HomeMy WebLinkAboutADF&G-ConnellyJnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
DEPARTMENT OF FISH AND GAME
OFFICE OF THE COMMISSIONER
TONY'KNOWLES, GOVERNOR
ORIGINAL
P.O. BOX 25S2e
JUNEAU, ALASKA I)9802-5526
PHONE: (9O~ ,~o4~00
FACSIMILE: (9O7) 4tt5-2332
November 15, 2002
Honorable Magaiie R. Salas
Office of the Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
¢D..<
Dear Secretary Sales:
Re: MOTION TO INTERVENE
Cormelly Lake Hydroeleetric Project, FERC No. 12336-000 and 12338-000
Pursuant to 18 CFR §385.210, 385.211, and 385.214, enclosed are the original and eight copies
of the Alaska Department ofFish and Game's (ADF&G) MOTION TO INTERVENE on the
proposed Connelly Lake Hydroelectric Project.
Clayton Hawkes, in our Douglas regional office, will serve as the primary depar~ent liaison and
contact for this licensing review. Mr. Hawkes will coordinate with other deparUnental staff,
including Carl Schrader of the Douglas regional office of ADF&G. Mr. Schrader is our lead
representative for departmental fish habitat permits that will be required for this project.
Sincerely,
Frank Rue
Commissioner
CA3: Kelly Hepler, ADF&G
Robert Mecum, ADF&G
Ellen Fritts, ADF&G
Randolph Erieksen, ADF&G
Blaine Hollis, Alaska AG Office
Linch Shaw, NMFS
Wayne Regelin, ADF&G
Mary Pete, ADF&G
Neil Barren, ADF&G
Jim Powell, ADEC
James Balsiger, NMFS
Richard Enriquez, USFWS
11-K2LH
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
BEFORE THE
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
In the matter of:
Connelly Lake Hydroelectric Project
"Power" Creek and Chilkoot River
Haines, Alaska Projects No. 12336-000 and 12338-000
ALASKA DEPARTMENT OF FISH AND GAME'S
MOTION TO INTERVENE
Pursuant to 18 CFR § 385.713, enclosed are the original and eight copies of the Alaska
Department of Fish and Game's (ADF&G) motion to intervene on competing pre "hminary permit
applications for the proposed Connelly Lake Hydroelectric Project.
I. INTERESTS
The Petitioner, the Alaska Department of Fish and Game (ADF&G), is the State of Alaska's
principal manager of fish and wildlife resources and their habitats. ADF&G is mandated under
state law to "manage, protect, maintain, improve, and extend the fish, game, and aquatic plant
resources of the state in the interest of the economy and general well-being of the state..." (AS
16.05.020). Among ADF&G's various powers and duties are "to assist the United States Fish
and Wildlife Service in the eufo~ent of federal laws and regulations pertaining to fish and
game..." (AS 16.05.050), and protect fish habitat (AS 16.05.840 and AS 16.05.870).
Managing Alaska's fish and wildlife resources and protecting the habitat that sustains them are
integral to the health of the state's economy. Collectively, comm~cial, sport, and subsistence
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
Secretary Magalie R. Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
fisheries generate over a billion dollars annually to the state's economy. Following the oil
Industry and government sectors, these fisheries represent the third largest source of income to
the state's economy. Tourism is the fourth largest industry In Alaska. Tourism depends, in part,
on maintaining water-related recreational opportunities such as fishing, hunting, and sightseeing.
Accordingly, balancing development with maintaining the quality and quantity of aquatic and
terrestrial habitats are high priorities in Alaska.
Alaska Power and Telephone Company (AP&T, FERC No. 12336-000) and Pacific Energy
(FERC No. 12338-000), filed competing applications for the Connelly Lake project on August
14 and 16, 2002, respectively. These proposals for Federal Energy Regulatory Commission
(FERC/Commission) licensed projects appear to be basically the same as AP&T's earlier
proposals for preliminary FERC permits: Connelly Lake Hydroelectric Project (FERC No. 11715
and Upper Chilkoot Hydroelectric Project (FERC No. 11319). On January 9, 1993 t and April
29, 1996, the Commission issued preliminary permits to Haines Light and Power Company
(HL&P) to study the technical, environmental, and economic feasibility of developing the
proposed projecL In 1996, AP&T purchased HL&P, thereby acquiring the prior existing
preliminary permit for the Upper Chilkoot project. Preliminary permit (FERC No. 11715) was
issued on August 27, 1999, for the same project with a different name - Connelly Lake.
Therefore, if our interpretation is accurate, the present applications are the fourth and fifth
preliminary permits issued to study the feasibility of developing hydroelectric power at this site.
z Preliminary Permit for FERC Project 11319 expired on December 31, 1995.
