HomeMy WebLinkAboutGrant Lake Falls Creek Round IV Grant Application
Renewable Energy Fund Round IV
Grant Application
AEA 11-005 Application Page 1 of 20 7/21/2010
Application Forms and Instructions
The following forms and instructions are provided to assist you in preparing your application for
a Renewable Energy Fund Grant. An electronic version of the Request for Applications (RFA)
and the forms are available online at: http://www.akenergyauthority.org/RE_Fund-IV.html
Grant Application
Form
GrantApp4.doc Application form in MS Word that includes an outline
of information required to submit a complete
application. Applicants should use the form to assure
all information is provided and attach additional
information as required.
Application Cost
Worksheet
Costworksheet4.doc Summary of Cost information that should be
addressed by applicants in preparing their application.
Grant Budget Form GrantBudget4.doc A detailed grant budget that includes a breakdown of
costs by milestone and a summary of funds available
and requested to complete the work for which funds
are being requested.
Grant Budget Form
Instructions
GrantBudgetInstructions4.pdf Instructions for completing the above grant budget
form.
• If you are applying for grants for more than one project, provide separate application
forms for each project.
• Multiple phases for the same project may be submitted as one application.
• If you are applying for grant funding for more than one phase of a project, provide
milestones and grant budget for completion of each phase.
• If some work has already been completed on your project and you are requesting
funding for an advanced phase, submit information sufficient to demonstrate that the
preceding phases are satisfied and funding for an advanced phase is warranted.
• If you have additional information or reports you would like the Authority to consider in
reviewing your application, either provide an electronic version of the document with
your submission or reference a web link where it can be downloaded or reviewed.
REMINDER:
• Alaska Energy Authority is subject to the Public Records Act AS 40.25, and materials
submitted to the Authority may be subject to disclosure requirements under the act if no
statutory exemptions apply.
• All applications received will be posted on the Authority web site after final
recommendations are made to the legislature.
• In accordance with 3 AAC 107.630 (b) Applicants may request trade secrets or
proprietary company data be kept confidential subject to review and approval by the
Authority. If you want information is to be kept confidential the applicant must:
o Request the information be kept confidential.
o Clearly identify the information that is the trade secret or proprietary in their
application.
o Receive concurrence from the Authority that the information will be kept
confidential. If the Authority determines it is not confidential it will be treated as a
public record in accordance with AS 40.25 or returned to the applicant upon
request.
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 2 of 20 7/21/2010
SECTION 1 – APPLICANT INFORMATION
Name (Name of utility, IPP, or government entity submitting proposal)
Kenai Hydro, LLC
Type of Entity:
Independent Power Producer
(sole member is the Homer Electric Association)
Mailing Address
3977 Lake St
Homer , AK 99603
Physical Address
same
Telephone
907-283-2375
Fax
907-335-6213
Email
msalzetti@homerelectric.com
1.1 APPLICANT POINT OF CONTACT / GRANTS MANAGER
Name
Mike Salzetti
Title
Generation Engineer
Mailing Address
Homer Electric Assoc
3977 Lake St
Homer, AK 99603
Telephone
907-283-2375
Fax
907-335-6213
Email
msalzetti@homerelectric.com
1.2 APPLICANT MINIMUM REQUIREMENTS
Please check as appropriate. If you do not to meet the minimum applicant requirements, your
application will be rejected.
1.2.1 As an Applicant, we are: (put an X in the appropriate box)
An electric utility holding a certificate of public convenience and necessity under AS
42.05, or
x An independent power producer in accordance with 3 AAC 107.695 (a) (1), or
A local government, or
A governmental entity (which includes tribal councils and housing authorities);
Yes
1.2.2. Attached to this application is formal approval and endorsement for its project by
its board of directors, executive management, or other governing authority. If the
applicant is a collaborative grouping, a formal approval from each participant’s
governing authority is necessary. (Indicate Yes or No in the box )
Yes
1.2.3. As an applicant, we have administrative and financial management systems and
follow procurement standards that comply with the standards set forth in the grant
agreement.
Yes
1.2.4. If awarded the grant, we can comply with all terms and conditions of the attached
grant form. (Any exceptions should be clearly noted and submitted with the
application.)
Yes
1.2.5 We intend to own and operate any project that may be constructed with grant
funds for the benefit of the general public.
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 3 of 20 7/21/2010
SECTION 2 – PROJECT SUMMARY
This is intended to be no more than a 1-2 page overview of your project.
2.1 Project Title – (Provide a 4 to 5 word title for your project)
Grant Lake Hydroelectric Facility
2.2 Project Location –
Include the physical location of your project and name(s) of the community or communities that will
benefit from your project.
The project would be harnessing the hydro energy of the Grant Lake watershed located near
Moose Pass, Alaska.
Persons benefitted would be the utility customers in the Kenai Peninsula.
2.3 PROJECT TYPE
Put X in boxes as appropriate
2.3.1 Renewable Resource Type
Wind Biomass or Biofuels
x Hydro, including run of river Transmission of Renewable Energy
Geothermal, including Heat Pumps Small Natural Gas
Heat Recovery from existing sources Hydrokinetic
Solar Storage of Renewable
Other (Describe)
2.3.2 Proposed Grant Funded Phase(s) for this Request (Check all that apply)
Reconnaissance x Design and Permitting
Feasibility Construction and Commissioning
x Conceptual Design
2.4 PROJECT DESCRIPTION
Provide a brief one paragraph description of your proposed project.
The Grant Lake Hydroelectric Facility would consist of 5 MW of installed capacity with an
average annual output of 20,600 MWh o f energy, installed on the Grant lake watershed near
Moose Pass, Alaska. The proposed Project is comprised of a diversion dam at the outlet to
Grant Lake (under consideration), an intake structure in Grant Lake, a tunnel, a surge tank, a
penstock, a powerhouse, a tailrace detention pond, a switchyard with disconnect switch & step-
up transformer, and an overhead or underground transmission line. The intake would be in
Grant Lake near its outlet. Water would be conveyed from the intake through a 3200’ penstock
to a powerhouse containing two Francis-type turbines. The powerhouse would be located near
the bank of Grant Creek and would discharge through a second penstock into Grant Creek. A
transmission line would connect the facility to the Railbelt grid near Moose Pass. Please see
the attached Project Description that was filed with FERC on August 13th, 2010. Kenai Hydro
LLC, whose sole member is the Homer Electric Association (HEA), was created in 2008 to
evaluate and possibly develop this site as a low impact hydroelectric facility.
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 4 of 20 7/21/2010
2.5 PROJECT BENEFIT
Briefly discuss the financial and public benefits that will result from this project, (such as reduced fuel
costs, lower energy costs, etc.)
Energy from the project would reduce consumption of carbon-based energy sources, thereby
helping to improve air quality in Kenai Peninsula Borough. This renewable energy would also
stabilize the long term price of power to consumers, and it would be a significant step in
diversifying HEA’s generation portfolio.
It is estimated that nearly $239,579,449 can be saved in avoided fuel cost over a 50-year
period. This represents a tremendous value to the rate payers of Alaska and a generation asset
that would produce clean, renewable power for Alaskans throughout this century.
2.6 PROJECT BUDGET OVERVIEW
Briefly discuss the amount of funds needed, the anticipated sources of funds, and the nature and source
of other contributions to the project.
Approximately $1,875,000 is needed to complete the Phase 2 studies that were commenced in
2009. We are calling the portion of Phase 2 work yet to be completed “Phase 2 Continuation”.
The Phase 2 Continuation studies would be sufficient to culminate in a FERC license application
expected to be submitted in 2013. Kenai Hydro is requesting that the Alaska Energy Authority
(AEA) provide 80% of this amount, or $1,500,000
The initial draft study plans did not anticipate the increased breadth of scope recommended by
some of the agency partners in early 2010. Subsequent to agency review of the 2009 Field
Season results and receipt of public comments it was decided to revisit the scope of fisheries
studies and other investigations to ensure that all concerns were sufficiently addressed. The
2010 Field Season had already begun when the decision was made to significantly alter its
scope. It was felt that the current direction of the 2010 Field Season would not adequately
redress the recent concerns expressed by agency partners, and therefore the most prudent
course would be to suspend activities until such time as the scope of work could be revised to
the satisfaction of the agency partners. Although the 2010 Field Season was abbreviated, a
considerable amount of valuable information was obtained. This grant request is seeking funds
so that a revised set of Phase 2 field studies, “Phase 2 Continuation”, can resume in 2011.
Phase 1 Reconnaissance studies, which were completed in January 2009, were partially funded
by a $100,000 AEA grant. AEA also provided a $816,000 grant award to fund Phase 2 activities
from 2009 through July 2010. Results from these studies motivate Kenai Hydro to seek
additional grant funding to support the continuation of Phase 2.
Phase 2 Continuation funds will be drawn from a combination of grants and internal financing.
The HEA Board of Directors recently authorized an internal appropriation (attachment HEA BOD
R 10-25) of over $2,000,000 for continued funding of the Grant Lake hydro project enabling
Kenai Hydro to provide the 20% matching funds in cash, and the in-kind match of management
and administrative staffing costs. Kenai Hydro, LLC remains committed to the project while it
continues to recommend itself as economically and environmentally viable.
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 5 of 20 7/21/2010
2.7 COST AND BENEFIT SUMMARY
Include a summary of grant request and your project’s total costs and benefits below.
Grant Costs
(Summary of funds requested)
2.7.1 Grant Funds Requested in this application. $1,500,000
2.7.2 Other Funds to be provided (Project match) $375,000
2.7.3 Total Grant Costs (sum of 2.7.1 and 2.7.2) $1,875,000
Project Costs & Benefits
(Summary of total project costs including work to date and future cost estimates to get to a fully
operational project)
2.7.4 Total Project Cost (Summary from Cost Worksheet
including estimates through construction)
$27,160,000
2.7.5 Estimated Direct Financial Benefit (Savings) $239,579,449 over a 50
year project lifetime
2.7.6 Other Public Benefit (If you can calculate the benefit in
terms of dollars please provide that number here and
explain how you calculated that number in your application
(Section 5.)
$
PROJECT COST SUMMARY
The preliminary total cost estimate for the project through construction is $27,160,000. This
estimate includes a $22,660,000 capital cost (based on a 5-MW project at an estimated
$4,532/kW) and an estimated $4,500,000 for development costs.
Description
Preliminary Cost
Estimate
Phase 1 Reconnaissance 105,000$
Phase 2 Resource Assess/Feasibility Analysis/Concept Design 2,000,000$
Phase 3 FERC Licensing & Final Design 2,395,000$
Phase 4 Construction & Commissioning 22,660,000$
Total Preliminary Cost Estimate 27,160,000$
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 6 of 20 7/21/2010
SECTION 3 – PROJECT MANAGEMENT PLAN
Describe who will be responsible for managing the project and provide a plan for successfully
completing the project within the scope, schedule and budget proposed in the application.
3.1 Project Manager
Tell us who will be managing the project for the Grantee and include contact information, a
resume and references for the manager(s). If the applicant does not have a project manager
indicate how you intend to solicit project management support. If the applicant expects project
management assistance from AEA or another government entity, state that in this section.
Mr. Mike Salzetti (HEA) will oversee the development of this project with the assistance of Mr.
Brad Zubeck (HEA). Their brief professional biographies are attached in Section 7, Attachment
A as requested.
Mr. Salzetti has the guidance, support and staffing of his parent organization for
managing this project from its current state through design, construction and operation. Kenai
Hydro, LLC has also contracted with qualified consultants to conduct the
engineering studies and detailed design.
3.2 Project Schedule
Include a schedule for the proposed work that will be funded by this grant. (You may include a
chart or table attachment with a summary of dates below.)
A summary of the dates is provided below:
PHASE 2 Continuation – Schedule Summary
Task Name Start Finish
Task 6 – Field Studies 07/2011 3/2013
2011 - 2012 Field Studies 07/2011 10/31/2012
Milestone # 1: At conclusion of Field Studies 3/2013
Task 7 – Engineering/Project Scoping 7/2011 10/2012
2011 – 2012 Engineering/Project Scoping –
Milestone #2
7/2011 10/2012
2012 Engineering Cost Analysis – Milestone #3 8/2012 10/2012
Task 8 – FERC License Application 7/15/2011 10/30/2013
Draft License Application 7/15/2011 5/30/2013
Milestone # 4: Final Decision to Make FERC
License Application
10/1/2013 10/30/2013
See attached project schedule.
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 7 of 20 7/21/2010
3.3 Project Milestones
Define key tasks and decision points in your project and a schedule for achieving them. The
Milestones must also be included on your budget worksheet to demonstrate how you propose to
manage the project cash flow. (See Section 2 of the RFA or the Budget Form.)
Milestone #1 would be the completion of the field studies / Environmental Assessments. The
anticipated date of completion is 3/30/2013 although we would be seeking reimbursement on
this milestone on an “as progress is made” basis. Field studies completed under this milestone
would include terrestrial studies, cultural studies, recreational & visual studies, water resource
studies, aquatic resource studies as well as study oversight and management.
Milestone #2 Preliminary Engineering / Project Scoping. The anticipated completion date is
10/31/2012. This task would include the preliminary engineering required for the FERC exhibit
F & G drawings.
Milestone #3 Engineering Cost Analysis. The anticipated completion date is 10/31/2012. This
task would include the engineering cost analysis required for exhibit A of the FERC license
application.
Milestone #4 FERC License Application and would be complete by 10/30/2013. This would
include the preparation of both the draft and final license applications.
3.4 Project Resources
Describe the personnel, contractors, equipment, and services you will use to accomplish the
project. Include any partnerships or commitments with other entities you have or anticipate will
be needed to complete your project. Describe any existing contracts and the selection process
you may use for major equipment purchases or contracts. Include brief resumes and references
for known, key personnel, contractors, and suppliers as an attachment to your application.
Mr. Mike Salzetti will be responsible for management and direct oversight of the project
development. He has the guidance, support and staffing of his parent organization for
managing this project from its current state through design, construction and operation.
Kenai Hydro LLC, whose sole member is the Homer Electric Association (HEA), was created to
evaluate and develop the site as a low impact hydroelectric facility. Kenai Hydro, LLC has
contracted well- qualified consultants to conduct the engineering, studies, permitting, process
management and facilitation.
Based on their recent FERC relicensing performance with the Cooper Lake hydro facility, Long
View Associates (LVA) was hired to prepare FERC preliminary permit applications. The
preliminary permit for this project was secured and issued by FERC October 7, 2008. LVA will
be retained in various capacities, such as permitting or FERC license application management.
HDR Alaska, Inc.(HDR) has provided engineering and consulting services for the feasibility
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 8 of 20 7/21/2010
phase of this project, and provided their services on a Task Order basis. HDR is a nation-wide
engineering firm with a full-service office in Anchorage. HDR Alaska, Inc. has a long history in
this state and offers a full spectrum of engineering, planning, and environmental services.
Résumés of HDR’s key personnel are provided in Section 7 appendices. Additional consulting
services will be provided as needed.
An organizational chart is provided below representing the general tasks and planned
assignments.
3.5 Project Communications
Discuss how you plan to monitor the project and keep the Authority informed of the status.
The project manager will issue reports to AEA on a mutually agreeable schedule throughout the
life of the grant. These reports can be customized to meet AEA needs. The expectation is that
these reports could be a one page summary-type document submitted quarterly. The project
would also expect to process requests for reimbursement on a monthly basis. The project
consultants will provide weekly status reports, and other summaries and analyses on a pre-
determined schedule.
