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FINAL ENVIRONMENTAL IMPACT STATEMENT
Hydroelectric Power Development
HARZAMEBASCO
Suslt na Joint Venture
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Du r :UMENT COlVTR Ot
:tiPPER SCJSITNA RIVER ~ BASIN
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SOUTHCEIVTR!!L __ RAI~EL'r AREA, ALASKA
OFFICE OF THE CHIEF OF ENGINEERS
DEPARTMENT OF THE ARMY
WASHINGTON, D.C. 20314
JANUARY 1977 11
DEPARTMENT OF THE ARMY
REPLY TO
ATTENTION OF:
NPAEN-PL-R
ALASKA DISTRICT. CORPS OF ENGINEERS
P.O. BOX 7002
ANCHORAGF 'Al-ASKA 99510
:; JLIL 1'979
Inclosed is the Final Environmental Impact Statement for Hydroelectric
Power Development, Upper Susitna River Basin, Southcentral Railbelt Area,
Alaska dated January 1977. The statement was filed with the Environmental
Protection Agency on 26 June 1979. No administrative action will be
taken regarding the proposal soener than 30 days from the date of this
letter or publication in the Federal Register, which ever is later.
Comments should be received at this office prior to the expiration of
the 30 day period.
1 Incl
As stated
Sincerely,
ERNELa9A<2~-l__
Lt Colonel, Corps of Engineers
Acting District Engineer
.SUMMARY.
Hyroelectric Power Development, Upper Susitna River Basin
(Southcentral.Railbelt Area, Alaska)
( ) Revised Draft Environmental Statement (X) Final Environmental
Statement
Responsit>Je Office: Alaska District, Corps of Engineers
Colonel Lee R. Nunn, District Engineer
P. 0. Box 7002, Anchorage~ Alaska 99510
Telephone (907) 276-4915
1. Name of Action: ( ) Administrative (X) Legislative
2. Description of Action: The recommended plan is to construct dams on
the upper Susitna River at Watana and Devil Canyon, powerplants, electric
transmission facilities to the Railbelt load centers, access roads, and
permanent operation and recreational facilities. The project has been
authorized for detailed preconstruction studies. When funded, environ-
mental, social, economic, and engineering aspects of the project will be
studied at greater depth over a period of several years prior to recom-
mending to Congress whether or not the project should be advanced to
final design and construction. A major supplement to the Environment~l
Impact Statement will be prepared at the conclusion of preconstruction
stage studies. The supplement will be coordinated for public review and
comment and furnished to the Congress along with the Alaska District•s
final recommendations.
3. a. Environmental Impacts: The two-dam system would inundate some
50,500 acres extending 84 miles upstream from Devil Canyon Darn. Nine
miles of a total 11-mile reach of white water would be inundated in
Devil Canyon. Transmission lines would total 364 miles in length;
corridors would average 186-210 feet in width, and require about 8,200
acres of right-of-way, of which about 6,100 acres would require vege-
tative clearing. The project would utilize a renewable resource to
produce projected power needs of the Railbelt area equivq.lent to the
annual consumption of 15 million barrels of oil. Heat and noise and air
pollution problems associated with most alternative energy production
sources would be prevented. Stream flows for some distance below Devil
Canyon would carry significantly reduced sediment loads during the
summer months. Recreational opportunity would be increased by access
roads and creation of project-related recreational facilities.
b. Adverse Environmental Effects: The following adverse impacts would
result from project in1plementation: impairment of visual quality resulting
from access roads, dams, and transmission lines; loss of vegetation and
habitat due to inundation and road construction; creation of public
access resulting in increased pressure on wildlife and need for intensi-
fied game management and fire prevention practices;
i i /Summat~y
increased turbidity of Susitna River downstream from Devil Canyon Dam
during winter months; prevention of future mineral extraction from
inundated land and limitations of options for uses of lands affected hy
the transmission corddors; direct impact on moose through some reduc-
tion of existing habitat; possible inhibition of movement of caribou
which cross the reservoir between calving and summer ranges; temporary
degradation of air, water. and vegetation as a result 6f slash and
debris disposal; inundation of one historical site and any archeo-
logical sites ~vhich might be discovered within the reservoir pools;
social impacts related to seasonality of construction work and demands
upon services of small communities 1 ocated in the vicinity of construc-
tion activity.