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
Secretary Magalie R. Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
The two applications do not specifically state where the powerhouse and tailrace would be
located in the Chilkoot River watershed. Based upon the fact that the two proposed projects
have identical penstock lengths and similar hydraulic head as the previous applications, these
proposals likely have similar site configurations as HL&P's original proposed project, which
discharged to an anadromous fish stream containing about 0.25 miles of anadromous habitat,
designated by HL&P as "Power" Creek.
Power Creek is catalogued for AS 16.05 (Title 16) permit protection and is identified as ADF&G
# 115-33-10200-2016 in the Catalog of Wa!er~ important for Spawnlng- Re~ing or Migration of
(Catalog). 2 This clesr-water U'ibutary to the Cliilkoot River provides rearing
habitat for Dolly Varden char and coho salmon. Projects within or affecting anadromous fish
water bodies are jurisdictional under AS 16.05.870 and require a Title 16 Fish Habitat Permit
from ADF&G. Projects that have the potential to impact fish passage (applies to all fish species
in all fish-bearing waters) are subject to AS 16.05.840 and also require a Title 16 Permit.
The proposed project transmission lines and access roads would traverse the Chilknot Valley.
Pacific Energy's proposed transmission line, if above ground, would have the potential to
electrocute eagles that use power poles to roost. This important wildlife habitat area is part of
the Alaska Chilkat Bald Eagle Preserve (Preserve), established in June 1982 under AS 41.21.610
- 41.21.630 to protect and perpetuate the world's largest concentration ofbald eagles and their
2 The CAtalog of Waters ~t for SDawninm Rearino or Mim-ation of Anadromous Fishes and Atlas
to the Catalog are included in the Commission's April 2002 revised list of comprehonsive plans.
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
Secretary Magalie R. Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
4 November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
critical habitat. The proposed project area also provides important habitat for brown and black
bears, moose, mountain goats, fiubearers, and other wildlife. The project has the potential to
adversely affect the migrations of some of these species. Article VIII, Section 4, of the
Constitution of the State of Alaska states that fish and wildlife and all replenishable resources
belong to the state and shall be utilized, developed, and maintained on the sustained yield
principle. Pursuant to AS 16.05.020, ADF&G manages game species for conservation and
development through harvest regulations promulgated by the Alaska Board of Game in
accordance with AS 16.05.255.
Responding to AP&T's application in a July 18, 2002, letter, Alaska Department of Natural
Resources, Division of Parks and Outdoor Recreation (ADNR-DPOR) notified the Commission
that numerous concenls and issues remain that were expressed in ADNR-DPOR's original
December 29, 1994, comment letter to HL&P and that many of the studies conducted by HL&P
are out of date and "should not be relied upon as either factual or representative of existing
conditions." ADNR-DPOR also questioned whether AP&T could conduct studies within the
PreserTe that will cause "only minor alterations or disturbances of lands and waters." From
November to February, bald eagles heavily use the Chilkoot Lake/River Unit and human impacts
during this period should be resUicted. About 100-300 eagles feed here throughout the fall and
winter. Most of the proposed project works, including the dam and penstock, would be within an
identified mountain goat winter concentration area (ADNR-DOPR 2002). 3
3 Ch/Ikat Bald Eagle Preserve Management Plan (Public Review Dra~). April 2002. Alaska ~t
of Natural Resources; Division of Mining, Land and Water, Resom~e Assessment and Development
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
• Secretary Magalie R. Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
AP&T's appfication for this new preliminary permit (page 10) indicates that the "previous"
applicant conducted "baseline" fish, wildlife, and botanical resource studies. We are not aware
of any baseline wildlife studies that were completed by HL&P or AP&T under the preliminary
permits for FERC No. 11319 and 11715. ADF&G only provided HL&P with records of hunter
success for mountain goat and brown bears. In 1995, HL&.P contracted with ADF&G to conduct
a preliminary fisheries survey of the project area, including the existing "Glory Hole" Road
corridor. Our 1995 report to HL&P on the fish survey (Ericksen et al. 1995) 4 documented
juvenile coho salmon and Dolly Varden char in Power Creek and sampled seven slxeams along
the proposed access road that support spawning and/or roaring fish. However, this earlier study
was insufficient to characterize fisheries habitat or to establish population estimates, stating that
because of recent low salmon escapements 5, the season of the survey, and the limited methods
employed, fish species/life stages in many of the study sites may not have been adequately
represented. 6 It also stated that the introduction of glacial water from the lake would likely be
detrimental to Power Creek. Introduction of glacial water that is much colder and rich in
Sect/on, and the D/vision of Parks and Outdoor Recreation.
http://www.dnr.state.al~ us/mlw/planning/cbep/
4 Ericksen, R., Gaede, M. and E. Holle. 1995. Fish and fish habitat surveys conducted in the Upper
Ch/lkoot Valley near Haines, Alasim, during 1995.
s The Lynn Canal commercial fisheries target salmon returning mainly to the Chilkat and Chilkoot rivers.