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 9 of 20 7/21/2010
3.6 Project Risk
Discuss potential problems and how you would address them.
1. An important stakeholder issue might be overlooked during the preliminary permit phase
and it could become a project impediment during the FERC license application.
It was recently learned that the proposed Iditarod Commemorative Trail route may intersect
project access and transmission line routing. We have met with the USFS and Alaska DNR to
discuss the issue and we are working on plans to achieve a solution, and we don’t anticipate
that this will pose a major hurdle in the project’s development.
Kenai Hydro will continue to consult with potential stakeholders (i.e., agencies, NGOs, Native
Corporations, and communities) to ensure that all significant concerns are addressed in the field
studies in anticipation of the licensing process for the Grant Lake project. By continuing to work
through and finalize issues, we hope to obviate any latent concerns and move into a FERC
licensing application with the full support stakeholders.
2.Risk of not being able to successfully negotiate interconnection and transmission agreements.
These agreements will be the subject of discussion on an ongoing basis, but it is the intent of
Kenai Hydro that these agreements be executed in advance of a FERC license application. The
cost of developing these agreements will not be underwritten by the grant funding.
SECTION 4 – PROJECT DESCRIPTION AND TASKS
• Tell us what the project is and how you will meet the requirements outlined in Section 2 of
the RFA.
• The level of information will vary according to phase(s) of the project you propose to
undertake with grant funds.
• If you are applying for grant funding for more than one phase of a project provide a
plan and grant budget form for completion of each phase.
• If some work has already been completed on your project and you are requesting funding for
an advanced phase, submit information sufficient to demonstrate that the preceding phases
are satisfied and funding for an advanced phase is warranted.
4.1 Proposed Energy Resource
Describe the potential extent/amount of the energy resource that is available.
Discuss the pros and cons of your proposed energy resource vs. other alternatives that may be
available for the market to be served by your project.
Energy Potential
Precisely quantifying the available energy from Grant Lake will be amongst the work performed
with this grant request. However, initial estimates derived from hydrology data recommend a 5
MW installed with a Capacity Factor of ~50% or 20.6 GWh annually.
The historical record for energy potential was garnered from USGS stream gage 15256000
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 10 of 20 7/21/2010
records, located on Grant Creek approximately 1/3 mile upstream from the mouth which has an
11-year period of record from 1947 to 1958. This stream gage has a drainage basin of 44.2
square miles and the average annual flow for the period of record was 193-cfs.
Pros
Hydropower is renewable, long-lived, efficient, dispatchable and environmentally responsible
energy that emits no greenhouse gases, waste or air pollution. It uses readily available
technologies, it is low maintenance, displaces consumption of fossil fuels, and it provides long-
term price stability to energy consumers. This particular facility could greatly enhance HEA’s
spinning reserve capacity which provides a significant fuel savings.
Hydropower opportunities on the Kenai Peninsula are extremely limited; potential resources
have been catalogued by the US Geological Survey – Water Resources of Alaska. Proximity to
the Railbelt grid, low impact , and available energy recommend a Grant Lake hydro facility to be
atop the short list of viable Kenai Peninsula renewable resources.
The most expedient solution to local energy needs is construction of natural gas-fired generation.
These units are less expensive to procure and install, require a much shorter time to permit, and
have a relatively small footprint compared to hydro power. However, gas-fired units are not
sustainable, subject to market-driven fuel pricing and availability, shorter lived, cost more to
operate and maintain, and emit greenhouse gases.
Cons
Disadvantages of hydropower include high initial investment, relatively long time required to
permit/license, and potential impact on habitats and water quality.
4.2 Existing Energy System
4.2.1 Basic configuration of Existing Energy System
Briefly discuss the basic configuration of the existing energy system. Include information about
the number, size, age, efficiency, and type of generation.
HEA has a 42 MW gas turbine( eff. ~ 40%) at Nikiski that was built in 2001, and it has an 11%
share of the Bradley Lake hydro energy. HEA has recently undertaken to renovate its Nikiski unit
to include an 18 MW steam turbine. This addition* will boost the facility’s capacity to 82 MW
(*renovation will include refurbishing the extant duct firing capability of 22 MW) which is
commensurate to an improvement of 46% in efficiency. Future system capacity may include one
or more aero-derivative turbines at a HEA-owned Soldotna facility. The average HEA combined
load is 62.4 MW (~546 GWh/yr), with winter peaks approaching 85 MW and summer lows
occasionally less than 40 MW.
4.2.2 Existing Energy Resources Used
Briefly discuss your understanding of the existing energy resources. Include a brief discussion of
any impact the project may have on existing energy infrastructure and resources.
HEA’s wholesale contracts expire at the end of 2013 and its Board of Directors has approved a
path for HEA to develop assets that will achieve complete self-reliance. This requires that HEA
nearly double its current generation capacity. A hydro facility at Grant lake would contribute to
attaining that goal.
HEA is also seeking to diversify its generation portfolio and moderate its reliance on natural gas.
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 11 of 20 7/21/2010
Part of this diversification is to develop renewable generation. The proposed project would
represent approximately 4 % of HEA’s future energy needs, and would be a significant step in
adding renewable energy to its portfolio. Furthermore, the addition of hydroelectric facilities
would facilitate development of other renewable resources such as wind.
4.2.3 Existing Energy Market
Discuss existing energy use and its market. Discuss impacts your project may have on energy
customers.
The primary market for this project’s energy is HEA consumers, and a secondary market is other
Railbelt utilities. A potential market may soon exist for Renewable Energy Credits that can be
sold to utilities or industries seeking a means to comply with various Renewable Energy
Standards or Policies.
This project will have the following positive impacts on the existing energy system and its
customers:
1. Incrementally stabilize the long-term price of power.
2. Provide approximately 4 % of HEA’s immediate generation needs from clean, renewable
hydropower.
3. Offset and reduce greenhouse gas emissions.
4. Provide stored, dispatchable energy (spinning reserve).
5. Improve consumer confidence in its utility leadership and management.
4.3 Proposed System
Include information necessary to describe the system you are intending to develop and address
potential system design, land ownership, permits, and environmental issues.
4.3.1 System Design
Provide the following information for the proposed renewable energy system:
• A description of renewable energy technology specific to project location
• Optimum installed capacity
• Anticipated capacity factor
• Anticipated annual generation
• Anticipated barriers
• Basic integration concept
• Delivery methods
The hydro project would be comprised of an impoundment dam at the outlet of Grant Lake, a
3200 foot 10’ diameter feed penstock, a surge tank, two Francis-type turbines with a combined 5
MW gross capacity power house, and a 200 foot discharge penstock. The dam (under
consideration) would control outflow from the lake, creating or maintaining storage capacity. The
intake tap, an above and below-grade penstock, would be in Grant Lake near its outlet. Water
would be conveyed from the intake through the inlet feed penstock to a powerhouse located near
the bank of Grant Creek, and would ultimately discharge through a second penstock into Grant
Creek. A 7.5 MVA transformer would be used to convert the 13.8 kV generator voltage to 24.9
kV transmission voltage, and a 4100’ radial circuit would connect the facility to the Railbelt grid
near Moose Pass.
Historic Grant Creek flows recommend an optimal turbine of 5 MW and suggest a Capacity
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 12 of 20 7/21/2010
Factor of about 50%; this would yield an average annual energy output of ~21.4 GWh.
A discharge pond is also being considered to enhance the spinning reserve potential of the
facility. Phase 2 Continuation funds will facilitate engineering and field studies to further refine
the design alternatives.
4.3.2 Land Ownership
Identify potential land ownership issues, including whether site owners have agreed to the
project or how you intend to approach land ownership and access issues.
The legal description and ownership of lands (ADNR 2006) within the proposed project boundary
are provided in the table below. All land is referenced to the Seward Meridian. Un-shaded rows
pertain to the Grant Lake outlet and Grant Creek. Shaded rows include Grant Lake in its entirety
and potential transmission areas.
Township Range Section Ownership
5N 1W 36 Private
5N 1E 27 USDA Forest Service
5N 1E 28 USDA Forest Service
5N 1E 29 USDA Forest Service
5N 1E 30 State patented land
5N 1E 31 State patented land
5N 1E 32 State patented land
5N 1E 33 USDA Forest Service
5N 1E 34 USDA Forest Service
5N 1E 35 USDA Forest Service
5N 1E 36 USDA Forest Service
4N 1E 1 USDA Forest Service
4N 1E 2 USDA Forest Service
4N 1E 3 USDA Forest Service
4N 1E 5 USDA Forest Service
4N 1E 6 State patented land
4N 1E 7 State patented land
4N 1W 1 Private
4N 1W 12 Private
4.3.3 Permits
Provide the following information as it may relate to permitting and how you intend to address
outstanding permit issues.
• List of applicable permits
• Anticipated permitting timeline
• Identify and discussion of potential barriers
A comprehensive listing of permits was developed in Phase 1. Phase 2 efforts included
preliminary applications for requisite permits in support of a FERC license application. This
permitting application was accomplished during 2009-2010.
A preliminary list of permits is provided below:
o USDA Forest Service, Special Use Application (SUA)
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 13 of 20 7/21/2010
o Alaska Railroad Corp., Access Road & Transmission Line ROW Crossing of
Tracks
o Transmission Line Right-of-Way, lease or purchase agreements
o AKDNR, Water Rights
A permit to invoke the Traditional License Program was granted by FERC on Sept 15th, 2009.
Kenai Hydro, LLC filed a preliminary permit application with FERC on April 28, 2008 and was
issued a permit on October 7, 2008 (attachment FERC 10-7-08). The purpose of the preliminary
permit term is to determine the feasibility of a proposed project on Grant Lake and Creek in the
Kenai Peninsula Borough, Alaska, and would occupy federal lands managed by the Chugach
National Forest. A Pre-Application Document (PAD) was filed with FERC on August 6, 2009.
FERC approved the Traditional License Program (TLP) as the appropriate course with which to
proceed and secure a FERC license (attachment FERCTLP 9-15-09).
4.3.4 Environmental
Address whether the following environmental and land use issues apply, and if so how they will
be addressed:
• Threatened or Endangered species
• Habitat issues
• Wetlands and other protected areas
• Archaeological and historical resources
• Land development constraints
• Telecommunications interference
• Aviation considerations
• Visual, aesthetics impacts
• Identify and discuss other potential barriers
All of the issues identified in the initial portion of Phase 2 will continue to be addressed during
Phase 2 Continuation studies; the revised scope of investigations has been tailored to directly
address issues of concern recognized in 2009 work.
4.4 Proposed New System Costs and Projected Revenues
(Total Estimated Costs and Projected Revenues)
The level of cost information provided will vary according to the phase of funding requested and
any previous work the applicant may have done on the project. Applicants must reference the
source of their cost data. For example: Applicants Records or Analysis, Industry Standards,
Consultant or Manufacturer’s estimates.
4.4.1 Project Development Cost
Provide detailed project cost information based on your current knowledge and understanding of
the project. Cost information should include the following:
• Total anticipated project cost, and cost for this phase
• Requested grant funding
• Applicant matching funds – loans, capital contributions, in-kind
• Identification of other funding sources
• Projected capital cost of proposed renewable energy system
• Projected development cost of proposed renewable energy system
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 14 of 20 7/21/2010
Phase 2 Resource Assessment, Feasibility Analysis and Concept Design
This grant application seeks funding to support continued Phase 2 studies and work. The cost
estimate is based upon Phase 1 consultant costs, the costs encountered in the 2009 Phase 2
work, and an understanding of the scope of remaining work to be accomplished under the FERC
preliminary permit. The costs requested in this application cover studies and work for the 2011
and 2012 field seasons, and FERC License Preparation & Application in2013.
$1,875,000 is needed to complete a Phase 2 study and culminate in a FERC license application.
Kenai Hydro requests as part of this application that AEA provide 80% of this amount, or
$1,500,000.
Phase 2 Continuation funds will be drawn from a combination of existing and future grant funding
as well as internal financing. Kenai Hydro, LLC is committed to providing the 20% matching
funds in cash, as well as the in-kind match for the cost of management and administrative
staffing.
Phase 3 FERC Licensing & Final Design
The costs of final engineering and FERC Licensing are not precisely reckoned, but are estimated
at approximately eleven (11%) percent of the projected construction cost or about $2.4-million.
This would be the final engineering of preparing plans and specifications for construction.
Phase 4 Construction and Commissioning
The cost of construction and commissioning is conservatively estimated at $4,532/kW or
$22,660,000 for a nominal 5 MW plant. Construction costs for recent, similarly-sized plants in
remote Alaska have been approximately $3,000/kW. It is our hope that this project might
ultimately improve upon the preliminary estimate of $4,532/kW. The final design concept
achieved at the end of Phase 2 will refine the projected construction cost.
Other Funding Sources
Kenai Hydro will pursue other potential sources of funding while the project continues to achieve
successive project milestones, positive economic and environmental reviews. Although no
specific alternate sources of funding have yet been identified, among the possibilities are
legislative appropriations.
4.4.2 Project Operating and Maintenance Costs
Include anticipated O&M costs for new facilities constructed and how these would be funded by
the applicant.
(Note: Operational costs are not eligible for grant funds however grantees are required to meet
ongoing reporting requirements for the purpose of reporting impacts of projects on the
communities they serve.)
Operations and maintenance will be financed through typical utility accounting procedures using
revenue generated by the hydro facility and other utility cash flows. The facility would be
essentially unmanned requiring only periodic inspection and routine maintenance. Annual O &M
costs are anticipated to be about $100,000 (in 2010 dollar) escalating at 3% per year which is
easily supported by the project’s expected annual revenue.
4.4.3 Power Purchase/Sale
The power purchase/sale information should include the following:
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 15 of 20 7/21/2010
• Identification of potential power buyer(s)/customer(s)
• Potential power purchase/sales price - at a minimum indicate a price range
• Proposed rate of return from grant-funded project
Energy from the project will be sold to Homer Electric Association (HEA) for the benefit of its
customers at prevailing rates. It should be noted that the project would incrementally stabilize
long term electricity rates. It is likely that the acceptable rate-of-return will be kept to single-digit
margins.
4.4.4 Project Cost Worksheet
Complete the cost worksheet form which provides summary information that will be considered
in evaluating the project.
Download the form, complete it, and submit it as an attachment. Document any conditions or
sources your numbers are based on here.
See the attached Cost Worksheet completed for the proposed Grant Lake project.
The Grant Lake Hydro Benefit-cost Sept 2010 shows a benefit-cost ration of 1.42, whereas a
previous study (Ebasco - 1984) had a ratio of 1.20 for a 7-MW project.
SECTION 5– PROJECT BENEFIT
Explain the economic and public benefits of your project. Include direct cost savings,
and how the people of Alaska will benefit from the project.
The benefits information should include the following:
• Potential annual fuel displacement (gal and $) over the lifetime of the evaluated
renewable energy project
• Anticipated annual revenue (based on i.e. a Proposed Power Purchase Agreement price,
RCA tariff, or cost based rate)
• Potential additional annual incentives (i.e. tax credits)
• Potential additional annual revenue streams (i.e. green tag sales or other renewable
energy subsidies or programs that might be available)
• Discuss the non-economic public benefits to Alaskans over the lifetime of the project
Potential Fuel Displacement
It is estimated that $239,579,449 can be saved in avoided fuel cost over a 50-year period (using
a 2010 dollars metric). This represents a tremendous value to the rate payers of Alaska and a
generation asset that will produce clean, renewable power for Alaskans throughout this century.
Anticipated Annual Revenue
Annual revenue minus the fuel savings cost accounted for above is estimated at approximately
$7/MWh in 2010 dollars escalated at a 5% power price escalation factor. This equates to a
revenue stream of $35,502,179 over a 50-year period.
Potential Additional Annual Incentives
The potential tax credits are purely speculative, and will depend on the form of the business
entity that carries the project into licensing, construction and operation
Potential Additional Annual Revenue Streams
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 16 of 20 7/21/2010
It may be possible to sell Renewable Energy Credits engendered by this project, but lack of an
existing market renders a forecast purely speculative.
The renewable energy will incrementally stabilize the long term price of power providing an
attractive incentive to potential local businesses.
It may also be possible to sell spinning reserve capacity from this asset when HEA is not utilizing
the spin from this facility.
Non-Economic Public Benefit
The energy from the project would reduce consumption of carbon-based energy sources, and
help to improve air quality in Kenai Peninsula Borough. The project would also be an important
step in diversifying HEA’s future generation portfolio.
A requisite public access road to the dam would substantially enhance recreational opportunities
at Grant Lake.
SECTION 6– SUSTAINABILITY
Discuss your plan for operating the completed project so that it will be sustainable.
Include at a minimum:
• Proposed business structure(s) and concepts that may be considered.
• How you propose to finance the maintenance and operations for the life of the project
• Identification of operational issues that could arise.
• A description of operational costs including on-going support for any back-up or existing
systems that may be require to continue operation
• Commitment to reporting the savings and benefits
Operations and maintenance will be financed through typical utility accounting procedures using
revenue generated by the hydro facility and other utility cash flows. The facility would be
essentially unmanned requiring only periodic inspection and routine maintenance. Annual O &M
costs are anticipated to be about $100,000 (in 2010 dollar) escalating at 3% per year which is
easily supported by the project’s expected annual revenue.
SECTION 7 – READINESS & COMPLIANCE WITH OTHER GRANTS
Discuss what you have done to prepare for this award and how quickly you intend to proceed
with work once your grant is approved.
Tell us what you may have already accomplished on the project to date and identify other grants
that may have been previously awarded for this project and the degree you have been able to
meet the requirements of previous grants.
Since a significant portion of work has already been completed, and draft study plans have been
formulated, Kenai Hydro is prepared to resume activities immediately upon receipt of grant
funding.
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 17 of 20 7/21/2010
The reconnaissance Phase 1 was completed in 2009, the results of which suggested pursuing
feasibility work. To that end, Field Studies were initiated in 2009 and executed through July of
2010. An authorization to proceed to licensing using the Traditional License Program was
granted by FERC on 9/15/2009 – refer to attachment “FERCTLP 9-15-2009” Numerous agency
and interested shareholder forums have been held, and public comment processes have been
undertaken. The FERC scoping process has been completed and FERC issued Scoping
Document 2 for this project on 8/23/2010 – refer to attachment “KHL_FERC_Scoping2”. Kenai
Hydro has also maintained a website, www.kenaihydro.com that contains project information.
Phase 1 Reconnaissance studies, which were completed in January 2009, were partially funded
by a $100,000 AEA grant. AEA also provided a $816,000 grant award to fund Phase 2 activities
from 2009 through July 2010. The results from these studies motivate Kenai Hydro to seek
additional grant funding to support the continuation of Phase 2.
SECTION 8– LOCAL SUPORT
Discuss what local support or possible opposition there may be regarding your project. Include
letters of support from the community that would benefit from this project.
The project has encountered some not unexpected minor, local opposition, but initial reaction of
this sort is common and misunderstanding tends to diminish as people become more
knowledgeable with a project’s details and unsubstantiated rumors are dispelled. Among
ongoing tasks are the receipt, cataloguing and redress of public comments.
The HEA Board of Directors which represents 21,586 member - owners has shown consistent
support for renewable energy projects.
Attached you will find letters of support for this project from Speaker of the Alaska State House,
Representative Mike Chenault; Alaska State Senate President, Senator Gary Stevens; and
Alaska State Representative, Paul Seaton.
SECTION 9 – GRANT BUDGET
Tell us how much you want in grant funds Include any investments to date and funding sources,
how much is being requested in grant funds, and additional investments you will make as an
applicant.
Include an estimate of budget costs by milestones using the form – GrantBudget3.doc
Overview
The Grant Lake hydro project has been the subject of several previous studies. The most recent
and significant of these was published by Ebasco in 1984 - electronic copies of Ebasco’s
complete report are provided with this application on CD-ROM. Ebasco’s effort was funded by
the State of Alaska through AEA’s predecessor, the Alaska Power Authority. This extensive
study ultimately recommended that the State file a FERC license application and proceed with
further development of a project that would displace gas-fired generation. It is our position that
this recommendation is even more valid considering the Railbelt’s heavy dependence on gas-
fired generation.
Phase 2 is broken into the following three general Tasks:
• Task 6 – Field Studies
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 18 of 20 7/21/2010
• Task 7 – Engineering, Design & Management of Studies
• Task 8 – FERC License Preparation & Application.
Task numbers start at “6” because Phase 1 included Tasks 1 to 5. Phase 2 tasks are to be
performed concurrently.
Task 6 – Field Studies
The budget proposed for Task 6 covers the following scope of studies: aqautic, water, cultural
resources, recreational/visual and terrestrial. The aquatic resources, hydrology and
geomorphology assessment, fish population and distribution surveys. Cultural studies will
include consultation with various groups, entities or persons to collect and summarize existing
information, and literature review. Recreational studies will include quantifying the use of the site
and related resources and facilities. Terrestrial studies will include plant surveys; wetlands
mapping; landbird, shorebird, and waterbird surveys; bat surveys; bear den survey; and moose
winter habitat surveys.
Task 7 – Engineering, Design & Management
This budget is intended to cover the cost of engineering, planning, oversight, and surveying
required to refine concept layouts and studies.
Task 8 – FERC License Preparation & Application
This budget is for a FERC licensing manager and costs or expenses related to developing the
FERC draft and final license applications.
The total cost of completing Phase 2 from its current state, including all State and Local
Matching Cash and In-Kind funds, is $1,875,000.
State Funds
This application requests $1,875,000 to complete the activities associated with the Phase 2
Feasibility Analysis/Concept Design of the proposed project. This is to cover all applicable costs
other than the Direct Labor and Benefits of Kenai Hydro, LLC management and administrative
staff. It is anticipated that the State would provide 80% of the $1,875,000 for Phase 2
Continuation, or approximately $1,500,000.
Local Match Funds (Cash)
Kenai Hydro, LCC plans to honor a 20% match in cash, or $375,000 of the estimated Phase 2
Continuation total.
Local Match Funds (In-Kind)
Kenai Hydro, LLC will provide and fund project management and administrative staffing.
Nature & Source of Funds
Funds will initially be drawn from a combination of existing and future grant funding as well as
internal financing. The Alaska Energy Authority has given notice of an award of $816,000 to this
project that has helped to accomplish the reconnaissance phase of the project and a significant
portion of the Phase 2 studies. It has passed the initial engineering assessment and
reconnaissance, and now further feasibility work, Phase 2 Continuation, is needed. Kenai
Hydro, LLC is committed to providing the 20% matching funds, plus management and
administrative staffing while project remains economically and environmentally viable. Support
for this was demonstrated by the HEA Board of Directors Resolution 10-25, dated June 1, 2010,
that authorized an internal appropriation of over $2,000,000 for continued funding of the Grant
Lake hydro project, see attachment HEA BOD 10-25. Continued project support was evidenced
by the same BOD with resolution 10-41 of August 17th, see attachment HEA BOD 10-41.
Renewable Energy Fund
Grant Application Round IV
AEA11-005 Grant Application Page 19 of 20 7/21/2010
SECTION 9 – ADDITIONAL DOCUMENTATION AND CERTIFICATION
SUBMIT THE FOLLOWING DOCUMENTS WITH YOUR APPLICATION:
A. Contact information and professional resumes of key personnel per application form
Section 3.1 and 3.4.
a. Homer Electric Association, Inc.
b. Longview Associates
c. HDR Alaska, Inc.
B. Grant Lake/Falls Creek Hydroelectric Project TLP Schedule
C. Grant Lake/Falls Creek Budget Form per application form Section 9 – Grant Budget
D. FERC Order Issuing Preliminary Permit – October 7, 2008
E. Grant Lake/Falls Creek Project Cost/Benefit Worksheet per application form Section
4.4.4.
F. Grant Lake/Falls Creek Benefit Cost Analysis – September 2010
G. FERC Authorization to use the TLP – September 15, 2009
H. FERC Scoping Document 2 for Grant Lake/Falls Creek – August 23, 2010
I. HEA Board of Directors Resolution 10-25 – January 1, 2010
J. HEA Board of Directors Resolution 10-41 – August 17, 2010
K. HEA General Manager Authorization – August 17, 2010
L. Letters demonstrating local support per application Section 8
a. Alaska State Senator, Gary Stevens
b. Alaska State Representative, Mike Chenault
c. Alaska State Representative, Paul Seaton
M. Electronic version (CD-ROM) of grant application
N. The EBASCO Grant Lake Feasibility Analysis (on CD-ROM only)
Rene wab le En ergy Fun d
Grant Ap plica tio n Roun d IV
The undersigned certifies that this application for a renewable energy grant is truthful
and correct, and that the applicant is in compliance with , and will continue to comply
with , a" federal and state laws including existing credit and federal tax obligations.
Print Name Bradl ey P . Ja norsc hke -
Signature ~ .--::;::; V -~ \...-
..P
Title Ge nera l Ma na ger
Date Sept e mb er 14 . 2010
AEA 11-005 Grant Application Page 20 of 20 7/21 /2010
IDTask NameStartFinish1Prefiling Activities: Preliminary Permit IssuedTue 10/7/08Tue 10/7/082Preliminary Permit ManagementWed 10/1/08Mon 9/29/145PAD/NOI DevelopmentWed 4/1/09Mon 5/17/106PAD DevelopmentWed 4/1/09Wed 8/5/0915FERC PAD/NOI Review ProcessThu 8/6/09Mon 5/17/1025Study Program Mon 3/2/09Sat 3/30/13262009 Study Season Mon 3/2/09Fri 1/8/1034FERC Early Scoping ProcessTue 5/11/10Mon 8/23/1039Study ProgramSat 5/1/10Wed 10/31/1240Study Plan Development and Review ProcessTue 5/4/10Tue 3/29/11472010 Field ProgramSat 5/1/10Tue 9/7/10482011-2012 Field ProgramFri 7/15/11Wed 10/31/1249Study ReportsSat 9/1/12Sat 3/30/1350Issue Draft Study Reports Sat 9/1/12Tue 10/30/1251Issue Final Study ReportsSat 12/1/12Sat 3/30/1352Preliminary Engineering Design/Project ScopingTue 7/3/12Tue 10/30/1253Exhibit F DrawingsTue 7/3/12Tue 10/30/1254Engineering Cost EstimateWed 8/1/12Tue 10/30/1255License Application Wed 5/1/13Wed 10/30/1356Draft License Application (DLA)Wed 5/1/13Thu 5/30/1357Consultation Regarding DLA and Mitigation ProposalFri 5/31/13Fri 9/27/1358Final License ApplicationTue 10/1/13Wed 10/30/1310/7/089/1/1212/1/125/1/1310/1/Q3Q4Q1Q2Q3Q4Q1Q2Q3Q4Q1Q2Q3Q4Q1Q2Q3Q4Q1Q2Q3Q4Q1Q208200920102011201220132Kenai Hydro LLCGrant Lake/Falls Creek Hydroelectric ProjectTraditional Licensing Process SchedulePage 1
Renewable Energy Fund Grant Round IV Grant Budget Form 7-21-10
Milestone or Task Anticipated
Completion Date
RE- Fund
Grant Funds
Grantee Matching
Funds
Source of Matching
Funds:
Cash/In-kind/Federal
Grants/Other State
Grants/Other
TOTALS
(List milestones based on phase and type of project.
See Attached Milestone list. )
$ $ $
#1 Field Studies / Environmental Assessment 3/2013 $1,108,000 $277,000 Cash $1,385,000
#2 Preliminary Engineering / Project Scoping 10/2012 $100,000 $25,000 Cash $125,000
#3 Engineering Cost Analysis 10/2012 $12,000 $3,000 Cash $15,000
#4 FERC License Application 10/2013 $280,000 $70,000 Cash $350,000
$ $ $
$ $ $
$ $ $
$ $ $
$
$
TOTALS $1,500,000 $375,000 $1,875,000
Budget Categories:
Direct Labor & Benefits $ $ $
Travel & Per Diem $ $ $
Equipment $ $ $
Materials & Supplies $ $ $
Contractual Services $1,500,000 $375,000 $1,875,000
Construction Services $ $ $
Other $ $ $
TOTALS $1,500,000 $375,000 $1,875,000
Applications should include a separate worksheet for each project phase (Reconnaissance, Feasibility, Design and Permitting, and Construction)-
Add additional pages as needed
Renewable Energy Fund Grant Round IV Grant Budget Form 7-21-10
Project Milestones that should be addressed in Budget Proposal
Reconnaissance Feasibility Design and Permitting Construction
1. Project scoping and
contractor solicitation.
2. Resource identification and
analysis
3. Land use, permitting, and
environmental analysis
5. Preliminary design analysis
and cost
4. Cost of energy and market
analysis
5. Simple economic analysis
6. Final report and
recommendations
1. Project scoping and contractor
solicitation.
2. Detailed energy resource
analysis
3. Identification of land and
regulatory issues,
4. Permitting and environmental
analysis
5. Detailed analysis of existing
and future energy costs and
markets
6. Assessment of alternatives
7. Conceptual design analysis
and cost estimate
8. Detailed economic and
financial analysis
9, Conceptual business and
operations plans
10. Final report and
recommendations
1. Project scoping and contractor
solicitation for planning and
design
2. Permit applications (as
needed)
3. Final environmental
assessment and mitigation
plans (as needed)
4. Resolution of land use, right of
way issues
5. Permit approvals
6. Final system design
7. Engineers cost estimate
8. Updated economic and
financial analysis
9. Negotiated power sales
agreements with approved
rates
10. Final business and operational
plan
1. Confirmation that all design
and feasibility requirements
are complete.
2. Completion of bid documents
3. Contractor/vendor selection
and award
4. Construction Phases –
Each project will have unique
construction phases, limitations,
and schedule constraints which
should be identified by the
grantee
5. Integration and testing
6. Decommissioning old
systems
7. Final Acceptance,
Commissioning and Start-up
8. Operations Reporting
UNITED STATES OF AMERICA 125 FERC ¶ 62,018
FEDERAL ENERGY REGULATORY COMMISSION
Kenai Hydro, LLC Project No. 13212-000
ORDER ISSUING PRELIMINARY PERMIT
(Issued October 07, 2008)
On April 28, 2008, Kenai Hydro, LLC filed an application, pursuant to section 4(f) of
the Federal Power Act (FPA),
1 to study the feasibility of the Grant Lake Project. The project
would be located on Grant Lake and Creek in Kenai Peninsula Borough, Alaska, and would
occupy federal lands managed by the Chugach National Forest.