4. Alternatives: Construct no additional electrical generating facili-
ties, construct -othei~ Susitna hydroelectric alternatives, construct
other Southcerrtral Railbelt hydroelectric facilities, develop other
alternative energy generating faci 1 iti es using resources such as coa 1,
oil, and natural gas, nuclear power~ geothermal, solar, or other alter-
native power generating resources.
5. Comments Received:
a.· District Review of Draft Statement:
United States Department of the Interior
Alas~a Power Administration
Geological Survey---Reston, Virginia
Fish and Wildlife Service
Bureau of Outdoor Recreation--Seattle, Washington
National Park Service--Anchorage, Alaska
National Park Service--Seattle~ Washington
Bureau of Indian Affairs--Juneau, Alaska
Bur·eau of land Management-~Anchorage, A 1 aska
United States Department of Commerce
United States Environmenta"i Protection Agency
Department of the Army
U.S. Army Cold Regions Research and Engineering Laboratory--Hanover,
Ne\AJ Hampsh·i re
Department of Transportation
Coast Guard--Seattle, Washington
Federal Aviation Administration--Anchorage, Alaska
Federal Highway Administi~ation--Portland, Oregon
Department of Housing and Urban Deve1 opment--Seattl e, Washington ,
Department of Agriculture--Soil Conservation Service
Federal Power Comm·ission
State of Alaska--Office of the Governor
Greater Anchorage Chamber of Commerce
Office of the Mayor--Anchorage9 Alaska
Sierra Club
Alaska Conservation Society--College, Alaska
Alaska Conservation Society--Anchorage, Alaska
Knik Kanoers and Kayakers, Inc.--Anchorage, Alaska
Cook Inlet Region, Inc.--Anchorage, Alaska
Orah Dee Clark Jr. High, Seventh Grade, Sixth Period Class
Private Citizens
b. Deeartmental Review of Revised Draft Statement:
United States Department of the Interior
United States Department of Agriculture
United States Department of Commerce
United States Environmental Protection Agency
Federal Energy Administration
United States Department of Transportation
Federal Power Commission
United States Department of Housing and Urban Development
United States Department of Health, Education, and Welfare
Office of the Governor of Alaska--State Clearinghouse
6. Draft Statement to CEQ 3 October 1975.
Revised Draft Statement to CEQ 9 Ju1y 1976.
Final Statement to EPA 26 June 1979 •
Summary/iii
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Looking downstream on Susitna River at Devil Canyon darosite. Dam would be
located near bottom of photo. Vegetation is mostly white spruce.
)
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FINAL ENVIRONMENTAL IMPACT STATEMENT
SOUTHCENTRAL RAILBELT AREA, ALASKA
HYDROELECTRIC POWER DEVELOPMENT
UPPER SUSITNA RIVER BASIN
Table of Contents
Project Description
Purpose and Authority
Scope of the Study
Description of Action
Page
1
1
1
3
Environmental Setting Without the Project 9
Physical Characteristics 9
Description of the Area 9
River Characteristics 12
Cook Inlet 14
Geology/Topography 14
General 14
Susitna Basin 15
Transmission Line Corridor 15
Seismic Areas 17
Minerals 17
Climate 18
Biological Characteristics 18
Fish 18
Anadromous Fish 18
Resident Fish 21
Birds 21
Waterfowl 21
Raptors 21
Other Birds 23
Mammals 23
Caribou 23
Moose 25
Grizzly/Brown Bears 25
Black Bears 27
Da 11 Sheep 27
Mountain Goats 28
Wolves 28
Wolverines 28
Other Mamma 1 s 28
Threatened Wildlife of the United States 30
Vegetation 30
Cultural Characteristics 31
Population 31
Economics 33
i
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Table of Contents (Cont•d)
Page
Transportation 36
Rail 36
Roads 36
Air 36
Other Forms of Transportation 36
Recreation 37
Access 37
Hunting 37
Fishing 38
Boating 38
Camping 38
Other Outdoor Recreational Activities 38
Historical Resources 39
Archaeological Resources 39
Energy Needs 40
Relationship of the Proposed Action to
Land Use Plans 43
Present Land Status 43
Alaska Native Claims Settlement Act 43
Utility Corridors 44
Environmental Impacts of the Proposed Action 45
Hydrology and Water Quality 45
Fish 48
Wildlife 52