Catch and river escapement of ~t Lake sockeye salmon were well below average since 1993.
(Bachman, IL, A. McGregor ~ M.S. Kelley. 1999. Fishery Managenm~t Plan for the Lynn Canal
ldisW/ct 15) Drift O'~, Fis.bery, .1999. ADF&G Regional Information Report IJ99-18)
To determine protection, nutlgation, and enhancement measures, ADF&G generally requ/res sampling
adequate to determine fish species composition, distribution, relative abundance, periodicity of
occurrence by life phases (m/gration, spawning, incubation and rearing), and adult anadromous fish
escapement numbers.
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
• Secretary Magalie IL Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
6 November 15, 2002
FERC No. 12336000
FERC No. 12338-000
sediment could adversely affect all fish life stages through alteration of Power Creek's thermal
regime and increasing sedimentation, respectively.
ADF&G's 1995 report also reiterated the need for new bridges and necessary repairs and
improvements if the Glory Hole Road is re-opened. AP&T's application asserts that no new
roads would be required to perform project studies. However, the Glory Hole Road trespasses
through a Native allotment (no public right-of-way is provided) and is in very poor condition,
with several collapsed log stringer bridges and inadequately sized or inoperable culverts that may
be impeding fish passage. Many of the stream crossings were further destroyed by a flood event
on October 19-20, 1998. The degraded road crosses several anadromous tributaries and
threatens a major spring-fed spawning area known as the "Glory Hole" with sedimentation.
The Chilkoot River (ADF&G Anadromous Waters Catalog # 115-33-10200) provides important
habitat for several anadromous and resident salmonid species that conlribute to important
recreational, coramezcial, and subsistence fisherizs. The Upper Chilkoot River provides
spawning and rearing habitat for coho and sockeye salmon and Dolly Varden char. The Chilkoot
River near the Power Creek confluence provides very important salmon spawning habitat. On
December 12, 1994, ADF&G staff observed approximately 1,800 five and 300 dead adult coho
salmon near the mouth of Power Creek. Lower Chilkoot River is catalogued for pink, chum,
coho, and sockeye salmon, Dolly Varden char, and cutthroat trout. The proposed project would
affect upstream and downstream fish passage, spawning, incubation, and rearing habitat.
Protection, improvement, and maintenance of fish habitat and production in these systems are
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
Secretary Magalie 1L Salas
Counelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
essential to fishery production in the Chi]koot River watershed. These fish are a significant food
source for the eagle population and other wildlife.
Neither application provides any information about the statutory purposes of the Preserve. The
Preserve is a major eagle nesting, feeding, and rearing area and is most heavily used by eagles
from November to February. The Chilkoot River portion of the Preserve is a narrow band along
the Chilkoot River that is managed primarily for recreation, fish and wildlife, water quality and
other natural features, including a major spring-fed salmon spawning area known as the "Glory
Hole," which is critical as a food source for eagles.
Pursuant to AS 41.21.610 "The primary purpose for establishing the Alaska Ch/Ikat Bald Eagle
Preserve is to protect and perpctoat¢ the Chilkat bald eagles and their essential habitats within
the Alaska Chilkat Bald Eagle Preserve in recognition of their statewide, nationally, and
internationally significant values in perpetuity." The Alaska Chilkat Bald Eagle Preserve was
also ~abHsh~l to:
1) protect and sustain the natural salmon spawning and rearing areas of the Chilkat River and
Chilkoot River systems within the preserve in perpetuity;
2) provide continued opportunities for research, study and enjoyment of bald eagles and other
wildlife;
3) ensure to the maximum extent practicable water quality and necessary water quantity under
applicable laws;
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
• Secretary Magalie R. Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
4) provide for other public uses consistent with the primary purpose for which the Preserve was
established; and
5) provide an opportunity for the continued traditional and natural resource based lifestyle of
the people living in the Preserve area, consistent with the Preserve's primary purpose.
Pursuant to AS 41.21.618, continued opportunities for traditional uses of the Preserve at levels
and by methods and means that are compatible with the protection of the bald eagle population
are guaranteed. These historically compatible uses include but are not limited to hunting,
trapping, fishing, berry picking, other subsistence and recreational uses, operation of motorized
vehicles, and the harvesting of personal-use firewood.
