low-income threshold criteria”
method. To use the “low-income threshold criteria,” the percent of the
population below the poverty level in the identified block group must be
equal to or greater than that of the reference population (native regional
corporation).
c)A map showing the project boundary and location(s) of any proposed project-
related construction in relation to any identified environmental justice
communities within the geographic scope. Denote on the map if the block group
is identified as an environmental justice community based on the presence of
minority population, low-income population, or both.
d)A discussion of anticipated project-related effects on any environmental justice
communities for all resources where there is a potential nexus between the effect
and the environmental justice community. For any identified effects, please also
describe whether or not any of the effects would be disproportionately high and
adverse.
e)If environmental justice communities are present, please provide a description of
your public outreach efforts regarding your project, including:
i.a summary of any outreach to environmental justice communities
conducted prior to filing the application (include the date, time, and
location of any public meetings beyond those required by the
regulations);
ii.a summary of comments received from members of environmental
justice communities or organizations representing the communities;
iii.a description of information provided to environmental justice
communities; and
iv.planned future outreach activities and methods specific to working with
the identified communities.
f)A description of any mitigation measures proposed to avoid and/or minimize
project effects on environmental justice communities.
g)Identification of any non-English speaking groups, within the geographic scope of
analysis, that would be affected by the project (regardless of whether the group is
part of an identified environmental justice community). Please describe your
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule B
13
previous or planned efforts to identify and communicate with these non-English
speaking groups, and identify and describe any measures that you propose to avoid
and minimize any project-related effects non-English speaking groups.
h) If new construction is proposed, identification of sensitive receptor locations (e.g.,
schools, day care centers, hospitals, etc.) within the geographic scope of analysis.
Show these locations on the map generated in step c. Provide a table that includes
their distances from project facilities and any project-related effects on these
locations, including measures taken to avoid or minimize project-related effects.
This study should be conducted in consultation with other relicensing stakeholders who
express interest. When you file your final study report with the Commission, please
include documentation of any consultation you conducted with entities that expressed
interest in environmental justice, copies of their comments, and an explanation of how
you have addressed their comments in your final response.
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Project No. 14873-001
Schedule B
14
Environmental Justice Data Table Template
RACE AND ETHNICITY DATA
LOW-
INCOME
DATA
Geography Total
Population
(count)
White
Alone
Not
Hispanic
(count)
African
American
(count)
Native
American/
Alaska
Native
(count)
Asian
(count)
Native
Hawaiian
& Other
Pacific
Islander
(count)
Some
Other
Race
(count)
Two or
More
Races
(count)
Hispanic
or
Latino
(count)
Total
Minority
(%)
Below
Poverty
Level (%)
State
Native
Regional
Corporation
County or
Borough
Census
Tract X,
Block
Group X
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
Document Content(s)
P-14873-001 Nuyakuk Comments on PSP_signed.pdf ...........................1
Document Accession #: 20220628-3034 Filed Date: 06/28/2022
2
June 29, 2022
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
RE: Comments on the Proposed Study Plan and re-iteration of two Study Requests for the
Nuyakuk River Hydroelectric Project (P-14873)
Dear Secretary Bose:
On March 30, 2022, Nushagak Cooperative reissued the Proposed Study Plan (PSP) for the
Nuyakuk Hydroelectric Project (P-14873) after you lifted the licensing process abeyance on
March 10, 2022. The reissued PSP, which was originally filed in early 2020, included five of the
studies we requested on February 4, 2020 (accession # 20200204-5068). We are providing
comments on the studies included in the reissued PSP (Enclosure 1) and reiterating our request
for two studies with modifications: the Flow Duration Curve Change Analysis and the Future
River Flows and Water Temperatures (Enclosure 2).
The stated purpose of the proposed Nuyakuk Hydroelectric Project (Project) is to transition six
communities from diesel generation to hydroelectric generation and support fish processing and
packaging efforts in those communities. The proposed Project will create a renewable power
source and drastically reduce the operating costs each household, salmon processing, and other
industries. With the affected communities paying as much as $8 per gallon for diesel, the Project
has the potential to offset more than $1 million dollars annually.
This Project purpose is consistent with our agency mission to support resilient ecosystems and
coastal communities. We support the development of safe, climate resilient renewable energy.
However, hydropower development can compromise the habitat and sustainability of migratory
fish such as salmon; fish upon which the local communities rely. In waterways such as the
Nuyakuk River, which support a significant portion of Bristol Bay sockeye salmon and four
other salmon species, the impacts of energy development can directly affect fish and habitat.
Protection of migratory fish and their habitat warrant equal consideration to energy generation
throughout the licensing proceedings. The Nuyakuk Project is consistent with the Strategic
Conservation Action Plan for Southwest Alaska Watershed, which you accepted as a
comprehensive plan. Therefore, measures to protect fish and their habitat should be considered
integral components of the Nuyakuk River Hydroelectric Project design. Close coordination
with us and other state and federal resource agencies will facilitate the review and design
2
process that supports the project purpose while protecting the fish and habitat resources vital to
the local communities and ecosystem.
Critical to this review process is an understanding of the expected environmental conditions
during the term of any potential license. The requested Flow Duration Curve Change Analysis and
the Future River Flows and Water Temperatures studies address the future river and
environmental conditions and is integral to several proposed studies. Information generated from
these two studies will support the design, operation, and potential mitigation needs for the
proposed project in an environment known to be changing. Understanding the future
environmental condition, which has become standard practice across government agencies, will
also support an economically viable project that supports the local communities. Our staff and
our NOAA climate science partners are available and willing to discuss the details of the Future
River Flows and Water Temperatures study to ensure its value for all parties.
Please contact Sean Eagan sean.eagan@noaa.gov or by phone at 907-586-7345 or Sean
McDermott at sean.mcdermott@noaa.gov if you have any questions.
Sincerely,
Gretchen Harrington
Assistant Regional Administrator for
Habitat Conservation
Enclosure 1: National Marine Fisheries Service’s Comments on Nushagak Cooperative’s
Proposed Study Plan
Enclosure 2: National Marine Fisheries Service's Revised Study Requests for the Nuyakuk Project
(FERC No. P-14873)
cc: Matt Cutlip, FERC, Matt.Cutlip@ferc.gov
Will Chaney, Nushagak Cooperative, wchaney@nushagak.coop
Laura Johnson, McMillen Jacobs Associates, ljohnson@mcmjac.com
Cory Warnock, McMillen Jacobs Associates, Warnock@mcmjac.com
Carol Mahara, USFWS, carol_mahara@fws.gov
Kevin Keith, ADFG, kevin.keith@alaska.gov
Bryan Nass, BBSRI, bryan@bbsri.org
Lee Borden, ADFG, lee.borden@alaska.gov
Tim Sands, ADFG, tim.sands@alaska.gov
1
Enclosure 1
NOAA Fisheries Comments on the Studies Described in the
Nuyakuk Proposed Study Plan (March 3, 2022)
June 29, 2022
Our global comment is to commit to fewer study components; however, focus on doing the
components that remain well.
4.1.1 Characterization of the Fish Community (FC) and Behavior Near the Project Area
Study
FC-1 Baseline Migratory patterns (questions 3 and 4) are extremely important to understand
potential project effects. If a species migrates during a 2-month period, we request
information about the early returning fish, mid-returning fish, and late returning fish. Those
that migrate up the cascade at the tail ends of the run may be the most important as they will
demonstrate passage through the falls at lower water (Page 35).
FC-2 Most movement of smolt downstream through the falls will be primarily non-volitional
(i.e., move with currents). We still request information on both the early out-migrants and
the late out-migrants to idenitify which portion of the river they favor in Zone 1 above the
falls (Page 35).
FC-3 We recommend the fall sampling events extend into October as we know there will be
resident fish and coho in the river. The climate is changing and Chinook and sockeye could
also be returning later (Page 40).
FC-4 We do not support significant physical fish sampling in Zone 2. Similar quality data could
be obtained with a greater level of safely by tagging fish above and below the cascade
(Zones 1 and 3) and tracking them through the falls. We do support the use of drones to
identify holding or staging areas. It should be noted that although drones can show that fish
are holding in a certain area, there could be subsurface holding areas which the drones will
not identify (Page 41).
FC-5 Minnow Trapping - If smolt primarily stay in the main current and the minnow traps are
place at the stream margins, the minnow traps will not capture a good cross-section of
outmigrating smolt (Page 41).
FC-6 This still reads like a list of “candidate” techniques and provides agencies very little
information on methods that will be actually used. We anticipate more discussion with
consultants as fish sampling methods are defined in the next nine months (Pages 41-43).
FC-7 We fully support biotelemetry surveys and encourage the utilities to conduct studies that
last throughout the summer. We do not have a strong preference for radio or acoustical
telemetry, however, the study design and implementation must be rigorous.
FC-8 We support the deployment of fixed antennae on the various islands within the falls, if
possible. This would provide complementary information to that collected through drones.
FC-9 Downstream Migrant Trapping- One or two 24-hour sets of minnow traps would be good.
Smolt likely move in crepuscular timeframes similar to the Kvichak River at Igiugig. It is
possible that 6 hours nighttime sets would capture the majority of the smolt.
2
FC-10 Telemetry efforts should be set up with the vision that studies will likely extend for 3-5
summers. Based on past experience, it is unlikely that studies will cease prior to
construction.
4.1.2 Nuyakuk Falls Fish Passage (FP) Study
FP-1 We recommend the downstream passage studies be grouped with Fish Entrainment and
Impingement as that is the primary threat to downstream passage.
FP-2 The most important upstream migration goal is the amount of time adult fish take to pass
through the falls. If you can determine the time to passage at most flows that fish are likely
to experience post project, the exact route through the cascade is less important.
FP-3 We would like to see fish tracked through the falls at flows twice the lowest flow that will
be in the falls during upstream migration for the low end and up to 10,000 cfs. The low
flow tracking is of more interest than the higher flow tracking. A fish that is holding due to
high flows will likely have a chance at lower flows before the migration window closes.
FP-4 Tracking the route of out-migrating smolt is primarily important in Zone 1 near and
immediately upstream of the intake. Tracking or modeling the smolt route through the
cascade will not likely add much value.
FP-5 Objective two is actually more important and easier to quantify than objective one (Page
50).
FP-6 Stranding or trapping of a sufficient number of adults to affect the population is not a likely
outcome. Focusing on smolts would be more productive (Page 50).
FP-7 HEC-RAS models will be extremely useful and accurate in Zones 1 and 3. We fully support
their use in looking at the effects of the intake and the tailrace. We question whether a
useful HEC-RAS model can be developed for the complex flow dynamics that exist in the
falls. If you develop it, calibration and validation will be challenging.
4.1.3 Fish Entrainment and Impingement (E&I) Study
E&I-1 (Geographic Scope) The correct extend for the 2-D model should be three river widths
upstream of the center of the Intake Structure (Page 69).
E&I-2 Goal 5: Since specific details of technical features such as fish screens will not be designed
for several years, this study cannot be based on those specifics (Page 71).
E&I-3 We recommend considering options to design a system where screens or other deterrents
can be added later, if the smolt entrainment percentages are initially too high.
E&I-4 While we do not consider a groin to be necessary or desirable component, we are more
comfortable with a non-continuous groin made of large natural rocks than a concrete wall.
A non-continuous groin will support removing material from in front of the intake during
high flow event.
E&I-5 Include information on whether the results from desktop entrainment study that you plan to
replicate actually matched entrainment monitoring carried out once the project was
completed.
E&I-6 The impingement study should focus on juvenile fish. Salmon adults that make it up the
Nuyakuk cascade will be inclined to swim up current and can likely outswim the intake
velocities (Page 76).
3
E&I-7 Turbine and blade designs that decrease the likelihood of juveniles touching the moving
parts are currently being developed. Expand the investigation beyond the traditional Francis
and Kaplan turbines.
4.1.4 Assessment of False Attraction at the Tailrace Fish Barrier (T) Study
T-1 NMFS 2011 was updated to NMFS 2022: Anadromous Salmonid Passage Facility Design.
It is available at https://www.fisheries.noaa.gov/resource/document/anadromous-
salmonid-passage-facility-design (Page 82)
4.1.5 Chinook and Sockeye Salmon Life Cycle Modeling (LCM)
LCM-1Objective 1- We have a mandate to maintain healthy anadromous fish populations across
their full range, including the Nuyakuk River (Page 85). The Nuyakuk salmon play a
crucial role in maintaining genetic diversity in the larger Bristol Bay watershed.
LCM-2 Data Acquisition – Passage success can be equally or better determined by tracking fish
below and above the project. The 2D hydrologic model (which should be hydraulic model)
will have trouble capturing the fine scale flow paths through the cascade which the fish may
utilize (Page 91).
4.1.7 Future Flows Study
We request you replace most of this text with our rewritten Future River Flows and Water
Temperature Study (Enclosure 2).
4.2.2 Flow Duration Curve Assessment
See our modifications to the Flow Duration Curve Change Analysis study request (Enclosure 2).
4.2.3 Ice Processes (IP) Assessment
IP-1 Include information gained about ice process from the substantial ice formation last winter.
Even though the climate is warming, ice events will happen in the future.
4
Enclosure 2
National Marine Fisheries Service's Revised Study Requests for the Nuyakuk Project
(FERC No. P- 14873)
June 29, 2022
The National Marine Fisheries Service hereby modifies two of our study requests with the
Federal Energy Regulatory Commission for Dillingham Cooperative’s (Applicant) Nuyakuk
River Project (P-14873) in Alaska. The Nushagak Utility included the content of five of the
seven study requests from our February 4, 2020 filing in their 2020 Proposed Study Plan (PSP).
The Applicant included the content of all seven studies in the 2022 PSP; however, we have since
updated the Flow Duration Curve Change Analysis (Study 4) and Future River Flows (Study 5).
We request that this new language be included in the Final Proposed Study Plan. Each study is
supported using the Commission's study plan criteria at 18 CFR 5.9(b). Information derived from
each of these studies will inform the decision process during this licensing action.
The two modified studies, included below, are:
Study 4: Flow Duration Curve Change Analysis
Study 5: Future River Flows and Water Temperatures
Nushagak Utility included the following five studies in both the 2020 and 2022 PSPs. These five
requests are identical to what we requested in our February 4, 2020 Study Request letter
(accession # 20200204-5068).
Study 1: Fish Distribution, Timing of Migration, and Abundance
Study 2: Upstream Fish Passage through Nuyakuk Falls
Study 3: Downstream Passage and Intake Design
Study 6: Ice Processes Assessment
Study 7: Assessment of False Attraction at the Tailrace Fish Barrier
5
Study Request 4
Flow Duration Curve Change Analysis
Background
Published studies indicate shifting climate conditions for Bristol Bay watershed over the last 50
years (Thoman 2019) and project future change as a result of climate change (Wobus 2015)
during the next century. During the term of any new license for this project, Southwest Alaska
will experience increasing temperatures and increasing annual precipitation (Walsh 2018). The
resulting changes in environmental conditions during the next 30-50 years will influence project
operations, scope and scale of project related impacts, and the effectiveness of mitigation
measures designed to protect fish habitat. This study will help identify trends in flow conditions
to provide a forward-looking evaluation of the flow duration curve. Data from this study will
inform the licensing process with specific application to project design, operation and fish
protection measures. The Applicant suggested a similar study during the November 18, 2019
project kickoff meeting.
Content of Study Request (18 CFR § 5.9 (b))
1. § 5.9 (b): Goals and Objectives of Request
The goal of the study is to evaluate changes in the flow duration curve for the Nuyakuk River
that have happened during the USGS 15302000 gage record which spans 69 years (1953-
2022). There are a few years with no data and many years where the winter flow is estimated
from nearby rivers. This study request will not analyze climate projections or future flows.
The objectives of this study are:
a. Determine if flow pattern observable for the USGS Nuyakuk River gage record
exhibit stationarity as hydrologist assumed for decades, or if there is a statistically
significant trend (Milly 2008) consistent with other gage records in Northern climates
where a change analysis has been completed.
b. Use the appropriate data to inform the development of climate resilient license
articles. This is a statistical study using peer reviewed existing USGS flow data.
2. § 5.9 (b): Resource Management Goals
The relevant resource management goals are captured in the NOAA Fisheries’ Alaska
Geographic Strategic Plan for 2020-2023 (NOAA 2020) and the Strategic Conservation
Action Plan for Southwest Alaska (SASHP 2017). Identified in the Alaska Geographic
strategic plan is (1) ensuring healthy, sustainable fisheries and mariculture over the long term
with ecological, economic, and socio-cultural benefits for the nation and (2) supporting the
socio-economic well-being of fisheries, and fishing communities through science-based
decision-making and compliance with regulations. Our involvement is also supported by
mandates under the Fish and Wildlife Coordination Act and Magnuson-Stevens Fishery
Conservation and Management Act.
6
3. § 5.9 (b): Relevant Public Interest Considerations
The requestor, the National Marine Fisheries Service, is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
4. 5.9 (b): Existing Information and Need for Additional Information
The existing flow curve relies on methods developed prior to our current understanding of
climate, especially that although stream flows are variable between years and months, they are
often no-longer tied to a static horizontal line (stationarity). The analysis will indicate if
stationarity (Milly 2008) exists at the Nuyakuk gage. This evaluation has not been completed
for this USGS gage record. Methods exist to complete a similar analysis in a more rigorous
fashion and indicate the months showing clear trends versus those merely indicating variation
between years
Figure 1. This analysis of the Nuyakuk Gage at Tikchik Lake Outlet (USGS #15302000) indicates
the onset of spring runoff begins 20 days earlier now. November and December flows are higher
the last two decades than in any time from 1954 - 2000.
7
Figure 2. Average daily flow for each May at USGS gage record at Tikchik Lake outlet. The 69
years exhibit an upward trend due to early snowmelt, with current flows almost double those of
the early 1950s (~3,500 vs ~6,500 cfs). Average May flows were consistently between 2,000 and
6,000 cfs from 1954 to 1975. From 1975 to 1995 average May flows above 6,000 cfs occur in 33
percent of the years. After 2002 average May flows were above 10,000 cfs more in more years
than below 4,000 cfs which was the average those first 30 years.
5. § 5.9 (b): Nexus Between Project Operations and Effects on the Resource Studied,
and How the Study Results would Inform the Development of License Requirements
River flow and its seasonal patterns directly influence project design and operations, and
mitigation measures intended to protect public trust resources. As this is a new project
development, the applicant should consider the changing environmental conditions on which
their project is dependent for successful operation. As flow patterns change, changes in
project operations often occur. For example, the Bradley Lake Project (P-8221) licensee
decided not to divert water from Battle Creek on November through May based on gage data
from the historical record. Historical data indicated no flow worthy of diversion during this
timeframe. In 2019, both November and December saw 1,000’s of acre feet flow down
Battle Creek as large precipitation events arrived primarily as rain. Based on the license
condition, which was premised on the historical, stationary hydrograph, the licensee could
not capture this potential generation.
Likewise, project operations influence the behavior of migrating fish within the project area.
The information collected by this study would support the analysis of direct and cumulative
effects of the proposed project on migratory fish and aid in the development of any necessary
license articles regarding measures to achieve fish passage. If this watershed runoff pattern is
non-stationary, then design consideration, operations models and license articles should be
flexible enough to deal with to manage future change.
6. § 5.9 (b): Consistency with Generally Accepted Practice
Studies should use current literature, existing data from the USGS gage (USGS No.
15302000), and standard practices accepted by the scientific community. A duration curve
change analysis is a standard Bureau of Reclamation analysis method. Many utilities with
8
hydropower projects are employing it for their decision making processes.
7. § 5.9 (b): Considerations of Level of Effort and Cost
All the data necessary to complete this study are available. The analysis could be completed
within two to four months. The level of effort and cost is commensurate with the proposed
project size and the likely license term. No alternatives have been proposed.
9
Study Request 5
Future River Flows and Water Temperatures
Overview
The Nuyakuk Project has the potential to be designed and operated in a manner that maintains
habitat quality and suitability for the fish and provide renewable hydropower for six Alaskan
communities currently dependent on diesel for power generation. To realize the combined benefits
it is necessary to understand the consistent projection of increases in precipitation and changing
timing of flows in the Nuyakuk watershed. Therefore, we request that the existing peer reviewed
climate model predictions be used to model future discharges and water temperatures for the
Nuyakuk River, in accordance with peer- reviewed published methods and generally accepted
practice as described below. This information will inform the development of license articles
guiding operation and maintenance, including mitigation measures, as well as the development of a
climate resilient project design.
The best available science indicates temperature, precipitation, and stream flows will increase in
the Bristol Bay region, and much of south central Alaska (IPCC 2018; Walsh et al. 2018;
USGCRP 2018; Chapin et al. 2018). Thus, higher stream flows are likely to occur within the
project area during the prospective license term. Some ongoing trends and anticipated climate
changes have implications for management of the hydropower facility and fish habitat. These
include a decrease in the proportion of precipitation falling as snow, with many sub-basins no
longer expected to be snow-dominated (Littell et al 2018), and as a consequence, an altered
hydrograph with earlier but perhaps lower spring/summer peak. January through April flows will
continue to increase as low elevation sub-basins partially melt out during freshets rather than
staying frozen for four continuous months. Peer-reviewed, publicly available downscaled climate
model projections have been developed for this region. These model projections should be
analyzed as part of this licensing process to support flow analysis for this project.
There is a significant body of literature on climate change in the Arctic and Alaska in particular
(Stewart et al 2022, Markon et al 2018). While these publications give a sense of what kinds of
changes may be observed in the Nushugak River, due to proximity, analysis of a region including
this basin, and other similarities, a study of the Nuyakuk basin itself is needed to understand the
combined changes of the proposed project and climate change on fish habitat.
Background
The Nuyakuk River supports a commercial, subsistence, and recreational sockeye fishery, as well
as many other fish species, including large runs of Chinook and coho salmon. These species rely on
these riverine systems for refuge, spawning, rearing and nursery habitat. The Nuyakuk River and
Tikchik Lake supports the second largest sockeye run in the world; second only to the Kvichak
River and Lake Iliamna. Adult sockeye pass through the Nuyakuk cascade to spawn in the lakes
above. Smolts pass back down the cascade on route to the ocean to mature. Furthermore, the timing
of adult escapement and smolt outmigration is keyed to water temperature, which is strongly
affected by air temperature (Mauger et al. 2016) and projected to change with increasing air
temperature.
10
Salmonids are affected by changes in flows because stages in their life history are timed to
coincide with periods of flow and appropriate water temperature. Future flows through the
Nuyakuk cascade will be altered by the Project’s water withdrawal and by changing climate
patterns. Many of the climate change effects described below have likely impacts on salmonids
(Leppi et al 2014; Wobus et al 2015) and potentially compounded by the proposed Project’s
operations. Given that increased flows are projected by the five member ensemble of global
climate models (GCM) best fitted for Western Alaska, these increases provide opportunities to
benefit both the hydropower generation and fish management and protection. Therefore, it is
critical to have estimates of future flows and stream temperatures to assess the combined effects
of the project and climate on these trust resources. This study is at the core of producing more
evenly distributed year-around hydropower generation, while at the same time protecting and
maintaining this salmon fishery. This is in line with recent literature that highlights opportunities
to design and operate hydropower projects for sustainability of both power production and the
riverine environment (Brown et al. 2015; Poff et al. 2016). Thus, this study request will identify
forward-looking, climate resilient outcomes for hydropower development and fisheries.
Trends in the Region
We included published literature for the Bristol Bay Watershed. Documented trends include (all
Thoman & Walsh 2019 unless noted):
● Increase of 3.7º F in air temperature in the Bristol Bay region, 1969-2018
●Increase of 13 percent increase in annual total precipitation in Bristol Bay Region, 1969-
2018.
●Lowest sea ice extent in Bering Sea in February 2019 in last 170 years
● Total change in mean annual temperature in Alaska from 1976-2020 of 5.3°F, and 9.6°F,
5.2°F, 2.5°F, 3.2°F changes seasonally (winter, spring, summer, fall)1
● The climate normals for the Bristol Bay region for 1991-2020, announced by NOAA
in May 2021, are +1.1°F compared to the climate normal for 1981-2010. 2
● Bristol Bay has rarely frozen in the last decade; people and animals used walk or sled to
the nearby islands mid-winter on a regular basis (Markoff 2019).
Nuyakuk Watershed Hydrology
The proposed project will be located on the Nuyakuk River at a cascade approximately five river
miles downstream from the Tikchik Lake outlet, which drains the northern Wood River
Mountains, a 1,544 square mile watershed. The watershed contains six large lakes that comprise
12 percent of the land area. An additional 50 percent of the watershed is below 1000 feet in
elevation. While the highest peak is over 5,000 feet, the vast majority of the watershed is below
3,000 feet in elevation. There are no significant glaciers; permanent snowfields make up less
than 1% of the watershed. The proposed project would divert water out of the river above
Nuyakuk Falls, pass it through a tunnel(s) to a powerhouse located at the base of Nuyakuk Falls.
Nuyakuk Falls is a ½ mile long cascade with only 28 feet of elevation change. The Nuyakuk
watershed drains the west side of the Nushagak River basin. The Koktuli River, another tributary
1 https://akclimate.org/climate-change-in-alaska/
2 https://akclimate.org/the-new-climate-normals/
11
to the Nushagak that was modeled in a project discussed below, drains from the east side of the
Nushagak.
There is a 69-year USGS gage record at Tikchik Lake outlet. The lowest mean daily winter flows
this decade are approximately 2,000 cfs, with the daily flows dropping below 1,500 cfs during
two winters. A broad, snowmelt-driven peak arrives in late-May/early-June and remains through
mid-August. The flow typically remains above 10,000 cfs for two months with a peak flow
between 15,000 and 22,000 cfs. Half of the Octobers in the last decade have had a second peak
over 10,000 cfs lasting days to two weeks. The Nuyakuk River hydrograph is not flashy because
it has several large upstream lakes.
The hydrology of the Nuyakuk basin is changing (Figures 1, 4 and 5). Consistent with climate
models, mid-winter flows are higher, spring melt is happening 20 days earlier, and late falls
flows are also higher. While late summer months flows have decreased slightly, there is still
sufficient water to generate energy and provide sufficient flow for fish passage through Nuyakuk
cascade.
Figure 1. This analysis of the Nuyakuk Gage at Tikchik Lake Outlet (USGS #15302000) indicates the
onset of spring runoff begins 20 days earlier now. November and December flow were higher the last
two decades then in any time from 1954 - 2000.
Relevant Climate Studies
Global climate models strongly agree on 21st century projections of significant increases in winter
precipitation and temperature in Alaska and across high latitudes (Maloney et al 2014). This
finding of increases in winter precipitation is also consistent across three generations of the IPCC
Coupled Model Intercomparison Project (CMIP). CMIP is an internationally coordinated project
that provides a standard experimental protocol for studying global climate models (GCMs)
(CMIP3, CMIP5 and recently available CMIP6.
Temperatures in Alaska are projected to rise dramatically in the next decades, within the period of
the proposed license (Figure 2) (Stewart et al 2022). Most of the warming has occurred in the
12
winter and spring and the least amount in the summer and fall. Spring temperatures have been
above average since the late 1980s, and winter temperatures have been mostly above average
since 2001.
Figure 2. Observed and projected changes (compared to the 1925–1960 average) in near surface
air temperature for Alaska as a whole. Observed data are for 1925–2020, while model
simulations of the historical period are shown for 1901–2005. Projected changes for 2006–2100
are from global climate models for two possible futures: one in which greenhouse gas emissions
continue to increase (RCP 8.5, higher emissions) and another in which greenhouse gas emissions
increase at a slower rate (RCP 4.5, lower emissions). Temperatures in Alaska (orange line) have
increased by about 3.5°F since 1925 but with large multidecadal variations. Shading indicates
the range of annual temperatures from the set of models. Observed temperatures are generally
within the envelope of the modeled historical simulations (gray shading). Historically
unprecedented warming is projected during this century. Less warming is expected under a
lower emissions future (the coldest end-of-century projections being about 2°F warmer than the
historical average; green shading) and more warming under a higher emissions future (the
hottest years being about 15°F warmer than the hottest year in the historical record; red shading).
Sources: CISESS and NOAA NCEI, Figure 1 in Stewart et al 2022.
With respect to precipitation, Alaska is projected to have higher precipitation across the state, with
a statistically significant increase of 10 to >15% for the Nushagak basin based on CMIP5 models
(Stewart et al 2022). Significant changes in the hydrograph are projected, due to both these
projected temperature and precipitation changes.
Recent work has emphasized several trends and projections that are highly relevant for the
nexus/combined management of hydropower and fish habitat. In particular, there is both a trend in
the proportion of precipitation falling as rain vs snow, and the same trend is seen in GCM
projections (Littell et al 2018). This results in an altered seasonal hydrograph, with earlier peak
flows, and lower late summer flows because most of what would have run off slowly as snowmelt
13
has already run off. One effect of increasing temperatures is a shift in the proportion of
precipitation falling as rain vs snow that will result in an altered hydrograph and necessitate
different management of the hydropower facility both for power and for fish habitat. Littell et al
(2018) have analyzed basins including those in the Bristol Bay climate division to assess the
snowfall equivalent to precipitation ratio (SFE:P). They find that the historically snow-dominated
or transitional watersheds in the Bristol Bay region watersheds (grouped together in this study,
includes the Nushagak), shift to transitional or rain-dominant watersheds in the 2050s to 2080s.
The SFE decreases by about 25% for mid-century and about 41% under the higher scenario
(RCP8.5) (their table 5). While overall more precipitation is projected, the SFE:P ratio decreases
to about 45 percent by mid-century and to about 34 percent by the 2080’s (their table 7). By the
late 21st century, only 33-50 percent of the HUC-12 watersheds in the Bristol Bay climate
division that are currently snow dominated will be snow dominated. This will require a different
management of the hydropower facility both for power and for fish habitat.
Recent peer-reviewed studies have described the changes projected by the CMIP5 generation of
IPCC models (few CMIP6-based studies are published yet). Wobus et al (2015) analyzed the
changes by CMIP5 models to assess flow changes in other parts of the Nushagak basin, finding
large changes in monthly temperature and precipitation projected based on five global climate
models (Figure 3).
Leppi et al. (2014) linked climate scenarios from GCMs and habitat models for the Chuitna River
in south central Alaska and used this in a coho salmon population model to assess how projected
climate change could affect survival at each freshwater life stage and, in turn, production of coho
salmon smolts. Relevant for the Nuyakuk basin, this study finds a significant increase in peak
discharge, temperature and other stream variables at several points in the salmon migration and
development period.
These changes seen by Wobus et al (2015) are consistent with those already being seen in the
observed USGS gage record at Tikchik Lake outlet. The trend in flows for May (Figure 4) and
November (Figure 5), two months that are important for potential changes in salmonids, as well as
for hydropower demand. After 2002, average May flows are more likely to be above 10,000 cfs
than below 4,000 cfs - the average those first 30 years. Average May flows have not been below
4,000 cfs in eight years. Higher May flows could provide hydropower in the late spring, when less
water has been available in the historic record. If this upward trend continues, coho runs might start
extending into November and there will be sufficient water for energy production to support the
needs of the six communities while leaving sufficient water in the river for fish.
14
Figure 3. Monthly changes in future temperature
and precipitation projected for five GCMs (Figure
3 in Wobus et al. 2018).
Figure 4: Average daily flow for each May at USGS gage record at Tikchik Lake outlet. The 69 years
exhibit an upward trend due to earlier snowmelt, with current flows almost double those of the early 1950s
(~3,500 vs ~6,500 cfs). Flows were consistently between 2,000 and 6,000 cfs from 1954 to 1975. From
1975 to 1995 average May flows above 6,000 cfs occur in 33 percent of the years. After 2002, average
May flows are more likely to be above 10,000 cfs than below 4,000 cfs - the average those first 30 years.
Average May flows have not been below 4,000 cfs in eight years.
15
Figure 5: Average daily flow for each November at USGS gage record at Tikchik Lake outlet. The
trend over the past 69 years is for about 50% more flow in the present. Note the interannual variability
of the flows (e.g. 2019, 2020, and 2021, or 1979, 1980 and 1981). Note that there are some missing
years of data in the late 1990s.
The Future River Flows and Water Temperatures study request includes employing the data from
an existing peer-reviewed ensemble of downscaled GCMs (Walsh 2018; Wobus 2015) and use a
hydrologic model to project mean monthly (at a minimum) or daily Nuyakuk River discharges
and stream temperature. The Wobus and Walsh climate projections, each based on five state of the
art models developed for the IPCC, provide mean monthly precipitation and air temperatures in
the Nushagak watershed during the license term. They project a range of plausible future
scenarios.
Content of Study Request (18 CFR § 5.9 (b))
1. § 5.9 (b): Goals and Objectives of Request
The goals of this study are to determine mean flows and water temperature during the assumed
50-year term of the license, at least at a monthly time scale, and weekly or daily if feasible.
Details of the recommended study are provided in the § 5.9 (b) Generally Accepted Practices
section below. NOAA Fisheries and its NOAA climate science partners are available and
willing to discuss the details of the climate and flow studies to ensure its value for all parties.
We assume a 50-year license will be issued, and total project development time of eight years,
so we propose projecting the climate from 2030 to 2080. The objectives of this study are:
1. Use existing downscaled climate projections preferably supplied by University of
Alaska, Fairbanks (Walsh et al 2018; Wobus et al 2015) to model and predict
Nuyakuk River flow and temperatures during the license term. These should be done
at least at a monthly time scale and weekly or daily if feasible.
16
2.Use this information to determine the future timing of returning adult salmon and
when water will be needed in the river to support fish passage both up and down the
falls. This information will inform the Nuyakuk Falls Fish Passage (Study 1.2);
Assessment of False Attraction (Study Request 1.4); Chinook and Sockeye Salmon
Life Cycle Modeling (Study 1.5) and the Economic Decision Support Tool.
3.Use this information to project timing of out-migrating smolt. This information
will inform the Ice Process (Study 2.3) and Fish Entrainment and Impingement
(Study 1.3).
4. Use future flow information to inform turbine sizing and winter, spring and fall
energy production.
5.Use future flow information to inform project design and operation including tunnel
design, groin design, and any attempt to mesh winter hydropower with other electric
generation facilities to meet domestic winter power demands of the six communities.
2. § 5.9 (b): Resource Management Goals
The relevant resource management goals are captured in the NOAA Fisheries Alaska
Geographic Strategic Plan for 2020-2023 (NOAA 2020) and the Strategic Conservation
Action Plan for Southwest Alaska (SASHP 2017). Identified in this plan is the long-term
goal of healthy oceans support healthy populations of marine species and sustainable
commercial and recreational fisheries. Our involvement is also supported by mandates under
the Fish and Wildlife Coordination Act and Magnuson-Stevens Fishery Conservation and
Management Act.
3. § 5.9 (b): Relevant Public Interest Considerations
The requestor, the National Marine Fisheries Service, is a federal resource agency with a
mandate to protect and conserve fisheries resources and associated habitat.
4. § 5.9 (b): Existing Information and Need for Additional Information
The USGS Nuyakuk gauge at the Tikchik Lake Outlet has an existing, mostly complete, flow
record spanning 69 years (1953 - 2022). Since it is four miles upriver from the proposed site,
those values can be scaled to the larger watershed and used for the analysis.
Baseline flows in the Nuyakuk River have already changed based on 69 years of USGS gauge
and are likely to continue changing in the coming decades due to the effects of climate change
(Figures 1, 4, 5). The climate-induced changes to existing conditions will interact with the
project operations and the diversion of substantial flow from the river reach where migrating
fish are challenged by a series of cascades. An understanding of how the river flows will
change over time will inform the design, operations, project viability and need for mitigation
measures over the term of the license.
Projected future daily or weekly flow values would better inform the project design and
license review process than only projected future monthly flows. For example, knowing the
projected average March flow in the Nuyakuk will be 3,000 cfs, is less useful than knowing
most days in March the flow will be between 2,200 and 2,600, but a two-day rain on snow
event causing 8,000 cfs will be likely (Figure 2), and in the last week of March flows will
average 3,200 cfs caused by the early onset of spring melt.
17
Bristol Bay Regional Seafood Development Association and Bristol Bay Native Corporation
funded an integrated watershed model in 2021 for the Nushagak Watershed constructed using
the MIKE SHE modeling code developed by the Danish Hydrology Institute. Calibration will
be substantially complete in 2022 using Fish Habitat Partnership money. Once this existing
model is adapted to a more spatially dense grid with a more frequent time step, it will work
well for projecting future flows and temperatures in Nuyakuk River. One piece of this study
request is to retrofit the existing model to the smaller Nuyakuk watershed.
Additional information includes developed projections of air temperature and precipitation for
the upper Nushagak and Kvichak rivers (Figure 2) (Wodbus 2015). This analysis do not
project flows or temperatures in the Nuyakuk River. While the CMIP 6 models outputs might
refine those air temperature and precipitation projections, it is also reasonable to consider the
integrated watershed model (discussed below) using either CMIP 5 data or CMIP 6 data
depending on availability of appropriate downscaled products. Several studies have
documented climate induced changes in flows and stream temperature in other areas of
southcentral and southwest Alaska (Leppi 2014; Winfree 2014; and references within). The
methods from these studies could be replicated. The steps and data available to complete the
analyses are described below at the end of this study request. Walsh (2018), in a project at the
University of Alaska, also recently published downscaled monthly climate data for Western
Alaska that includes this region.
5. 5.9 (b): Nexus Between Project Operations and Effects on the Resource Studied, and
How the Study Results would Inform the Development of License Requirements
There is a direct nexus between the combined impacts of changes in flow and fish habitat
caused by water withdrawals to supply the project turbines and climate change. The
Nushagak Utility proposes to remove different amounts of water from the Nuyakuk River at
different times of the year. The timing and volume of flows are projected to change due to
climate warming. During some time periods this could have a significant effect on salmon
productivity, particularly during smolt outmigration. However, operations could be
designed, and conditioned in the license, to maintain appropriate fish passage protection
measures. This study will help estimate how much water will be available for power
generation in each month during the license term. It will provide the flow analysis to indicate
how salmon migration timing (both upstream and downstream) will change due to water
temperature changes. Finally, it will inform and integrate with the Ice Processes Study,
Sockeye and Chinook Lifecycle Study, Risk Analysis Study, and the Economic Decision
Support Tool. Developing the requested future flow and temperature data at the onset will
also help limit the need for revisiting project design features, including mitigation measures,
as future environmental conditions change.
The project is not causing climate change, however, the project’s operations, long-term
viability, and the fish habitat will be affected by changing climate. The proposed project
operations will compound the effects of climate change by altering the volume of water
flowing through the Nuyakuk cascades. As flow patterns change, changes in project
operations often occur. Likewise, project operations influence the behavior of migrating fish
within the project area. The information collected by this study would support the analysis of
direct and cumulative effects of the proposed project on migratory fish and aid in the
18
development of any necessary license articles regarding measures to achieve fish passage.
Projections of a range of flow volumes at different times of the year will inform the quantity
of water necessary to ensure economical project operations and suitable habitat function
during the salmon migration periods.
6. § 5.9 (b): Consistency with Generally Accepted Practice
It has become generally accepted practice to consider climate change in hydropower design
among planners and designers of hydropower and water supply facilities. The best available
science now includes the presently observed and projected future impacts of climate change on
water resources, as demonstrated by Congress directing the Secretary of Interior, via the
Secure Water Act, to coordinate with NOAA and its programs to ensure access to the best
available information on climate change [Secure Water Act (§) 9503 (c)]. The following are
examples - dating back more than fifteen years - from water projects such as Nuyakuk and
others permitted by FERC - in which managers and planners incorporate the risks of climate
change in their project design of projects, as well as in long-range operations planning:
● The U.S. Bureau of Reclamation (BOR) and Army Corps of Engineers (ACOE) both use
climate projections in their long range operations planning and design, including
hydropower generation, flood control, and water supply. These agencies jointly
commissioned and released a report that identifies the needs of local, state, and federal
water management agencies for climate change information and tools to support long-
term planning (Brekke 2009). Beginning more than a decade ago, ACOE and BOR and a
consortium of agencies funded downscaled hydrologic projections for use in planning for
reservoirs and hydropower operations (Bureau of Reclamation 2009, Dalton et al 2010).
The BOR-funded project was then subsequently updated for the next generation of IPCC
global climate models (CMIP5, Brekke 2013, Pierce et al. 2015). These flow projections
are currently being updated using the CMIP6 GCMs.
● The River Management Joint Operating Committee for Bonneville Power Administration,
ACOE, and BOR commissioned climate scenarios for use (River Management Joint
Operating Committee, 2010, a-c). The plans for this were published as a peer-reviewed
article (Hamlet, et al 2013).
● Non-Federal facilities are also being designed and managed with consideration of climate
risks. The Water Utility Climate Alliance (WUCA) includes twelve of the Nation's largest
water providers, many of which manage hydropower facilities. It was formed to provide
leadership and collaboration on climate change issues affecting the country's water
agencies. Among WUCA’s key messages is, “Warming is here and now. Climate
adaptation planning is not just about the future. Water utilities are experiencing the
effects of a changing climate on their water resources today.”3 WUCA and its member
cities advocate the use of climate projections and planning for a range of futures (Stratus
Consulting and Denver Water 2015, Vogel et al. 2015).
● The American Society of Civil Engineers (ASCE) recommended the use of climate
change in design criteria. In a policy statement originally approved in 1990, (PS360)4,
3 https://www.wucaonline.org/
4 https://www.asce.org/advocacy/policy-statements/ps360---climate-change
19
ASCE highlighted the importance of climate change on the built environment. This
policy has been revised and adopted several times since then. In 2018 it indicated a
growing need for engineers to incorporate future climate change into project design
criteria, and in 2021, support for “Revisions to engineering design standards, codes,
regulations and associated laws that strengthen the sustainability and resiliency of
infrastructure at high risk of being affected by climate change.”5
A growing body of U.S. policy requires and provides guidance on consideration of climate
risks, and use of climate information by federal agencies. In addition to the Secure Water Act,
this includes Executive Orders dating back to 2009 have directed federal water and hydropower
agencies such as the BOR, ACOE and Department of Energy to consider climate change in
their projects (Executive Order (EO) 13514, replaced by EO 13693, titled Planning for Federal
Sustainability in the Next Decade, March 19, 2015). On Dec 8, 2021, President Biden signed
EO 14057 6, which orders agencies to integrate climate-readiness across missions and programs
and bolster resilience of Federal assets, including hydropower facilities 7. Federal agencies have
increasingly considered the risks of climate change (e.g. NMFS 2016 and Udall 2013).
The downscaled climate projections we recommend follow in this tradition, based on the same
IPCC global climate models. In particular, the University of Alaska Fairbanks’ Alaska Climate
Research Center (http://akclimate.org/) has produced the Scenarios Network for Alaska and
Arctic Planning (SNAP, https://www.snap.uaf.edu).
In FERC’s Order rejecting the request for rehearing by National Marine Fisheries Service and
the Center for Water Advocacy of the formal study dispute determination regarding Susitna
(July 18, 2014), FERC stated, “as climate change modeling continues to advance, it may
eventually yield data and knowledge that can and should be used to formulate license
requirements that respond to environmental effects caused by climate change.” That time has
come. Another generation of IPCC models (IPCC 2021) has consistent findings - albeit further
refined - with previous IPCC (IPCC 2013 and IPCC 2007) and U.S. National Climate
Assessment analysis, while also providing more detailed and relevant information for natural
resource planners. Climate modeling and especially downscaling methodology has improved
significantly in the last decade. Furthermore, in the last five years climate change effects have
been acknowledged across all departments of the State of Alaska Government. Downscaled
climate projections datasets developed for Alaska (Walsh 2018) and elsewhere are being used
as generally accepted practice in the design and operational planning for hydropower. We
encourage FERC to evaluate this study request in light of the advances in science, the generally
accepted practice, and in a context of understanding both the risks of climate change and the
potential opportunities of the projected increases in temperature and precipitation and the
effects on managing flows both for hydropower and fish habitat.
We request a study similar to the future flow and temperature analyses in Wobus et al (2015),
5 Ibid.
6 https://www.whitehouse.gov/briefing-room/statements-releases/2021/12/08/fact-sheet-president-biden-signs-
executive-order-catalyzing-americas-clean-energy-economy-through-federal-
sustainability/#:~:text=The%20executive%20order%20will%20reduce,%2C%20healthy%2C%20and%20resilient%2
0communities
7 https://www.whitehouse.gov/briefing-room/statements-releases/2021/10/07/fact-sheet-biden-administration-releases-
agency-climate-adaptation-and-resilience-plans-from-across-federal-government/
20
Leppi et al (2014), and Mauger et al. (2016). The steps and data available to do these analyses
are described below. New climate modeling is not needed. Rather, we request analyses of
existing, publicly available and peer-reviewed datasets based on existing CMIP dataset, using
peer-reviewed and generally accepted practices, as described in those articles and cites therein.
The basic analysis that is needed is to move from downscaled GCM projections of
temperature and precipitation to projected flows and water temperatures from a integrated
hydrologic model for the Nuyakuk River specifically. The hydrologic modeling should then
be analyzed and presented in a technical report of the future flows available, and thus the
hydropower and fish habitat needs. Additionally, this report will include an analysis of the
impacts of projections on the project nexus, and hydropower facilities. The three major steps
are:
a.Downscaled GCM Outputs. We recommend use of the dataset described by Walsh et
al (2018), an existing, peer-reviewed and publicly available monthly downscaled
climate projection dataset, and related data. Scenarios Network for Alaska and Arctic
Planning (SNAP), along with related data is available for download at:
https://www.snap.uaf.edu. This dataset is based on the 5th IPCC generation of global
climate models (CMIP5). Walsh et al (2018) analyzed the over 35 GCMs to assess
which five best represent climates in Alaska as a whole. See (Lader 2017) or (Bieniek
et al. 2015) for a more detailed description of the downscaling model procedure and an
evaluation against historical temperature and precipitation data. Their product provides
monthly values of projected future air temperature and precipitation. Monthly values
are the minimum needed for analyses of future flows, but may average out changes.
Wobus et al (2015) generated daily values, and thus were able to discern shorter time
scale features in river flows. If technically feasible and available for the Nuyakuk
River, this daily scale is preferable because of the finer time scale changes that daily
analyses would detect.
Because 30 months have passed since this study was originally proposed (2/4/2020),
new downscaling efforts are underway and downscaled CMIP 6 climate products may
become available before this study is started. Furthermore, a dynamically downscaled
product for all of Alaska may be available soon. If by the time this study is executed, a
sub-monthly or daily downscaled product is available, that would be preferable. If a
CMIP6-based appropriate downscaled product becomes available, that product may be
used instead of the Walsh et al 2018 dataset. However, it is not necessary to wait for
CMIP6.
Predicted temperatures and precipitation should be analyzed for at least three periods
of the license, for example, early, the first third (e.g. 2030 – 2047); the middle third,
(e.g. 2047-2064); and the late or final third (e.g. 2064 to 2080) for the Nuyakuk
watershed. This will allow consideration of flow trends that may evolve over the
period, and potentially different operations as projected conditions change.
b.Hydrologic Modeling. A published, vetted hydrologic model should be used to
translate these downscaled climate outputs (precipitation and temperature) into other
hydroclimate variables (evaporation, soil percolation, surface runoff) and ultimately
the timing and volume of runoff into the Nuyakuk River, and stream temperatures.
Several watershed models that integrate atmospheric conditions with surface water
21
and groundwater could be applied to the Nuyakuk watershed; however, they would
require extensive development.
We recommend the MIKE SHE system (Graham and Butts 2005), a fully distributed,
parameter integrated, hydrologic code that simulates the flow of water within and
among surface water, groundwater, and the unsaturated zone. Atmospheric
conditions, including precipitation, air temperature, and evapotranspiration drive
continuous flows within the hydrologic system. A modified degree-day snowmelt
method, the code simulates snow accumulation if air temperatures fall below a
freezing threshold, and it also simulates snowmelt processes including evaporation
(sublimation and wet- snow evaporation), rain-on-snow, changes in wet and dry
snow storage, and refreezing of wet snow. The Wobus et al (2014) effort, also
implemented a heat balance algorithm to simulate stream temperatures (Loinaz et al.
2013). The hydrologic models then projects monthly (or daily) water temperatures
based on predicted air temperature and the relative river contributions from surface
water versus groundwater sources versus snowfields sources.
Furthermore, the MIKE/SHE system is recommended because Bristol Bay
Regional Seafood Development Association and Bristol Bay Native Corporation
already funded the development of an integrated watershed model for the Nushagak
watershed using MIKE/SHE MIKE 11 code developed by the Danish Hydrologic
Institute (DHI). MIKE SHE has been used and verified extensively worldwide and
in the U.S. since the mid-1970s, by multiple federal agencies including USACE,
FEMA, USDOE, USDA, academic researchers and others to support evaluation of
complex networks of hydraulic structures and operations, nature and extent of
impacts on hydrologic/ecologic systems, and optimization of mitigations. As a cost
saving measure, we recommend adapting the existing larger Nushagak model to the
Nuyakuk watershed.
c. Technical Report. The potential climate change effects should be summarized in a
Technical Report. This technical report should include a description of the
assumptions made, models used, and other background information. The report will
provide interpretation and guidance on the science knowledge developed, in order to
translate them into useable knowledge, through syntheses and translational products
developed to address the hydropower, water, and fisher habitat needs. Additionally,
this report will include an analysis of the impacts of projections on the project nexus,
and hydropower facilities. The report will include an electronic supplement that makes
the data used in this study available for the use of other studies.
7. § 5.9 (b): Considerations of Level of Effort and Cost
This study can be completed in six months because climate projections for the region
already exist. It will be ready as input to other studies. The cost ($50,000-75,000) is
reasonable considering the PAD estimated that $1,000,000 annually in diesel cost could be
avoided once this project comes online. Correctly sizing turbine and designing them for
maximum efficiency at the flows expected during the license term could change the unit
efficiency by ten percent. Producing daily projected flows and temperatures, compared to
monthly, will increase the cost and time required slightly, but not significantly.
22
Citations
Bieniek, P.A., Bhatt, U.S., Walsh, J.E., Rupp, T.S., Zhang, J., Krieger, J.R., and Lader, R. 2015.
Dynamical Downscaling of ERA-Interim Temperature and Precipitation for Alaska. Journal of
Applied Meteorology and Climatology 55(3): 635-654. doi:10.1175/JAMC-D-15-0153.1.
Brekke, Levi, B.L. Thrasher, E.P. Maurer, T. Pruitt. 2013. Downscaled CMIP3 and CMIP5
Climate Projections: Release of Downscaled CMIP5 Climate Projections, Comparison with
Preceding Information and Summary of User Needs. U.S. Department of Interior, Bureau of
Reclamation, Tech. Rep. (2013) 116 pp.
Brekke, L. et al 2011. Addressing Climate Change in Long-Term Water Resources Planning and
Management User Needs for Improving Tools and Information. U.S. Army Corps of
Engineers Civil Works Technical Series CWTS-
Brekke, L. D., Maurer, E. P., Anderson, J. D., Dettinger, M. D., Townsley, E. S., Harrison, A., &
Pruitt, T. (2009). Assessing reservoir operations risk under climate change. Water Resources
Research, 45. doi:Artn W0441110.1029/2008wr006941
Brown, C.M., Lund, J.R., Cai, X., Reed, P.M., Zagona, E.A., Ostfeld, A., Hall, J., Characklis,
G.W., Yu, W., and Brekke, L. 2015. The future of water resources systems analysis: Toward a
scientific framework for sustainable water management. Water Resources Research 51(8):
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guidebook.pdf
INTERIOR REGION 11 • Alaska
Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Subject: Nuyakuk River Hydroelectric Project (P-14873) Proposed Study Plan
Dear Ms. Bose:
Thank you for the opportunity to provide input on the updated Proposed Study Plan (PSP) for the
Nuyakuk River Hydroelectric Project (P-14873), as filed by Nushagak Cooperative, Inc. with the
Federal Energy Regulatory Commission (FERC), March 2, 2022. The U.S. Fish and Wildlife
Service (Service) has reviewed the updated PSP and is submitting the enclosed comments in
accordance with the Fish and Wildlife Coordination Act (16 U.S.C. 661-667e) and Alaska National
Interest Lands Conservation Act (16 USC 410hh-3233, 43 USC 1602-1784).
We look forward to working with FERC and other stakeholders on this project. For more
information or if you have any questions, please contact Ms. Carol Mahara (carol_mahara@fws.gov,
907-280-9751) or Ms. Libby Benolkin (Elizabeth_Benolkin@fws.gov) at the Anchorage Fish and
Wildlife Conservation Office.
Sincerely,
Acting for
Douglass M. Cooper
Branch Chief, Ecological Services
Enclosure
cc: Ingrid Brofman, FERC
Will Chaney, Nushagak Cooperative
Laura Johnson, McMillen Jacobs Associates
Cory Warnock, McMillen Jacobs Associates
Sean Eagan, National Marine Fisheries Service
Kevin Keith, Alaska Department of Fish and Game
United States Department of the Interior
U.S. FISH AND WILDLIFE SERVICE
Southern Alaska Fish and Wildlife Field Office
Anchorage Fish and Wildlife Conservation Office
4700 BLM Road
Anchorage, Alaska 99507
In Reply Refer to:
FWS/IR11/SAFWFO, AFWFO
1
U.S. Fish and Wildlife Service Comments on the
Proposed Study Plan for Nuyakuk River Hydroelectric Project
June 29, 2022
Characterization of the Fish Community and Behavior Near the Project Area
4.1.1.5 Existing Information and Need for Additional Information (p. 36 & pp. 44-46)
This study proposes to identify fish species distribution and abundance near the project site,
specifically it proposes to identify the relative abundance of fishes in the Project Area seasonally,
the baseline migratory patterns and behaviors for Sockeye Salmon and Chinook Salmon, and the
proportion of adults that successfully pass through the Falls Reach. It seems the methods used
for Adult Salmon Migratory Behavior Observation are to inform the species/life stage periodicity
chart and adult migratory behavior through the three project Zones. Please specify if this
information will also be used to estimate run sizes. We realize there are many factors that can
impact escapement such as ocean conditions, fishing, and climate, but we recommend discussing
pre-project escapement trends (including the 1950-2006 Sockeye Salmon escapement data
mentioned on page 36) as this may be informative for monitoring and adaptive management
strategies once the project is in place.
4.1.1.7 Methodology (pp. 40-46)
We request additional information be depicted in figures to help visualize where proposed
sampling activities would occur. Currently Figure 4-3 (p. 42) shows the five transect lines to be
established at 200-meter intervals in Zones 1 and 3 as discussed on page 40, as well as the
primary location for a downstream migrant trap discussed on page 46. We recommend the
following information as stated in the Methodology section also be depicted in Figure 4-3 or in
an additional figure if necessary:
• “Fish collection surveys will occur over a 50-m-long reach located on both stream banks
beginning at the downstream end of each transect…Given the methods to deploy, it is
anticipated that each sampling event will last 10 days to cover the 10, 50m transects” (p.
40). It is not clear how these 50-meter -long survey reaches are related to the 10 transect
lines depicted in Figure 4-3. Do the lines represent the downstream end of each 50-meter
survey reach? Clarification in the narrative, and modification of Figure 4-3 will improve
the understanding of sampling areas.
• “[F]ish sampling in Zone 2 will occur on an opportunistic basis at locations that are
determined safe to sample based on depth and velocity (Figure 4-3)” (p. 40). Figure 4-3
is mentioned for Zone 2, but there doesn’t appear to be anything depicted in that figure
for Zone 2. Are there specific instream margin areas in Zone 2 that are the most likely
locations for safe sampling? If so, please depict those locations in a figure.
• “Downstream migrant trapping may occur at several locations in the Project area to
account for spatial variability; however, survey efforts will be focused in Zone 1 near the
2
proposed Project intake (Figure 4-3)” (p. 46). Have other potential trapping locations
been identified? If so, please depict them in a figure.
Nuyakuk Falls Fish Passage Study
4.1.2.7 Methodology, Table 4-2 (p. 57)
Since the leaping and jumping capabilities in this study are based on body size for each species,
please consider modifying Table 4-2 to indicate body dimensions at the top of the table, perhaps
listing size in the heading with the species name.
In addition, it is unclear how the average size of fish in Nuyakuk compare to sizes used in the
table. Please consider using Age Sex Length data for Nuyakuk fish to identify how body sizes
may be different, and then inform how leaping and jumping capabilities may need to be adjusted.
4.1.2.7 Methodology, LiDAR (p. 61)
The study indicates LiDAR acquisition occurred in May 2020, but the highly turbulent water
made mapping problematic in some areas. We recommend acquiring LiDAR when flows are
less than 3,000 cubic feet per second or in March when flows are the lowest.
Chinook and Sockeye Salmon Life Cycle Modeling (pp. 85-95)
Please explain why other anadromous and resident species are omitted from the Life Cycle
Modeling studies. What is the rationale for selecting Sockeye Salmon and Chinook Salmon, and
what kind of information for other species will be inferred from studying these two species?
Please consider including resident species for Life Cycle Modeling.
Future Flows and Water Resources Studies (pp. 106-114)
We appreciate that the Nushagak Cooperative is proposing the Future Flows, Water Quality
Assessment, and Ice Processes Assessment studies. We agree considering climate model
predictions and the subsequent impacts on future discharge and water temperature will be key to
maximizing effectiveness of project design and proposed protection, mitigation, and
enhancement (PME) measures, especially if a daily downscaled product is available that can
provide localized projections for Nuyakuk. Similarly, we agree considering ice processes will
help inform project designs that can address risk from these processes. Finally, we agree
gathering dissolved oxygen and temperature data from above and below the falls is important for
providing a baseline for natural conditions, and it will help inform adaptive management
considerations should changes to baseline conditions occur during project operations.
Subsistence Study (pp. 122-124)
There appear to be related impacts on subsistence that are not analyzed. The proposed
Subsistence Study plan states that “analysis will assess the timing and location of subsistence use
and would be necessary to develop PME measures with regard to the timing of activities,
3
particularly during project construction” (p. 123). In addition, information gained in the
Aquatics/Fisheries Resources, Caribou Population Evaluation, and Subsistence studies will help
identify PME measures to minimize impacts to subsistence resource abundance, and to the
subsistence users themselves. However, the Project Facilities section (p.16) mentions the
construction of a localized access road and new transmission lines which would require
construction and maintenance of right-of-ways. Please provide analysis on how these and other
project related actions may impact competition for or access to subsistence resources.
Page 1 of 6
June 30, 2022
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
RE: Comments on the Proposed Study Plan for the Nuyakuk River
Hydroelectric Project (Docket P-14873-001)
Dear Secretary Bose:
The United Tribes of Bristol Bay (UTBB) provides the following comments on
the Nushagak Electric & Telephone Cooperative’s (Cooperative) updated
Proposed Study Plan (PSP) for the Nuyakuk River Hydroelectric Project.
UTBB is a Tribal consortium working to protect the traditional Yup’ik,
Dena’ina, and Alutiiq ways of life in Southwest Alaska that depend on the
pristine Bristol Bay Watershed and all it sustains, most notably Bristol Bay’s
wild salmon. UTBB represents 15 federally recognized Tribes in Bristol Bay
which constitutes over 80 percent of the region’s population.
At the outset, we want to reiterate the importance of meaningful Tribal and
public engagement throughout the licensing process and the significant barriers
to participation in the process so far. The Nuyakuk River is a crucial river in the
Bristol Bay Watershed, significantly contributing to the region’s salmon runs
and sustaining many of our Tribal members’ subsistence way of life. Thus, it is
critical that Bristol Bay Tribes and community members have a voice in this
process. To date, opportunities to engage in the process have been severely
limited. For example, the Federal Energy Regulatory Commission (FERC)
decided to not require additional study plan meetings, restricting opportunities
for engagement on the updated PSP. The previous virtual study plan meetings
held in April 2020, at the outset of the COVID-19 pandemic, are not an
adequate substitute for public engagement on the updated PSP, particularly
given the long period of time that has passed and the changes to the proposed
studies.
Accessible and understandable information is fundamental to providing
opportunities for engagement. As a first step to making the PSP more
accessible, the document should include an executive summary and an appendix
that defines the many technical terms and acronyms used in the document.
UTBB Headquarters:
P.O. Box 1252
Dillingham, AK 99576
Phone: 907-842-1687
Fax: 907-842-1853
UTBB Member Tribes:
Nondalton Tribal Council
P.O. Box 49
Nondalton, AK 99640
New Stuyahok Traditional
Council
P.O. Box 49
New Stuyahok, AK 99636
Levelock Village Council
P.O. Box 70
Levelock, Alaska 99625
Curyung Tribal Council
P.O. Box 216
Dillingham, Alaska 99576
Ekuk Village Council
P.O. Box 530
Dillingham, Alaska 99576
Manokotak Village Council
P.O. Box 169
Manokotak, Alaska 99628
New Koliganek Village Council
P.O. Box 5057
Koliganek, Alaska 99576
Traditional Council of Togiak
P.O. Box 310
Togiak, Alaska 99678
Clarks Point Village Council
P.O. Box 90
Clark’s Point, Alaska 99569
Twin Hills Village Council
P.O. Box TW
Twin Hills, Alaska 99576
Aleknagik Traditional Council
P.O. Box 115
Aleknagik, AK 99555
Portage Creek Village Council
1327 E. 72nd Unit B
Anchorage, AK 99518
Chignik Lake Traditional Council
P.O. Box 33
Chignik Lake, AK 99548
Pilot Point Tribal Council
PO Box 449
Pilot Point, AK 99649
Pedro Bay Village Council
PO Box 47020
Pedro Bay, AK 99647
Page 2 of 6
Additionally, FERC and the Cooperative should provide regular updates to keep Tribes and
community members informed at each step of the licensing process and foster meaningful
engagement. Any updates should be communicated in a manner and method that is accessible to
Tribes and community members in the region. Because of internet access inequities in rural
Alaska, FERC’s website is not be accessible to all, and the agency should reach out to Tribes
regarding their preferred method of communication. Limiting in-person meetings to Dillingham
is not accessible for all Tribes and community members, including the communities closest to
the proposed Project area.
Aquatic/Fisheries Resources
The Nushagak District of Bristol Bay has been the most productive river system in Bristol Bay in
recent years. According to the Bristol Bay Regional Seafood Development Association
(BBRSDA), harvests of sockeye salmon in the Nushagak District averaged 15.5 million fish per
year over the past 5 years. In the last 20 years, the Nuyakuk River has accounted for up to 24
percent of the Nushagak River’s sockeye salmon run according to Bristol Bay Science and
Research Institute (BBSRI). Therefore, it is imperative that critical anadromous and resident fish
habitat at the proposed Project site have more than a two-year study program to adequately
characterize the aquatic resources that will be impacted by decreasing the flow through the
Nuyakuk cascades due to the proposed Project. It is important that the project determine the
optimal instream flow requirements for fish passage, rearing, and overwintering during all four
seasons of the year in the Revised Study Plan (RSP).
River flow conditions are critical to supporting fish migration and other ecological functions.
Pacific salmon and other fish species migrate up the Nuyakuk cascades during flow conditions
ranging from 4,000 to 15,000 cfs between July and October. The Cooperative proposes leaving a
minimum of 1,000 cfs in the river reach between the project intake and tailrace. This represents a
direct Project-related impact to the culturally and commercially important fishery. No data exists
to indicate the proposed bypass base flow will provide safe, timely, and effective passage for
returning adult salmon. Therefore, characterizing the relationship between flow and passage
suitability in the bypassed reach is needed to establish baseline conditions, determine which
species can pass up the cascade at which flows, and evaluate potential effects (e.g., delay,
stranding) of project operations on the migration of adult and juvenile salmon in the proposed
bypass reach. Baseline conditions need to include year-round studies to evaluate winter and
spring foraging, juvenile rearing, and spawning habitat. Climate change has impacted Bristol
Bay by increasing air temperature by 3.7o F and an increase of 13 percent in annual precipitation
from 1969 to 2010.1 Therefore, it is important that this project evaluates future flows because
temperature, precipitation, and stream flows will increase in Bristol Bay due to climate change.
According to the National Oceanic and Atmospheric Administration’s National Marine Fisheries
Service, the Nuyakuk River has an average return of 370,000 sockeye salmon in addition to four
other returning salmon species. The Nuyakuk River counting tower data on sockeye salmon from
1 Thoman, R., J.E. Walsh. 2019. Alaska’s changing environment: documenting Alaska’s physical
and biological changes through observations. 16.
Page 3 of 6
1959-1999 varied from 20,250 in 1967 to over 3 million sockeye salmon in 1980.2 In 2006, the
Alaska Department of Fish and Game (ADF&G) reported a cumulative sockeye salmon count of
170,760.3 Therefore, the proposed two-year field program is inadequate given the large annual
variability related to sockeye salmon escapement numbers in the Nuyakuk River.
The proposed economic decision support tool and integrated risk assessment need to include a
comprehensive analysis of the potential costs and risks. The cost-benefit analysis should include
an analysis of not only hydropower but wind and solar power as potential alternatives to replace
the diesel-generated power in Bristol Bay.
The amount of water that will be diverted by the project and the potential impacts of change in
the flow over the cascades on salmon outmigration and in-migration and resident fish habitat are
critical concerns that must be comprehensively addressed in the proposed studies. Under Alaska
law, the development and operation of a hydroelectric site at the Nuyakuk River Falls is only
permissible if the operation and development “maintains at least 70 percent of the daily upstream
water flow of an affected river along the natural course of the river.”4 A critical question is if the
project changes the flow by 30 percent what will the impacts be? Will this change in flow impact
outmigration and increase potential entrainment of the juvenile salmon and impact the ability of
the adult salmon making it up the cascades to reach their spawning grounds? The proposed
studies need to determine how the intake, groin, and tailrace structures will alter fish habitat
characteristics and change the water depth, velocity, and habitat composition.
Concerns about the proposed project infrastructure include how the groin and intake structures
and Kaplan turbines will impact the smolt outmigration on the Nuyakuk River. Smolt migrate
through the cascades not only in springtime but throughout the summer months. Therefore, smolt
migration studies need to be conducted not just once a year but from May through July. These
studies need to determine the smolt distribution in the horizontal and vertical water column to
better design the intake and groin structures and reduce the entrainment and impingement
impacts to smolt. More information is needed about ice buildup on the concrete groin and intake
structures, and whether a concrete groin structure is appropriate in a river where water will
overtop the groin during high flow conditions.
Subsistence Study
The PSP provides limited information about the proposed subsistence study, hindering
meaningful comment. The limited amount of information provided is especially concerning
given the critical importance of the Nuyakuk River to many of our Tribal members’ subsistence
way of life.
2 ADF&G Regional Information Report No. 2A00-08. Counting tower projects in Bristol Bay Area, 1955-
1999 by Cindy J. Anderson. September 2000.
3 ADF&G Fish Count Data Search for the Nuyakuk River, 2003-2006,
https://adfg.alaska.gov/sf/FishCounts/index.cfm?ADFG=main.home.
4 Alaska Stat. Ann. § 41.21.167(e).
Page 4 of 6
The limited information available regarding the geographic scope of the study suggests that the
scope is too narrow to adequately analyze potential impacts to subsistence uses and resources.
The anticipated scope will focus on subsistence use in the proposed Project area. This approach
emphasizes the place where subsistence occurs instead of the fish and wildlife that communities
harvest. This approach may be appropriate where communities’ use areas overlap with the
project area or for non-migratory species. However, it is not a suitable approach for communities
whose use areas do not overlap with the project area and rely on migratory species, like salmon.
Though communities throughout Bristol Bay harvest salmon that migrate through the proposed
Project area, only some of those communities engage in subsistence activities within the Project
area. Thus, any adverse impacts to salmon and other migratory species will result in adverse
impacts to subsistence far beyond what the current scope would encompass. The proposed
subsistence study must be expanded beyond the current place-based approach to include analysis
of migratory species that migrate through the proposed Project area but are harvested outside the
Project area. Unless the scope is expanded, the study will significantly underestimate potential
impacts to subsistence.
Furthermore, the Cooperative’s proposal to rely exclusively on the ADF&G’s community
subsistence surveys will not provide the information need to adequately analyze potential
impacts to subsistence uses. Harvest surveys are unable to account for the inherent variability in
subsistence systems and many rural residents do not participate in ADF&G surveys, so the data
collected may not accurately reflect actual harvests. The subsistence study should include
additional methods beyond household harvest surveys to accurately reflect subsistence uses.
Tribes must be involved in developing and conducting these subsistence studies. The proposed
subsistence study should also be broadened to include cultural values, spirituality, and social
sharing networks. The household surveys proposed in the subsistence study are designed to
gather information on the amount of resources harvested and are not suited to provide
information regarding the full range of potential impacts on subsistence.