Recreation 54
Historical Resources 55
Archaeological Resources 58
Vegetation 58
Mining 60
Agriculture 60
Roads 60
Construction Activities 61
Workers' Facilities 61
Esthetics 62
Earthquakes ~3
Sedimentation 64
Climatic Conditions 64
Air Pollution 65
Social 65
Population 65
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Table of Contents (Cont'd)
Adverse Environmental Effects Which
Cannot be Avoided
Alternatives to the Proposed Action
General
Alternative Sources of Power
No AcHon
Coal
Oil and Natural Gas
Nuclear Power
Geothermal
Solar
Wind and Tidal
Wood
Intertie
Solid Waste
Hydropower
Alternative Hydrologic Basins in the
Southcentral Railbelt Area
Rampart Canyon
Wood Canyon
Chakachamna lake
Bradley Lake
Susitna River
Alternative Hydroelectric Plans in the
Upper Susitna River Basin
General
Devil Canyon
Watana
Devil Canyon High Dam
Devil Canyon-Denali
Three-Dam System
Four-Dam System
Kaiser Four-Dam System
Alternative Power Transmission Corridors
Alternatives to Susitna 1
Alternatives to Nenana 1
Alternatives to Susitna and Nenana
Corridors
Relationship Between local Short-Term Uses
of Man•s Environment and Enhancement
of Long-Term Productivity
iii
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Table of Contents (Cont'd)
Irreversible or Irretrievable Commitments
of Resources in the Proposed Action
Changes in Land Use
Destruction of Archaeological or
Historical Sites
Change in River Use
Construction Activities
Fuel Requirements
Manpower
Material
land
Coordination with Other Agencies
General
Public Participation Program
?elected Bibliography
Economic Data
Comments and Responses
Proposed Transmission Line Corridor
(Photos Courtesy, Alaska Power Administration)
Title
TABLES
Title
Flows
Data on the Proposed Project and
Selected Susitna Alternatives
LIST OF FIGURES
The Railbelt
Upper Susitna River Basin Location Map
Transmission System Layout
Upper Susitna River Basin
Geology of the Railbelt Area
Wildlife--Waterfowl Habitat
Wildlife--Caribou and Bison
Wildlife--Moose, Dall Sheep, Brown Bear
Projected Energy Demand
Proposed Recreation Plan
Coal and Geothermal Areas
Oil and Gas Potential
Southcentral Key Hydroelectric Alternatives
Alternative Transmission Corridors
Potential Mineral Development Areas
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1.0 PROJECT DESCRIPTION
1.01 Purpose and Authority. The utilization of renewable resources to
produce electrical energy for domestic and industrial uses has become a
primary concern in today•s energy crisis. The consumption of nonre-
newable sources of energy such as petroleum and natural gas has now
reached a critical point where conservation of domestic sources must be
considered. With the forecast increase in development for Alaska and
corresponding increase in demand for electric power, the Committee on
Public Works of the U. s. Senate adopted a resolution on 18 January
1972, requesting a study for the provision of power to the Southcentral
Railbelt area of Alaska. The resolution is quoted as follows:
That the Board of Engineers for Rivers and Harbors created under
the provisions of Section 3 of the River and Harbor Act approved
June 13, 1902, be, and is hereby, requested to review the reports
of the Chief of Engineers on: Cook Inlet and Tributaries, Alaska,
published as House Document Numbered 34, Eighty-fifth Congress;
Copper River and Gulf Coast, Alaska, published as House Document
Numbered 182, Eighty-third Congress; Tanana River Basin, Alaska,
published as House Document Number 137, Eighty-fourth Congress;
Yukon and Kuskokwim River Basins, Alaska, published as House
Document Numbered 218, Eighty-eighth Congress; and, other pertinent
reports, with a view to determining whether any modifications of
the recommendations contained therein are advisable at the present
time, with particular reference to the Susitna River hydroelectric
power development system, including the Devil Canyon Project and
any competitive alternatives thereto, for the provision of power to
the Southcentral Railbelt area of Alaska.