The April 2002 Public Review DraR of the Alaska Chilkat Bald Eagle Preserve Management
Plan states that redevelopment of the Glory Hole Road is "not considered consistent with the
management objectives of the Chilkoot River area." If rebuilt to access in-holdings, the road
should not be built to design standards that have the effect of greatly increasing current
recreation use levels or access levels or access the Haines State Forest, except incidentally. ~
Realignments and upgrades of this road must be approved by ADNR-DPOR. If upgraded, the
road should be re-routed to avoid the Glory Hole. However, ADNR-DPOR's draft Management
Plan guidelines for the Chilkoot River/Lake Management Unit requires that all upland areas
within the Preserve be retained in their natural condition. The Management Plan's SIzucturc and
The proposed project area is adjacent to the very popular Clxilkoot Lake State Recreation Site.
Therefore, opening the road to the public would dramatically increase v~sitshon in the Upper Chilkoot
valley and risks to aquatic habitat.
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
Secretary Magalie IL Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
9 November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
Use Permit Conditions state: "Other than those activities that are traditionally allowed within the
Preserve, all other commercial and industrial activities shall be conducted on private uplands, not
within the Preserve."
H. PROJECT DESCRIPTION
It is our interpretation that the currently proposed AP&T and Pacific Energy projects are
essentially the same projects that have been under preliminary permits since 1993 (FERC No.
11319 and 11715).
The project proposed by AP&T would be operated as a storage project and would consist oi~ (1)
a proposed 48-foot-high, 575-foot-long rocktill dam at the Lake outlet, (2) Conneliy Lake, which
would have a minimum water surface elevation of 2,280 feet, its current level, and a maximum
water surface elevation of 2,312 feet, (3) a screened intake slructure at elevation 2,270 feet, (4) a
6,188-foot-long penstock, 48-inch-diameter to a valve house with an auxiliary release adjacent to
the darn, then 30-inch-diameter, (5) a powerhouse containing one generating unit with an
installed capacity of 6.2 megawatts, (6) a 14-mile-long, 34.5-kilovolt underground transmission
line connecting to an existing power line, and (7) appurtenant facilities.
The Pacific Energy project would be operated in a run-of-river mode and would consist of." (I) a
50-foot-high 575-foot-long rockfiil dam at the Lake outlet, (2) Connelly Lake, which has a
surface area of 150 acres at normal water surface elevation of 2,280 feet, (3) a 6,200-foot-long,
30-inch-diameter penstock, (4) a powerhouse containing one generating unit with an installed
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000--
Secretary Magalie R. Salas
Connelly Lake HydroelecU'ic Project
Re: MOTION TO INTERVENE
10 November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
capacity of 6.0 megawatts, (5) a 15-mile-long, 34.5-kilovolt transmission line connecting to an
existing power line, and (6) appurtenant facilities.
The AP&T application indicates that portions of the project are within the Preserve. The Pacific
Energy application only states that project lands are owned by the State of Alaska. However,
both projects would be mainly within the Chilkat Bald Eagle Preserve and Haines State Forest.
Roads necessary for project access and transmission line corridors may also cross one or more
Native allotments, and other private land.
!il. BASIS FOR MOTION
Preliminary studies of the proposed project raised serious concerns regarding anadromous fish
habitat and management of the Preserve. ADF&G does not believe either project as proposed
could be developed in a manner that will not degrade terrestrial and aquatic habitat in the
Chilkoot Valley, be consistent with the mandates of the Preserve, and not have the potential to
adversely affect fish and wildlife populations that are, in part, of economic and social importance
to the Haines region.
As an affected interest and stakeholder, ADF&G respectfully moves for intervention in this
proceeding. Intervener status (in combination with ADF&G's other functions under the Fish and
Wildlife Coordination Act and other federal and state laws) will enable ADF&G to fully
participate in this proceeding and to recommend appropriate license stipulations for the
protection of fish and wildlife resources affected by the proposed project and related facilities.
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
Secretary Magalie R. Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
11 November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
IV. CONCLUSION
Based on the above rationale, the ADF&G respectfully requests the Commission to grant this
motion for intervention. Thank you for your consideration of this request.
Sincerely,
Frank Rue
Commissioner
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
Secretary Magaiie R. Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
12 November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
DECLARATION OF SERVICE
In the matter of:
Connelly Lake Hydroelectric Project (Project No. 12336-000 and 12338-000)
The attached Alaska Department ofFish and Game Motion To Intervene has been serviced to
each person below by ftrst-class mail. ADF&G requests that subsequent filings, actions, and
decisions in this proceeding be served on the following representatives:
Honorable Magaiie R. Salas
Office of the Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, D.C. 20426
Glen D. Martin
Alaska Power & Telephone Company
P.O. Box 3222
191 Otto Street
Port Townsend, WA 98368
Brent L. Smith, President
Northwest Power Services, Inc.
P.O. Box 535
Rigby, Idaho 83442
Chip Dennerlein, Director
Alaska Department ofFish and Game
Habitat and Restoration Division
P.O. Box 25526
Juneau, Alaska 99802-5526
Frank Rue, Commissioner
Alaska Department ofFish and Game
P.O. Box 25526
Juneau, Alaska 99802-5526
Bill Hanson, Regional Supervisor
Alaska Department offish and Game
Habitat and Restoration Division
P.O. Box 240020
Douglas, Alaska 99824-0020
Clayton Hawkes, Hydro-Project Review
Coordinator
Alaska Department ofFish and Game
Habitat and Restoration Division
P.O. Box 240020
Douglas, Alaska 99824-0020
Carl Schrader, Habitat Biologist
Alaska Department offish and Game
Habitat and Restoration Division
P.O. Box 240020
Douglas, Alaska 99824-0020
Christopher Estes, Chief Statewide Aquatic
Resom'c~ Coordination Unit
Alaska Department offish and Game
Division of Sport Fish/RTS
Statewide Aquatic Resources Coordination Unit
333 Raspberry Rd.
Anchorage, Alaska 99518-1599
Kevin Brownlec, Southeast Alaska Instteam
Flow Coordinator
Alaska Department ofFish and Game
Division of Sport Fish/RTS
Statewide Aquatic Resources Coordination Unit
P.O. Box 240020
Douglas, Alaska 99824-0020
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000
Secretary Magalie R. Salas
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
13 November 15, 2002
FERC No. 12336-000
FERC No. 12338-000
Joe Klein, Hydrologist
Alaska Department ofFish and Game
Division of Sport Fish/RTS
Statcwide Aquatic Resources Coordination Unit
333 Raspberry Rd.
Anchorage, Alaska 99518-1599
Ken Lord, Attorney
Deputy Regional Solicitor
Office of the Regional Solicitor, Alaska Region
4320 University Drive
Suite 300
Anchorage, Alaska 99508
Ted Mcyers, Director
National Marine Fisheries Service
Alaska Regional Office
Habitat Conservation
P.O. Box 21668
Juneau, AK 99802
Mr. Thomas Meyer, NOAA Attorney
Office of General Council, Alaska Region
National Oceanic and Atmospheric
Administration
P.O. Box 21109
Juneau, Alaska 99802
John Dunker
Alaska Department of Natural Reso~
Division of Minin& Land, and Water
400 Willoughby Avenue, 4 ~ Hoor
Juneau, Alaska 99801-1796
Chilkat Indian Village
Ms. Lani S. Hotch, Secretary
37 Chilkat Ave
P.O. Box 210
Klukwan, Alaska 99827
David B. Allen, Director
USDI, U.S. Fish & Wildlife Service
Division of Habitat Conservation
1011 E. Tudor Road
Anchorage, Alaska 99503-6119
Steve Brookmann
U.S. Fish & Wildlife Service
Ecological Services
3000 Vintage Blvd., Suite 201
Juneau, Alaska 99801-7100
Douglas Mutter, Regional Environmental Officer
USDI, Office of the Secretary
Office of Envir. Policy and Compfiance
1689 C. Street, Room 119
Anchorage, Alaska 99501-5126
Bill Garry
Alaska Department of Natural Resources
Division of Parks and Outdoor Recreation
400 Willoughby Avenue, 4 ~ Floor
Juneau, Alaska 99801-1796
Eric Holle, President
Lynn Canal Conmwation
P.O. Box 964
Haines, Alaska 99827-0564
Chilkoot Indian Association
Lee E. Clayton, Preaident
P.O. Box 490
Haines, Alaska 99827
Jnofflclal FERC-Generated PDF of 20021126-0061 Received by FERC OSEC 11/25/2002 in Docket#: P-12336-000--
" Secretary Magalie R. Salas 14
Connelly Lake Hydroelectric Project
Re: MOTION TO INTERVENE
Novemb~ 15, 2002
FERC No. 12336-000
FERC No. 12338-000
Jan Konigsberg
Director, Alaska Salmonid Biodivcrsity Program
Trout Unlimited
1399 West 34th Avenue, Suite 205
Anchorage, Alaska 99503-3655
Matthew Davidson
SE Alaska Conservation Council
419 Sixth St.
Suite 200
Juneau, Alaska 99801