The proposed project would consist of: (1) an earth filled, concrete faced gravity dam
10 feet high and 200 feet wide; (2) a reservoir with an approximate surface elevation of 800
feet MSL, an approximate surface area of 1,888 acres, and a storage capacity of 37,760 acre
feet; (3) a 5 foot diameter, 1 mile long penstock constructed of high density polyethylene or
steel; (4) a powerhouse containing one turbine generator unit with a total installed capacity of
about 5 MW; (5) a 1-2 mile long, 115 kV transmission line and; (6) appurtenant facilities.
The annual production would be 17.5 GWh, which would be sold to a local utility.
Background
The Commission issued public notice of the application on July 21, 2008. The U. S.
Department of the Interior and the U.S. Department of Agriculture (USDA) filed motions to
intervene to be parties in the proceeding.
2 The USDA also filed comments.
USDA commented on resource issues that need to be evaluated by the permittee
during the course of the preliminary permit. These issues include fish and wildlife, recreation,
and visual resources. The USDA also states the permittee will need to obtain a Special Use
Authorization in order to perform work related to the permit on National Forest lands.
Discussion
1 16 U.S.C. § 797(f) (2000).
2 Timely, unopposed motions to intervene are granted by operation of Rule 214 of the
Commission’s Regulations.Id.§ 385.214(a)(3) (2008).
20081007-3019 FERC PDF (Unofficial) 10/07/2008
Project No. 13212-000 2
The purpose of a preliminary permit is to maintain priority of application for a license
during the term of the permit while the permittee conducts investigations and secures data
necessary, after consultation with the appropriate resource agencies, to determine the
feasibility of the proposed project and prepares an acceptable development application. The
permit confers no authority on the permittee to undertake construction of the proposed project
or any part thereof,
3 or to occupy or use lands or other property of the United States or of any
other entity or individual.
If, during the course of the permittee’s investigation into the feasibility of the proposal,
the permittee decides to prepare a development application, it must first prepare a Notice of
Intent (NOI) and Pre-Application Document (PAD) pursuant to Sections 5.5 and 5.6 of the
Commission’s Regulations. Pursuant to Part 5 of the Commission’s regulations, 18 C.F.R.
Part 5, the permittee must use the Integrated Licensing Process unless the Commission grants
a request to use an alternative process (Alternative or Traditional Licensing Process).
Pursuant to Section 5.3, such a request must accompany the NOI and PAD and set forth
specific information justifying the request.
4 Should the permittee file a development
application, notice of the application will be published, and interested persons and agencies
will have an opportunity to intervene and to present their views concerning the project and the
effects of its construction and operation.
A preliminary permit is not transferable. The named permittee is the only party
entitled to the priority of application for license afforded by this preliminary permit. In order
to invoke permit-based priority in any subsequent licensing competition, the named
permittee must file an application for license as the sole applicant, thereby evidencing its
intent to be the sole licensee and to hold all proprietary rights necessary to construct, operate,
and maintain the proposed project. Should any other parties intend to hold during the term of
any license issued any of these proprietary rights necessary for project purposes, they must be
included as joint applicants in any application for license filed. In such an instance, where
parties other than the permittee are added as joint applicants for license, the joint application
will not be eligible for any permit-based priority. See City of Fayetteville,16 FERC 61,209
(1981).
The Director orders:
3 Issuance of this preliminary permit is thus not a major federal action significantly
affecting the quality of the human environment.
4See Commission Order 2002, issued July 23, 2003.
20081007-3019 FERC PDF (Unofficial) 10/07/2008
Project No. 13212-000 3
(A) A preliminary permit is issued for the this project to Kenai Hydro, LLC, for a
period effective the first day of the month in which this permit is issued, and ending either 36
months from the effective date or on the date that a development application submitted by the
permittee has been accepted for filing, whichever occurs first.
(B) This preliminary permit is subject to the terms and conditions of Part I of the
Federal Power Act and related regulations. The permit is also subject to Articles 1 through 4,
set forth in the attached standard form P-1.
(C) This order is issued under authority delegated to the Director and constitutes final
agency action. Requests for rehearing by the Commission may be filed within 30 days from
the date of issuance of this order, pursuant to 18 C.F.R. 385.713.
William Guey-Lee
Chief, Engineering and Jurisdiction Branch
Division of Hydropower Administration
and Compliance
20081007-3019 FERC PDF (Unofficial) 10/07/2008
Form P-1 (Revised February 2007)
FEDERAL ENERGY REGULATORY COMMISSION
TERMS AND CONDITIONS OF
PRELIMINARY PERMIT
Article 1. The purpose of the permit is to maintain priority of application for a license
during the term of the permit while the permittee conducts investigations and secures data
necessary to determine the feasibility of the proposed project and, if said project is found to be
feasible, prepares an acceptable application for license. In the course of whatever field studies
the permittee undertakes, the permittee shall at all time exercise appropriate measures to
prevent irreparable damage to the environment of the proposed project. All test sites shall be
restored as closely as possible to their original condition and to the satisfaction of the
Commission's authorized representative or, where federal lands are affected, to the
satisfaction of the agency administering such lands.
Article 2. The permit is not transferable and may, after notice and opportunity for
hearing, be canceled by order of the Commission upon failure of the permittee to prosecute
diligently the activities for which a permit is issued, or for any other good cause shown.
Article 3. The priority granted under the permit shall be lost if the permit is canceled
pursuant to Article 2 of this permit, or if the permittee fails, on or before the expiration date of
the permit, to file with the Commission an application for license for the proposed project in
conformity with the Commission's rules and regulations then in effect.
Article 4. At the close of each six-month period from the effective date of this permit,
the permittee shall file four copies of a progress report with the Secretary, Federal Energy
Regulatory Commission, 888 First Street, N.E., Washington, D.C. 20426; and shall serve a
copy on the interveners in this proceeding. The report shall describe, for that report period,
the nature and timing of what the permittee has done under the pre-filing requirements of 18
CFR §§ 4.38 and 5 and other applicable regulations; and, where studies require access to and
use of land not owned by the permittee, the status of the permittee's efforts to obtain
permission therefor.
20081007-3019 FERC PDF (Unofficial) 10/07/2008
Renewable Energy Fund Round 4
Project Cost/Benefit Worksheet
RFA AEA11-005 Application Cost Worksheet Page 1 7-21-10
Please note that some fields might not be applicable for all technologies or all project
phases. The level of information detail varies according to phase requirements.
1. Renewable Energy Source
The Applicant should demonstrate that the renewable energy resource is available on a
sustainable basis.
Annual average resource availability. The water resource is well documented in the form
of USGS stream gaging data available on Grant
Creek and Fall Creek, as well as in the referenced
1984 Ebasco study.
Unit depends on project type (e.g. windspeed, hydropower output, biomasss fuel)
2. Existing Energy Generation and Usage
a) Basic configuration (if system is part of the Railbelt 1
i. Number of generators/boilers/other
grid, leave this section blank)
ii. Rated capacity of generators/boilers/other
iii. Generator/boilers/other type
iv. Age of generators/boilers/other
v. Efficiency of generators/boilers/other
b) Annual O&M cost (if system is part of the Railbelt grid, leave this section blank)
i. Annual O&M cost for labor
ii. Annual O&M cost for non-labor
c) Annual electricity production and fuel usage (fill in as applicable) (if system is part of the
Railbelt grid, leave this section blank)
i. Electricity [kWh]
ii. Fuel usage
Diesel [gal]
Other
iii. Peak Load
iv. Average Load
v. Minimum Load
vi. Efficiency
vii. Future trends
d) Annual heating fuel usage (fill in as applicable)
i. Diesel [gal or MMBtu]
ii. Electricity [kWh]
iii. Propane [gal or MMBtu]
iv. Coal [tons or MMBtu]
1 The Railbelt grid connects all customers of Chugach Electric Association, Homer Electric Association, Golden Valley Electric
Association, the City of Seward Electric Department, Matanuska Electric Association and Anchorage Municipal Light and Power.
Renewable Energy Fund Round 4
Project Cost/Benefit Worksheet
RFA AEA11-005 Application Cost Worksheet Page 2 7-21-10
v. Wood [cords, green tons, dry tons]
vi. Other
3. Proposed System Design Capacity and Fuel Usage
(Include any projections for continued use of non-renewable fuels)
a) Proposed renewable capacity
(Wind, Hydro, Biomass, other)
[kW or MMBtu/hr]
Hydro
b) Proposed annual electricity or heat production (fill in as applicable)
i. Electricity [kWh] 5 MW nominal
ii. Heat [MMBtu]
c) Proposed annual fuel usage (fill in as applicable)
i. Propane [gal or MMBtu]
ii. Coal [tons or MMBtu]
iii. Wood [cords, green tons, dry tons]
iv. Other
4. Project Cost
a) Total capital cost of new system $27,160,000
b) Development cost $4,500,000
c) Annual O&M cost of new system ~$100,000
d) Annual fuel cost $ 0
5. Project Benefits
a) Amount of fuel displaced for
i. Electricity 197,626 MCF per year
ii. Heat
iii. Transportation
b) Current price of displaced fuel $6.83/ MCF of natural gas (2010)
c) Other economic benefits 19,585 MCF per year of spin savings & 44 fewer unit
starts.
d) Alaska public benefits Stabilize rates, lower emissions per kWh, conserve gas
6. Power Purchase/Sales Price
a) Price for power purchase/sale
7. Project Analysis
Renewable Energy Fund Round 4
Project Cost/Benefit Worksheet
RFA AEA11-005 Application Cost Worksheet Page 3 7-21-10
a) Basic Economic Analysis
Project benefit/cost ratio 1.42 this ratio is sensitive to the price of natural gas. See attached
Grant Lake Hydro Benefit – Cost Sept 2010 spreadsheet for details.
Payback (years) To be determined
AEA Grant RFA, Round 1 Application, October 8, 2008
GRANT LAKE/CREEK HYDRO BENEFIT-COST ANALYSIS
ASSUMPTIONS
5.0000 MW, Power Capacity 4%/Year, Discount Rate 9.6 Mcf per MWh for LM2500 Gas-fired Plant
47%CAPACITY FACTOR 3%/Year, Cost Escalation for O&M & Gas beyond 203 197,626 Mcf, Gas Required for Equivalent Hydro Energy
2.4 aMW, Net Capacity 5%/Year, Power Price Escalation 7 $/MW of Generation Without Fuel Cost
8760 Hours Per Year 10%/Year, Cost of Capital
100%Availability Multiplier 5.00$ /MWh, Estimated O&M Cost
20586000 kWh, Estimated Annual Power Production
4,532.00$ /kW Estimated Construction Cost
DATE
YEAR
#
DESIGN &
PERMITTING
COST
CONSTRUCTION
COST
Pay
Period
Cost of Capital
(Interest on
Loan)O&M COST
Present Worth
(PW) of Design
& Permitting
Costs
PW of
Construction
Cost
PW of Cost of
Capital
PW of O&M
Cost PW of All Costs
Projected
Price of Gas
($/Mcf)
Annual Avoided
Fuel Cost
Annual Fuel
Savings for 3MW
Spin
Total Annual
Fuel Savings Annual Revenue
Fuel Savings +
Annual Revenue
Present Worth of
Annual Avoided
Cost
Net Present Worth
= PW Avoided
Costs - PW All
Costs
Benefit:Cost
Ratio
PRESENT WORTH (2008) TOTALS ($4,006,640)($17,908,527)($25,898,683)($3,067,924)($50,881,775)$217,966,615 $21,612,834 $239,579,449 $38,502,179 $278,081,628 ($72,229,181)($21,347,406)1.42
2010 1 $900,000 $0 $0 ($865,385)6.83$ $133,762 $144,102
2011 2 $900,000 $0 $0 ($832,101)6.77$ $132,724 $151,307
2012 3 $900,000 $0 $0 ($800,097)7.16$ $140,256 $158,872
2013 4 $900,000 $0 $0 ($769,324)7.68$ $150,470 $166,816
2014 5 $900,000 $0 $0 ($739,734)8.05$ $157,661 $175,157
2015 6 $0 $22,660,000 1 $2,266,000 $0 ($17,908,527)($1,790,853)8.42$ $1,664,602 $165,056 $1,829,658 $183,915 $2,013,573
2016 7 $0 $0 2 $2,252,224 $102,930 ($1,711,505)($78,218)8.60$ $1,699,513 $168,518 $1,868,031 $193,110 $2,061,142 ($1,566,298)
2017 8 $0 $0 3 $2,237,071 $106,018 ($1,634,606)($77,466)8.73$ $1,725,128 $171,058 $1,896,186 $202,766 $2,098,952 ($1,533,684)
2018 9 $0 $0 4 $2,220,403 $109,198 ($1,560,026)($76,721)8.68$ $1,716,010 $170,154 $1,886,163 $212,904 $2,099,068 ($1,474,777)
2019 10 $0 $0 5 $2,202,068 $112,474 ($1,487,638)($75,984)8.94$ $1,767,043 $175,214 $1,942,257 $223,549 $2,165,806 ($1,463,141)
2020 11 $0 $0 6 $2,181,899 $115,849 ($1,417,320)($75,253)9.40$ $1,857,321 $184,166 $2,041,487 $234,727 $2,276,214 ($1,478,585)
2021 12 $0 $0 7 $2,159,713 $119,324 ($1,348,950)($74,529)9.94$ $1,965,023 $194,845 $2,159,868 $246,463 $2,406,332 ($1,502,988)
2022 13 $0 $0 8 $2,135,309 $122,904 ($1,282,411)($73,813)10.34$ $2,044,061 $202,682 $2,246,743 $258,786 $2,505,529 ($1,504,756)
2023 14 $0 $0 9 $2,108,464 $126,591 ($1,217,585)($73,103)10.79$ $2,131,547 $211,357 $2,342,904 $271,726 $2,614,630 ($1,509,884)
2024 15 $0 $0 10 $2,078,935 $130,389 ($1,154,359)($72,400)11.27$ $2,227,579 $220,879 $2,448,459 $285,312 $2,733,771 ($1,517,966)
2025 16 $0 $0 11 $2,046,453 $134,300 ($1,092,618)($71,704)11.52$ $2,276,074 $225,688 $2,501,762 $299,578 $2,801,339 ($1,495,658)
2026 17 $0 $0 12 $2,010,722 $138,329 ($1,032,251)($71,015)11.77$ $2,325,078 $230,547 $2,555,625 $314,557 $2,870,182 ($1,473,474)
2027 18 $0 $0 13 $1,971,419 $142,479 ($973,148)($70,332)12.24$ $2,419,778 $239,937 $2,659,715 $330,284 $2,990,000 ($1,475,948)
2028 19 $0 $0 14 $1,928,186 $146,754 ($915,199)($69,655)12.93$ $2,555,308 $253,376 $2,808,684 $346,799 $3,155,483 ($1,497,726)
2029 20 $0 $0 15 $1,880,628 $151,156 ($858,294)($68,986)13.56$ $2,679,154 $265,656 $2,944,810 $364,139 $3,308,949 ($1,510,161)
2030 21 $0 $0 16 $1,828,316 $155,691 ($802,326)($68,322)14.21$ $2,808,192 $278,451 $3,086,643 $382,346 $3,468,989 ($1,522,309)
2031 22 $0 $0 17 $1,770,772 $160,362 ($747,187)($67,665)14.97$ $2,957,665 $293,272 $3,250,937 $401,463 $3,652,399 ($1,541,150)
2032 23 $0 $0 18 $1,707,473 $165,172 ($692,767)($67,015)15.60$ $3,083,214 $305,721 $3,388,935 $421,536 $3,810,471 ($1,546,008)
2033 24 $0 $0 19 $1,637,845 $170,128 ($638,959)($66,370)16.36$ $3,233,149 $320,588 $3,553,737 $442,613 $3,996,350 ($1,559,062)
2034 25 $0 $0 20 $1,561,254 $175,231 ($585,653)($65,732)17.40$ $3,438,880 $340,988 $3,779,867 $464,743 $4,244,611 ($1,592,225)
2035 26 $0 $0 21 $1,477,004 $180,488 ($532,739)($65,100)18.23$ $3,602,539 $357,216 $3,959,755 $487,981 $4,447,735 ($1,604,250)
2036 27 $0 $0 22 $1,384,329 $185,903 ($480,108)($64,474)18.78$ $3,710,615 $367,932 $4,078,547 $512,380 $4,590,927 ($1,592,210)
2037 28 $0 $0 23 $1,282,386 $191,480 ($427,647)($63,854)19.34$ $3,821,934 $378,970 $4,200,904 $537,999 $4,738,902 ($1,580,317)
2038 29 $0 $0 24 $1,170,249 $197,225 ($375,242)($63,240)19.92$ $3,936,592 $390,339 $4,326,931 $564,898 $4,891,829 ($1,568,572)
2039 30 $0 $0 25 $1,046,898 $203,141 ($322,778)($62,632)20.52$ $4,054,689 $402,049 $4,456,739 $593,143 $5,049,882 ($1,556,973)
2040 31 $0 $0 26 $911,213 $209,235 ($270,138)($62,030)21.13$ $4,176,330 $414,111 $4,590,441 $622,801 $5,213,242 ($1,545,519)
2041 32 $0 $0 27 $761,958 $215,513 ($217,202)($61,434)21.77$ $4,301,620 $426,534 $4,728,154 $653,941 $5,382,095 ($1,534,209)
2042 33 $0 $0 28 $597,778 $221,978 ($163,848)($60,843)22.42$ $4,430,669 $439,330 $4,869,999 $686,638 $5,556,636 ($1,523,042)
2043 34 $0 $0 29 $417,181 $228,637 ($109,949)($60,258)23.09$ $4,563,589 $452,510 $5,016,099 $720,969 $5,737,068 ($1,512,016)
2044 35 $0 $0 30 $218,523 $235,496 ($55,377)($59,678)23.78$ $4,700,496 $466,085 $5,166,582 $757,018 $5,923,600 ($1,501,132)
2045 36 $0 $0 31 $242,561 ($59,105)24.50$ $4,841,511 $480,068 $5,321,579 $794,869 $6,116,448 ($1,490,387)
2046 37 $0 $0 32 $249,838 ($58,536)25.23$ $4,986,757 $494,470 $5,481,227 $834,612 $6,315,839 ($1,479,781)
2047 38 $0 $0 33 $257,333 ($57,973)25.99$ $5,136,359 $509,304 $5,645,663 $876,343 $6,522,006 ($1,469,313)
2048 39 $0 $0 34 $265,053 ($57,416)26.77$ $5,290,450 $524,583 $5,815,033 $920,160 $6,735,193 ($1,458,982)
2049 40 $0 $0 35 $273,005 ($56,864)27.57$ $5,449,164 $540,321 $5,989,484 $966,168 $6,955,652 ($1,448,786)
2050 41 $0 $0 36 $281,195 ($56,317)28.40$ $5,612,639 $556,530 $6,169,169 $1,014,476 $7,183,645 ($1,438,726)
2051 42 $0 $0 37 $289,631 ($55,776)29.25$ $5,781,018 $573,226 $6,354,244 $1,065,200 $7,419,444 ($1,428,799)
2052 43 $0 $0 38 $298,320 ($55,239)30.13$ $5,954,448 $590,423 $6,544,871 $1,118,460 $7,663,331 ($1,419,005)
2053 44 $0 $0 39 $307,269 ($54,708)31.03$ $6,133,082 $608,136 $6,741,217 $1,174,383 $7,915,601 ($1,409,344)
2054 45 $0 $0 40 $316,487 ($54,182)31.96$ $6,317,074 $626,380 $6,943,454 $1,233,102 $8,176,556 ($1,399,813)
2055 46 $0 $0 41 $325,982 ($53,661)32.92$ $6,506,586 $645,171 $7,151,757 $1,294,758 $8,446,515 ($1,390,413)
2056 47 $0 $0 42 $335,762 ($53,145)33.91$ $6,701,784 $664,526 $7,366,310 $1,359,495 $8,725,806 ($1,381,143)
2057 48 $0 $0 43 $345,834 ($52,634)34.93$ $6,902,837 $684,462 $7,587,300 $1,427,470 $9,014,770 ($1,372,001)
2058 49 $0 $0 44 $356,209 ($52,128)35.98$ $7,109,923 $704,996 $7,814,918 $1,498,844 $9,313,762 ($1,362,986)
2059 50 $0 $0 45 $366,896 ($51,627)37.06$ $7,323,220 $726,146 $8,049,366 $1,573,786 $9,623,152 ($1,354,099)
2060 51 $0 $0 46 $377,903 ($51,130)38.17$ $7,542,917 $747,930 $8,290,847 $1,652,475 $9,943,322 ($1,345,337)
2061 52 $0 $0 47 $389,240 ($50,639)39.31$ $7,769,204 $770,368 $8,539,572 $1,735,099 $10,274,671 ($1,336,701)
2062 53 $0 $0 48 $400,917 ($50,152)40.49$ $8,002,280 $793,479 $8,795,760 $1,821,854 $10,617,614 ($1,328,189)
2063 54 $0 $0 49 $412,944 ($49,670)41.71$ $8,242,349 $817,284 $9,059,632 $1,912,947 $10,972,579 ($1,319,801)
2064 55 $0 $0 50 $425,333 ($49,192)42.96$ $8,489,619 $841,802 $9,331,421 $2,008,594 $11,340,015 ($1,311,535)
COSTS
Power Production & Construction Financial Avoided Costs
SAVINGS
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON,D.C.20426
September 15,2009
OFFICE OF ENERGY PROJECTS
Project No.13212-001 and 13211-001
–Alaska
Grant Lake/Falls Creek Hydroelectric
Project
Kenai Hydro,L.L.C.
Steve Gilbert,Manager
Kenai Hydro,L.L.C.
6921 Howard Avenue
Anchorage,AK 99504
Reference:Authorization to Use the Traditional Licensing Process
Dear Mr.Gilbert:
In a letter filed August 6,2009,you requested to use the Traditional Licensing
Process (TLP)in preparing a license application for the proposed 4.5-megawatt Grant
Lake/Falls Creek Hydroelectric Project,which would be located on Grant Lake,Grant
Creek and Falls Creek on the Kenai Peninsula,near the community of Moose Pass,
Alaska.On August 6,2009,you filed a notice of intent and pre-application document
(PAD)for the proposed project.
On August 7,2009,you filed documentation that you published notice of your
request to use the TLP in editions of the Anchorage Daily News,Peninsula Clarion and
Homer Tribune.Your notice contained the information required in 18 C.F.R.§5.3(d)(2)
of the Commission’s regulations,including a statement requesting that comments on the
request to use the TLP be filed with the Commission within 30 days of the date of the
notice,which was by September 5,2009.
The U.S.Forest Service (Forest Service)and Alaska Department of Fish and
Game (Alaska DFG)filed comments September 4 and 8,2009,respectfully,supporting
the use of the TLP,with the request that scoping be held early in the licensing process to
advance timely study development and provide time for analysis of results.The Kenaitze
Indian Tribe,filed comments September 4,2009,expressing no opposition to the use of
the TLP.
20090915-3018 FERC PDF (Unofficial) 09/15/2009
P-13212-001 and P-13211-001 2
Comments from Michael Coone y and the Sierra Club Alaska Chapter,filed
September 8,and 10,2009,respectfully,expressed concerns with the use of the TLP,
particularly that the process does not afford adequate public involvement in which to
voice environmental concerns.The Sierra Club also expressed concerns that the
Integrated License Process (ILP),the Commission’s default license process,would need
to be modified through lengthened timeframes,to ensure adequate study development
and deployment.
Also,comments from the Alaska Center for the Environment,filed September 8,
2009,while not advocating one process over the other,do express the different
advantages of the ILP and TLP,noting that early scoping is one benefit of the ILP.
Holding scoping early in the licensing process,as suggested by the Forest Service
and the Alaska DFG,would provide early identification of issues by all interested parties,
which would help to foster the development of any needed studies.Kenai Hydro,L.L.C.,
in a comment filed September 10,2009,expressed support of the TLP with early scoping
and requested agencies and interested parties to consider this as an option when filing
their comments.Early scoping also addresses some of the concerns of the Sierra Club
Alaska Chapter and the Alaska Center for the Environment.In consideration of the
above,I am granting your request to use the TLP with early scoping.
If you have an y questions,please contact Joseph Adamson at (202)502-8085 or
via email at joseph.adamson@ferc.gov.
Sincerely,
Ann F.Miles,Director
Division of Hydropower
Licensing
cc:Mailing List
Public Files
Brad Zubeck,Project Engineer
Kenai Hydro,L.L.C.
280 Airport Way
Kenai,AK 99611
20090915-3018 FERC PDF (Unofficial) 09/15/2009
Document Content(s)
P-13212-001Letter.DOC.................................................1-2
20090915-3018 FERC PDF (Unofficial) 09/15/2009
FEDERAL ENERGY REGULATORY COMMISSION
Washington,D.C.20426
August 23,2010
OFFICE OF ENERGY PROJECTS
Project Nos.13212-001-AK and 13211-001-AK
Grant Lake/Falls Creek Hydroelectric Project
Kenai Hydro,LLC
Subject:Scoping Document 2 for the Grant Lake/Falls Creek Hydroelectric Project
To the Party Addressed:
On August 6,2009,Kenai Hydro,LLC (Kenai Hydro)filed with the Federal
Energy Regulatory Commission (Commission)a Notice of Intent to file a license
application,a request to use the Traditional Licensing Process,and a Pre-Application
Document for the proposed 5-megawatt Grant Lake/Falls Creek Project.
The Grant Lake/Falls Creek Hydroelectric Project (Grant Lake/Falls Creek Project
or project;FERC Project Nos.13212-001 and 13211-001),located on Grant Creek near
the outlet of Grant Lake just east of the Seward Highway (State Route 9)in the Kenai
Peninsula Borough near the community of Moose Pass,Alaska.The Commission granted
Kenai Hydro’s request to use the Traditional Licensing Process (TLP),with early
scoping,on September 15,2009.
Based on comments received and pursuant to the National Environmental Policy
Act (NEPA),Commission staff intends to prepare an Environmental Assessment (EA),
which will be used by the Commission to determine whether,and under what conditions,
to issue a license for the project.To support and assist our environmental review,we are
beginning the public scoping process to ensure that all pertinent issues are identified and
analyzed,and that the EA is thorough and balanced.
On May 11,2010,we issued Scoping Document 1,in which we disclosed our
preliminary view of the scope of environmental issues associated with the proposed
action.Based on the oral comments made at the June 2 and 3,2010 public scoping
meetings in Moose Pass,Alaska,and written comments received during the scoping
process,we have prepared the enclosed Scoping Document 2 (SD2).We appreciate the
participation of governmental agencies,non-governmental organizations,and the general
public in the scoping process.The enclosed SD2 for the proposed project is intended to
serve as a guide to the issues and alternatives to be addressed in the EA. SD2 is issued for
informational use by all interested entities;no response is required.Key changes fro SD1
to SD2 are identified in bold,italicized type.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
2
This scoping document is being distributed to both Kenai Hydro LLC’s
distribution list and the Commission’s official mailing list (Section 9.0 of the attached
SD2).If you wish to be added or removed from the Commission’s official mailing list,
please mail your request to Kimberly D.Bose,Federal Energy Regulatory Commission,
888 First Street,N.E.,Room 1A,Washington,DC 20426.All written requests must
specify your wish to be removed or added to the mailing list and must clearly identify the
following on the first page:Grant Lake/Falls Creek Hydroelectric Project Nos.13212-
001 and 13211-001.
For any questions about the SD2,the scoping process,or how the Commission
staff will develop the EA for this project,please contact Mark Ivy at (202)502-6156 or
mark.ivy@ferc.gov.Additional information about the Commission’s licensing process
and the Grant Lake/Falls Creek Hydroelectric Project may be obtained from our website,
http://www.ferc.gov.
Enclosure:Scoping Document 2
cc:Mailing List
Public Files
20100823-3012 FERC PDF (Unofficial) 08/23/2010
SCOPING DOCUMENT 2
GRANT LAKE/FALLS CREEK HYDROELECTRIC PROJECT
ALASKA
PROJECT NOS.13212-001 AND 13211-001
Federal Energy Regulatory Commission
Office of Energy Projects
Division of Hydropower Licensing
Washington,D.C.
August 2010
20100823-3012 FERC PDF (Unofficial) 08/23/2010
ii
TABLE OF CONTENTS
1.0 INTRODUCTION .....................................................................................................1
2.0 SCOPING ...................................................................................................................3
2.1 PURPOSES OF SCOPING .............................................................................................3
2.2 SCOPING MEETINGS AND COMMENTS ........................................................................4
2.3 ISSUES RAISED DURING SCOPING ..............................................................................5
3.0 PROPOSED ACTION AND ALTERNATIVES ..................................................14
3.1 THE PROPOSED ACTION .......................................................................................14
3.1.1 Proposed Project Facilities.............................................................................14
3.1.2 Proposed Project Operations ..........................................................................14
3.2 ALTERNATIVES TO THE PROPOSED ACTION .......................................................15
3.3 NO ACTION............................................................................................................15
4.0 SCOPE OF CUMULATIVE EFFECTS AND RESOURCE ISSUES ................15
4.1 CUMULATIVE EFFECTS ........................................................................................15
4.1.1 Resources That Could Be Cumulatively Affected .........................................16
4.1.2 Geographic Scope ...........................................................................................16
4.1.3 Temporal Scope ..............................................................................................16
4.2 RESOURCE ISSUES.................................................................................................16
4.2.1 Geologic and Soils Resources ........................................................................17
4.2.2 Water Quantity and Quality*.........................................................................17
4.2.3 Aquatic Resources*........................................................................................17
4.2.4 Terrestrial Resources ......................................................................................18
4.2.5 Threatened and Endangered Species.............................................................19
4.2.6 Recreation Resources and Land Use*..........................................................19
4.2.7 Aesthetic Resources .......................................................................................20
4.2.8 Cultural Resources ........................................................................................20
4.2.9 Socioeconomics .............................................................................................20
4.2.10 Developmental Resources ............................................................................20
5.0 POTENTIAL STUDIES..........................................................................................20
6.0 EA PREPARATION SCHEDULE ........................................................................22
7.0 PROPOSED EA OUTLINE....................................................................................23
8.0 COMPREHENSIVE PLANS .................................................................................24
9.0 FERC OFFICIAL MAILING LIST ......................................................................26
20100823-3012 FERC PDF (Unofficial) 08/23/2010
iii
LIST OF FIGURES
FIGURE 1.PROJECT LOCATION AND FACILITIES FOR THE GRANT LAKE PROJECT (SOURCE:
KENAI HYDRO LLC,SECTION 3 UPDATE,FILED AUGUST 13,2010)............................2
20100823-3012 FERC PDF (Unofficial) 08/23/2010
iv
ACRONYMS AND ABBREVIATIONS
ACE Alaska Center for the Environment
Alaska DEC Alaska Department of Environmental Conservation
Alaska DF&G Alaska Department of Fish and Game
Alaska DNR Alaska Department of Natural Resources
APE Area of Potential Effect
cfs cubic feet per second
COE United States Army Corps of Engineers
Commission or FERC Federal Energy Regulatory Commission
EA environmental assessment
EIS environmental impact statement
Forest Service U.S.Forest Service
FPA Federal Power Act
FWS U.S.Fish and Wildlife Service
Grant Lake Project Grant Lake/Falls Creek Hydroelectric Project
GWh gigawatt-hours
INHT Iditarod National Historic Trail
KAP Kenai Area Plan
Kenai Hydro Kenai Hydro,L.L.C./applicant
KMTA NHA Kenai Mountains –Turnagain Arm National
Heritage Area
KRS Kenai River Sportsfishing
KRWF Kenai River Watershed Foundation
kV kilovolt
msl mean sea level
MW megawatt
MWh megawatt-hours
NEPA National Environmental Policy Act
NPS National Park Service
NMFS National Marine Fisheries Service
NGO non-governmental organizations
PAD Pre-Application Document
PDEA preliminary draft environmental assessment
permits Preliminary Permits
project Grant Lake/Falls Creek Hydroelectric Project
RBCA Resurrection Bay Conservation Alliance
SD1 Scoping Document 1
SD2 Scoping Document 2
TLP Traditional Licensing Process
20100823-3012 FERC PDF (Unofficial) 08/23/2010
1
1.0 INTRODUCTION
The Federal Energy Regulatory Commission (Commission or FERC),under the
authority of the Federal Power Act (FPA),1 may issue licenses for terms ranging from 30
to 50 years for the construction,operation,and maintenance of non-federal hydroelectric
projects.On August 6,2009,Kenai Hydro (applicant)filed a Pre-Application Document
(PAD)and Notice of Intent to seek an original license for the 5-megawatt (MW)Grant
Lake/Falls Creek Hydroelectric Project (Grant Lake Project or project).2
The Grant Lake Project would be located on Grant Lake,Grant Creek and Falls
Creek on the Kenai Peninsula,near the community of Moose Pass,Alaska (Figure 1).
Portions of the project would occupy federal lands within the Chugach National Forest,
administered by the U.S.Forest Service (Forest Service).The PAD filed on August 6,
2009,included a diversion from Falls Creek diverting flows into a 13,000-foot-long pipe
to Grant Lake.On May 3,2010,the applicant filed a revised PAD and this diversion and
pipe are no longer being considered as part of the proposed project.On August 13,2010,
the applicant filed a revision to section 3.0 of the PAD which includes several
modifications to the project works.The project will now either include a smaller
diversion dam at the outlet of Grant Lake or no diversion dam at all,and will include
an intake,a power tunnel and short penstock,a powerhouse,a tailrace detention pond,
and a tailrace returning flows to Grant Creek.A more detailed description of the key
project facilities is provided in section 3.0.
The National Environmental Policy Act (NEPA)of 1969,3 the Commission’s
regulations,and other applicable laws require the Commission to independently evaluate
the environmental effects of issuing an original license for the Grant Lake Project as
proposed,and to consider reasonable alternatives to the applicant’s proposal.Although
Commission staff intends to prepare a draft and final environmental assessment (EA),
there is a possibility that an Environmental Impact Statement (EIS)will be required.The
EA will describe and evaluate the probable effects,including any site-specific and
cumulative effects,of the proposed action and alternatives.
1 16 U.S.C.§791(a)-825(r).
2 On October 7,2008,the Commission issued two Preliminary Permits (permits)to
Kenai Hydro to study the feasibility of developing hydroelectric projects on Grant Lake
and Falls Creek.The permits provide the applicant protection under the FPA from
competitive applications while conducting the studies and processes necessary to
complete an application for license.
3 National Environmental Policy Act of 1969,as amended (Pub.L.91-190.42
U.S.C.4321-4347,January 1,1970,as amended by Pub.L.94-52,July 3,1975,Pub.L.
94-83,August 9,1975,and Pub.L.97-258,§4(b),September 13,1982).
20100823-3012 FERC PDF (Unofficial) 08/23/2010
20100823-3012 FERC PDF (Unofficial) 08/23/2010
2
Figure 1. Project location and facilities for the Grant Lake Project (Source: Kenai Hydro
LLC, Section 3 update, filed August 13, 2010).
3
2.0 SCOPING
This Scoping Document 2 (SD2)is intended to advise all participants as to the
proposed scope of the EA and to seek additional information pertinent to this analysis.
This document contains:(1)a description of the scoping process;(2)a description of the
proposed action and alternatives;(3)a preliminary identification of environmental issues
and proposed studies;(4)a request for comments and information;(5)a proposed EA
outline;and (6)a preliminary list of comprehensive plans which would be applicable to
the project.
2.1 Purposes of Scoping
Scoping is the process used to identify issues,concerns,and opportunities for
enhancement or mitigation associated with a proposed action.According to NEPA,the
process should be conducted early in the planning stage of the project.
The purposes of scoping include:
•invite participation of federal,state and local resource agencies,Indian tribes,
non-governmental organizations (NGOs),and the public to identify significant
environmental and socioeconomic issues related to the proposed project;
•determine the depth of analysis and significance of issues to be addressed in the
EA;
•identify how the project would or would not contribute to cumulative effects in
the project area;
•identify reasonable alternatives to the proposed action that should be evaluated
in the EA;
•solicit,from participants,available information on the resources at issue,
including existing information and study needs;and
•determine the resource areas and potential issues that do not require detailed
analysis during project review.
We issued Scoping Document 1 (SD1)for the project on May 11,2010,to enable
appropriate resource agencies,Indian tribes,and other interested parties to more
effectively participate in and contribute to the scoping process.In SD1,we requested
clarification of preliminary issues concerning the Grant Lake/Falls Creek Project and
20100823-3012 FERC PDF (Unofficial) 08/23/2010
4
identification of any new issues that need to be addressed in the EA.We revised SD1
following the scoping meetings and after reviewing comments filed during the scoping
comment period.Key changes to SD1 are identified in bold,italicized type.
2.2 Scoping Meetings and Comments
The Commission’s staff held two scoping meetings in Moose Pass,Alaska,to
discuss potential issues associated with the Grant Lake/Falls Creek Project.The
scoping meetings were announced in local newspapers and in the Federal Register.An
evening scoping meeting was held on June 2,2010,and a morning meeting was held
on June 3,2010.A court reporter recorded oral comments made during the scoping
meetings.
In addition to the oral comments received at the scoping meetings,the following
17 agencies,individuals,and NGOs filed written comments on the SD1:
Entity Date Filed
Seward Iditarod Trail Blazers June 5,2010
John Polonowski June 15,2010
William Brennan June 23,2010
Kenai River Watershed Foundation
(KRWF)
June 25,2010;July 6,2010;July 19,2010
Becky Long June 25,2010
Michael Cooney July 6,2010
Alaska Center for the Environment (ACE)July 6,2010
Shawn Lynch July 6,2010
Resurrection Bay Conservation Alliance
(RBCA)
July 6,2010,July 7,20104
U.S.Department of Commerce,National
Oceanic and Atmospheric Administration,
National Marine Fisheries Service
July 6,2010
Alaska Department of Natural Resources,
Division of Mining,Land &Water
(Alaska DNR)
July 6,2010
U.S. Department of Interior,Fish and
Wildlife Service
July 6,2010
4 Public comments in response to a resolution regarding the development of the Grant
Lake/Falls Creek Hydropower Project considered by the Kenai Peninsula Borough
Assembly,during their June 21,2010 council meeting,were submitted as part of the
public record for this proceeding.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
5
U.S.Department of Interior,National
Park Service (NPS)
July 6,2010
Alaska Department of Fish and Game,
Division of Sport Fishing (Alaska DF&G)
July 6,2010
Kenai Hydro,LLC July 7,2010
U.S. Department of Agriculture,Forest
Service (Forest Service)
July 9,2010
U.S.Department of the Army,Corps of
Engineers (COE)
August 3,2010
All comments received are part of the Commission’s official record for the
project.Information in the official file is available for inspection and reproduction at
the Commission's Public Reference Room,located at 888 First Street,N.E.,Room 2A,
Washington,DC 20426,or by calling (202)502-8371.Information also may be
accessed through the Commission’s eLibrary using the “Documents &Filing”link on
the Commission’s web page at http://www.ferc.gov.Call (202)502-6652 for assistance.
2.3 Issues Raised During Scoping
The general concerns raised by participants in the scoping process are
summarized below by subject area.Oral comments received at the scoping meetings
are similar to those written comments submitted to the Commission during the
comment period.The summaries do not include every oral and written comment made
during the scoping process.For instance,we do not address comments that are
recom mendations for license conditions or schedule.Such comments will be addressed
when we request final terms,conditions,recommendations,and comments when we
issue our Ready for Environmental Analysis (REA)notice.This SD2 presents our
current view of issues and alternatives to be considered in the EA.
General Comments
Comment:Moose Pass community representatives stated that the environmental
document should be an EIS rather than an EA due to the controversial nature of the
project.
Response:The scoping process would satisfy NEPA requirem ents irrespective of
whether an EA or EIS is issued by the Commission.While our intent at the time of
scoping is to prepare an EA,a final decision on whether to prepare an EIS or an EA
will be made after completion of any required studies and the filing of Kenai Hydro’s
license application.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
6
Comment:Moose Pass community and NGO representatives encouraged the
exploration of Lowell Creek near Seward as an alternative site that may be better suited
to hydropower development.
Response:The current scoping effort is focused on Kenai Hydro’s proposed project at
Grant Lake which is filed with the Commission.
Comment:Alaska DNR requested that the Kenai Area Plan (KAP,2001)be added to
the list of comprehensive plans reviewed for this project.
Response:We will consider the KAP in our analysis.Please note that this plan should
be filed with the Commission in accordance with 18 CFR section 219,in order to be
considered for addition to the Commission’s List of Comprehensive Plans.
Comment:KRWF expressed concerns regarding the appropriateness of early scoping
for this project.
Response:Early scoping was requested by Forest Service and Alaska DF&G to
provide time for study development and for the analysis of results.
Resources That Could Be Cumulatively Affected
Comment:Moose Pass community and RBCA representatives stated that all resources
may be cumulatively impacted by this project.ACE indicated that the watershed may
be cumulatively affected as a result of project development.NPS and Forest Service
indicated that recreation may be cumulatively affected,and the Forest Service specified
that cumulative impacts to the Iditarod National Historic Trail (INHT)should be
thoroughly analyzed.
Response:The geographic scope for cumulative impacts analysis is identified in
section 4.1.2 as the Kenai River Basin;thus,the watershed will be analyzed regarding
cumulative impacts for water quantity,water quality,and fishery resources (as
identified in section 4.1.1).Conducting cumulative impact analysis for recreation
resources was raised during scoping and we have revised section 4.1.1 accordingly.
Geology and Soils Resources
Comment:COE requested an analysis of wetland and terrestrial soils.
Response:A bullet was added to assess the effects of the proposed project construction
and operations on soils in section 4.2.1.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
7
Comment:Alaska DNR and RBCA state that a reduction in water flows in the
bypassed reach may affect sediment transport and materials recruitment downstream.
Response:A bullet was added to assess the effects of the proposed project construction
and operations on sediment transport and materials recruitment downstream in section
4.2.1.
Water Quantity and Quality
Comment:Forest Service stated that project construction and operation could increase
heavy metal leaking to water in the project area as a result of water level fluctuations of
Grant Lake,an area of past mining and milling operations,and that this potential
effect should be analyzed.
Response:A bullet was added to assess the effects of project construction and
operations on heavy metal leaking into project area water as a result of water level
fluctuations of Grant Lake in section 4.2.2.
Comment:ACE stated that road development and vegetation clearing may affect water
quality.
Response:As currently stated in section 4.2.2,assessing the effects of project
construction and operation on water quality of Grant Lake,Grant Creek,Falls Creek,
Lower Trail Lake,and the Narrows,is sufficiently broad to capture road development
and clearing.
Comment:Moose Pass community and RBCA representatives voiced concern
regarding the potential impact of climate change on the amount of water available for
power generation,noting that the glaciers which feed the rivers and lakes in the region
have been receding.
Response:Predictions of future flow scenarios on any given stream would be too
speculative given the state of the science at this time.However,we do suggest that,
when making flow recommendations and conditions,agencies consider whether
different requirements for high and low water years are appropriate.
Aquatic Resources
Comment:Moose Pass community representatives requested that a model be
developed to assess the potential impact on anadromous fish of reducing summer flows
in order to enhance power generating flows during the winter months.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
8
Response:In the PAD,Kenai Hydro identified plans to conduct an instream flow study
to assess impacts from project operations.The results of this analysis will be analyzed
within the context of any license application that may be submitted by the applicant.
Comment:Alaska DF&G states that the effects of modified flows below the
powerhouse on aquatic resources should be evaluated.
Response:As currently stated in Section 4.2.3,assessing the effects of project
construction and operation on fish and aquatic resources of Grant Lake,Grant Creek,
Falls Creek,Lower Trail Lake,and the Narrows,is sufficiently broad to capture the
effects of modified flows on aquatic resources below the powerhouse.
Comment:Forest Service indicates that the effects of project construction and
operation on changes in distribution and abundance of aquatic insects should be
analyzed.
Response:As currently stated in Section 4.2.3,assessing the effects of project
construction and operation on fish and aquatic resources of Grant Lake,Grant Creek,
Falls Creek,Lower Trail Lake,and the Narrows,is sufficiently broad to capture
changes in distribution and abundance of aquatic insects..
Comment:RBCA indicates that the effects of project construction and operation on
changes in distribution and abundance of anadromous fish should be analyzed.
Response:As currently stated in section 4.2.3,assessing the effects of project
construction and operation on fish and aquatic resources of Grant Lake,Grant Creek,
Falls Creek,Lower Trail Lake,and the Narrows,is sufficiently broad to capture
changes in distribution and abundance of anadromous fish.
Comment:COE suggests the inclusion of riffle pool complexes as special aquatic sites
that should be evaluated regarding potential environmental impacts.
Response:As currently stated in section 4.2.3,assessing the effects of project
construction and operation on fish and aquatic resources of Grant Lake,Grant Creek,
Falls Creek,Lower Trail Lake,and the Narrows,is sufficiently broad to capture riffle
pool complexes.
Comment:Moose Pass community representatives suggest that if the geographic scope
of analysis is extended to include the mouth of the Kenai River,an assessment of the
impacts on beluga whales would be necessary.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
9
Response:The geographic scope for cumulative effects analysis for water quantity and
quality and aquatic resources has been set as the Kenai River basin,as stated in SD1.
Project effects outside of the basin would be impossible to directly attribute to the
proposed project therefore,extending the geographic scope to include open ocean
habitat utilized by beluga whales is not appropriate.Should the geographic scope of
analysis be extended to include the mouth of the Kenai River,a determination will be
made as to appropriateness of incorporating an assessment of the impacts on beluga
whales.
Terrestrial Resources
Comment:Alaska DNR suggested expanding the geographic scope to include areas
potentially impacted by project related road developm ent.
Response:A geographic scope is not defined within most of the bullets in section 4.2.4
so as to include all areas potentially impacted by project development,including road
development.
Comment:Forest Service states that the effects of project construction and operation
on changes to animal movem ent in and through the project area as well as
displacement and disruption of seasonal movement patterns should be analyzed.
Response:The existing bullet in section 4.2.4,effects of project construction and
operation on wildlife movement between Grant Lake and Trail Lake,has been modified
to include movement through the project area as well as displacement and disruption of
seasonal movement patterns.
Comment:Forest Service suggests that the effects of increased access on harvestable
wildlife should be analyzed.
Response:A bullet was added to assess that the effects of increased access to
harvestable wildlife in section 4.2.4.
Comment:Forest Service commented that project effects may extend beyond the
immediate project area.
Response:We agree.An analysis of the project effects may extend beyond the
immediate vicinity of the project.
Comment:ACE indicated that the Kenai Brown Bear is a species of special concern
that may be impacted by project development.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
10
Response:As currently stated in section 4.2.4,brown bear are identified as a Species of
Special Concern by the State of Alaska and will be included in the analysis.
Comment:Forest Service indicates that the effects of project construction and
operation on changes in distribution and abundance of aquatic insects’predators
should be analyzed (a specific interest in bats was expressed).
Response:In section 4.2.4,bats were added to the list of Management Indicator
Species under the bullet for effects of project construction and operation on wildlife
critical life stages,distribution,and abundance.
Comment:ACE requested further studies of avian use at Grant Lake.
Response:The existing bullet in section 4.2.4,effects of project construction and
operation on breeding and rearing habitat and nesting success of shorebirds and
waterfowl in Grant Lake and Inlet Creek has been broadened to include other avian
use in and around Grant Lake and Inlet Creek.
Recreation Resources and Land Use
Comment:Moose Pass community representatives and NPS identified the need to
determine the spectrum of recreational activities that occur within the project area and
assess the impacts of project development on each type of use.
Response:In the PAD,Kenai Hydro indicated that a recreational use assessment
would be conducted.The assessment should provide information to assess the effects
of project construction and operation on existing recreation and land use in and
around Grant Lake,Grant Creek,Falls Creek,Lower Trail Lake and the Narrows,as
stated in the existing bullet in section 4.2.6.
Comment:RBCA stated that displaced users from Grant Lake will likely increase
visitation to nearby water bodies including Carter Lake,Vagt Lake,Upper Trail Lake,
Trail River,Kenai Lake and Crescent Lake.The effects of increased use at alternative
destinations should be examined.
Response:A bullet has been added to section 4.2.6 to address this issue.
Comment:NGOs and Forest Service raised the issue of project construction and
operations on winter recreation use of Grant Lake due to unstable ice.
Response:This issue is already listed and will be evaluated.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
11
Comment:Forest Service stated that the effects of the proposed project on the roadless
character of the Kenai Mountains Roadless Area should be fully analyzed,including
any vegetative clearing along the shoreline of Grant Lake.Similarly,Moose Pass
community,NGO,and agency representatives voiced concern over the development of
the proposed access road within one mile of a Forest Service designated roadless area
(Kenai Mountains)and the potential for unauthorized motorized use.
Response:A bullet has been added to section 4.2.6 to address this issue.
Comment:The Forest Service,Alaska DNR,NGOs,and Moose Pass comm unity
representatives raised the issue of the proposed project access road affecting the Vagt
Lake Trail as well as the INHT right-of-way.The most recently proposed road corridor
would likely substantially alter and compromise the desired INHT recreation
experience,as well as fall within the Kenai River Special Management Area.
Response:A bullet has been added to section 4.2.6 to address this issue.
Comment:Moose Pass community representatives suggested that a 1000-foot lake
frontage development prohibition may exist on Upper and Lower Trail Lakes.
Response:After reviewing the Moose Pass Comprehensive Plan,the Kenai Peninsula
Borough Plan and the Kenai River Comprehensive Management Plan,no reference to
such a development restriction was found.
Comment:Moose Pass community and RBCA representatives identified a need to
conduct a detailed analysis of the impacts associated with development of the access
road and transmission line on neighboring landowners.
Response:As currently stated in section 4.2.6,assessing the effects of project
construction and operation on local residential land use,is sufficiently broad to capture
any impacts associated with development of the access road and transmission line on
neighboring landowners.
Comment:ACE suggests that project development may have an impact on the Black
Mountain Research Natural Area.
Response:As stated in section 4.2.6,effects of project construction and operation on
existing recreation and land use in and around Grant Lake,Grant Creek,Falls Creek,
Lower Trail Lake and the Narrows,is sufficiently broad to address potential impacts on
the Kenai Lake-Black Mountain Research Natural Area.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
12
Aesthetic Resources
Comment:NGOs and Moose Pass community representatives indicated that project
facilities,including the access road,powerhouse,transmission lines and surge tank will
negatively affect the aesthetics of the area as they will be visible from the Seward
Highway,Alaska Railroad,and from the air.Forest Service recommended that the
aesthetic impact assessment of project construction and operation consider aerial
views.Similarly,RBCA states that security lighting would mar the nighttime sky and
view.
Response:As currently stated in section 4.2.7,effects of project construction,facilities,
and operation on the aesthetic values of the project area,including noise and light
pollution,is sufficiently broad to addresses the aesthetic concerns identified by Moose
Pass Community and NGO representatives.
Cultural Resources
Comment:RBCA noted that known historic sites would be flooded thus jeopardizing
any existing artifacts located at those sites.
Response:As currently stated in section 4.2.8,effects of project construction and
operation on historical and archaeological resources,and properties of traditional
religious and cultural importance to Native Alaska tribes is sufficiently broad to
address concerns of flooding existing artifacts.
Comment:Moose Pass community representatives stated that the proposed project
falls within the recently designated Kenai Mountains –Turnagain Arm National
Heritage Area (KMTA NHA).
Response:Commission staff will review the management plan developed for the
KMTA NHA,should the plan be completed within the time frame of this license
application,in order to assess potential effects of project development on the KMTA-
NHA.
Comment:Forest Service and Moose Pass community representatives stated that an
assessment of impacts on subsistence use of resources should include both Native and
non-Native rural residents.
Response:comment noted and the bullet addressing this issue,in section 4.2.8,has
been modified to include non-Natives.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
13
Socioeconomic Resources
Comment:Several respondents indicated that energy infrastructure issues may
influence the need for increased power generation on the Kenai Peninsula.Moose
Pass community representatives state that an assessment should be conducted
regarding how the proposed Alaska Bullet Gas Line might impact the need for energy
and the cost/benefits of this project.Also,NPS stated that the regional electric grid
may already be at capacity and that there is an excess of power being generated on the
Kenai Peninsula.
Response:The need for power will be assessed in our developmental analysis for the
proposed project.
Comment:Moose Pass community and NGO representatives requested a study of the
potential impacts of project construction and operation on the recreation and tourism
driven local economy.Additionally,Moose Pass community representatives stated that
project development would negatively affect the comm unity without providing any
direct benefits to the residents of the area.
Response:As currently stated in section 4.2.9,the effects of project construction and
operation on local,tribal,and regional economies will be assessed.The public benefits
associated with project development will also be assessed.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
14
3.0 PROPOSED ACTION AND ALTERNATIVES
In accordance with NEPA,the environmental analysis will consider the following
alternatives,at a minimum:(1)the no-action alternative,(2)the applicant's proposed
action,and (3)alternatives to the proposed action.
3.1 The Proposed Action
3.1.1 Proposed Project Facilities
The project would consist of:a new 2-foot-high,120-foot-wide concrete gravity
dam on Grant Lake (or no dam at all),with a 60-foot-wide spillway section at elevation
700 feet mean sea level (msl)if new dam is built);the 1,790-acre Grant Lake with active
storage of 15,900 acre-feet between 687 and 698 feet msl;new outlet works including a
48-inch-diameter pipe and gatehouse;a new multi-level intake at Grant Lake;a new
3,200-foot-long,10-foot-high horseshoe power tunnel;a new 8-foot-diameter,110-foot-
high surge tank (10 feet would extend above ground);a new 360-foot-long,72-inch-
diameter steel penstock;a new powerhouse containing two Francis generating units with
total installed capacity of 5 MW;a new 200-foot-long open channel tailrace;a new 5 acre
tailrace detention pond;a 3.5-mile-long,overhead or underground transmission line at
24.9-kilovolt (kV);a new 4-mile-long access road;and appurtenant facilities.
3.1.2 Proposed Project Operations
Kenai Hydro is proposing to operate the project block loading and level control
(run-of-river)modes.The primary operational mode will be block loading at a specific
output level.Level control,or balancing of outflow to inflow,will likely only occur
during periods of low natural inflow to Grant Lake when the reservoir is at or near
minimum pool elevation.Additionally,the project will be used to fulfill a portion of
Homer Electric Company’s spinning reserve capacity requirement.With Grant Lake
operating as a regulating reservoir,the typical mode of operation will be to capture
high spring and summer runoff and to enter the late fall and winter season with the
reservoir full at elevation 698 feet msl (without an impoundment structure)or 700 feet
msl (with an impoundment structure).Water from Grant Lake would be diverted at the
new multi-level intake into the power tunnel,surge tank,and powerhouse.Flows from
the powerhouse would be discharged back into Grant Creek.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
15
3.1.3 Proposed Environmental Measures
Kenai Hydro proposes to conduct studies (section 5.0)to analyze the project’s
impact on environmental resources and develop appropriate protection,mitigation,and
enhancement measures.At this time,Kenai Hydro has identified the following
environmental measures to protect and enhance environmental resources of the project.
Terrestrial Resources
•Incorporate raptor protection guidelines into the transmission line design.
•Install collision avoidance devices on the transmission line in appropriate
locations to protect migratory birds.
Aesthetic Resources
•Incorporate setbacks into the transmission line route to minimize visual impacts
as viewed from the Seward Highway.
3.2 Alternatives to the Proposed Action
The EA will consider and analyze all recommendations for operation or facility
modifications,as well as for protection,mitigation,and enhancement measures identified
by Commission staff,resource agencies,Indian tribes,NGO’s,and the public.
3.3 No Action
Under the no-action alternative,the Commission would deny a license for the
proposed Grant Lake Project.The project would not be built and there would be no
change to the existing environment.We use this alternative to establish baseline
environmental conditions for comparison with other alternatives.
4.0 SCOPE OF CUMULATIVE EFFECTS AND RESOURCE ISSUES
4.1 Cumulative Effects
According to the Council on Environmental Quality's regulations for implementing
NEPA (50 C.F.R.1508.7),a cumulative effect is the effect on the environment that
results from the incremental effect of the action when added to other past,present and
reasonably foreseeable future actions,regardless of what agency (Federal or non-Federal)
or person undertakes such other actions.Cumulative effects can result from individually
20100823-3012 FERC PDF (Unofficial) 08/23/2010
16
minor but collectively significant actions taking place over a period of time,including
hydropower and other land and water development activities.
4.1.1 Resources That Could Be Cumulatively Affected
Based on information in the PAD,preliminary staff analysis,and scoping input,
we have identified water quantity,water quality,fishery resources,and recreation
resources as resources that could be cumulatively affected by the proposed construction
and operation of the project.
4.1.2 Geographic Scope
Our geographic scope of analysis for cumulatively affected resources is defined by
the physical limits or boundaries of the proposed action’s effect on the resources and
contributing effects from other hydropower non-hydropower activities within the Kenai
River Basin.
At this time,we have tentatively identified the Kenai River Basin as our
geographic scope of analysis for water quantity,water quality,fishery resources and
recreation resources.As more information is provided during the licensing process the
geographic scope may be adjusted as appropriate.
4.1.3 Temporal Scope
The temporal scope of our cumulative effects analysis in the EA will include a
discussion of past,present,and future actions and their effects on each resource.Based
on the potential term of a new license,the temporal scope will look 30-50 years into the
future,concentrating on the effect to the resources from reasonably foreseeable future
actions.The historical discussion will,by necessity,be limited to the amount of available
information for each resource.The quality and quantity of information,however,
diminishes as we analyze resources further away in time from the present.
4.2 Resource Issues
In this section,we present a preliminary list of environmental issues to be
addressed in the EA.We have identified these issues,which are listed by resource area,
by reviewing the PAD and the Commission’s record for this proceeding.This list is not
intended to be exhaustive or final,but contains those issues raised to date that could have
substantial effects.After the scoping process is complete,we will review the list and
determine the appropriate level of analysis needed to address each issue in the EA.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
17
Issues identified by an asterisk (*)will be analyzed for both cumulative and site specific
effects.
4.2.1 Geologic and Soils Resources
•Effects of project construction and operation on erosion and sedimentation of
Grant Lake and its shoreline.
•Effects of project construction and operation on erosion or sedimentation of the
existing Inlet Creek delta.
•Effects of construction of the proposed outlet works,diversion structure,
intake structure,tunnel,penstock,surge tower,powerhouse,tailrace
detention basin,tailrace,access roads and transmission line on erosion and
sedimentation of Grant Creek,the Narrows and Lower Trail Lake..
•Disposal/dispersion methods of spoil material resulting from construction of
the proposed project facilities and impact on the surrounding areas.
4.2.2 Water Quantity and Quality*
•Effects of project construction and operation on the water quality of Grant
Lake,Grant Creek,Falls Creek,Lower Trail Lake,and the Narrows.
•Effects of project construction and operation on the hydrology of Grant Lake,
Grant Creek,Falls Creek,Lower Trail Lake and the Narrows.
•Effects of project construction and operation on heavy metal leaking as a
result of water level fluctuations of Grant Lake.
4.2.3 Aquatic Resources*
•Effects of project construction and operation on the fish and aquatic resources
in Grant Lake,Grant Creek,Falls Creek,Lower Trail Lake and the Narrows.
•Effects of diverted flows on fish and aquatic resources in the proposed
bypassed reach of Grant Creek.
•Effects of Grant Lake reservoir fluctuations on fish and aquatic resources.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
18
•Effects of entrainment on fish populations in Grant Lake and Grant Creek.
•Effects of the loss of habitat connectivity and bi-directional passage on resident
fish populations in Grant Lake and Grant Creek.
•Effects of project construction and operation on changes in distribution and
abundance of aquatic insects.
•Effects of the proposed project construction and operations on sediment
transport and materials recruitment downstream.
4.2.4 Terrestrial Resources
•Effects of project construction and operation on the distribution and abundance
of plant species designated by the Forest Service as sensitive.
•Effects of project construction and operation on the distribution and abundance
of invasive plant species.
•Effects of project construction and operation on forest/scrub,wetland,riparian,
and littoral habitats used by wildlife on Grant Lake and Grant Creek.
•Effects of project construction and operation on wildlife critical life stages,
distribution,and abundance,including:
o Wildlife species designated by the Forest Service as Management
Indicator Species,such as:brown bear,moose,bats and mountain goat.
o Wildlife species designated by the Forest Service as Species of Special
Interest,such as:Canada lynx,wolverine,river otter,marbled murrelet,
Townsend’s warbler,Northern goshawk,bald eagle,and osprey.
o Wildlife species designated by the State of Alaska as Species of Special
Concern,such as:olive-sided flycatcher,gray-cheeked warbler,
blackpoll warbler,and brown bear.
•Effects of project operation on availability of fish as food for wildlife.
•Effects of project construction and operation on wildlife movement as well as
displacement and disruption of seasonal movement patterns through the
20100823-3012 FERC PDF (Unofficial) 08/23/2010
19
project area.
•Effects of project construction and operation on increased access to
harvestable wildlife.
•Effects of project operation on littoral wildlife habitat at the narrows between
Upper and Lower Trail Lakes.
•Effects of project construction and operation on breeding and rearing habitat
and nesting success of shorebirds and waterfowl,and other avian use in and
around Grant Lake and Inlet Creek.
•Effect of project transmission lines on raptors and other birds,including
electrocution and collision hazards.
4.2.5 Threatened and Endangered Species
•No federally listed threatened and endangered species are known to occur in
the project vicinity.No issues regarding threatened and endangered species
have been identified at this time.
4.2.6 Recreation Resources and Land Use*
•Effects of project construction and operation on existing recreation and land
use in and around Grant Lake,Grant Creek,Falls Creek,Lower Trail Lake and
the Narrows.
•Effects of project construction and operation on current and future (over the
term of a license)recreation demand and use,including barrier-free access and
the need for and benefit of interpretive opportunities (such as interpretive
signs)at the project.
•Effects of project construction and operation on local residential land use.
•Effects of project construction and operation on the roadless character of the
Kenai Mountains Roadless Area.
•Effects of the development of a project access road on the existing Vagt Lake
Trail as well as the INHT right of way.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
20
•Effects of recreational use at Grant Lake on the potential to increase
recreational use at nearby water bodies.
4.2.7 Aesthetic Resources
•Effects of project construction,facilities,and operation on the aesthetic values
of the project area,including noise and light pollution.
•Effects of the transmission line on Scenic Byway viewpoints from the Seward
“All American”Highway and views from existing recreation trails such as the
Iditarod National Historic Trail.
4.2.8 Cultural Resources
•Effects of project construction and operation on historical and archaeological
resources,and properties of traditional religious and cultural importance to
Native Alaska tribes.
•Effects of Grant Lake reservoir fluctuations and reduced flows in Grant Creek
on archaeological resources located along the reservoir shoreline.
•Effects of project construction and operation on subsistence use (hunting,
fishing,and gathering)involving Native Alaskan tribes and non-Native
Alaskans.
4.2.9 Socioeconomics
•Effects of project construction and operation on local,tribal,and regional
economies.
4.2.10 Developmental Resources
•Effects of recommended environmental measures on project generation and
economics.
•Effects of construction,operation,and maintenance on project economics.
5.0 POTENTIAL STUDIES
Depending upon the findings of studies completed by Kenai Hydro,L.L.C.and the
20100823-3012 FERC PDF (Unofficial) 08/23/2010
21
recommendations of the consulted entities,the applicant will consider,and may propose
certain measures to enhance environmental resources affected by the project as part of the
proposed action.The following are the applicant’s initial study proposals to fill
information gaps to address the above issues and determine appropriate environmental
measures.Further studies may need to be added to this list based on comments provided
to the Commission from interested participants,including Indian tribes.Kenai Hydro,
L.L.C.proposes the following:
Geology and Soils
•Grant Lake Shoreline Erosional Processes Study
Water Resources
•Hydrology of Grant Lake/Grant Creek and Falls Creek Watersheds
•Water Quality of Grant Lake/Grant Creek and Falls Creek Watersheds
Fisheries and Aquatic Resources
•Grant Lake Fish Resources Distribution and Abundance
•Grant Creek Fish Resources Abundance and Distribution
•Grant Creek Habitat Modeling/Instream Flow Analysis
•Falls Creek Fish Resources Distribution and Abundance
Terrestrial Resources
•Wildlife and Bird Surveys and Habitat Use Mapping
•Vegetation Surveys and Mapping
•Wetlands Mapping
Cultural Resources
•Subsistence and Cultural Use Study
•Historical and Archeological Resources Survey
Recreation Resources and Land Use
•Recreation Use Assessment
•Land Use and Facilities Study (includes lands,roads,and construction
practices)
20100823-3012 FERC PDF (Unofficial) 08/23/2010
22
Visual and Aesthetic Resources
•Aesthetic/Visual Resources Study
Socioeconomics
•Socioeconomics assessment to assess project-related effects on the local and
regional economy.
6.0 EA PREPARATION SCHEDULE
At this time,we anticipate the need to prepare a draft and final EA.The draft EA
will be sent to all persons and entities on the Commission’s service and mailing lists for
the Grant Lake Project.The EA will include our recommendations for operating
procedures,as well as environmental protection and enhancement measures that should
be part of any license issued by the Commission.All recipients will then have 30 days to
review the EA and file written comments with the Commission.All comments on the
draft EA filed with the Commission will be considered in preparation of the final EA.
The major milestones,including those for preparing the EA,are as follows:5
Major Milestone Target Date
Scoping Meetings June 2-3,2010
License Application Filed October 2013
Ready for Environmental Analysis Notice Issued January 2014
Deadline for Filing Comments,Recommendations and
Agency Terms and Conditions/Prescriptions March 2014
Draft EA Issued September 2014
Comments on Draft EA Due November 2014
Final EA Issued February 2015
If Commission staff determines that there is a need for additional information or
additional studies,the issuance of the Ready for Environmental Analysis notice could be
delayed.If this occurs,all subsequent milestones would be delayed by the time allowed
for the applicant to respond to the Commission’s request.
5 This schedule assumes that a draft and final EA would be prepared.If a draft and
final EIS is prepared the target dates for comments on the draft EIS and deadline for
filing modified agency recommendations may need to be revised.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
23
7.0 PROPOSED EA OUTLINE
The preliminary outline for the Grant Lake Project EA is as follows:
TABLE OF CONTENTS
LIST OF APPENDICES
LIST OF FIGURES
LIST OF TABLES
ACRONYMS AND ABBREVIATIONS
EXECUTIVE SUMMARY
1.0 INTRODUCTION
1.1 Application
1.2 Purpose of Action and Need for Power
1.3 Statutory and Regulatory Requirements
1.3.1 Federal Power Act
1.3.1.1 Section 18 Fishway Prescriptions
1.3.1.2 Section 4(e)Conditions
1.3.1.3 Section 10(j)Recommendations
1.3.2 Clean Water Act
1.3.3 Endangered Species Act
1.3.4 Coastal Zone Management Act
1.3.5 National Historic Preservation Act
1.3.6 Magnuson-Stevens Fishery Conservation and Management Act
1.4 Public Review and Comment
1.4.1 Scoping
1.4.2 Interventions
1.4.3 Comments on the Application
1.4.4 Comments on Draft EA
2.0 PROPOSED ACTION AND ALTERNATIVES
2.1 No-action Alternative
2.2 Proposed Action
2.2.1 Proposed Project Facilities
2.2.2 Project Safety
2.2.2 Proposed Project Operation
2.2.3 Proposed Environmental Measures
2.2.4 Modifications to Applicant’s Proposal—Mandatory Conditions
2.3 Staff Alternative
2.4 Staff Alternative with Mandatory Conditions
2.5 Alternatives Considered but Eliminated from Detailed Study
20100823-3012 FERC PDF (Unofficial) 08/23/2010
24
3.0 ENVIRONMENTAL ANALYSIS
3.1 General Description of the River Basin
3.2 Scope of Cumulative Effects Analysis
3.2.1 Geographic Scope
3.2.2 Temporal Scope
3.3 Proposed Action and Action Alternatives
3.3.1 Geologic and Soil Resources
3.3.2 Aquatic Resources
3.3.3 Terrestrial Resources
3.3.4 Threatened and Endangered Species
3.3.5 Recreation and Land Use
3.3.6 Cultural Resources
3.3.7 Aesthetic Resources
3.3.8 Socioeconomics
3.4 No-action Alternative
4.0 DEVELOPMENTAL ANALYSIS
4.1 Power and Economic Benefits of the Project
4.2 Cost of Environmental Measures
4.3 Comparison of Alternatives
5.0 CONCLUSIONS AND RECOMMENDATIONS
5.1 Comparison of Effects of Proposed Action and Alternatives
5.2 Comprehensive Development and Recommended Alternative
5.3 Unavoidable Adverse Effects
5.4 Recommendations of Fish and Wildlife Agencies
5.5 Consistency with Comprehensive Plans
6.0 FINDING OF NO SIGNIFICANT IMPACT (OR OF SIGNIFICANT IMPACT)
7.0 LITERATURE CITED
8.0 LIST OF PREPARERS
APPENDICES
8.0 COMPREHENSIVE PLANS
Section 10(a)(2)of the FPA,16 U.S.C.section 803(a)(2)(A),requires the
Commission to consider the extent to which a project is consistent with federal and state
comprehensive plans for improving,developing,or conserving a waterway or waterways
affected by a project.We have a preliminarily identified and reviewed the plans listed
below that may be relevant to the proposed Grant Lake Project.Agencies are requested
to review this list and inform the Commission staff of any changes.If there are other
comprehensive plans that should be considered for this list that are not on file with the
Commission,or if there are more recent versions of the plans already listed,they can be
filed for consideration with the Commission according to 18 C.F.R. 2.19 of the
20100823-3012 FERC PDF (Unofficial) 08/23/2010
25
Commission’s regulations.Please follow the instructions for filing a plan at
http://www.ferc.gov/industries/hydropower/gen-info/licensing/complan.pdf.
Alaska
Alaska Department of Fish and Game.Anchor River/Fritz Creek Critical Habitat
Area,June 1989;Anchorage Coastal Wildlife Refuge,February 1991;Kachemak
Bay/Fox River Flats Critical Habitat Areas,December 1993;McNeil River State
Game Refuge &State Game Sanctuary (draft),November 1995;Mendenhall
Wetlands State Game Refuge,March 1990;Minto Flats State Game Refuge,
March 1992;Palmer Hay Flats State Game Refuge,November 1986;Trading Bay
State Game Refuge &Redoubt Bay Critical Habitat Area,July 1994;Susitna Flats
State Game Refuge,March 1988;Tugidak Island Critical Habitat Area,June 1995;
Yakataga State Game Refuge,June 1999.Juneau,Alaska.
Alaska Department of Fish and Game.1998.Catalog of waters important for
spawning,rearing or migration of anadromous fishes.November 1998.Juneau,
Alaska.
Alaska Department of Fish and Game.1998.Atlas to the catalog of waters
important for spawning,rearing or migration of anadromous fishes.November
1998.Juneau,Alaska.
Alaska Department of Fish and Game.2000.Kenai Peninsula brown bear
conservation strategy.Juneau,Alaska.June 2000.
Alaska Department of Fish and Game.1997.Kenai River comprehensive
management plan.Juneau,Alaska.December 1997.
Alaska Department of Natural Resources.1984.Fish Creek management plan.
Anchorage,Alaska.August 1984.
Alaska Department of Natural Resources.2004.Alaska's Outdoor Legacy:
Statewide Comprehensive Outdoor Recreation Plan (SCORP)2004-2009.Juneau,
Alaska.July 2004.
Federal
Bureau of Land Management.1981.South central Alaska water resources study:
Anticipating water and related land resource needs.Anchorage,Alaska.
October 1,1981.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
26
Forest Service.2002.Chugach National Forest revised land and resource
management plan.Department of Agriculture,Anchorage,Alaska.May 31,2002.
U.S.Fish and Wildlife Service.Undated.Fisheries USA:the recreational fisheries
policy of the U.S.Fish and Wildlife Service.Washington,D.C.
9.0 FERC OFFICIAL MAILING LIST
If you want to receive future mailings for this project and you did not receive
notice of these meetings from the Commission,please send your request by mail to:
Kimberly D.Bose,Secretary,Federal Energy Regulatory Commission,888 First Street,
NE,Room 1A,Washington,DC 20426.All written requests to be added to the
Commission’s mailing list must clearly identify the following on the first page:“Grant
Lake/Falls Creek Hydroelectric Project Nos.13212-00 and 13211-0011.”You may use
the same method to remove your name from the Commission’s mailing list for this
project.
Also,please notify the applicant if you would like to be placed on their
Distribution List for this project.
Register online at http://www.ferc.gov/esubscribenow.htm to be notified via email
of new filings and issuances related to this or other pending projects.For assistance,
please contact FERC Online Support at FERCOnlineSupport@ferc.gov or toll free (806)
208-3676,or for TTY,(202)502-8659.
20100823-3012 FERC PDF (Unofficial) 08/23/2010
Document Content(s)
P-13212-001Letter.DOC.................................................1-32
20100823-3012 FERC PDF (Unofficial) 08/23/2010
ALASKA STATE LEGISLATURE
SESSION ADDRESS INTERIM ADDRESSES:
Alaska State Capitol 112 Mill Bay Road 345 W. Sterling Hwy.#102
Juneau, AK 99801-1182 Kodiak, AK 99615 Homer, AK 99603
(907) 465-4925 (907) 486-4925 (907) 235-0690
Fax (907) 465-3517 Fax (907) 486-5264 Fax (907) 235-4008
Senator Gary Stevens
Senate President
September 14, 2010
To whom it may concern:
The provision of clean, affordable, renewable energy for Alaska in the 21st century is foremost
among the many challenges confronting our state. Homer Electric Association’s (HEA)
proposed Grant Lake Hydroelectric Facility would be a significant step in achieving this
objective.
The Grant Lake Hydro project, at the headwaters of the Kenai River watershed near Moose Pass,
would supply 5 MW of low impact, low cost hydro energy to the residents of the Kenai
Peninsula. The displacement of conventional generation would conserve dwindling Cook Inlet
gas supplies; and secure long term price stability. Initial feasibility studies and the Federal
Energy Regulatory Commission’s granting of a licensing path recommend that this project’s
potential be thoroughly investigated.
The enhanced flexibility in systems operation afforded by this project will also facilitate the
development of other non-dispatchable renewables, such as wind.
Clean, affordable energy and jobs for Alaskans: that’s an energy solution we can all agree upon.
I endorse and applaud Homer Electric Association’s efforts to make this project a reality.
Sincerely,
Senator Gary Stevens
Senate President
Alaska State Legislature
State Capitol, Room 102 345 W. Sterling Highway
Juneau, AK 99802 Suite 102B
Phone: 465-2689 Homer, AK 99603
Fax: 465-3472 Phone: 235-2921
Toll Free (800) 665-2689 Fax: 235-4008
Representative_Paul_Seaton@legis.state.ak.us
REPRESENTATIVE Paul Seaton
District 35
September 14, 2010
To whom it may concern:
The provision of clean, affordable, renewable energy for Alaska in the 21st century is foremost among the
many challenges confronting our state. Homer Electric Association’s (HEA) proposed Grant Lake
Hydroelectric Facility would be a significant step in achieving this objective.
The Grant Lake Hydro project, at the headwaters of the Kenai River watershed near Moose Pass, would
supply 5 MW of low impact, low cost hydro energy to the residents of the Kenai Peninsula. The
displacement of conventional generation would conserve dwindling Cook Inlet gas supplies; and secure
long term price stability. Initial feasibility studies and the Federal Energy Regulatory Commission’s
granting of a licensing path recommend that this project’s potential be thoroughly investigated.
The enhanced flexibility in systems operation afforded by this projects will also facilitate the development
of other non-dispatchable renewables, such as wind.
Clean, affordable energy and jobs for Alaskans: that’s an energy solution we can all agree upon. I
endorse and applaud Homer Electric Association’s efforts to make this project a reality if it proves to be
economically and environmentally sound.
Sincerely,
Representative Paul Seaton