1.02 Scope of the Study. The Southcentral Railbelt area is that portion
of the Yukon and southcentral subregions which extends from Cook Inlet
and the Gulfof Alaska on the south to the southern slopes of the Brooks
Range on the north, a distance of about 500 miles. This area, containing
about 75 percent of Alaska's population, is served by the Alaska Rail-
road and is commonly referred to as the 11 Railbelt 11 (see Figure l).
Major power resources, both hydroelectric and fossil fuels, and the
greatest power demands are in this region.
THE RAILBELT·
NIILE.5
so IOO
The proposed action discussed in this draft environmental impact
statement is a two-dam system located in the Upper Susitna River Basin,
which will provide hydroelectric power to the Southcentral Railbelt
region in Alaska.
1.03 Description of Action. The recommended plan consists of construc-
tion of dams and powerplants on the upper Susitna River at Watana and
Devil Canyon, and electric transmission facilities to the Railbelt load
centers, access roads, permanent operating facilities, and other project-
related .. features.
A subsidiary purpose in the construction of the electric trans-
mission .line will be the interconnection of the two largest electric
power distribution grids in the State of Alaska, which will result in
increased reliability of service and lower cost of power generation.
The proposed plan for the Watana site (Figure 2) would include the
construction of an earthfill dam with a structural height of 810 feet at
river mile 165 on the Susitna River. The reservoir at normal full pool
would have an elevation of 2,200 feet and a crest elevation of 2,210
feet, have a surface area of approximately 43,000 acres, and would
extend about 54 river miles upstream from the damsite to about 4 miles
above the confluence of the Oshetna River with the Susitna.
The generating facilities at Watana would include three Francis
reaction turbines with a capacity of 236 MW (megawatts) per unit and a
maximum unit hydraulic capacity of 7,770 cfs (cubic feet per second).
The firm annual production of electrical power at Watana would be 3.1
billion kilowatt-hours.
Development of the Devil Canyon site includes the construction of
a concrete, thin-arch dam with a maximum structural height of 635 feet
·and with a crest elevation of 1,455 feet. The dam would be located at
river mile 134 on the Susitna River. Devil Canyon reservoir would have
a water surface area of about 7,550 acres at the normal full pool
elevation of 1,450 feet. The reservoir would extend about 28 river
miles upstream to a point near the Watana damsite, and would be confined
within the narrow Susitna River canyon.
The generating facilities at Devil Canyon would include four Francis
reaction turbines with a capacity of 17l MW per unit and a maximum unit
hydraulic capacity of 6,250 cfs. The firm annual energy provided at
Devil Cainyon would be 3.0 billion kilowatt-hours.
A total of 6.1 billion kilowatt-hours of firm annual energy would
be produced by the combined Devil Canyon-Watana system. Secondary
annual average energy production from this two-dam system includes an
3
Looking upstream toward Watana damsite. Tsusena Creek in left center of photo.
Damsite just beyond the visible section of river.
) Looking upstream toward Watana damsite. Tsusena Creek in left center of photo.
Damsite just beyond the visible section of river. )
FIGURE 2
5
UPPER
LOCATION MAP
SCALE
0 50 IOOMIIe1
additional 0.8 billion kilowatt-hours per year. The 6.9 billion kilo-
watts of firm and secondary annual energy would be the energy equivalent
of about 15 million barrels of oil per year, or about 112 billion cubic
feet of natural gas per year, or about 1.5 billion barrels of oil over a
100-year project-life period.
Most of the generated electrical power would be utilized in the
Fairbanks-Tanana Valley and the Anchorage-Kenai Peninsula areas. The
proposed transmission system would consist of two 198-mile, 230 kv
single circuit lines from Devil Canyon to Fairbanks (called the Nenana
corridor), and two 136-mile, 345 kv single circuit lines from Devil
Canyon to the Anchorage area (called the Susitna corridor). