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HomeMy WebLinkAbout2.5 Planning-level Scope of Work for Environmental Services for the West Creek Hydropower ProjectPlanning-level Scope of Work for Environmental Services for the West Creek Hydropower Project Municipality of Skagway Sunday, September-13-15 The Municipality of Skagway (MOS) is planning to submit an application for Renewable Energy Fund grant from the Alaska Energy Authority (AEA) for the West Creek Hydropower Project (the Project). The Project would construct a roller-compacted concrete gravity dam on West Creek, a tributary of the Taiya River in southeast Alaska near the City of Skagway. The dam would be approximately 175 feet high with a crest length of approximately 1,500 feet. An ungated overflow spillway, sized for the probable maximum flood, would be located centrally in the dam to discharge flood flows into the existing river channel. The primary transmission line would be a submarine cable approximately 3.9 miles from the powerhouse to a landing on Nahku Bay (aka Long Bay) about 2 to 3 miles northwest of Skagway. The primary purpose for the Project is the supply of electricity to cruise ships that dock in Skagway during the summer months. Discussions are ongoing regarding the export of power to the Yukon Territory, Canada, which expects large future load growth from mineral developments. If funded, the Project would require environmental review under the National Environmental Policy Act (NEPA) led by the Federal Energy Regulatory Commission (FERC). The Project is adjacent to the Dyea Town site unit of Klondike Gold Rush National Historic Park (KLGO); the Dyea Town site is part of a National Historic Landmark. MOS has conducted early consultation with the National Park Service (NPS) and other agencies. This consultation has resulted in an enhanced understanding of environmental issues. The MOS has prepared an estimated scope of work and budget for assessing potential impacts to the following resource areas and producing a technical report that would be supplied to FERC: • Transportation • Visual and aesthetic resources • Noise • Air quality • Cultural, historic, and archaeological resources • Recreation • Socioeconomics • Environmental justice This memorandum describes the likely approach to completing the requested reviews, as well as the anticipated budget. Please note that at this time, these are considered planning-level estimates only, provided in support of a grant application. Final costs will need to be developed in the future. APPROACH The MOS assumed approach is based on the requirements of NEPA, the AEA grant application, FERC guidelines, and likely approaches to respond to early comments from NPS. We will produce a technical report with eight chapters, covering the categories listed above, that would be provided to FERC. FERC would then provide the technical report to a team preparing third-party NEPA documentation. Our technical approach relies on the following assumptions: 1.) Should the grant be awarded, sufficient construction and design information will be available to conduct a technical analysis. 2.) There will be two alternatives under consideration: Build and No Build. 3.) Other Project details that are not yet known or understood could affect the budget, so we have presented reasonable planning-level ranges. 4.) All other parameters required to be analyzed under NEPA (e.g., wetlands, wildlife, natural resources) are being conducted by other parties and will be available for input and coordination as needed. The technical report chapters build upon each other in a holistic manner, as shown in Figure 1. The analyses will also require some input from the natural resources impact analysis, which we understand is being conducted separately. Figure 1 Relationship of Analyses and Approach to Development of Chapters According to the West Creek Master Plan (MOS 2014), the area is primarily used for resource gathering and recreation (hiking, fishing, hunting, gathering firewood, and berry picking by residents and tourists visiting KLGO). The existing road passes through KLGO and crosses both the Taiya River and West Creek. Therefore, construction and operation of the dam and a short segment of new roadway could potentially affect historic resources such as the Dyea Town site. The Project may also impact visitor access to those resources and may have adverse effects on air, noise, and visual quality; visitor appreciation of the area; and transportation patterns. The proposed analyses would assess potential impacts from the Project to these resources, as required by NEPA and FERC Division of Hydropower Licensing guidelines (FERC 2008). TEAM The MOS team will be managed by Dr. Chad P. Gubala and executed by a contractor team, Anchor QEA. Anchor will be led by Dr. Joshua Burnam, Principal Environmental Planner. Dr. Burnam will be