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HomeMy WebLinkAboutComments-APT-GrantLynn Canal Conservation, Inc. Box 964 • Haines, Alaska 99827 (907) 766-2295 • lcc11@aptalaska.net To: Butch White, Grants Manager Alaska Energy Authority Anchorage, AK From: Lynn Canal Conservation, Inc. Haines, Alaska Date: February 10, 2009 Re: Comments on Alaska Power and Telephone Grant Request for Connelly Lake Hydro Project PART I: Summary of Comments Introduction Lynn Canal Conservation is a membership organization based in Haines. We have over 200 local members. We have long advocated f or the use of renewable energy sources to replace fossil fuels. We support APT’s efforts to supply the Upper Lynn Canal grid with 100% hydropower. However, we have concerns about the impacts the Connelly Lake project could have on the environment and the community of Haines. Recently, another hydropower site, Schubee Lake, has been discovered. It offers approximately the same power potential as Connelly Lake, but without the environmental risks, and at a fraction of the construction costs (Schubee Lake eliminates the need for costly road and dam construction). Given the high value of the fisheries resources of the Chilkoot watershed and the complexity of constructing a road and dam in the valley, we believe it would not be prudent for our community to pursue the Connelly Lake site without simultaneously studying the feasibility of other sites, such as Schubee Lake, that do not present such an extreme habitat risk. (See attached comments from the National Marine Fisheries Service concerning the risk to essential habitat of the Connelly Lake project.) We are also concerned about the location of a substantial part of this project within the Chilkat Bald Eagle Preserve, which has rather strict guidelines for allowable activities. (See attached Preserve management plan.) Recommendations We would like to see APT at this time be limited to just Phase II funding (they are also requesting Phase III fundung) and for the company to apply this funding for resource assessment of hydropower for the Upper Lynn Canal. We would prefer to see the funds go toward a study of Schubee Lake but could also see the value of a comparative analysis of both Schubee and Connelly Lakes. We have met with APT and presented our proposal for the Schubee Lake site, The company expressed an interest in looking further into the Schubee Lake option. The Haines Borough Assembly as well as the borough’s Energy Sustainability Commission have also expressed an interest in examining the Schubee Lake as well as other renewable energy options at this time. See attached Haines Borough Resolution (specifically, the second “whereas”) which cites the Energy Commission’s recommendation to the Assembly. It commission recommends that the borough… “…support efforts by APT to secure funding to do additional design and data gathering for hydro electric sources including but not limited to Connelly Lake and Schubee Lake to help inform the public process prior to permitting.” While we fully endorse the concept of moving quickly toward zero use of fossil fuels in local energy production, we realize that Haines is currently close to that goal, being somewhere near 95% fossil-free (with still some diesel use in midwinter). We feel that, because we are not currently experiencing a local power production crisis, we should take the time needed to identify the best long- term hydro site(s). We feel that there is a need for a more comprehensive feasibility study that would include—in addition to the Connelly Lake project—the following: 1) the feasibility of the Schubee Lake site. 2) the maximum potential of the Kasidaya Creek site, which was only very recently completed. 3) the potential of the proposed West Creek hydro project, which is being studied by the city of Skagway, especially in regards to servicing the cruise ship industry. 4) the feasibility of a modest wind project of supplementing midwinter hydropower generation. 5) the potential for significantly reducing power demand (especially in midwinter) through an aggressive conservation program. Having reviewed your guidelines, we believe that while single phase funding for APT would clearly fall within the guidelines, multiphase funding would not. Our situation in the Upper Lynn Canal seems to be one for which more resource assessment and public input is appropriate—especially given the initial cost estimate of the Connelly lake project. At the same time we recommend that the dollar amount of the APT Phase II funding request be adjusted upward to allow for a more comprehensive resource assessment, or that APT receive two consecutive annual grant awards to conduct the needed feasibility studies. Other concerns The previous APT hydro projects were done with solid backing from the community, but we are concerned that the proposed project will become a divisive one. In addition to our concerns, separate opposition could come from locals living in the nearby Lutak residential area, commercial fishermen, and wilderness tour operators. Additionally, because of the sensitive nature of the upper Chilkoot fish and wildlife habitat (salmon spawning areas, bear denning, etc.) the permitting process will surely be quite lengthy and result in extensive (and expensive) mitigation requirements. PART II: Connelly Lake vs. Schubee Lake Detailed Comparison Schubee Lake In the early 1980’s, AP&T commissioned a study of potential hydropower sites in the Upper Lynn Canal area. Thirteen sites are detailed in a document titled “Table 17”. Two of those sites, Goat Lake and Kasidaya Creek have been developed. Connelly Lake, then called Upper Chilkoot Lake, was the next obvious choice for development. Schubee Lake is not listed in Table 17. Schubee Lake is located 3315 feet above the east side of Taiya Inlet about three miles south of AP&T’s Kasidaya Creek project. On the USGS maps f rom the 1970’s that were probably used when Table 17 was put together, a small lake appears at the foot of the Schubee Glacier. It isn’t even named. Almost by accident, while looking at a USGS map from the 1990’s, one of our volunteers noticed a mile-long lake where there hadn’t been one previously. A more recent Google Earth image shows a 300-acre lake at the foot of the glacier – Schubee Lake. Apparently a lot of ice has gone over the falls in the last thirty years. Methodology Hydropower is calculated by multiplying the volume of flowing water (measured in cubic feet per second – CFS) by the drop, or head. The result is a measure of electrical power, measured in kilowatts or megawatts. Calculating flow using a USGS topographic map and following contour lines carefully, it is possible to determine the collection area of a drainage in square miles. One square mile has 27, 878,400 square feet. National Weather Service data from the Haines airport shows that we get about 48 inches, or 4 feet of precipitation annually. Of course, this amount varies for different areas of the Upper Lynn Canal, but there is a lack of data for areas beyond the airport. Multiplying 27, 878,400 square feet by 4 feet gives us approximately 111,500,000 cubic feet of water per square mile per year. There are 31,536,000 seconds in a year. Divide and you get 3.5 cubic feet per second (CFS) per square mile. This means that, theoretically, every square mile in our area should be able to deliver a constant flow of 3.5 CFS. In reality, some water will be lost to evaporation, vegetation and flow into the bedrock. The flow also varies seasonally, with peak flows in the June and July runoff and almost no flow in the winter. Stored water is measured in acre-feet. With four feet of annual precipitation, each square mile in our area has the potential to capture 2560 acre-feet of water (4 x 640 acres/square mile). Glaciers effect water flow. Connelly Lake and Schubee Lake both have glaciers in the upper reaches of their drainages. Glaciers can either add to, or diminish, the annual flow in a drainage. In warm years, when the glaciers are shrinking, melting ice can augment the annual precipitation, perhaps considerably. Conversely, in cold years more of that year’s precipitation will be stored as snow in the upper reaches of the glacier than will be released as melting ice farther below. Last year, after a snowy winter and a cool summer, local glaciers actually gained mass, bucking the trend of the past decades. Because of its variability, we have not included the annual net gain or loss by the glaciers to either system’s estimate of annual flow. If climate trends continue, and the glaciers continue to shrink, this additional flow will increase the power potential of each system, at least until the ice is gone. Collection Area Connelly Lake: ~ 4.4 square miles. Schubee Lake: ~ 2.7 square miles. Total Annual Precipitation Falling on the Drainage Connelly Lake: ~ 11,264 acre-feet. Schubee Lake: ~ 6,912 acre-feet. Theoretical Constant Flow Connelly Lake: ~ 15.4 CFS Schubee Lake: ~ 9.45 CFS Head Connelly Lake: 2070 feet Schubee Lake: 3315 feet Power Potential Connelly Lake and Schubee Lake have nearly identical power potential. Entering the head and the flow into the hydropower calculator at baipatra.com shows that either system should be able to produce about 2.7 megawatts (MW) continuously (12 month flow). AP&T’s plan calls for their Kasidaya Creek generator, a run of the river project, to provide power for Haines and Skagway most of the year. This allows their storage project at Goat Lake to recharge. Goat Lake operates during the winter months when the Kasidaya project cannot. If Connelly Lake or Schubee Lake were run on a 6-month flow regime they could generate 5.4 MW. On a 4-month flow regime they could produce 8.1 MW. On a 3-month flow regime they could produce 10.8 MW. AP&T is calling for a 12 MW capacity on the Connelly Lake project. To generate this much power with a head of 2070 feet requires about 70 CF S. This means that the generators could only operate at that rate for less than three months before using an entire year’s water. Perhaps they are counting on the shrinking glacier adding water to the system. Lake Surface Area Connelly Lake: ~ 85 acres Schubee Lake: ~ 300 acres Lake Capacity Connelly Lake: 9000 acre-feet (with dam). This is the “largest practical reservoir” as noted in AP&T’s application. Earlier estimates indicated 3500 acre - feet (Table 17) and 4700 acre-feet. None of these estimates exceed the 11,264 acre-feet that the drainage collects annually. Schubee Lake: The depth of Schubee Lake is unknown at this time. This is one of the questions that would be answered with Phase II funding. Topography, as indicated on the USGS map, suggests that the lake could be very deep. Goat Lake, in similar terrain, is 300 feet deep. If Schubee Lake were to average 50 feet deep it would contain ~ 15,000 acre-feet, far exceeding the 6912 acre-feet that the drainage collects annually. Penstock Connelly Lake: ~ 6200 feet Schubee Lake: ~ 7400 feet if run directly to tidewater below the lake’s outfall. Transmission Line Connelly Lake: 14 miles of buried cable. Schubee Lake: Approximately 1 mile to tie in with the existing submarine cable, or 3 miles to the Kasidaya Creek powerhouse. Road Connelly Lake: 14 miles, plus bridges. AP&T’s application states that the former logging road, RS 2477, “can still be used after some repairs and tree trimming”. This is not true. The road beyond Chilkoot Lake is largely gone, consumed by the river. AP&T’s estimated cost for rebuilding this road is far too low. Schubee Lake: No road. Dam Connelly Lake: 48’ x 575’ concrete and rock dam built two thousand feet up a steep mountainside. Constructing this dam would be a monumental undertaking. Schubee Lake: No dam. The penstock would siphon water from deep in the lake, as is the case with Goat Lake. Impacts Connelly Lake: The value of the Chilkoot watershed to the community of Haines is enormous. Subsistence, commercial and sport fishers rely on the watershed’s productivity. The Chilkoot is also important for tourism and recreation, and for its cultural and historic