Section 106 Evaluation
The stated goal of the proposed study is to comply with the National Historic Preservation Act
(NHPA) Section 106 process. To satisfy this goal, the proposed study must be revised to clarify
the respective roles of FERC and the Cooperative, address the archaeological bias in the
proposed study, and expand the study’s scope beyond discrete historic sites to include broader
intangible cultural resources, such as Traditional Cultural Properties and cultural landscapes.
The proposed Section 106 evaluation should be revised to clearly define FERC’s roles and
obligations under the NHPA. In carrying out its responsibilities under Section 106, FERC must
“consult with any Indian tribe or Native Hawaiian organization that attaches religious and
cultural significance” to historic properties that may be affected by the Project.5 The Advisory
Council on Historic Preservation’s regulations implementing the Section 106 process also
provide that consultation “should be conducted in a sensitive manner respectful of tribal
sovereignty” and must “recognize the government-to-government relationship between the
Federal Government and Indian tribes.”6 Though FERC may authorize the Cooperative to
5 54 U.S.C. § 302706(b).
6 36 C.F.R. § 800.2(c)(2)(ii)(B)–(C).
Page 5 of 6
initiate Section 106 consultation, FERC remains legally responsible for all required findings and
determinations and “for [its] government-to-government relationships with Indian tribes.”7
Under the proposed study methodology, the Cooperative’s subcontractor is responsible for
“consulting with Tribal groups.”8 The proposed methodology must be revised to make clear that
FERC remains responsible for its government-to-government relationship with Tribal
governments and the Cooperative’s subcontractor cannot assume consultation responsibilities
without a Tribal government’s consent. Additionally, the methodology of the proposed study
reflects an applicant-driven process. Though it is appropriate for the Cooperative and its
subcontractor to assist in information gathering and analysis, the proposed study should be
revised to make clear that the ultimate responsibility for making findings and determinations
remains with FERC and FERC is responsible for ensuring any information and analysis prepared
by the Cooperative and its subcontractor meet applicable standards and guidelines.
The proposed Section 106 evaluation demonstrates a clear archaeological bias that must be
remedied to ensure the proposed study includes the full scope of historic properties under the
NHPA. The NHPA defines “historic property” as “any prehistoric or historic district, site,
building, structure, or object included on, or eligible for inclusion on, the National Register”9 and
includes, “[p]roperty of traditional religious and cultural importance to an Indian tribe or Native
Hawaiian organization.”10 As proposed, the Section 106 Evaluation relies on archaeological field
surveys and existing information from the Alaska Historic Resources Survey (AHRS). The
proposed surveys are designed to gather information about discrete archaeological sites and do
not provide the information needed to adequately identify and evaluate impacts to historic
properties of traditional religious and cultural importance to Tribes. The proposed study must be
revised to include other methodologies, including ethnographic studies.
Cultural monitors approved by the respective Tribal government should also be a part of any
surveys to minimize effects to cultural resources. Cultural monitors will be able to assist work
crews in identifying inadvertent discoveries of cultural resources and reducing impacts to other
traditional resources (e.g., water, fish, caribou, moose, berries) and customary practices (e.g.,
fishing, hunting, berry picking, sharing knowledge on the land).
The Section 106 evaluation’s reliance on existing information from the AHRS raises significant
concerns given the shortcomings of this data. The AHRS substantially underreports the number
of cultural resources within the area surrounding the proposed Project and demonstrates a
significant bias in favor of archeological resources. There are also cultural resources Tribes do
not want disclosed in the AHRS for confidentiality reasons. Thus, the proposed study’s reliance
on the AHRS would substantially underestimate intangible cultural resources, like Traditional
Cultural Properties and cultural landscapes. The proposed study should be revised to expand the
scope of existing information and where additional information is needed, must include
ethnographic studies along with the proposed archaeological surveys.
7 36 C.F.R. § 800.2(c)(4).
8 Proposed Study Plan at 126.
9 54 U.S.C. § 300308.
10 54 U.S.C. § 302706(a); 36 C.F.R. § 800.16(l)(1).
Page 6 of 6
UTBB looks forward to working collaboratively with FERC and the Cooperative throughout the
licensing process. If you have any questions, please contact Alannah Hurley, UTBB Executive
Director, at: ahurley@utbb.org, or Delores Larson, UTBB Deputy Director, at:
dlarson@utbb.org.
Sincerely,
Alannah Hurley
Executive Director
United Tribes of Bristol Bay
1
To: Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
From: Molly Welker
Date: June 30, 2022
Subject: Nuyakuk River Hydroelectric Project (FERC No. 14873) Comments on Proposed Study
Plan
Dear Secretary Bose:
On March 2, 2022, Nushagak Electric & Telephone Cooperative (licensee) filed a request with
the Federal Energy Regulatory Commission to re-initiate the Integrated Licensing Process for the
Nuyakuk River Hydroelectric Project (FERC No. 14873). At the same time, the Cooperative
filed a revised Proposed Study Plan for the project. On March 10, 2022, FERC approved the
Cooperative’s process plan and schedule, which included a deadline of June 30, 2022, for
comments on the Proposed Study Plan (PSP). I live in Anchorage, AK and have represented the
United Tribes of Bristol Bay at the Aquatic Resources Working Group meetings over the last
year that discussed and revised the PSP. I have reviewed the March 2022 PSP and offer the
following comments.
The Nushagak District of Bristol Bay has been the most productive river in Bristol Bay in recent
years. According to the Bristol Bay Regional Seafood Development Association (BBRSDA),
harvests of sockeye salmon in the Nushagak District averaged 15.5 million fish per year over the
past 5 years. In the last 20 years, the Nuyakuk River has accounted for up to 24% of the
Nushagak River’s sockeye salmon run according to Bristol Bay Science and Research Institute
(BBSRI). Therefore, it is imperative that critical anadromous and resident fish habitat at the
project site have more than a 2-year field program to adequately characterize the aquatic
resources that will be impacted by decreasing the flow through the Nuyakuk cascades due to the
Nuyakuk River Hydroelectric Project. It is important that the project determine the optimal
instream flow requirements for fish passage, rearing, and overwintering during all four seasons
of the year in the Revised Study Plan (RSP).
River flow conditions are critical to supporting fish migration and other ecological functions.
Pacific salmon and other fish species migrate up the Nuyakuk cascades during flow conditions
ranging from 4,000 to over 15,000 cfs between July and October. The Cooperative proposes
leaving a minimum of 1,000 cfs in the river reach between the project intake and tailrace. This
represents a direct project related impact to the culturally and commercially important fishery.
No data exists to indicate the proposed bypass base flow will provide safe, timely, and effective
passage for returning adult salmon. Therefore, characterizing the relationship between flow and
passage suitability in the bypassed reach is needed to establish baseline conditions, determine
which species can pass up the cascade at which flows , and evaluate potential effects (e.g., delay,
stranding) of project operations on the migration of adult and juvenile salmon in the proposed
bypass reach. Baseline conditions need to include year-round studies to evaluate winter and
spring foraging, juvenile rearing, and spawning habitat. According to Thoman (2019) climate
2
change has impacted Bristol Bay by increasing air temperature by 3.7 oF and an increase of 13%
in annual precipitation from 1969 to 2010. Therefore, it is important that this project evaluat es
future flows because temperature, precipitation, and stream flows will increase in Bristol Bay
due to climate change.
According to NOAA’s National Marine Fisheries Service the Nuyakuk River has an average
return of 370,000 sockeye salmon in addition to four other returning salmon species. The
Nuyakuk River counting tower data on sockeye salmon from 1959-1999 varied from 20,250 in
1967 to over 3 million sockeye salmon in 1980 (ADF&G Regional Information Report
No.2A00-08). In 2006, ADF&G reported a cumulative sockeye salmon count of 170,760
(ADF&G 2022). Therefore, the proposed two-year field program is inadequate given the large
annual variability related to sockeye salmon escapement numbers in the Nuyakuk River.
We understand the importance of the Cooperative trying to reduce the high cost of power
generation in the Bristol Bay region. Therefore, the proposed economic decision support tool and
integrated risk assessment need to include a comprehensive analysis of the potential costs and
risks. The cost-benefit analysis should include an analysis of not only hydropower but wind and
solar power as potential alternatives to replace the diesel-generated power in Bristol Bay. More
economic information needs to be provided to the stakeholders so that they can make the
decision if cheaper power is worth the risk of the project impacting fish.
Traditional ecological knowledge, the cultural value of the fishery, and subsistence studies need
to be included in the RSP to improve our understanding of how historically anadromous fish and
resident fish use the cascade area and to understand their value and importance to the local
communities. We need to know what fish habitat occur in the Nuyakuk cascade because the
gradient averages only 1% and probably contains some fish habitat of value for both anadromous
fish and resident fish. The studies proposed in the RSP need to determine if the project will
cause unacceptable harm to the fish. The studies need to be reproduceable and repeatable so that
they can be continued before and after operation of the hydroelectric project.
How much water will be diverted by the project is a concern and whether a change in the flow
over the cascades could impact salmon outmigration and in -migration and resident fish habitat. A
critical question is if the project changes the flow by 30% what will the impacts be? Will this
change in flow impact outmigration and increase potential entrainment of the juvenile salmon
and impact the ability of the adult salmon making it up the casc ades to reach their spawning
grounds? The proposed studies need to determine how the intake, groin, and tailrace structures
will alter fish habitat characteristics and change the water depth, velocity , and habitat
composition.
Concerns about the proposed project infrastructure include how the groin and intake structures
and Kaplan turbines will impact the smolt outmigration on the Nuyakuk River. Smolt migrate
through the cascades not only in springtime but throughout the summer months. Therefore,
smolt migration studies need to be evaluated not just once a year but from May through July.
These studies need to determine the smolt distribution in the horizontal and vertical water
column to better design the intake and groin structures and reduce the entrainment and
impingement impacts to smolt. More information is needed about ice buildup on the concrete
3
groin and intake structures, and whether a concrete groin structure is even a good idea in a river
when during high flow conditions water will overtop the groin.
The PSP is a comprehensive document that should include an executive summary and an
appendix that defines the many technical terms and acronyms used in the document. This will
allow an overview and summary of the document so that stakeholders do not have to read the
entire document to understand the purpose of the project and all the aquatic resources studies
being proposed. More tribal engagement is needed through an increase in outreach and
education efforts about the project to the up-river villages. This is a vital step so that all
stakeholders can provide feedback on the project.
References
ADF&G Regional Information Report No. 2A00-08. Counting tower projects in Bristol Bay
Area, 1955-1999 by Cindy J. Anderson. September 2000.
ADF&G Fish Count Data Search for the Nuyakuk River, 2003-2006. Online at:
https://adfg.alaska.gov/sf/FishCounts/index.cfm?ADFG=main.home Accessed June 2022.
Thoman, R., J.E. Walsh. 2019. Alaska’s changing environment: documenting Alaska’s physical
and biological changes through observations. 16 pp. Available at: Alaska’s - Changing-
Environment_2019_WEB.pdf.
Nuyakuk River Hydroelectric Project
FERC No. 14873 Revised Study Plan
Nushagak Cooperative, Inc. August 2022
APPENDIX G:
Proposed Study Plan Comment Responses
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-1 August 2022
Comments received on the Proposed Study Plan (PSP) for the Nuyakuk River Hydroelectric Project (P-14873) filed with FERC on March 2, 2022 and
Nushagak Cooperative's responses.
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
1 ADF&G
(Kevin
Keith)
4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
In general, we are supportive of the fish abundance and distribution
study. The range of methods (literature review, beach seines,
minnow trapping, electrofishing, gill/trammel netting, environmental
DNA, visual surveys, incline plane/rotary screw traps, sonar, and
radio/acoustic tags) should provide a robust picture of fish presence
near the project area. Consistent sampling from April through
September will be necessary to understand the seasonal use of the
area and how project operation may affect the various fish species.
We appreciate the comment.
2
ADF&G
(Kevin
Keith)
4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
Based on past research and general knowledge of the area, it is well-
known that the five species of Pacific salmon migrate up through the
Falls as adults and back down through the Falls as juveniles. Aerial
surveys, either by helicopter or drone, are proposed to estimate the
magnitude and timing of the adult migration, and incline plane traps
in combination with sonar are proposed to estimate the magnitude,
timing, and spatial distribution of the juvenile out-migration. The
cross-channel distribution of the juvenile out-migration should be
studied near the proposed intake location in order to understand
what proportion of smolts may be subject to entrainment at the
intake. It is essential that both the adult and juvenile salmon studies
are begun early enough in the season and continued long enough to
cover the complete time range of both upstream and downstream
migration.
An Aquatic Resource Working
Group (ARWG) including
representatives from ADF&G,
NOAA, Univ. or Washington,
Bristol Bay Science and
Research Initiative, regional
tribes and NGOs was
established in October 2020 and
used a collaborative process
with routine meetings to
advance the fish study
components of the PSP. In June
2022 a core segment of this
group were able to participate in
a visit to the proposed project
site and a follow up discussion
of field methods based on site
specific conditions.
The fish sampling methods in
the RSP have been be revised
after the site visit and per
discussions at the June 2022
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-2 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
AWRG meeting, which
emphasized the need for fish
behavior information to inform
the life cycle model. As
described in the RSP, adult
passage will be evaluated
through use of bio-telemetry and
remote imagery with a focus on
fish behavior, route selection
and passage success not
numbers of fish moving
upstream. The downstream
movement of fish will be
address with a channel-spanning
sonar array in combination with
incline plane traps and fish
sample to address species
composition. Studies will begin
in the spring as soon as it is
feasible to launch and operate
equipment safely and
effectively. The details of study
design will be worked out after
the field testing of methods in
August 2022.
3
ADF&G
(Kevin
Keith)
4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
For the resident fish species (for example, Arctic grayling, rainbow
trout, northern pike), it is less clear how often, or even if, they move
upstream and downstream through the Falls. This is an important
question because the project proposes to significantly decrease flows
in the Falls during certain times of the year. The proposed study may
or may not be able to answer this question. In addition to the
proposed methods, we recommend the deployment of radio tags to
better understand passage through the Falls by resident fish species.
As discussed and agreed upon
during the June 2022 AWRG
meeting, biotelemetry will be
used to evaluate the seasonal use
of the fall by Arctic grayling.
This is included in the RSP.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-3 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
4
ADF&G
(Kevin
Keith)
4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
It is also possible that the Falls reach serves as an important food
source for resident species, particularly during the winter when it is
usually the only part of the river not covered in ice. For this reason,
we recommend winter sampling in the open water just downstream
of the Falls; underwater camera systems would likely work well, but
there may be other methods that would also be effective.
As discussed and agreed upon
during the June 2022 AWRG
meeting, winter sampling will be
attempted downstream of the
falls to address resident fish
presence. Methods used will be
determined after the field
methods testing in August 2022.
5
ADF&G
(Kevin
Keith)
4.1.2 Nuyakuk Falls
Fish Passage Study
The fish passage study is one of the most important studies in the
Proposed Study Plan. This study requires the collection of
scientifically sound data and careful analysis in order to
meaningfully inform a decision-making process that is consistent
with the protection of the fish resources of the Nuyakuk River.
While we are supportive of the modeling approach for this study, as
summarized in the Proposed Study Plan, we do have some concerns.
The applicant has proposed using LiDAR to collect the bathymetry
data that will be necessary; LiDAR seems like a safe and efficient
way to map the topography of the Nuyakuk Falls. However, it is our
understanding that the LiDAR that has been collected at the site has
some very significant gaps throughout the study site, likely due to
the turbulence of the Falls. Comprehensive bathymetric data
throughout the Falls is imperative to ensure high confidence in the
2D hydraulic model proposed for study analysis and ultimately for
the decision-making process. We encourage the applicant to
carefully assess bathymetry results and consider alternative methods
to supplement the existing data as needed to ensure a robust dataset,
particularly for any critical barriers in the Falls that may be
identified.
We appreciate the comment and
will be collecting additional data
to support the bathymetric
mapping obtained from lidar as
described in the RSP. In
addition, fish crews will collect
depth data specifically in blind
areas from the lidar, during field
methods testing in August 2022.
6 ADF&G
4.1.2 Nuyakuk Falls
Fish Passage Study
We expect the 2D hydraulic model to assess the lower thresholds of
flows in the Falls that allow for fish passage. We would note that
there may be days in June and July when tens of thousands of
sockeye salmon migrate upstream through the Falls. So fish passage
We appreciate the comment and
the fish passage assessment will
consider the abundance of fish
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-4 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
(Kevin
Keith)
should not just be considered in terms of the ability of a single fish
to physically navigate up the Falls, but in terms of thousands of
salmon per hour to move efficiently up the Falls.
that utilize the falls during the
June/July timeframe.
7
ADF&G
(Kevin
Keith)
4.1.2 Nuyakuk Falls
Fish Passage Study
To supplement the 2D hydraulic model, we strongly recommend that
aerial photos of the entire Falls reach (either by means of a drone or
a helicopter) be taken at different flow levels with an emphasis on
the lowest flows of the year. These photos would allow for a more
robust assessment of the possibility of fish passage at low flows than
an assessment that relied solely on the 2D model.
We agree and have
supplemented the RSP with
methodology for the utilization
of a drone to capture high-
quality aerial images at a variety
of flows.
8
ADF&G
(Kevin
Keith)
4.1.2 Nuyakuk Falls
Fish Passage Study
Both Figure 4-3 and Figure 4-5 present the hydrograph of the
Nuyakuk River. That is, they present the average discharge for a
given time period. As this study is developed, it will be more
important to consider the low flow events in the hydrological record
(i.e. flows at the 90% or 95% exceedance during different times of
the year, particularly from April to October during salmon
migration); those are the times when hydropower operation would
be most in conflict with fish passage.
We agree and will assess fish
passage at all realistic critical
flows to be as comprehensive as
possible.
9
ADF&G
(Kevin
Keith)
4.1.3 Fish
Entrainment and
Impingement Study
The proposed study of entrainment and impingement will combine a
literature review with site-specific hydrology and flow information.
The literature review will include target fish species and sizes and
swimming velocities, intake and intake screen design considerations,
approach and sweeping velocities, debris management, structural
modifications, and entrainment deterrent systems. Site-specific
information will include a hydraulic model of the intake reach with
consideration of the full range of natural flows and project operation
flows.
All five species of Pacific salmon will migrate upstream past the
intake as adults and will migrate downstream past the intake as
smolt. We are particularly concerned that the groin may act as a
funnel for outmigrating smolt and that the groin will substantially
As was communicated during
the recent ARWG meeting and
site visit, if a groin is determined
to be necessary it would be in
the form of a series of boulders
that would not be visible at
higher river flows. Further, use
of boulders would create a
porous environment where
downstream passage by out-
migrating juvenile salmonids
could easily be facilitated
through the natural channel.
Additional text has been added
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-5 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
increase the rate of impingement and/or entrainment. We request
that the entrainment study also consider design modifications to the
groin that would allow for smolt passage past the groin at the range
of flows that occur during smolt outmigration.
to the conceptual design
description of the RSP to further
define what the groin would and
wouldn’t be.
10
ADF&G
(Kevin
Keith)
4.1.3 Fish
Entrainment and
Impingement Study
We are also concerned that the relevant fish entrainment study
reports referenced are all for sites with primarily warm water
fisheries, and no anadromous salmon species. The literature review
should be expanded to include all hydroelectric projects in the
Pacific Northwest with anadromous salmon species and similar
proposed design and operational characteristics.
We will seek out additional
literature related to entrainment
studies for salmonids at Pacific
Northwest facilities.
11
ADF&G
(Kevin
Keith)
4.1.4 Assessment of
False Attraction at
the Tailrace Fish
Barrier
The proposed study of false attraction to the tailrace will be essential
to inform the final design of the project. The scope and magnitude of
the proposed study are appropriate for a project this size. One part of
the proposed study is, “A review of available information regarding
tailrace designs at similar hydroelectric facilities as well as
protective engineering design criterion associated with minimizing
salmon false attraction and the potential for migration delay.” This
review should include a careful consideration of the various pitfalls
of tailrace design and how this project would avoid them.
The false attraction assessment
will take into account potential
design issues in an effort to
design the most appropriate
tailrace for the site.
12
ADF&G
(Kevin
Keith)
4.2.2 Flow Duration
Curve Assessment
ADF&G is supportive of the goals and methodology of this study.
The utility of the study could be increased fairly simply by
presenting the results in terms of flow at the Nuyakuk Falls, rather
than in terms of flow at the outlet of Tikchik Lake. A streamgage
was recently installed at the project location and we expect an
excellent correlation between the flows at the project and the flows
upstream, where there is a long-term record.
We appreciate the comment and
agree. Data from the stream
gage at the Project location will
be utilized for this study if a
strong correlation between the
two gaging stations is
determined. Assessment of the
stationarity trend in the
watershed based on the USGS
record remains the primary goal
of this study.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-6 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
13
ADF&G
(Kevin
Keith)
4.3.2 Caribou
Population
Evaluation
The proposed study will evaluate the Mulchatna Caribou Herd
(MCH) within Game Management Units 17B and 17C (where the
proposed hydroelectric project would be located). The objectives of
the proposed study are comprised of evaluations of population status
and trends, health, habitat assessment, and land use. Each of these
evaluations is necessary. Furthermore, an evaluation of how the
proposed project would affect each of these elements is also
necessary.
As the Proposed Study Plan notes, “The Cooperative has initiated
preliminary discussion with ADFG to establish collaboration and
mechanisms for data sharing.” We will continue to work with the
Cooperative so that the possible impacts from the proposed project
on the MCH can be well understood.
We appreciate the comment.
14
ADF&G
(Kevin
Keith)
4.4.1 Subsistence
Study
In our Study Requests, which we filed with FERC on February 4,
2020, ADF&G requested a Subsistence Study using standardized
ADF&G methodologies. These methodologies are meant to ensure
the quality of the data collected and to maintain positive working
relationships with local communities. Use of these standard
methodologies will also facilitate the interpretation of the data
collected. For these reasons, ADF&G is in agreement with the
proposed Subsistence Study.
We appreciate the comment.
15
ADF&G
(Kevin
Keith)
4.4.1 Subsistence
Study
The study design will be guided by the research principles outlined
in the Alaska Federation of Natives Guidelines for Research1 and by
the National Science Foundation, Office of Polar Programs in its
Principles for the Conduct of Research in the Arctic2, as well as the
Alaska confidentiality statute (AS 16.05.815). These principles
stress community approval of research designs, informed consent,
anonymity of study participants, community review of draft study
findings, and the provision of study findings to each study
community upon completion of the research.
We appreciate the comment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-7 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
1.Alaska Federation of Natives. 2013. “Alaska Federation of Natives
Guidelines for Research.” Alaska Native Knowledge Network.
Accessed June 6, 2020. http://www.ankn.uaf.edu/IKS/afnguide.html
2.National Science Foundation Interagency Social Science Task
Force. 2018. “Principles for the Conduct of Research in the Arctic.”
Accessed June 6, 2020.
https://www.nsf.gov/geo/opp/arctic/conduct.jsp
16
ADF&G
(Kevin
Keith)
4.4.1 Subsistence
Study
The primary method for collecting subsistence harvest and use
information in this project will be through a systematic household
survey. Following receipt of comments at the scoping meeting
where the project is described to residents of the study communities,
ADF&G will finalize the survey instrument. The survey will be
structured to collect demographic, resource harvest and use, and
other economic data that are comparable with information collected
in other household surveys in the study communities across Alaska
and with data in the Community Subsistence Information System
(CSIS3). During surveys, ADF&G researchers will ask respondents
to indicate the locations of their fishing, hunting, and gathering
activities during the study year. ADF&G uses a standard mapping
method to conducting household surveys. Points are generally used
to mark harvest locations and polygons are used to indicate harvest
effort areas, such as areas searched while hunting caribou. Harvest
locations and fishing, hunting, and gathering areas are documented
on iPads using the Collector application (ESRI, or Environmental
Systems Research Institute) customized for Division of Subsistence
data collection needs.
3 ADF&G CSIS: http://www.adfg.alaska.gov/sb/CSIS/.
We appreciate the comment and
the collaboration.
17
ADF&G
(Kevin
Keith)
4.4.1 Subsistence
Study
Prior to beginning the household surveys, the ADF&G research
team will hire and train local research assistants (LRAs) in each
study community to aid in the household survey administration.
Hiring an LRA is very important for the community. LRAs support
We appreciate the comment and
the collaboration.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-8 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
community involvement with the project and receive funds that
provide local economic benefits.
18
ADF&G
(Kevin
Keith)
4.4.1 Subsistence
Study
After survey data have been analyzed by the Division of Subsistence
Section lead researcher, a public community review meeting in each
study community will be held to present draft study results at and
create an opportunity for residents to provide feedback to be
incorporated into the final report. A final report will be published in
ADF&G’s Subsistence Section Technical Paper series, and copies of
the technical paper and a summary document of the research
findings will be provided to the funding agency (the Cooperative),
the study communities, local Tribes, and the Dillingham ADF&G
office.
ADF&G requires and is requesting the Cooperative secure funding
for this research. ADF&G has had discussions with the Cooperative
regarding these surveys and will continue to work closely with them
in an effort to ensure that subsistence use of the project area is well
understood and ultimately protected.
We appreciate the comment and
the collaboration.
19 FERC
(David
Turner)
4.3.1 Botanical and
Wetlands Survey
Section 4.3.1.2 (Geographic Scope) of the proposed study plan states
that field data collection will be focused on the intake and
powerhouse vicinity shown in Figure 2-3, where the majority of the
terrestrial resources are expected to occur. Section 4.3.1.7
(Methodology, Study Component #2) states that a field vegetation
survey and delineation of wetlands and Waters of the U.S. will be
conducted in the area where project facilities are proposed for
construction, but no additional details are provided as to what area
that includes.
In contrast to this geographic scope, the pre-application document
states in Section 5.2.5 that, “An initial review of all existing
information documenting wetland presence, type and quantity in the
Project area will culminate in an aerial and on-foot field survey of
This section has been expanded
to clarify the scope of the
vegetation and wetlands
surveys.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-9 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
wetland areas that will be potentially impacted by the Project. At
this time, it is anticipated that wetlands that would be potentially
impacted (if any) would be primarily associated with the
construction and operation of the transmission line.”
Therefore, please clarify if any field vegetation surveys (wetland
delineation, mapping of BLM Alaska Special Status plant species
and non-native plants) are planned to be conducted along the project
transmission line corridor as part of the Botanical and Wetland
Survey. The proposed transmission line corridor totals 135 miles,
and transmission line poles are to be installed at 400-ft. intervals,
which would result in the installation of approximately 1,782 poles,
clearing of the right-of-way and associated ground disturbance from
pole installation and vehicular traffic. If no field surveys for
vegetation and wetlands are planned to be conducted in the
transmission line corridor, please explain how potential impacts to
vegetation will be evaluated within this area.
20
FERC
(David
Turner)
4.5.1 Noise
Section 4.5.1.8 (Proposed Deliverables and Schedule) states that the
noise study will be conducted between spring and fall 2023. One of
the purposes of the noise study is to evaluate the effect of noise on
caribou in the project area as described in Table 3-1. The desktop
portion of the caribou study is scheduled to be conducted from fall
2023 through fall 2024 (see Section 4.3.2.8), which includes
evaluating Mulchatna caribou herd (MCH) land use in the project
area.
There appears to be a disconnect between the timing of the noise
study and the caribou study. We recommend revising the timing of
these study plans so that sensitive areas for caribou are identified and
included in the noise study, rather than identified after the noise
study is completed. Preliminary MCH land use within GMU 17B
and 17C, including migration corridors, calving areas, and foraging
This section has been modified
to allow for sensitive area
identification prior to conducting
the noise study.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-10 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
patterns, should be available based on surveys through 2022 for the
purposes of identifying sensitive areas for the noise study.
21 FERC
(David
Turner)
4.5.1 Noise
Section 4.5.1.7 (Methodology) of the proposed study plan states the
study will be “developed in consultation with the Alaska Department
of Natural Resources (ADNR), Division of Parks and Outdoor
Recreation; Alaska Department of Fish and Game (ADFG); local
outfitters; and Native Alaskan tribes that use the Project area for
subsistence or other traditional cultural practices.” The proposed
study also states the study will “identify noise receptor areas (i.e.
wildlife habitat, recreation, and cultural areas) where sound data
needs to be collected,” and, “collect ambient sound level
measurements at the identified noise receptor sites.” We recommend
that the Cooperative work with the stakeholders mentioned above to
identify these noise receptor areas and sites. Please provide a
schedule and methods on how the Cooperative plans to consult with
the stakeholders listed on page 133 of the proposed study plan to
identify these noise receptors.
Additional text has been added
to document timing and methods
for the referenced consultation.
22
FERC
(David
Turner)
4.4.1 Subsistence
Study
The proposed subsistence study plan lacks certain details that would
help us evaluate the proposed study. For example, the study plan
mentions that the location of fishing, hunting, and gathering
activities will be collected during the surveys but does not indicate
that you would collect information on when (i.e., seasons) these
activities are conducted. Please include the survey instrument in the
Revised Study Plan so that the Commission and other stakeholders
can thoroughly evaluate the study proposal. Also, please make sure a
question related to the timing and seasonality of subsistence
activities is included in the survey.
Per collaboration with ADFG
(see comments and responses
14-18 above), we have
incorporated additional text on
the Subsistence Study
methodology into the RSP.
23
FERC
(David
Turner)
4.4.1 Subsistence
Study
The proposed study plan states that the ADFG intends to assist the
Cooperative with the subsistence study. There are steps listed in how
a comprehensive subsistence survey is conducted on the ADFG
Division of Subsistence website, but it is not clear if you intend to
We do intend to utilize ADFG’s
proposed methodology. Per
collaboration (see comments and
responses 14-18 above), we
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-11 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
follow these steps. Please indicate if you intend to follow the
ADFG’s survey guidelines, and if so, include them in your Revised
Study Plan. Please include a detailed methodology, including how
the surveys will be conducted (door to door, mail, online, etc.), who
will conduct the surveys, how many surveys would take place per
community, and when they surveys will be conducted. Please also
include how the community liaisons will be involved in the study,
how they would be identified, and details on any other planned
community consultation regarding the study. It is not clear if you
intend to conduct in-person interviews to supplement the survey. We
recommend that you include interviews with local users as
recommended in ADFG’s methodology.
have incorporated additional text
on the Subsistence Study
methodology into the RSP.
24
FERC
(David
Turner)
4.4.1 Subsistence
Study
Section 4.4.1.3 (Study Goals and Objectives) of the proposed study
plan states that Levelock and Dillingham are key survey areas from
a subsistence perspective. Under Sections 4.4.1.5 (Existing
Information and Need for Additional Information) and 4.4.1.6
(Project Nexus) you do not list Levelock Village or villages near
Dillingham such as the Village of Clark’s Point or Portage Creek
Village. Please clarify which communities and villages you plan to
survey, and if you don’t plan to survey Levelock Village, the Village
of Clark’s Point, or the Portage Creek Village, please explain why.
We have added text to the
specified section to document
those areas that will be surveyed.
25 FERC
(David
Turner)
Section 4.4.2 Section
106 Evaluation
The proposed Section 106 Evaluation study plan lacks certain details
that would help us evaluate the proposed study. For example, there
is almost no information about the survey methodology. The
proposed study plan states, “probability areas will be established
prior to field survey, based on topographic features and the locations
of previously recorded sites. Pedestrian surveys will be conducted in
areas considered to have higher probability for cultural resources.” It
is our understanding that no prior surveys of the study area have
been done. Consequently, how will existing information factor into
deciding which areas have a high probability to contain cultural
resources? You might consider modeling or reconnaissance level
surveys to narrow the areas of high probability that require surveys
Additional text has been added
to this section to further expand
the methods to be utilized.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-12 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
within the APE. Please describe the level of effort that would be
followed for the pedestrian surveys (e.g., percent of area to be
covered, length of transects, etc.).
26 FERC
(David
Turner)
Section 4.4.2 Section
106 Evaluation
Section 4.4.2.1 (General Description of Proposed Study) of the
proposed study plan states, “the APE will be defined in cooperation
with all consulting parties.” Please make sure you include the
Commission, the Alaska State Historic Preservation Office (Alaska
SHPO), and Tribes who have an interest in the project, in the
consultation process. Once the proposed APE is defined, please
request that the Alaska SHPO concur with the APE, in writing, prior
to conducting any field surveys or further analysis within the APE
and include the Commission on any correspondence with the SHPO
regarding the APE. Please revise the study plan to reflect this
guidance.
The process you describe related
to defining the APE are planned.
This section has been revised to
document this.
27
FERC
(David
Turner)
Section 4.4.2 Section
106 Evaluation
Section 4.4.2.2 (Geographic Scope) of the proposed study plan
states, “based on the current knowledge of the Project, the cultural
resources survey will focus on the Powerhouse, Diversion & Intake
structures, and the Conveyance Tunnels. The proposed airstrip and
access roads would also require archaeological survey. Consultation
may also identify other areas that should be archaeologically
surveyed.” The APE should, at a minimum, include the lands
enclosed by the proposed project boundary and lands or properties
outside the project boundary where project operation or other
project-related activities may cause changes in the character or use
of historic properties, if any historic properties exist. All areas that
have a high probability of containing archeological resources that
will be subject to ground-disturbing activities should be surveyed,
such as the project transmission line and portage trail. These areas
should be included in the APE.
The APE will include a broad
area composed primarily of
lands within the project
boundary where project-related
activities may cause changes in
the character of any existing
historic properties. We look
forward to working with the
appropriate agency
representatives to develop a
justifiable APE. All areas with a
high probability of containing
archeological resources and that
will be subject to ground-
disturbing activities will be
surveyed.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-13 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
28 FERC
(David
Turner)
Section 4.4.2 Section
106 Evaluation
Section 4.4.2.7 (Methodology) of the proposed study plan lists
methods for completing environmental documentation, including,
“draft, and final reports, including any determinations of eligibility
and recommendations on the project’s potential effects, if
requested.” The use of the term “if requested” is confusing and
misleading. Section 106 and the Commission’s regulations require
that the application describe the identified resources, determine their
eligibility, complete an assessment of the effects on the resources,
and propose measures to address the effects. Please revise the study
plan to remove “if requested.”
The phrase, “if requested” has
been removed.
29 FERC
(David
Turner)
Section 4.4.2 Section
106 Evaluation
Section 4.4.2.8 (Proposed Deliverables and Schedule) of the
proposed study plan lists, “writing a study plan in Winter/Spring
2023,” as a proposed deliverable. The study plan should already be
written and included in the proposed study plan document for
comment. Please explain what you mean by “write study plan” and
“propose any revisions to the study plan” in winter/spring 2023.
We agree that the wording was a
bit confusing. As such, this
section has been modified. The
intent of the referenced
statement was related to
collaborative development and
documentation of the APE.
30 FERC
(David
Turner)
Section 4.4.2 Section
106 Evaluation
We remind you that certain details in the draft and final reports
should be kept confidential and filed with the Commission and other
consulting parties as privileged, non-public documents.
We appreciate the comment, are
aware of the confidentiality
requirements and will move
forward accordingly.
31 FERC
(David
Turner)
Section 4.5.2
Recreation Inventory
by Season
The proposed Recreation Inventory by Season study plan (recreation
study) lacks certain details that would help us evaluate the proposed
study. For example, there is no information about the survey
methodology itself.
Section 4.5.2.7 (Methodology) of the proposed study plan states that
“The Cooperative will collaboratively conduct a comprehensive
recreational survey to be employed in Dillingham and the same 4
Per Section 4.5.2.7, a
combination of in-person,
electronic and paper surveys will
be utilized to be as
comprehensive as possible and
ensure as many people as
possible have access and
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-14 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
villages outlined in the subsistence survey in Section 4.4.1
(Koliganek, New Stuyahok, Ekwok and Aleknagik). Beginning in
2022, the Cooperative will develop an online portal by which
seasonal (4 times per year), recreational surveys will be submitted.
Contacts on the existing Project licensing contact list will be invited
to submit survey responses via the online portal. The Cooperative
will also invite participants to submit survey responses via social
media outlets and the Project licensing website. Surveys will begin
in the Spring of 2022 and continue through the winter of
2022/2023.”
What kind of survey will be employed in Dillingham and the four
villages? Is this an in-person oral survey, written survey, or
combination of the two? Are the surveys going to be conducted at
the same time as the subsistence surveys, to the same participants?
How are these participants being chosen and how many? If they are
going to be given to the same participants as the subsistence survey,
how will you mitigate for participant fatigue and interest? If the
recreation surveys are not being deployed at the same time as the
subsistence surveys, please describe when the surveys would take
place (times throughout the day, weekends/weekdays, participants,
etc.), who would be conducting the surveys, how many surveys
would take place per community (and how this is determined), and
how the surveys would be conducted (door to door, mail, online,
etc.). Please include this information in the Revised Study Plan.
Please explain if the online portal mentioned above is for the
Cooperative’s organization of data or if it is a public site for
members of the public to visit and fill out the survey online? Please
provide more information on how the survey link will be marketed,
for example which social media outlets will be utilized and
examples of social media groups that the survey will be posted on.
When will the online survey be available and open to the public?
The survey schedule listed under Section 4.5.2.8 (Proposed
Deliverables and Schedule) mentions surveys in January, April, July,
and October 2023 but the above description mentions spring of 2022
opportunity to fill out the
surveys.
With the understanding that the
overall study program for the
project will require a substantial
amount of logistical preparation
and coordination throughout,
there are no plans at this time to
conduct the subsistence and
recreation surveys at the same
time. That said, if the timing of
the surveys ends up coinciding
and efficiencies can be realized,
the Cooperative will endeavor to
coordinate the surveys.
Additional detail has been added
to Section 4.5.2.7 related to
timing of surveys and who will
be conducting the work. In
addition, the schedule has been
updated, per the request.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-15 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
through winter of 2023. Please correct this discrepancy. In addition,
please explain why an online survey would not be available to the
public continuously throughout the study season as compared to the
four months listed above.
Please update your proposed schedule as spring of 2022 has passed.
Please include the survey instrument in the Revised Study Plan so
that the Commission and other stakeholders can thoroughly evaluate
the study proposal. It is unclear if you intend to conduct in-person
surveys as well as the online survey. Please clarify in the revised
study plan. If the online survey and in-person/mailed survey are
different, please include both.
32 FERC
(David
Turner)
Section 4.5.2
Recreation Inventory
by Season
The proposed study plan states, “it is understood that supplemental
methods to the online portal may be necessary to reach a robust
enough data set to make conclusive determinations related to
potential recreational impacts associated with Project development.
A series of supplemental survey distribution methods may be
utilized to access as many interested individuals in these
communities as possible,” and then lists these supplemental
distribution methods. The identified supplemental distribution
methods include seasonal village site visits, mail-back surveys, and
calling. What criteria will be used to determine if these supplemental
distribution methods will be implemented and by when? How will
the seasonal village site visits be different than the comprehensive
recreational survey planned to be employed in Dillingham and the 4
villages outlined in Section 4.5.2.7? How will members of the public
be chosen to have a survey mailed to them? Will the instructions
also include postage and an envelope to mail back the survey? How
will phone numbers be selected to make survey calls (randomized by
what method, selected based on certain criteria, etc.)? What kinds of
local meeting places will the surveys be distributed at and how?
The supplemental methods listed
in Section 4.5.2.7 will be
conducted in addition to the
online option. The text has been
revised accordingly. The
seasonal village visits will be
utilized to both advertise the
availability of the surveys and
solicit survey input.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-16 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
33
FERC
(David
Turner)
Section 4.5.2
Recreation Inventory
by Season
Please provide a figure showing the geographic scope of the area
where the recreation inventory will take place.
A figure has been added (Figure
4-26).
34 FERC
(David
Turner)
Section 4.5.2
Recreation Inventory
by Season
What protocols are planned to maximize participation in surveys
through the planned methodology and through the supplemental
distribution methods?
Per all of the various methods
mentioned in Section 4.5.2.7,
the Cooperative is confident that
a high level of public
participation will be possible
and the availability of the
surveys will be conveyed to a
high proportion of those
individuals in the survey area.
35 FERC
(David
Turner)
Section 4.5.2
Recreation Inventory
by Season
The survey in the proposed study plan asks participants about usage
of the portage trail but does not ask about usage for all recreational
activities. The survey should ask about usage for all recreation
activities, including number of recreation trips and length of trips.
The survey asks about primary recreational activities conducted near
the proposed project but should also ask about all recreational
activities conducted in general near the proposed project area and
have the participant identify which is their primary activity. Boating
seems to be one of the most popular recreation activities in Wood-
Tikchik State Park; the PAD even mentions river floating as a highly
popular activity and states that one of the most popular river trips in
the park is near the project where some boaters exit the Park after
Nuyakuk Falls, therefore using the existing portage trail. Please
include river floating/boating as one of the recreational activities
listed in the survey; currently it is not listed as an activity along with
hunting, fishing, etc. As mentioned above, please include the survey
instrument in the Revised Study Plan so the Commission and other
stakeholders can thoroughly evaluate the study proposal.
Additional methods text has
been added to this section based
on the request.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-17 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
36 FERC
(David
Turner)
Section 4.5
Recreation and
Aesthetic Resources
Page 95 of the PAD states, “The proposed Project would be located
on the Nuyakuk River near Nuyakuk Falls. Project features would be
visible to both recreational users that float the river and subsistence
users that navigate upriver to access Tikchik Lake and the lower
Tikchik River. The proposed transmission lines may also be visible
from various viewpoints in the surrounding area, such as some of the
public use sites identified in the Nushagak & Mulchatna Rivers
Recreation Management Plan. It is anticipated that Project vicinity
aesthetic resources will be investigated as part of the overall Project
licensing study program.” Page 113 of the PAD states, “given the
remote location of the Project site, relatively limited recreational
activity occurs in the area. However, there are lodges located in the
drainage upstream of the Project site. Both guides associated with
those lodges and other individuals fish for a variety of species in the
river near the Project site and utilize it as a transportation corridor
for hunting activities. Overland activities utilizing snowmobiles and
ATVs also occur in the area along with aerial sightseeing. Given
these activities, a comprehensive visual and recreational assessment
of the Project area will occur with the intent of defining the extent of
the recreational activities that occur in the Project area and
describing all of the potential impacts associated with Project
development and operations. The on-site data collection component
of this effort would likely be conducted primarily from the air.”
These statements indicated that you intended to develop and conduct
a visual aesthetics assessment as part of the study process. Yet a
detailed study plan was not provided in the proposed study plan.
Please include a detailed aesthetic study plan in the revised study
plan. This plan should include a viewshed/landscape analysis that
identifies key areas where visitors would see the project and its
facilities and assess how those views would change following
project construction. The analysis could include photo simulations of
representative sites before and after the project is constructed and
should identify measures that could reduce those effects (e.g.,
lighting, painting, landscaping, etc.).
We have added text related to
the visual resource assessment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-18 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
37
FERC
(David
Turner)
N/A
To assist Commission staff with its analysis under the National
Environmental Policy Act (NEPA), we recommend that Nushagak
Electric and Telephone Cooperative conduct an Environmental
Justice Study (EJ Study) for the proposed Nuyakuk Hydroelectric
Project.
An Environmental Justice Study
was added to the RSP.
38
NMFS
(Gretchen
Harrington)
Global Our global comment is to commit to fewer study components;
however, focus on doing the components that remain well. We appreciate the comment.
39
NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
Baseline Migratory patterns (questions 3 and 4) are extremely
important to understand potential project effects. If a species
migrates during a 2-month period, we request information about the
early returning fish, mid-returning fish, and late returning fish.
Those that migrate up the cascade at the tail ends of the run may be
the most important as they will demonstrate passage through the
falls at lower water (Page 35).
We appreciate the comment.
40
NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
Most movement of smolt downstream through the falls will be
primarily non-volitional (i.e., move with currents). We still request
information on both the early out-migrants and the late out-migrants
to idenitify which portion of the river they favor in Zone 1 above the
falls (Page 35).
As discussed and agreed upon in
the June 2022 AWRG meeting,
we will proposed to document
the downstream movement of
salmon with a channel-spanning
sonar array in combination with
incline plane traps and fish
sampling to address species
composition and distribution
across the river. Studies will
begin in the spring as soon as it
is feasible to launch and operate
equipment safely and
effectively. The details of study
design will be worked out after
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-19 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
the field testing of methods in
August 2022.
41 NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
We recommend the fall sampling events extend into October as we
know there will be resident fish and coho in the river. The climate is
changing and Chinook and sockeye could also be returning later
(Page 40).
The current sampling schedule
was designed with 2 sampling
events to cover salmon
migration windows as Sockeye
and Chinook Salmon were
identified by the AWRG as the
primary species of concern.
Additional sampling events will
occur in late summer/early fall
and two winter events have been
proposed to focus on resident
fish potentially feeding at the
falls during winter. We can use
information from the Bristol
Bay fishery to help us
understand any changes in run
timing in the near future and can
adjust sampling events if needed
to cover salmon run timing.
42
NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
We do not support significant physical fish sampling in Zone 2.
Similar quality data could be obtained with a greater level of safely
by tagging fish above and below the cascade (Zones 1 and 3) and
tracking them through the falls. We do support the use of drones to
identify holding or staging areas. It should be noted that although
drones can show that fish are holding in a certain area, there could
be subsurface holding areas which the drones will not identify (Page
41).
As mentioned above, the use of
a drone to document habitat
conditions in Reach 2 has been
added to the RSP. Further, we
whole-heartedly agree that
safety is always the fundamental
consideration when conditions
such as those in Reach 2 are
present.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-20 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
43
NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
Minnow Trapping - If smolt primarily stay in the main current and
the minnow traps are place at the stream margins, the minnow traps
will not capture a good cross-section of outmigrating smolt (Page
41).
We appreciate the comment and
have incorporated multiple
methods to document smolt
presence, location and
abundance.
44
NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
This still reads like a list of “candidate” techniques and provides
agencies very little information on methods that will be actually
used. We anticipate more discussion with consultants as fish
sampling methods are defined in the next nine months (Pages 41-
43).
As communicated during our
June 2022 site visit and AWRG
meeting, we are committed to
further collaboration related to
method refinement during the
remainder of 2022. We have a
methods testing trip planned for
mid-August that will greatly
inform which of the currently
listed methods will be the most
effective and efficient. Those
will ultimately be communicated
to the ARWG for concurrence.
45
NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
We fully support biotelemetry surveys and encourage the utilities to
conduct studies that last throughout the summer. We do not have a
strong preference for radio or acoustical telemetry, however, the
study design and implementation must be rigorous.
We appreciate the comment.
46
NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
We support the deployment of fixed antennae on the various islands
within the falls, if possible. This would provide complementary
information to that collected through drones.
We appreciate the comment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-21 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
47
NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
Downstream Migrant Trapping- One or two 24-hour sets of minnow
traps would be good. Smolt likely move in crepuscular timeframes
similar to the Kvichak River at Igiugig. It is possible that 6 hours
nighttime sets would capture the majority of the smolt.
Thanks for your comment. The
proposed minnow trap soak
times include overnight to
capture any diel activity of
fishes.
48
NMFS
(Gretchen
Harrington)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
Telemetry efforts should be set up with the vision that studies will
likely extend for 3-5 summers. Based on past experience, it is
unlikely that studies will cease prior to construction.
All implemented study methods
will be established in a way
where they can be repeated in
future years, if necessary.
49
NMFS
(Gretchen
Harrington)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
We recommend the downstream passage studies be grouped with
Fish Entrainment and Impingement as that is the primary threat to
downstream passage.
Regardless of the order of the
studies in the RSP, downstream
passage assessments are
inherently linked to entrainment
and a comprehensive impact
assessment of downstream
movement of fish will be
conducted.
50 NMFS
(Gretchen
Harrington)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
The most important upstream migration goal is the amount of time
adult fish take to pass through the falls. If you can determine the
time to passage at most flows that fish are likely to experience post
project, the exact route through the cascade is less important.
We appreciate the comment and
have designed our studies to
answer this question.
51
NMFS
(Gretchen
Harrington)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
We would like to see fish tracked through the falls at flows twice the
lowest flow that will be in the falls during upstream migration for
the low end and up to 10,000 cfs. The low flow tracking is of more
interest than the higher flow tracking. A fish that is holding due to
high flows will likely have a chance at lower flows before the
migration window closes.
Because the river is unregulated
and we cannot adjust flows for
study, in the revised study plan
we have proposed the
combination of biotelemetry
under current unregulated flow
conditions with the 2 D
hydraulic model. This will help
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-22 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
us estimate what passage
conditions including depth and
velocities would be like with the
Project operating at various
flows and how that may affect
fish passage performance. We
have also proposed use of
underwater video to evaluate
holding behavior and combined
with the 2 D model will evaluate
how changes to holding habitats
may affect fish behavior with the
project operating.
52
NMFS
(Gretchen
Harrington)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
Tracking the route of out-migrating smolt is primarily important in
Zone 1 near and immediately upstream of the intake. Tracking or
modeling the smolt route through the cascade will not likely add
much value.
The sonar array and fish
trapping/netting is intended to
characterize the distribution of
salmon juveniles as they enter
the falls area. Safe passage
conditions though the falls will
be address by the Fish Passage
Study and 2 D modeling.
53
NMFS
(Gretchen
Harrington)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
Objective two is actually more important and easier to quantify than
objective one (Page 50). We appreciate the comment.
54
NMFS
(Gretchen
Harrington)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
Stranding or trapping of a sufficient number of adults to affect the
population is not a likely outcome. Focusing on smolts would be
more productive (Page 50).
We appreciate the comment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-23 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
55
NMFS
(Gretchen
Harrington)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
HEC-RAS models will be extremely useful and accurate in Zones 1
and 3. We fully support their use in looking at the effects of the
intake and the tailrace. We question whether a useful HEC-RAS
model can be developed for the complex flow dynamics that exist in
the falls. If you develop it, calibration and validation will be
challenging.
We appreciate the comment.
56
NMFS
(Gretchen
Harrington)
Section 4.1.3 Fish
Entrainment and
Impingement Study
(Geographic Scope) The correct extend for the 2-D model should be
three river widths upstream of the center of the Intake Structure
(Page 69).
Thank you for the comment.
Assuming that the LIDAR will
support moving the upstream
extent of the 2D model we will
be happy to move the upper
extent to be equal to this
distance.
57
NMFS
(Gretchen
Harrington)
Section 4.1.3 Fish
Entrainment and
Impingement Study
Goal 5: Since specific details of technical features such as fish
screens will not be designed for several years, this study cannot be
based on those specifics (Page 71).
We appreciate the comment and
intend to assess a variety of
existing projects with intake
infrastructure likely to be similar
to this Project, if constructed.
58 NMFS
(Gretchen
Harrington)
Section 4.1.3 Fish
Entrainment and
Impingement Study
We recommend considering options to design a system where
screens or other deterrents can be added later, if the smolt
entrainment percentages are initially too high.
We appreciate this comment and
will include this option in the
conceptual design as it moves
forward.
59
NMFS
(Gretchen
Harrington)
Section 4.1.3 Fish
Entrainment and
Impingement Study
While we do not consider a groin to be necessary or desirable
component, we are more comfortable with a non-continuous groin
made of large natural rocks than a concrete wall. A non-continuous
groin will support removing material from in front of the intake
during high flow event.
As was communicated during
the recent ARWG meeting and
site visit, if a groin is determined
to be necessary it would be in
the form of a series of boulders
that would not be visible at
higher river flows. Further, use
of boulders would create a
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-24 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
porous environment where
downstream passage by out-
migrating juvenile salmonids
could easily be facilitated
through the natural channel.
Additional text has been added
to the conceptual design
description of the RSP to further
define what the groin would and
wouldn’t be.
60
NMFS
(Gretchen
Harrington)
Section 4.1.3 Fish
Entrainment and
Impingement Study
Include information on whether the results from desktop entrainment
study that you plan to replicate actually matched entrainment
monitoring carried out once the project was completed.
If licensed, a monitoring plan
will be developed to
compare/contrast entrainment at
the Project relative to the
existing projects that were
assessed as part of the feasibility
study program.
61
NMFS
(Gretchen
Harrington)
Section 4.1.3 Fish
Entrainment and
Impingement Study
The impingement study should focus on juvenile fish. Salmon adults
that make it up the Nuyakuk cascade will be inclined to swim up
current and can likely outswim the intake velocities (Page 76).
Juveniles will be the focus of the
impingement study.
62
NMFS
(Gretchen
Harrington)
Section 4.1.3 Fish
Entrainment and
Impingement Study
Turbine and blade designs that decrease the likelihood of juveniles
touching the moving parts are currently being developed. Expand the
investigation beyond the traditional Francis and Kaplan turbines.
Agreed. Consideration of
established and emerging
technologies should be
considered. For example, the
Minimum Gap Runner turbines
from Voith should be
considered, in addition to others.
Added the following bullet to
the list of information obtained
through the literature review
process in Section 4.1.3.5:
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-25 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
“Injury, mortality and survival
rates of entrained primary fish
species and sizes passing
through experimental, “fish-
friendly” turbine arrangements.
63
NMFS
(Gretchen
Harrington)
Section 4.1.4
Assessment of False
Attraction at the
Tailrace Fish Barrier
Study
NMFS 2011 was updated to NMFS 2022: Anadromous Salmonid
Passage Facility Design. It is available at:
https://www.fisheries.noaa.gov/resource/document/anadromous-
salmonid-passage-facility-design (Page 82)
We appreciate the comment.
64
NMFS
(Gretchen
Harrington)
Section 4.1.5
Chinook and Sockeye
Salmon Life Cycle
Modeling
Objective 1- We have a mandate to maintain healthy anadromous
fish populations across their full range, including the Nuyakuk River
(Page 85). The Nuyakuk salmon play a crucial role in maintaining
genetic diversity in the larger Bristol Bay watershed.
We appreciate the comment.
65
NMFS
(Gretchen
Harrington)
Section 4.1.5
Chinook and Sockeye
Salmon Life Cycle
Modeling
Data Acquisition – Passage success can be equally or better
determined by tracking fish below and above the project. The 2D
hydrologic model (which should be hydraulic model) will have
trouble capturing the fine scale flow paths through the cascade which
the fish may utilize (Page 91).
As discussed in the RSP,
reaches 1 and 3 (above and
below the falls) will be
comprehensively evaluated in an
effort to substantially
supplement the 2-D modeling
data collected in Reach 2
66
NMFS
(Gretchen
Harrington)
Section 4.1.7 Future
Flows Study
We request you replace most of this text with our rewritten Future
River Flows and Water Temperature Study (Enclosure 2).
We have modified the text
according to your request.
67
NMFS
(Gretchen
Harrington)
Section 4.2.2 Flow
Duration Curve
Assessment
See our modifications to the Flow Duration Curve Change Analysis
study request (Enclosure 2).
We have modified the text
according to your request.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-26 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
68
NMFS
(Gretchen
Harrington)
Section 4.2.3 Ice
Processes
Assessment
Include information gained about ice process from the substantial ice
formation last winter. Even though the climate is warming, ice
events will happen in the future.
Minimal data was gathered
during last winter due to COVID
considerations as well as
ongoing collaborative dialogue
about study methods. We will be
ready to document ice
conditions/processes during the
2022/2023 winter.
69
NMFS
(Gretchen
Harrington)
Sections 4.2.2 Flow
Duration Curve
Assessment and 4.1.7
Future Flows Study
The National Marine Fisheries Service hereby modifies two of our
study requests with the Federal Energy Regulatory Commission for
Dillingham Cooperative’s (Applicant) Nuyakuk River Project (P-
14873) in Alaska. The Nushagak Utility included the content of five
of the seven study requests from our February 4, 2020 filing in their
2020 Proposed Study Plan (PSP). The Applicant included the
content of all seven studies in the 2022 PSP; however, we have since
updated the Flow Duration Curve Change Analysis (Study 4) and
Future River Flows (Study 5). We request that this new language be
included in the Final Proposed Study Plan. Each study is supported
using the Commission's study plan criteria at 18 CFR 5.9(b).
Information derived from each of these studies will inform the
decision process during this licensing action.
We appreciate the comment and
have modified the text per the
provided NMFS text.
70 ADNR (Ben
Corwin) N/A
Of additional concern are water rights. The licensee does not have a
valid application for water rights because the application process
requires the licensee to apply for land use access. The issues of
access are being worked out. We would like to make it clear that the
licensee has been in contact with the DNR and is working in good
faith.
It is important to note that there will need to be a companion
decision process for water rights that will include public notice and
requests to Nushagak Cooperative for studies. It is our opinion that
it would be better management of resources to include the studies
above as part of the study plans under FERC. The licensee can then
As noted, we have been in direct
contact with ADNR regarding
water rights and by the time of
the filing of this RSP have likely
submitted a complete water
rights application to the agency.
The Cooperative is unclear as to
the portion of the comment
related to “including the studies
above as part of the study plans
under FERC”. Per federal
requirement, we are currently
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-27 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
include the results in a single report that all public entities have
access to. It is in the public interest that the licensee includes these
studies. It is also in the public interest that these studies do not hold
up a future license due to delays in the water right process.
carrying-out this licensing under
the FERC Integrated Licensing
Process (ILP) and as such, all
studies incorporated into the
RSP will be part of the formal
FERC licensing process.
71 ADNR (Ben
Corwin)
Section 4.3
Terrestrial Resources
Evaluate potential impacts of industrial development and human
disturbance on the behavior, survival, recruitment, and distribution
of big game species including caribou, brown and black bear,
moose, and wolves, as well as small game and non-game species
during research, construction, and operation of the project
Per discussion with agencies and
the public, caribou were
documented as a priority species
for evaluation with the highest
potential for being impacted, as
a result of the proposed
transmission corridor.
72 ADNR (Ben
Corwin)
Section 4.3.2 Caribou
Population
Evaluation
Evaluate potential impacts to migratory corridors of Mulchatna
caribou. The annual seasonal migration route runs perpendicular to
proposed transmission route.
Per discussion with agencies and
the public, caribou were
documented as a priority species
for evaluation with the highest
potential for being impacted, as
a result of the proposed
transmission corridor.
73 ADNR (Ben
Corwin)
Section 4.4.1
Subsistence Study
Evaluate potential impacts to subsistence use, access and harvest
success during research, construction, and operation of the project
Per Section 4.4.1, current
subsistence use in the Project
area and potential impacts
related to Project construction
and operation are the focus of
this study.
74 ADNR (Ben
Corwin)
Section 4.5
Recreation and
Aesthetic Resources
Evaluate potential impacts to scenic resources of the park during
research, construction, and operation of the project.
As noted in Section 4.5.2,
impacts to sightseeing will be
evaluated.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-28 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
75 ADNR (Ben
Corwin)
Section 4.5.2
Recreation Inventory
by Season
Evaluate potential impacts to recreation, tourism and commercial
businesses during research, construction, and operation of the
project.
As noted in Section 4.5.2, the
potential construction period
impacts will be evaluated as part
of this study.
76 ADNR (Ben
Corwin)
Section 4.5.2
Recreation Inventory
by Season
Evaluate potential impacts to hunting access, harvest and effects to
game species populations, distribution, and subsequent changes to
ADFG regulations during research, construction, and operation of
the project.
As noted in Section 4.5.2,
impacts to hunting and fishing
will be evaluated.
77
BBRSDA
(Andy
Wink)
Defining the “Fish First” directive and ensuring data collection will
provide adequate measures to follow such a policy prior to project
construction, as well as monitoring conditions during project
execution.
What is “Fish First?” In November 2017, the NETC Board of
Directors adopted a “Fish First” directive when evaluating any
resource utilization. However, this resolution does not define how
fishery resources are to be protected or what an acceptable loss of
fish populations may be. Although the Fish First directive is a noble
and reasonable filter for potential resource utilization projects, it is
imperative that it be more specifically defined so that data collection
methods can provide useful tools for the decision-making and public
education process. Different people likely have varying definitions
of what they believe the “Fish First” directive means.
“Fish First” is the Cooperative’s
resolve to continue to honor and
preserve what the fish and
fisheries have and should
continue to provide to the
region, state and country.
78
BBRSDA
(Andy
Wink)
Further, it is concerning that the Proposed Study Plan (PSP) does not
appear to have a clear and/or adequate set of data collection
methodologies for counting the volume of fish migrating through the
Nuyakuk Falls area. The PSP lays out a goal of developing a Life
Cycle Model and Integrated Risk Assessment tool; however, even
the most sophisticated models are useless unless the input data is
sound. BBRSDA is concerned by the PSP document’s lack of a
clearly articulated study plan directed at enumerating fish passage in
As part of the “Fish First”
directive this project will be
designed and operated to
maintain suitable fish passage
condition and minimize
potential negative impacts to
salmon and the Nuyakuk
watershed. Consistent with this
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-29 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
the project area and the lack of consensus by subject matter experts
on the ARWG regarding how to measure fish passage volume. In the
opinion of BBRSDA, the PSP is too ambiguous about how critical
fish data will be collected in a reliable and consistent manner to
inform the LCM, IRA, and “Fish First” specifications – both for the
purposes of baseline data and post-construction monitoring.
commitment the Cooperative
has had extensive collaboration
with the ARWG (composed of
regional fish experts) and the
public in developing the study
plan. We have collaboratively
designed a sampling program to
give us the best opportunity to
collect the type and scale of
information that will be needed
to support a robust LCM model
for Sockey and Chinook Salmon
and Integrated Risk Assessment
that incorporates additional fish
species. In addition, the August
2022 field testing effort will
inform our knowledge of
effectiveness of sampling tools
at this challenging location and
will help us to ensure that the
data collected is appropriate and
informative for modeling efforts
and fish community
characterization.
79
BBRSDA
(Andy
Wink)
Finally on this point, the PSP needs to put forth a specific data
collection plan that will allow for reliable projections about impacts
on fish across varying levels of water flow. As this project will
redirect river water during periods of upriver migration, the
declining flow through the Nuyakuk Falls could have a substantial
impact on the ability of adult salmon to migrate upriver to spawning
beds
See previous comment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-30 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
80
BBRSDA
(Andy
Wink)
The proposed Nuyakuk Hydroelectic project assumes that for many
decades to come, the demand for electricity will follow the current
pattern where load increases substantially during the late spring and
summer months coinciding with the salmon season. Shoreside
processing plants consume large amounts of power to process and
freeze salmon. However, it is possible that in the future salmon
processing will shift offshore. In 2019, Northline Seafoods operated
such a business in Bristol Bay where the company froze whole-
round salmon on a barge without ever needing to deliver the fish to a
shoreside facility. A storm destroyed that barge when a mooring
buoy failed late in 2019, but Northline founders are looking at
options to restart similar operations. BBRSDA has investigated the
Northline whole-round approach and found it to have numerous
compelling attributes over the current processing model used in
Bristol Bay.
While it is impossible to predict whether the offshore, whole-round
approach will become the new normal in Bristol Bay in decades to
come, we believe it is prudent to point out that there is a reasonable
chance that the current processing model dominated by shoreside
facilities may not survive for the next 50-100 years. Therefore, it is
important to provide stakeholders with a clear sense of how a
potential shift in processing activity away from shoreside plants may
impact the economics of the proposed project. To what extent does
this change the predicted cost per kilowatt? What effect would this
shift have on the project’s cost burden for other NETC customers?
We are very fortunate that the
concept Nushagak Cooperative
has endeavored to study the
potential to provide enough
energy for the fresh frozen
salmon processing that todays
market all but demands. We are
aware of even more recent
efforts to cater to the offshore
processing by organizations
such as BBRSDA, all to provide
and market a higher quality
product. One realization is this
concept has the ability to allow
the processors to add "Processed
with renewable energy on site in
Alaska" to the label for
marketing purposes. We are
comfortable in the notion that
even if offshore processing took
hold, the shore based plants
would not dissolve completely.
There will still be a support
industry for the fishery, the
seasonal construction and hub
community power demands for
the Dillingham area. The bigger
and probably equally important
aspect of a concept such as this,
is the ability to secure a source
of energy that will provide
energy for the southwest Alaska
region for the next century or
more.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-31 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
81
USFWS
(Jennifer
Spegon)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
This study proposes to identify fish species distribution and
abundance near the project site, specifically it proposes to identify
the relative abundance of fishes in the Project Area seasonally, the
baseline migratory patterns and behaviors for Sockeye Salmon and
Chinook Salmon, and the proportion of adults that successfully pass
through the Falls Reach. It seems the methods used for Adult
Salmon Migratory Behavior Observation are to inform the
species/life stage periodicity chart and adult migratory behavior
through the three project Zones. Please specify if this information
will also be used to estimate run sizes. We realize there are many
factors that can impact escapement such as ocean conditions,
fishing, and climate, but we recommend discussing pre-project
escapement trends (including the 1950-2006 Sockeye Salmon
escapement data mentioned on page 36) as this may be informative
for monitoring and adaptive management strategies once the project
is in place.
The need for and ability to
collect project escapement data
has been discussed extensively
by the ARWG over the past 15
months. Given the highly
variable annual run sizes, the
well monitored fisheries
downstream, and the
challenging nature of the river in
the Project area, the AWRG has
determined that a Life Cycle
Model is the appropriate tool to
evaluating the potential for the
project to effect Chinook and
Sockeye Salmon populations.
The model will be built using
existing in-basin data, regional
data from operating hydropower
projects and will be refined with
site specific data collect
82
USFWS
(Jennifer
Spegon)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
We request additional information be depicted in figures to help
visualize where proposed sampling activities would occur. Currently
Figure 4-3 (p. 42) shows the five transect lines to be established at
200-meter intervals in Zones 1 and 3 as discussed on page 40, as
well as the primary location for a downstream migrant trap
discussed on page 46. We recommend the following information as
stated in the Methodology section also be depicted in Figure 4-3 or
in an additional figure if necessary:
• “Fish collection surveys will occur over a 50-m-long reach
located on both stream banks beginning at the downstream
end of each transect…Given the methods to deploy, it is
anticipated that each sampling event will last 10 days to
We had discussions about
adding the information
requested during multiple
ARWG meetings. Upon
dialogue and our June 2022 site
visit, it was clear that flow
conditions, especially in lower
Zone1, Zone 2 and upper Zone 3
during individual sampling
efforts will ultimately determine
locations. As such, it was
decided to not convolute the
figure with multiple potential
scenarios. To be clear, the
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-32 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
cover the 10, 50m transects” (p. 40). It is not clear how
these 50-meter -long survey reaches are related to the 10
transect lines depicted in Figure 4-3. Do the lines represent
the downstream end of each 50-meter survey reach?
Clarification in the narrative, and modification of Figure 4-3
will improve the understanding of sampling areas.
• “[F]ish sampling in Zone 2 will occur on an opportunistic
basis at locations that are determined safe to sample based
on depth and velocity (Figure 4-3)” (p. 40). Figure 4-3 is
mentioned for Zone 2, but there doesn’t appear to be
anything depicted in that figure for Zone 2. Are there
specific instream margin areas in Zone 2 that are the most
likely locations for safe sampling? If so, please depict those
locations in a figure.
• “Downstream migrant trapping may occur at several
locations in the Project area to account for spatial
variability; however, survey efforts will be focused in Zone
1 near the proposed Project intake (Figure 4-3)” (p. 46).
Have other potential trapping locations been identified? If
so, please depict them in a figure.
Cooperative has every intent of
surveying these areas as
comprehensively as flow
conditions and the associated
safety at the site allow.
83
USFWS
(Jennifer
Spegon)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
Since the leaping and jumping capabilities in this study are based on
body size for each species, please consider modifying Table 4-2 to
indicate body dimensions at the top of the table, perhaps listing size
in the heading with the species name.
Thank you for the comment.
We will look at available data to
confirm that the size distribution
of Nuyakuk salmon will be
represented by the data obtained
from previous studies with these
species in other basins.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-33 August 2022
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No. Agency PSP
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84
USFWS
(Jennifer
Spegon)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
In addition, it is unclear how the average size of fish in Nuyakuk
compare to sizes used in the table. Please consider using Age Sex
Length data for Nuyakuk fish to identify how body sizes may be
different, and then inform how leaping and jumping capabilities may
need to be adjusted.
The available data sets on
leaping ability of fishes that we
are familiar with and have used
previously on studies, have been
based on body length and depth
and not on age or sex. We are
not aware of such data but if it
exists and a citation can be
provided we would be happy to
take that into consideration.
85
USFWS
(Jennifer
Spegon)
Section 4.1.2
Nuyakuk Falls Fish
Passage Study
The study indicates LiDAR acquisition occurred in May 2020, but
the highly turbulent water made mapping problematic in some areas.
We recommend acquiring LiDAR when flows are less than 3,000
cubic feet per second or in March when flows are the lowest.
Green LiDAR data was
collected in 2020 at
approximately 5,500 cfs. An
additional reduction of 2,500 cfs
would not alleviate the
persistent turbulence in the falls
that resulted in some mapping
issues. Per substantive dialogue
with the ARWG over a number
of months, the Cooperative has
agreed to collect a series of
high-quality aerial images
further document habitat
presence, location and
availability in the falls at a
variety of flows.
86
USFWS
(Jennifer
Spegon)
Section 4.1.5
Chinook and Sockeye
Salmon Life Cycle
Modeling
Please explain why other anadromous and resident species are
omitted from the Life Cycle Modeling studies. What is the rationale
for selecting Sockeye Salmon and Chinook Salmon, and what kind
of information for other species will be inferred from studying these
two species? Please consider including resident species for Life
Cycle Modeling.
The ARWG met routinely over
the of a year or so to collaborate
on development of appropriate
tools that would allow for
assessment of potential impacts
to fish populations in the
Nuyakuk River (see Table 1-1).
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-34 August 2022
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No. Agency PSP
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PSP Comment Cooperative’s Response
Due to the heightened concern
about potential population level
effects on commercial salmon
populations and the fishery, the
location of the Project with the
salmon migration corridor, and
the knowledge that some
existing data was available for
Chinook and Sockeye salmon, it
was determined that a
quantitative life cycle model
would be developed for these
two species. As described in the
RSP, we have also proposed a
qualitative model for Pacific
Salmon and several resident
species recommended by the
ARWG to assess potential
impacts to these fish
populations. In addition, to help
validate the qualitative modeling
approach, we will be evaluating
Chinook and Sockeye salmon
impacts using both methods and
will be conduct a comparison of
results.
87
USFWS
(Jennifer
Spegon)
Section 4.2 Water
Resources
We appreciate that the Nushagak Cooperative is proposing the
Future Flows, Water Quality Assessment, and Ice Processes
Assessment studies. We agree considering climate model predictions
and the subsequent impacts on future discharge and water
temperature will be key to maximizing effectiveness of project
design and proposed protection, mitigation, and enhancement (PME)
measures, especially if a daily downscaled product is available that
can provide localized projections for Nuyakuk. Similarly, we agree
We appreciate the comment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-35 August 2022
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PSP Comment Cooperative’s Response
considering ice processes will help inform project designs that can
address risk from these processes. Finally, we agree gathering
dissolved oxygen and temperature data from above and below the
falls is important for providing a baseline for natural conditions, and
it will help inform adaptive management considerations should
changes to baseline conditions occur during project operations.
88
USFWS
(Jennifer
Spegon)
Section 4.4.1
Subsistence Study
There appear to be related impacts on subsistence that are not
analyzed. The proposed Subsistence Study plan states that “analysis
will assess the timing and location of subsistence use and would be
necessary to develop PME measures with regard to the timing of
activities, particularly during project construction” (p. 123). In
addition, information gained in the Aquatics/Fisheries Resources,
Caribou Population Evaluation, and Subsistence studies will help
identify PME measures to minimize impacts to subsistence resource
abundance, and to the subsistence users themselves. However, the
Project Facilities section (p.16) mentions the construction of a
localized access road and new transmission lines which would
require construction and maintenance of right-of-ways. Please
provide analysis on how these and other project related actions may
impact competition for or access to subsistence resources.
Based on the limited footprint of
the primary Project
infrastructure (save the
transmission corridor), and the
limited right of way associated
with the proposed transmission
corridor we are confident that
the study we have
collaboratively developed and
the cooperation with ADFG in
carrying-out the survey are
appropriate for the feasibility
studies.
89
UTBB
(Alannah
Hurley)
General
At the outset, we want to reiterate the importance of meaningful
Tribal and public engagement throughout the licensing process and
the significant barriers to participation in the process so far. The
Nuyakuk River is a crucial river in the Bristol Bay Watershed,
significantly contributing to the region’s salmon runs and sustaining
many of our Tribal members’ subsistence way of life. Thus, it is
critical that Bristol Bay Tribes and community members have a
voice in this process. To date, opportunities to engage in the process
have been severely limited. For example, the Federal Energy
Regulatory Commission (FERC) decided to not require additional
study plan meetings, restricting opportunities for engagement on the
updated PSP. The previous virtual study plan meetings held in April
2020, at the outset of the COVID-19 pandemic, are not an adequate
We appreciate the comment and
agree with your frustration
regarding COVID-related issues
over the past 2 years limiting the
Cooperative’s ability to hold as
many site-specific in-person
meetings as they wanted to. The
Cooperative did endeavor to
hold virtual meetings to keep the
Tribal interests and the public as
a whole informed during this
period. Now that restrictions
have been lifted, the
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-36 August 2022
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No. Agency PSP
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PSP Comment Cooperative’s Response
substitute for public engagement on the updated PSP, particularly
given the long period of time that has passed and the changes to the
proposed studies.
Cooperative has quickly held in-
person meetings and is currently
planning meetings in the
outlying villages for later this
summer. That commitment is
not just a 2022 anomaly. As has
been communicated from the
outset, the Cooperative views
Tribal and public input as
mandatory to this process and
now that they are able, will
consistently present to and
solicit input from these groups.
90
UTBB
(Alannah
Hurley)
General
Accessible and understandable information is fundamental to
providing opportunities for engagement. As a first step to making
the PSP more accessible, the document should include an executive
summary and an appendix that defines the many technical terms and
acronyms used in the document.
A technical terms and
abbreviations list is provided at
the beginning of the document
immediately after the table of
comments. With respect to the
summary request, the format of
the document has been crafted in
such a way so that consistent
descriptions, goals and
objectives, geographic scopes,
intent, reporting, etc. are
provided for each.
91
UTBB
(Alannah
Hurley)
General
Additionally, FERC and the Cooperative should provide regular
updates to keep Tribes and community members informed at each
step of the licensing process and foster meaningful engagement. Any
updates should be communicated in a manner and method that is
accessible to Tribes and community members in the region. Because
of internet access inequities in rural Alaska, FERC’s website is not
be accessible to all, and the agency should reach out to Tribes
regarding their preferred method of communication. Limiting in-
As mentioned above, the
Cooperative is committed (via
various means) to providing
regular status updates
throughout the process to both
Dillingham residents and those
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-37 August 2022
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person meetings to Dillingham is not accessible for all Tribes and
community members, including the communities closest to the
proposed Project area.
Tribal and public members in
outlying villages.
92
UTBB
(Alannah
Hurley)
Section 4.1
Aquatic/Fisheries
Resources
The Nushagak District of Bristol Bay has been the most productive
river system in Bristol Bay in recent years. According to the Bristol
Bay Regional Seafood Development Association (BBRSDA),
harvests of sockeye salmon in the Nushagak District averaged 15.5
million fish per year over the past 5 years. In the last 20 years, the
Nuyakuk River has accounted for up to 24 percent of the Nushagak
River’s sockeye salmon run according to Bristol Bay Science and
Research Institute (BBSRI). Therefore, it is imperative that critical
anadromous and resident fish habitat at the proposed Project site
have more than a two-year study program to adequately characterize
the aquatic resources that will be impacted by decreasing the flow
through the Nuyakuk cascades due to the proposed Project. It is
important that the project determine the optimal instream flow
requirements for fish passage, rearing, and overwintering during all
four seasons of the year in the Revised Study Plan (RSP).
We appreciate the comment and
share the view regarding the
importance of the Nuyakuk
watershed. Our collaboratively
developed 2-year fisheries
feasibility study program is
designed to assess both current
conditions and the potential for
impacts (positive and negative)
to the aquatic environment as a
result of potential Project
construction and operations.
That said, it is fully understood
that if licensed and ultimately
constructed, a series of
monitoring/adaptive
management plans would be
developed that outline methods
for monitoring the aquatic
environment to confirm
conditions defined during the
feasibility study period are a
reality. Further, if after the 2-
year study program, it is
determined that certain discreet
aquatic topics require more
investigation, the Cooperative is
committed to discussing those
areas with the ARWG and the
public to determine if any
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
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No. Agency PSP
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additional specific study
elements need evaluation.
93
UTBB
(Alannah
Hurley)
Section 4.1
Aquatic/Fisheries
Resources
River flow conditions are critical to supporting fish migration and
other ecological functions. Pacific salmon and other fish species
migrate up the Nuyakuk cascades during flow conditions ranging
from 4,000 to 15,000 cfs between July and October. The
Cooperative proposes leaving a minimum of 1,000 cfs in the river
reach between the project intake and tailrace. This represents a direct
Project-related impact to the culturally and commercially important
fishery. No data exists to indicate the proposed bypass base flow
will provide safe, timely, and effective passage for returning adult
salmon. Therefore, characterizing the relationship between flow and
passage suitability in the bypassed reach is needed to establish
baseline conditions, determine which species can pass up the
cascade at which flows, and evaluate potential effects (e.g., delay,
stranding) of project operations on the migration of adult and
juvenile salmon in the proposed bypass reach. Baseline conditions
need to include year-round studies to evaluate winter and spring
foraging, juvenile rearing, and spawning habitat. Climate change has
impacted Bristol Bay by increasing air temperature by 3.7o F and an
increase of 13 percent in annual precipitation from 1969 to 2010.1
Therefore, it is important that this project evaluates future flows
because temperature, precipitation, and stream flows will increase in
Bristol Bay due to climate change.
1Thoman, R., J.E. Walsh. 2019. Alaska’s changing environment:
documenting Alaska’s physical and biological changes through
observations. 16.
Any specific reference to 1,000
cfs in the RSP is hypothetical at
this point and intended to
provide a reference point for
figures presented in the
document. A fundamental
component of the the feasibility
studies are intended to define
flow conditions that allow for
safe, timely and effective
passage (upstream and
downstream) through the falls
for species present throughout
the year. It is fully anticipated
that, if the project is deemed
feasible, the Cooperative will
work with the ARWG, Tribal
interests, the public and FERC
to establish an acceptable
instream flow regime with
varying amounts of seasonal that
allows for consistent safe, timely
and effective fish passage for the
species present.
94
UTBB
(Alannah
Hurley)
Section 4.1
Aquatic/Fisheries
Resources
According to the National Oceanic and Atmospheric
Administration’s National Marine Fisheries Service, the Nuyakuk
River has an average return of 370,000 sockeye salmon in addition
to four other returning salmon species. The Nuyakuk River counting
tower data on sockeye salmon from 1959-1999 varied from 20,250
See response to Comment #92.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-39 August 2022
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in 1967 to over 3 million sockeye salmon in 1980.2 In 2006, the
Alaska Department of Fish and Game (ADF&G) reported a
cumulative sockeye salmon count of 170,760.3 Therefore, the
proposed two-year field program is inadequate given the large
annual variability related to sockeye salmon escapement numbers in
the Nuyakuk River.
2 ADF&G Regional Information Report No. 2A00-08. Counting
tower projects in Bristol Bay Area, 1955-1999 by Cindy J.
Anderson. September 2000.
3 ADF&G Fish Count Data Search for the Nuyakuk River, 2003-
2006,
https://adfg.alaska.gov/sf/FishCounts/index.cfm?ADFG=main.home.
95
UTBB
(Alannah
Hurley)
Section 4.1
Aquatic/Fisheries
Resources
The proposed economic decision support tool and integrated risk
assessment need to include a comprehensive analysis of the potential
costs and risks. The cost-benefit analysis should include an analysis
of not only hydropower but wind and solar power as potential
alternatives to replace the diesel-generated power in Bristol Bay.
To date the Cooperative has
studied wind in our area with
MET towers erected to quantify
wind resource quality. We
scored a 3 on a scale of 1-7 for
wind resource quality. We have
also looked at two other hydro
sites within the Wood-Tikchik
State Park in Grant and Elva
Lakes, both were cost
prohibitive due in large part to
amount of power they could
produce. Though we have not
investigated solar extensively, it
does appear to be making
advances. In reality, neither
wind nor solar could be
implemented sufficiently to
provide our area with a base
load product that would reliably
displace diesel. The Nuyakuk
River Project could provide that
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-40 August 2022
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PSP Comment Cooperative’s Response
base load criteria and would also
open up vast expanses of
territory for wind and solar
possibilities that could
supplement a hydro source. It is
that base load, and the ability to
shut down diesel generators that
is critical in making a project
feasible for us in DIllingham or
anywhere else in rural Alaska,
for that matter.
96
UTBB
(Alannah
Hurley)
Section 4.1
Aquatic/Fisheries
Resources
The amount of water that will be diverted by the project and the
potential impacts of change in the flow over the cascades on salmon
outmigration and in-migration and resident fish habitat are critical
concerns that must be comprehensively addressed in the proposed
studies. Under Alaska law, the development and operation of a
hydroelectric site at the Nuyakuk River Falls is only permissible if
the operation and development “maintains at least 70 percent of the
daily upstream water flow of an affected river along the natural
course of the river.” A critical question is if the project changes the
flow by 30 percent what will the impacts be? Will this change in
flow impact outmigration and increase potential entrainment of the
juvenile salmon and impact the ability of the adult salmon making it
up the cascades to reach their spawning grounds? The proposed
studies need to determine how the intake, groin, and tailrace
structures will alter fish habitat characteristics and change the water
depth, velocity, and habitat composition.
4 Alaska Stat. Ann. § 41.21.167(e).
We agree with this comment and
have collaboratively designed
the study program to address
these topics.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-41 August 2022
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No. Agency PSP
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PSP Comment Cooperative’s Response
97
UTBB
(Alannah
Hurley)
Section 4.1
Aquatic/Fisheries
Resources
Concerns about the proposed project infrastructure include how the
groin and intake structures and Kaplan turbines will impact the
smolt outmigration on the Nuyakuk River. Smolt migrate through
the cascades not only in springtime but throughout the summer
months. Therefore, smolt migration studies need to be conducted not
just once a year but from May through July. These studies need to
determine the smolt distribution in the horizontal and vertical water
column to better design the intake and groin structures and reduce
the entrainment and impingement impacts to smolt. More
information is needed about ice buildup on the concrete groin and
intake structures, and whether a concrete groin structure is
appropriate in a river where water will overtop the groin during high
flow conditions.
With specific respect to the
groin and as was communicated
during the recent ARWG
meeting and site visit, if a groin
is determined to be necessary it
would be in the form of a series
of boulders that would not be
visible at higher river flows.
Further, use of boulders would
create a porous environment
where downstream passage by
out-migrating juvenile
salmonids could easily be
facilitated through the natural
channel. Additional text has
been added to the conceptual
design description of the RSP to
further define what the groin
would and wouldn’t be.
98
UTBB
(Alannah
Hurley)
4.4.1 Subsistence
Study
The PSP provides limited information about the proposed
subsistence study, hindering meaningful comment. The limited
amount of information provided is especially concerning given the
critical importance of the Nuyakuk River to many of our Tribal
members’ subsistence way of life.
The RSP has been substantively
revised with additional
methodology related to the
subsistence study. Given our
collaboration with ADFG on
this study, we are using their
endorsed and previously used
methods for this assessment.
99
UTBB
(Alannah
Hurley)
4.4.1 Subsistence
Study
The limited information available regarding the geographic scope of
the study suggests that the scope is too narrow to adequately analyze
potential impacts to subsistence uses and resources. The anticipated
scope will focus on subsistence use in the proposed Project area.
This approach emphasizes the place where subsistence occurs
instead of the fish and wildlife that communities harvest. This
The RSP has been substantively
revised with additional
methodology related to the
subsistence study. Given our
collaboration with ADFG on
this study, we are using their
Nuyakuk River Hydroelectric Project
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approach may be appropriate where communities’ use areas overlap
with the project area or for non-migratory species. However, it is not
a suitable approach for communities whose use areas do not overlap
with the project area and rely on migratory species, like salmon.
Though communities throughout Bristol Bay harvest salmon that
migrate through the proposed Project area, only some of those
communities engage in subsistence activities within the Project area.
Thus, any adverse impacts to salmon and other migratory species
will result in adverse impacts to subsistence far beyond what the
current scope would encompass. The proposed subsistence study
must be expanded beyond the current place-based approach to
include analysis of migratory species that migrate through the
proposed Project area but are harvested outside the Project area.
Unless the scope is expanded, the study will significantly
underestimate potential impacts to subsistence.
endorsed and previously used
methods for this assessment.
100
UTBB
(Alannah
Hurley)
4.4.1 Subsistence
Study
Furthermore, the Cooperative’s proposal to rely exclusively on the
ADF&G’s community subsistence surveys will not provide the
information need to adequately analyze potential impacts to
subsistence uses. Harvest surveys are unable to account for the
inherent variability in subsistence systems and many rural residents
do not participate in ADF&G surveys, so the data collected may not
accurately reflect actual harvests. The subsistence study should
include additional methods beyond household harvest surveys to
accurately reflect subsistence uses. Tribes must be involved in
developing and conducting these subsistence studies. The proposed
subsistence study should also be broadened to include cultural
values, spirituality, and social sharing networks. The household
surveys proposed in the subsistence study are designed to gather
information on the amount of resources harvested and are not suited
to provide information regarding the full range of potential impacts
on subsistence.
If Tribal entities are interested in
assisting with the subsistence
surveys, the Cooperative would
wholly appreciate, support and
coordinate that approach.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-43 August 2022
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101
UTBB
(Alannah
Hurley)
Section 4.4.2 Section
106 Evaluation
The stated goal of the proposed study is to comply with the National
Historic Preservation Act (NHPA) Section 106 process. To satisfy
this goal, the proposed study must be revised to clarify the
respective roles of FERC and the Cooperative, address the
archaeological bias in the proposed study, and expand the study’s
scope beyond discrete historic sites to include broader intangible
cultural resources, such as Traditional Cultural Properties and
cultural landscapes.
We appreciate the comment and
as described in the RSP, look
forward to further dialogue with
UTBB and other interests during
the definition of the Area of
Potential Effect (APE).
102
UTBB
(Alannah
Hurley)
Section 4.4.2 Section
106 Evaluation
The proposed Section 106 evaluation should be revised to clearly
define FERC’s roles and obligations under the NHPA. In carrying
out its responsibilities under Section 106, FERC must “consult with
any Indian tribe or Native Hawaiian organization that attaches
religious and cultural significance” to historic properties that may be
affected by the Project.5 The Advisory Council on Historic
Preservation’s regulations implementing the Section 106 process
also provide that consultation “should be conducted in a sensitive
manner respectful of tribal sovereignty” and must “recognize the
government-to-government relationship between the Federal
Government and Indian tribes.”6 Though FERC may authorize the
Cooperative to initiate Section 106 consultation, FERC remains
legally responsible for all required findings and determinations and
“for [its] government-to-government relationships with Indian
tribes.”7
5 54 U.S.C. § 302706(b).
6 36 C.F.R. § 800.2(c)(2)(ii)(B)–(C).
7 36 C.F.R. § 800.2(c)(4).
UTBB appreciates the definition
of FERC’s role and obligations
with respect to the Section 106
process and the references
provided. The Cooperative
endeavored, via the RSP, to
define it’s commitments and
responsibilities associated with
Section 106 and implementation
of the study program. If further
commitment or dialogue is
deemed necessary with FERC,
the Cooperative would be happy
to provide you with the
appropriate cultural contact at
the Commission. This
individual will play an integral
role throughout the Section 106
evaluation/reporting/HPMP
development process.
103
UTBB
(Alannah
Hurley)
Section 4.4.2 Section
106 Evaluation
Under the proposed study methodology, the Cooperative’s
subcontractor is responsible for “consulting with Tribal groups.”8
The proposed methodology must be revised to make clear that
FERC remains responsible for its government-to-government
relationship with Tribal governments and the Cooperative’s
Per the Section 106 mandates
defined in your previous
comment it is explicit and
mandated that FERC’s role is
Nuyakuk River Hydroelectric Project
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subcontractor cannot assume consultation responsibilities without a
Tribal government’s consent. Additionally, the methodology of the
proposed study reflects an applicant-driven process. Though it is
appropriate for the Cooperative and its subcontractor to assist in
information gathering and analysis, the proposed study should be
revised to make clear that the ultimate responsibility for making
findings and determinations remains with FERC and FERC is
responsible for ensuring any information and analysis prepared by
the Cooperative and its subcontractor meet applicable standards and
guidelines.
8 Proposed Study Plan at 126.
consistently applied in all
studies such as this.
104
UTBB
(Alannah
Hurley)
Section 4.4.2 Section
106 Evaluation
The proposed Section 106 evaluation demonstrates a clear
archaeological bias that must be remedied to ensure the proposed
study includes the full scope of historic properties under the NHPA.
The NHPA defines “historic property” as “any prehistoric or historic
district, site, building, structure, or object included on, or eligible for
inclusion on, the National Register”9 and includes, “[p]roperty of
traditional religious and cultural importance to an Indian tribe or
Native Hawaiian organization.”10 As proposed, the Section 106
Evaluation relies on archaeological field surveys and existing
information from the Alaska Historic Resources Survey (AHRS).
The proposed surveys are designed to gather information about
discrete archaeological sites and do not provide the information
needed to adequately identify and evaluate impacts to historic
properties of traditional religious and cultural importance to Tribes.
The proposed study must be revised to include other methodologies,
including ethnographic studies.
9 54 U.S.C. § 300308.
10 54 U.S.C. § 302706(a); 36 C.F.R. § 800.16(l)(1).
Additional text has been added
to further clarify the planned
methods, schedule and intent of
the study.
Nuyakuk River Hydroelectric Project
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105
UTBB
(Alannah
Hurley)
Section 4.4.2 Section
106 Evaluation
Cultural monitors approved by the respective Tribal government
should also be a part of any surveys to minimize effects to cultural
resources. Cultural monitors will be able to assist work crews in
identifying inadvertent discoveries of cultural resources and
reducing impacts to other traditional resources (e.g., water, fish,
caribou, moose, berries) and customary practices (e.g., fishing,
hunting, berry picking, sharing knowledge on the land).
The Cooperative would
welcome any support respective
Tribes are willing to provide.
106
UTBB
(Alannah
Hurley)
Section 4.4.2 Section
106 Evaluation
The Section 106 evaluation’s reliance on existing information from
the AHRS raises significant concerns given the shortcomings of this
data. The AHRS substantially underreports the number of cultural
resources within the area surrounding the proposed Project and
demonstrates a significant bias in favor of archeological resources.
There are also cultural resources Tribes do not want disclosed in the
AHRS for confidentiality reasons. Thus, the proposed study’s
reliance on the AHRS would substantially underestimate intangible
cultural resources, like Traditional Cultural Properties and cultural
landscapes. The proposed study should be revised to expand the
scope of existing information and where additional information is
needed, must include ethnographic studies along with the proposed
archaeological surveys.
Additional text has been added
to further clarify the planned
methods, schedule and intent of
the study.
107
UTBB
(Molly
Welker)
Section 4.1
Aquatic/Fisheries
Resources
The Nushagak District of Bristol Bay has been the most productive
river in Bristol Bay in recent years. According to the Bristol Bay
Regional Seafood Development Association (BBRSDA), harvests of
sockeye salmon in the Nushagak District averaged 15.5 million fish
per year over the past 5 years. In the last 20 years, the Nuyakuk
River has accounted for up to 24% of the Nushagak River’s sockeye
salmon run according to Bristol Bay Science and Research Institute
(BBSRI). Therefore, it is imperative that critical anadromous and
resident fish habitat at the project site have more than a 2-year field
program to adequately characterize the aquatic resources that will be
impacted by decreasing the flow through the Nuyakuk cascades due
to the Nuyakuk River Hydroelectric Project. It is important that the
project determine the optimal instream flow requirements for fish
See response to Comment No.
92.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-46 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
passage, rearing, and overwintering during all four seasons of the
year in the Revised Study Plan (RSP).
108
UTBB
(Molly
Welker)
Section 4.1
Aquatic/Fisheries
Resources
River flow conditions are critical to supporting fish migration and
other ecological functions. Pacific salmon and other fish species
migrate up the Nuyakuk cascades during flow conditions ranging
from 4,000 to over 15,000 cfs between July and October. The
Cooperative proposes leaving a minimum of 1,000 cfs in the river
reach between the project intake and tailrace. This represents a direct
project related impact to the culturally and commercially important
fishery. No data exists to indicate the proposed bypass base flow
will provide safe, timely, and effective passage for returning adult
salmon. Therefore, characterizing the relationship between flow and
passage suitability in the bypassed reach is needed to establish
baseline conditions, determine which species can pass up the
cascade at which flows, and evaluate potential effects (e.g., delay,
stranding) of project operations on the migration of adult and
juvenile salmon in the proposed bypass reach. Baseline conditions
need to include year-round studies to evaluate winter and spring
foraging, juvenile rearing, and spawning habitat. According to
Thoman (2019) climate change has impacted Bristol Bay by
increasing air temperature by 3.7oF and an increase of 13% in annual
precipitation from 1969 to 2010. Therefore, it is important that this
project evaluates future flows because temperature, precipitation,
and stream flows will increase in Bristol Bay due to climate change.
Thoman, R., J.E. Walsh. 2019. Alaska’s changing environment:
documenting Alaska’s physical and biological changes through
observations. 16 pp. Available at: Alaska’s- Changing-
Environment_2019_WEB.pdf.
See response to Comment No.
93.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-47 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
109
UTBB
(Molly
Welker)
Section 4.1
Aquatic/Fisheries
Resources
According to NOAA’s National Marine Fisheries Service the
Nuyakuk River has an average return of 370,000 sockeye salmon in
addition to four other returning salmon species. The Nuyakuk River
counting tower data on sockeye salmon from 1959-1999 varied from
20,250 in 1967 to over 3 million sockeye salmon in 1980 (ADF&G
Regional Information Report No.2A00-08). In 2006, ADF&G
reported a cumulative sockeye salmon count of 170,760 (ADF&G
2022). Therefore, the proposed two-year field program is
inadequate given the large annual variability related to sockeye
salmon escapement numbers in the Nuyakuk River.
ADF&G Regional Information Report No. 2A00-08. Counting tower
projects in Bristol Bay Area, 1955-1999 by Cindy J. Anderson.
September 2000.
ADF&G Fish Count Data Search for the Nuyakuk River, 2003-2006.
Online at:
https://adfg.alaska.gov/sf/FishCounts/index.cfm?ADFG=main.home
Accessed June 2022.
See response to Comment No.
94.
110
UTBB
(Molly
Welker)
Section 4.1
Aquatic/Fisheries
Resources
We understand the importance of the Cooperative trying to reduce
the high cost of power generation in the Bristol Bay region.
Therefore, the proposed economic decision support tool and
integrated risk assessment need to include a comprehensive analysis
of the potential costs and risks. The cost-benefit analysis should
include an analysis of not only hydropower but wind and solar
power as potential alternatives to replace the diesel-generated power
in Bristol Bay. More economic information needs to be provided to
the stakeholders so that they can make the decision if cheaper power
is worth the risk of the project impacting fish.
See response to Comment No.
95.
111
UTBB
(Molly
Welker)
Section 4.1
Aquatic/Fisheries
Resources
Traditional ecological knowledge, the cultural value of the fishery,
and subsistence studies need to be included in the RSP to improve
our understanding of how historically anadromous fish and resident
fish use the cascade area and to understand their value and
importance to the local communities. We need to know what fish
We agree with this comment and
feel the collaboratively
developed aquatic study
program will assess these topics
and provide a mechanism for
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-48 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
habitat occur in the Nuyakuk cascade because the gradient averages
only 1% and probably contains some fish habitat of value for both
anadromous fish and resident fish. The studies proposed in the RSP
need to determine if the project will cause unacceptable harm to the
fish. The studies need to be reproduceable and repeatable so that
they can be continued before and after operation of the hydroelectric
project.
future monitoring if the Project
is deemed feasible.
112
UTBB
(Molly
Welker)
Section 4.1
Aquatic/Fisheries
Resources
How much water will be diverted by the project is a concern and
whether a change in the flow over the cascades could impact salmon
outmigration and in-migration and resident fish habitat. A critical
question is if the project changes the flow by 30% what will the
impacts be? Will this change in flow impact outmigration and
increase potential entrainment of the juvenile salmon and impact the
ability of the adult salmon making it up the cascades to reach their
spawning grounds? The proposed studies need to determine how the
intake, groin, and tailrace structures will alter fish habitat
characteristics and change the water depth, velocity, and habitat
composition.
See response to Comment No.
96.
113
UTBB
(Molly
Welker)
Section 4.1
Aquatic/Fisheries
Resources
Concerns about the proposed project infrastructure include how the
groin and intake structures and Kaplan turbines will impact the
smolt outmigration on the Nuyakuk River. Smolt migrate through
the cascades not only in springtime but throughout the summer
months. Therefore, smolt migration studies need to be evaluated not
just once a year but from May through July. These studies need to
determine the smolt distribution in the horizontal and vertical water
column to better design the intake and groin structures and reduce
the entrainment and impingement impacts to smolt. More
information is needed about ice buildup on the concrete groin and
intake structures, and whether a concrete groin structure is even a
good idea in a river when during high flow conditions water will
overtop the groin.
See response to Comment No.
97.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-49 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
114
UTBB
(Molly
Welker)
Section 4.1
Aquatic/Fisheries
Resources
The PSP is a comprehensive document that should include an
executive summary and an appendix that defines the many technical
terms and acronyms used in the document. This will allow an
overview and summary of the document so that stakeholders do not
have to read the entire document to understand the purpose of the
project and all the aquatic resources studies being proposed.
See response to Comment No.
90.
115
UTBB
(Molly
Welker)
Section 4.1
Aquatic/Fisheries
Resources
More tribal engagement is needed through an increase in outreach
and education efforts about the project to the up-river villages. This
is a vital step so that all stakeholders can provide feedback on the
project.
See response to Comment No.
91.
116
SHPO
(Judith
Bittner)
Section 4.4.2 Section
106 Evaluation
Scope of field activities: Much of the project is located on state
lands and as such any cultural resource investigation will need to
receive a State Cultural Resources Investigation Permit.
Identification level surveys on state lands are expected to conduct
sub-surface testing (50 by 50 cm squares) in high probability
locations. Cultural resources survey will need to occur in all of the
area of potential effect, including the transmission line routes.
We appreciate the comment and
look forward to upcoming
consultation related to the APE.
117
SHPO
(Judith
Bittner)
Section 4.4.2 Section
106 Evaluation
It is unclear how the study plan proposed to be drafted in Winter
2023 relates to this study plan. The March 2022 plan lacks detail
about the methods being proposed to complete cultural resources
inventory. It does not address how potential Traditional Cultural
Places will be investigated, what criteria will be used to define high
probability and how lower probability areas will be addressed, and
what consultation will occur to fully develop a detailed study plan.
Additional text has been added
to this section to further expand
the methods to be utilized to
address consultation, potential
Traditional Cultural Places, and
probability areas.
118
SHPO
(Judith
Bittner)
Section 4.4.2 Section
106 Evaluation
Ensure the correct references are made for regulations and statutes,
such as 54 USC 306 I 08 and 48 FR 44738-44739. We appreciate the comment.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-50 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
119
SHPO
(Judith
Bittner)
Section 4.4.2 Section
106 Evaluation
Recommend including possible drafting of a Section 106 agreement
document (a Memorandum of Agreement or a Programmatic
Agreement) into the timeline.
Additional text has been added
to the timeline to address the
possible need for a
Memorandum of Agreement or
a Programmatic Agreement.
120
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1
Aquatics/Fisheries
Resources
First we do not feel all our comments were properly addressed in our
formal letter from Feb 3, 2020 :Filing Description for Accession
Number 20200204-5118 in the elibrary:
We specifically asked that Coho and Pink salmon be included in the
proposed study plan. This was not addressed. We do not understand
why they are not included in the study plan as they are the second
and third largest salmon spawning species above the falls. The Pink
fry would seem to be very susceptible to hydro issues.
Five of the six fish studies are
being designed to evaluate fish
use of the falls and potential
impacts to ten target fish species
listed in Table 4-6, including
Coho and Sockeye salmon.
Fish sampling methods will
provide information on these
species in the project area. The
fish passage analysis evaluate
potential impacts these species
with respect to their ability to
move over the falls. The fish
entrainment and false attraction
studies will also consider
multiple species.
One of the six fish studies, the
life cycle model study, will take
a more detailed look at
population level effects on
Sockeye and Chinook salmon.
As described in Comment 86,
this decision was made in
collaboration with the ARWG to
complete a life cycle for these
species because existing
information is available to build
a life cycle model, as well as the
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-51 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
commercial significance of these
species to the region.
As described under the
Integrated Risk Assessment
Study, we have proposed a
qualitative model for Pacific
Salmon and several resident
species recommended by the
ARWG to assess potential
impacts to 10 target fish
populations. In addition, to help
validate the qualitative modeling
approach, we will be evaluating
Chinook and Sockeye salmon
impacts using both approaches
and will be conduct a
comparison of results. This will
help provide additional
confidence as to the outputs of
the qualitative model.
121
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1
Aquatics/Fisheries
Resources
We mentioned that a 2 year study would not gather enough
information when you consider all the variables. For example this
would only include 1 pink salmon life cycle. High water, low water,
warm years, cold years, large winters, cold winters, big salmon runs,
small salmon runs, etc... As a scientist I feel you cannot gather
enough information in just 2 years to safely predict this projects
impact on the salmon runs. We request more years of study for all
the salmon related studies.
We appreciate the level of
collaboration and technical
dialogue that has gone into the
development of this aquatic
studies program and feel
confident that its
implementation will define
whether or not the Project is
feasible for development.
122 Royal
Coachman
(Pat
Section 2.4.1
Proposed Project
Operations and
We continue to be confused by the law that states "that a compatible
use by a hydroelectric development at the Nuyakuk River Falls
maintains at least 70% of the daily flow in the river." This plan
Any specific reference to 1,000
cfs in the RSP is hypothetical at
this point and intended to
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-52 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
Vermillion,
Scott
Schumacher)
Section 4.1.4
Assessment of False
Attraction at the
Tailrace Fish Barrier
states that " a minimum instream flow of 1,000 cfs has been
assumed to pass downstream." As a result the Coop power
projections are based on currently illegal flows. This plan clearly
calls for more than " the 70% of the daily flow in the river'' How can
we be considering a project that, according to my understanding of
the law, is not allowed? As a result I feel the energy production and
thus viability of this project is in question. The viability and legality
of this project should be studied.
provide a reference point for
figures presented in the
document. A fundamental
component of the feasibility
studies is the objective t to
define flow conditions that
allow for safe, timely and
effective passage (upstream and
downstream) through the falls
for species present throughout
the year. It is fully anticipated
that, if the project is deemed
feasible, the Cooperative will
work with the ARWG, Tribal
interests, the public and FERC
to establish an acceptable
instream flow regime with
varying amounts of seasonal that
allows for consistent safe, timely
and effective fish passage for the
species present.
123
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
The request by ADNR to study pink salmon. The COOP 's response
is that study section 4.1.1 address this, but in the study 4.1.1 the
document states that" current migratory behavior of targeted species,
specifically Sockeye and Chinook salmon." 4.1.1does not address
ADNR's proposed study on pink salmon.
The Fish Community study
includes a literature review task.
Any available information on
fish in the Nuyakuk River will
be reviewed and incorporated
into the characterization of the
fish community and fish
behavior. We also will make
use of various methods
including sonar, fish trapping,
under water video and remote
aerial assessment to characterize
the fish use of habitat in and
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-53 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
around the falls and will include
Pink Salmon if they are present.
In addition, through the use of
the 2D model we will be
evaluating the flow, depth and
velocity conditions and how
they potentially will affect all
target fish species that pass the
falls as described in the PSP
Section 4.1.2, Fish Passage
Study.
Consistent with developing life
cycle models for Chinook and
Sockeye salmon, the migratory
behavior of these adults will be
studied in greater than other
salmon. However, the
information gained from these
biotelemetry efforts, along with
existing information on Pink
Salmon swimming and
migratory behavior will be used
to inform the qualitative
assessment for Pink Salmon that
is described in the Integrated
Risk Assessment study.
124
Royal
Coachman
(Pat
Vermillion,
The request by ADNR to "assess the effect of the predation of fish
by birds in the bypass reach" was denied. The water falls are a
significant food source for birds and resident fish. Reducing this
rapid by +80% will have an impact, and should be studied.
In Section 4.1.2.3 of the PSP,
the Fish Passage Study has
several objectives related to fish
stranding and trapping, density
dependent affects, and changes
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-54 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
Scott
Schumacher)
in habitat that would potentially
affect predation. This
information will be incorporated
in the Life Cycle Model and
Integrated Risk Assessment
studies to support integrated
assessment of impacts to the
Nuyakuk aquatic system.
It is important to note that the
aquatic studies defined in the
RSP will ultimately define
levels of seasonal withdrawal
that are acceptable and allow for
continued safe, timely and
effective passage of fish species
present in the area. The habitat
conditions suitable for
successful fish passage will be
evaluated with the 2 D hydraulic
model. No withdrawal numbers
are established at this point and
the model will be able for
evaluate how flow condition
through the falls would change
with any level of withdrawal and
we can evaluate how that would
affect predation risk.
125
Royal
Coachman
(Pat
Vermillion,
The requests for studies on the impact for recreation, sport fishing,
and commercial fishing are inadequately addressed in this plan.
We feel confident that the
combination of the
collaboratively developed on the
ground field studies,ife cycleand
economic modeling, and the
integrated risk assessment will
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-55 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
Scott
Schumacher)
provide sufficient information
on population of target fish
species to address concerns for
recreational, sport and
commercial fisheries.
126
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.5
Chinook and Sockeye
Salmon Life Cycle
Modeling
Again this section focuses on "sockeye and chinook salmon life
cycle model" and misses Pink, Silvers, and even the few Chums that
run this rapid. Let alone the grayling, and trout, that are known to
migrate this rapid for spawning and feeding reasons. Northern Pike,
whitefish, and lake trout have also been caught in and around this
rapid. All of these fish should be included in this study.
As described in comment 120,
the ARWG decided to pursue
life cycle models for the two
species for which sufficient
existing Nuyakuk data is
available to initiate model
development in 2022. Because
insufficient data were available
for quantitative analysis for all
target species, the Integrated
Risk Assessment Study includes
a qualitative evaluation of the
potential risks to these
populations.
127
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
We appreciate the historical nature of studying the Nuyakuk salmon
runs, but also feel it is paramount to get a new understanding of the
record Sockeye runs in the last few years. It is clear to us that
conditions have changed in the Nuyakuk drainage as we are seeing
Sockeye runs that are many times larger than when they had the
Nuyakuk fish counting station active. We worry that the historical
information does not adequately address the current runs.
Per the RSP, we will be
collecting robust data on
sockeye (adults and juveniles) in
2023 and 2024. In addition, the
life cycle model will be able to
identify sensitivities for the
Sockeye Salmon population that
will be applicable given the high
variation in run size for this
population.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-56 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
128
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
The Juv Rearing row under Sockeye salmon is not accurate. The
Sockeye rear year round on the Nuyakuk
Thank you for this information.
We will modify the periodicity
of Sockeye Salmon juvenile
rearing to reflect the presence of
river rearing Sockeye juveniles.
129
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
Adult migration is not included on the resident fish. There is a clear
Dolly Varden, Rainbow Trout, and Arctic Grayling migration on this
river and the Nuyakuk falls.
As described in the PSP the 2 D
model will provide information
as to flow concentrations,
changes in flow paths, depths
and velocities. This information
will be used to evaluate potential
risk to juveniles and resident
fishes moving through the falls
at reduced flows. The model
will support development of
operational flows that would
support safe, timely and
effective passage for all fish
species that migrate upstream
and downstream of the falls.
In addition, the fish sampling
will help us understand the use
of falls habitat by resident
fishes. Further, during the June
2022 ARWG meeting, it was
determined that additional focus
on Arctic Grayling seasonal use
of habitat at the fall will be
incorporated into the RSP.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-57 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
130
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
We know that much of the smolt migration occurs mid river, and
feel that this study needs to find a way to safely survey the middle of
the stream corridor or it will miss a major portion of the downstream
migration.
A sonar array will be tested in
August 2022 to help us
understand the horizontal and
vertical distribution of out
migrants as they move
downstream over the falls. If
there is available existing data
regarding fish distribution
and/or timing we would like to
incorporate that into our fish
community study and would ask
you to share it with the ARWG.
It will be helpful in ensuring our
study design is a rigorous as
possible.
131
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
We oppose any form of Gilt/trammel netting in around the falls.
There are large and old resident fish in this area. The rare nature of
these fish, and their importance in spawning, should not be risked by
gill netting. A visual survey will be all you need to show proof of
their existence in the falls region.
Any netting conducted in the
Project Area will be conducted
so as to minimize the risk of
mortality to fish from handling.
This includes use of
gill/trammel nets and seines in
areas upstream or downstream
of the falls. If any unexpected
mortality is encountered, we
would discontinue the use of
that capture method
immediately.
132
Royal
Coachman
(Pat
Vermillion,
Section 4.1.1
Characterization of
the Fish Community
and Behavior Near
the Project Area
The piscavores are ever present in this area. A dramatic reduction in
flows through the rapids, will have an impact and should be studied.
Agreed. The PSP does, and the
RSP will also, include
evaluating the effect of flow
reductions on habitat including
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-58 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
Scott
Schumacher)
those used by resident fishes for
feeding.
133
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.3 Fish
Entrainment and
Impingement Study
There is a creek roughly 1.6 miles upstream from this project site. It
is a spawning stream for salmon. The water between the project site
and the creek is very smooth. To the point that if you fly over this
section on a quiet sunny day, you can see the tannic water from this
creek hugging the south bank all the way to the falls. This creek
water will be on the side of the intake, and as a result going through
the intake. It should be studied in the entrainment study, if you have
100% of the creek water going through the turbines, I would assume
the fish that go up the creek will sit below it and not go through the
falls as they will not "smell" the creek.
Thank you for the information.
The potential for false attraction
is being studied and we will
incorporation this information
into that analysis.
134
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.3 Fish
Entrainment and
Impingement Study
We feel that pink salmon fry need to be considered in the
impingement study. We also feel that the grayling and other resident
fish downstream migration should also be considered.
The proposed Entrainment and
Impingement Study will be
address impingement and
entrainment based on size
categories of fish and will be
applicable to all target species,
including pink salmon and
Arctic Grayling.
135
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.3 Fish
Entrainment and
Impingement Study
In the mortality portion of the study we feel you are missing a large
area to consider. If you are drastically decreasing the cfs in the rapid,
and all smolt and fry will be forced to migrate down this section.
This will create a large migration of small fish, with low cfs, through
a piscivore concentrated area. This needs to be studied as those
smolt and fry depend on a high volume of water to get through the
gauntlet of Piscavores (whether avian or aquatic).
As described in the Fish Passage
Study of the PSP, the 2 D model
will provide information as to
flow concentrations, changes in
flow paths, depths and
velocities. This information will
be used to evaluate potential risk
to juveniles and resident fishes
moving through the falls at
reduced flows.
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-59 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
As mentioned in previous
comment responses, a
fundamental component of the
the feasibility studies is the
intent to define flow conditions
that allow for safe, timely and
effective passage (upstream and
downstream) through the falls
for species present throughout
the year. It is fully anticipated
that, if the project is deemed
feasible, the Cooperative will
work with the ARWG, Tribal
interests, the public and FERC
to establish an acceptable
instream flow regime with
varying amounts of seasonal that
allows for consistent safe, timely
and effective fish passage for the
species present, with predation
being taken into consideration.
136
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.1.5
Chinook and Sockeye
Salmon Life Cycle
Modeling
This should obviously include pink, and silver salmon as they are
both the 2nd and 3rd most abundant salmon species above the falls.
Resident fish life cycles should also be studied.
As described in Comment 120,
the ARWG agreed to develop
life cycle models for the two
species for which sufficient
existing Nuyakuk data is
available for this modeling
effort in 2022. Because
insufficient data were available
for quantitative analysis for all
target species, the Integrated
Risk Assessment Study includes
a qualitative evaluation of the
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-60 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
potential risks to these
populations.
137
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
Section 4.5.2
Recreation Inventory
by Season
We are worried that this project will have a significant negative
affect to the Royal Coachman Lodge and Tikchik Narrows Lodge.
Both of these lodges rely heavily on this location. It is one of our
client's favorites for both its fishing, and beauty. I do not think a
study can put a value on the uniqueness of this location. There is a
reason the State Park boundary goes around this location to protect
it. At a minimum we should attempt to put an economic value on
this beautiful site.
We appreciate the comment.
138
Royal
Coachman
(Pat
Vermillion,
Scott
Schumacher)
General
As you can imagine we feel that if this project is not studied
correctly it could have a detrimental effect on some of the last
healthy salmon runs left in the world. This plan states that the Coop
care deeply about the salmon runs on this river, and they feel
confident that their studies are adequate. I would like to see them
state that studies will continue after this project is started, and if they
find that this project is having a negative impact on the salmon runs
they will shut it down immediately.
The 2023 and 2024 studies are
wholly intended to determine if
the Project is feasible for
development. The Cooperative
is not committing to anything
further than that at this point and
will rely on the collaboratively
developed technical studies and
associated results to determine if
Project development and
operations are justified. As has
been mentioned multiple times
in outreach efforts and as is
standard for all projects licensed
and constructed through this
process, it is fully understood
that if licensed and ultimately
constructed, a series of
monitoring/adaptive
management plans would be
developed that outline methods
for monitoring the aquatic
environment to confirm
Nuyakuk River Hydroelectric Project
FERC No. 14873 PSP (Filed with FERC 03-02-2022) Comment Responses
Nushagak Cooperative, Inc. G-61 August 2022
Comment
No. Agency PSP
Section
PSP Comment Cooperative’s Response
conditions defined during the
feasibility study period are a
reality. These monitoring
efforts would take place over
multiple years and if
unanticipated impacts are
resulting from Project
operations, the adaptive
management process will be
implemented whereby
operations may be modified to
address any negative impacts on
the environment resulting from
Project impacts.