supported closely by planners Ashley Otherson and Nicolas Duffort to conduct noise and recreation analyses. Dr. Barbara Bundy will lead the analysis of environmental justice and cultural, historic, and archaeological impacts. Betsy Severtsen will prepare perspective renderings to support the visual and aesthetic impacts analysis. Other Anchor QEA staff will assist in developing the report. The Anchor team also includes Kittelson and Associates for transportation analysis, HMH Consulting for air quality analysis, and Natural Resources Economics for socioeconomic analysis. SCOPE OF WORK Task 1. Transportation Analysis The transportation impacts assessment will assess any anticipated effects of construction and operational traffic. This report will be a key source of information for visual/aesthetic, noise, and air quality analyses. It will include analyses of existing conditions and potential construction and operational impacts. The existing conditions analysis will evaluate the existing roadway transportation system, including conducting 24-hour bi-directional vehicle counts on Dyea Road and West Creek Road, recording peak hour traffic counts at key intersection locations, and identifying existing geometric and operational conditions within the corridor between Skagway and the proposed Project site. The construction and operational impacts analyses will include estimates of the trip generation, distribution, and assignment of traffic during and after construction of the proposed hydroelectric facilities; projection of roadway operations at key intersection and roadway link locations under the construction and operation traffic conditions; identification of geometric and operational deficiencies; and recommendations for mitigation measures to address construction impacts (if needed). Task 2. Visual and Aesthetic Analysis We will develop a qualitative assessment of visual and aesthetic impacts using FERC or other appropriate guidelines. The analysis will identify and describe views and viewsheds of priority concern to the public (primarily recreational users of the West Creek area and visitors to KLGO), estimate the visual impacts on those views, and recommend mitigation measures if needed. Development of perspectives showing existing conditions, construction, and operation will be used in identifying and evaluating impacts. Task 3. Noise Analysis Noise impacts will be analyzed following NPS guidance in Director’s Order #47, Soundscape Preservation and Noise Management (NPS 2000) and FERC guidelines. Baseline conditions will be defined using published data (USEPA 1971) where site-specific noise measurements have not been taken. Noise sources during construction and operation of the Project at the site and along travel routes will be analyzed to derive a sound pressure level and power level; and attenuation will be calculated. Noise impacts will be assessed based on attenuation; best management practices and mitigation will be recommended if needed. Task 4. Air Quality Analysis The air quality impact assessment will quantify emissions of criteria air pollutants regulated by the Clean Air Act and Alaska state law for construction and operation of the Project. Air pollutants emitted during the construction phase for the roadway extension, the reservoir and dam construction, and the powerhouse construction will be quantified. These will include pollutants emitted from mobile sources such as portable diesel generators, aggregate processing and handling equipment, trucks and boats, non-exhaust roadway induced fugitive emissions from truck traffic and on-site land clearing and construction, as well as material sites like stockpiles and stackers. Best management practices and mitigation will be recommended if needed. The second air quality analysis will quantify the air quality benefits to be realized in the City of Skagway through electrification of cruise ships at berth as well as from reduced use of the community diesel fired power generators for local electricity needs. The air quality improvement assessment will determine the quantity of annual criteria air pollutants removed from the Skagway air basin with a first order ambient modeling projection of the ground-level reduction in pollutant exposure to residents or visitors. Task 5. Cultural, Historic, and Archaeological Analysis Impacts to cultural, historic, and archaeological resources will be evaluated under NEPA, Section 106 of the National Historic Preservation Act, and NPS guidance. We will produce a map and narrative description of the Area of Potential Effects (APE), inventory historic properties and cultural landscapes within the APE, and identify Project effects. Mitigation will be recommended if needed. The inventory effort will include field archaeological survey in areas of ground disturbance, as well as field documentation of any built environment resources that may be affected (level of effort could vary significantly depending on Project design details). Field survey data and the results of the visual/aesthetic and recreation analysis will be used to identify effects. Task 6. Recreation Analysis We will develop a qualitative recreational analysis, which will evaluate construction and operation impacts and meet FERC guidelines. This analysis will include consideration of activities described in the West Creek Master Plan (MOS 2014) and the KLGO General Management Plan (NPS 1996). Data and analysis from the previous topics in Tasks 1 through 5 will be incorporated into the assessment, as will information on potential impacts to natural resources. Mitigation measures will be recommended, if needed. Task 7. Socioeconomic Analysis We will describe the full range of socioeconomic effects that may arise from the Project, in compliance with FERC guidelines and standards developed by the U.S. Environmental Protection Agency (USEPA 2010). Effects will be evaluated primarily in three categories:  Effects on the economic value of goods and services  Economic impacts, which trace the Project’s potential effects on the number of jobs and levels of income or revenue for different stakeholders  The distribution of these effects across stakeholders, accomplished both in the socioeconomic analysis and, with special regard to sensitive populations, in the environmental justice analysis The analysis will consider both those aspects of the Project’s effects that involve market transactions as well as those that do not. Effects that often are difficult to measure using market-based information, but that have economic importance, include changes in the value of ecosystem services, quality of life, and amenity values. We will identify the geographic and temporal boundaries within which each impact likely will occur, and the relevant populations (households, businesses, and communities) that likely will experience the effects. We also will describe the distribution of effects across the current generation and future generations. We will conduct the analysis of socioeconomic effects of the Project by comparing the with-Project scenario to a without-Project scenario that describes current conditions in the affected variables of interest and their likely short- and long-term trends. Task 8. Environmental Justice Analysis The environmental justice analysis will assess the Project’s potential temporary and long-term effects on low income or minority populations. The analysis will comply with NEPA requirements, Title VI of the Civil Rights Act (42 USC 2000), and the Presidential Executive Order (EO) on “Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations” (EO 12898, 1994). We will identify potential environmental justice communities using publicly available data such as the U.S. Census and information collected through the education system. The Project’s natural resources, noise, and air quality, socioeconomic analyses may also provide information relevant to the environmental justice assessment, especially regarding potential impacts to subsistence users, West Creek area residents, and individuals associated with the tourism industry. Measures to avoid, minimize, and mitigate impacts will be recommended, if needed. Task 9. Project Management Project management will be conducted by the MOS representative, Dr. Chad P. Gubala and includes monthly invoicing and development of Project reporting templates, as well as oversight of contractor activities. REFERENCES FERC (Federal Energy Regulatory Commission), 2008. Preparing Environmental Documents: Guidelines for Applicants, Contractors, and Staff. Office of Energy Projects, Division of Hydropower Licensing, Washington, DC. MOS (Municipality of Skagway), 2014. West Creek Master Plan, Assembly Public Hearing Draft. Available from: http://www.skagway.org/index.asp?Type=B_BASIC&SEC= {D2A1F511-7994-49C3-AC28- ABB050A06D6A}. Accessed: August 2014. NPS (National Park Service), 2000. Director’s Order #47, Soundscape Preservation and Noise Management. Available from: http://www.nps.gov/policy/DOrders/DOrder47.html. Accessed: August 2014. NPS, 1996. General Management Plan, Development Concept Plan, and Environmental Impact Statement: Klondike Gold Rush National Historic Park. Available from: http://www.nps.gov/history/history/online_books/klgo/klondike_dcp.pdf. Accessed: August 2014. Presidential Executive Order 12898, 1994. “Federal Actions To Address Environmental Justice in Minority Populations and Low-Income Populations.” 59 FR 7629. February 11, 1994. USEPA (U.S. Environmental Protection Agency), 1971. Community Noise. USEPA Office of Noise Abatement and Control, Washington, DC. USEPA, 2010. Guidelines for Preparing Economic Analysis. Available from: http://yosemite.epa.gov/EE%5Cepa%5Ceed.nsf/webpages/guidelines.html. Accessed: August 2014.