value. Approximately half of the sockeye salmon used by subsistence and commercial fishers originate and return to the Chilkoot. Many of our tourism businesses depend on the Chilkoot as a destination, both for the bears and the salmon they feed on. It is in the community’s best interest to make sure that the Chilkoot’s salmon runs are not diminished by any development. In our conversations with biologists who have worked in the upper Chilkoot, three areas of concern have emerged: the road and bridge to the powerhouse, the dam, and the potential for high concentrations of nitrogen in the water coming down the penstock. The Chilkoot River above the lake is very dynamic, that is, it frequently changes course across the width of the valley. Parts of the old logging road that AP&T plans to use to access the powerhouse site have become river channels. Restoring this logging road will involve a lot more than just clearing away alders from the former road bed. It would be a major undertaking requiring huge amounts of fill, with culverts and bridges designed to allow fish to pass unimpeded. Sediments created by the construction of the road and the burying of the power line would have to be contained. The new portion of the road that crosses the valley and then bridges the river to the powerhouse site would be the most problematic. This portion of the road would be perpendicular to the flow of the river. With the river as changeable as it is, the road would have to be designed to allow for water to pass in different places. Restricting the flow to one channel would put the roadbed at risk of erosion. It is possible that there is a suitable bridge site in place where the river is naturally constricted by the topography of the valley. It is difficult to imagine that this road could be built without some loss of habitat. There are two o ther factors that could impact the salmon: the risk of spills from vehicles and the impacts of increased human activity. There are also access issues, as the old road crosses private property. AP&T’s plan calls for a dam approximately 48 feet high and 575 feet long at the outlet of Connolly Lake. Presumably, the on-site equipment needed to construct this dam will have to be flown in by helicopter. Material to construct the dam (concrete and rock) would have to be trucked in and lifted to the site. What will the impact to the valley be from the thousands of truckloads of material being brought in, and the staging of those materials? The engineering and construction of the dam would have to be flawless. If it were to fail for any reason, such as an earthquake, the resulting flood caused by the sudden release of 9000 acre-feet of water (~ 3 billion gallons) and the thousands of cubic yards of dam material would likely scour the Chilkoot Valley down to bedrock and fill Chilkoot Lake and River with sediment. This would be the end of the fishery for hundreds, if not thousands, of years. There is also a campground downstream, as well as residences. Although the incidence of dam failure is rare, the engineers who created Table 17 acknowledged the possibility. They stated that, for several hydropower sites located above Skagway, “seismically induced structure failure could cause risk to life and property.” Hydroelectric projects in the Pacific Northwest have had problems with nitrogen becoming supersaturated in the water falling great distances. This excess nitrogen in the water causes a condition similar to “diver’s bends” that is fatal to fish. It seems to happen when water and air are compressed together. This can happen in the spillways of large dams. The Connelly Lake project will have a penstock, not a spillway carrying the water downhill, so it is unclear whether excess nitrogen is a potential problem. Still, it is a question that should be investigated. Schubee Lake – There would be no impact to fish, as water exiting the powerhouse would run directly to the sea. The only impact that some people may be concerned about would be visual. The long, thin waterfall coming from Schubee Lake would likely disappear or be greatly diminished. In our opinion, the need for hydropower outweighs the visual value of one waterfall. There are others nearby. The penstock would also be visible to boaters. Community Support Connelly Lake: There is already a community battle brewing over the Connelly Lake project. The Chilkoot Valley is important to a wide spectrum of people. Conservationists aren’t the only ones who are concerned. Opposition will probably delay the project. Schubee Lake: Full community support. Project Cost Connelly Lake: Estimated to cost $34 million. We suspect this figure is low because AP&T’s estimate to restore forest road RS 2477 and to build bridges is unrealistic. Schubee Lake: Cost is unknown, but this project is very similar to AP&T’s Goat Lake project, which cost $7.8 million. Certainly the cost would be substantially less than Connelly Lake because there would be no dam, no road, a much shorter transmission line, no environmental problems and no community opposition. Conclusion We would like to see AP&T receive Phase II funding for assessment and analysis of the Schubee Lake project. We believe it is a better project than Connelly Lake for many reasons. When we presented this information to Stan Selmer of AP&T, he was very interested in finding out more about Schubee Lake. There are some questions that need to be answered concerning the depth of the lake, the location of the penstock and powerhouse, and what the Forest Service thinks about diverting a waterfall into a penstock. We know that AP&T has been discussing amending their application to include Schubee Lake. We hope your program has the flexibility to allow them to do this. In light of this new information it would seem to be the reasonable thing to do. We are confident that when the Connelly Lake and Schubee Lake projects are compared, the choice will become obvious. It seems clear to us that Schubee Lake is the far more cost effective, environmentally sound and practical choice.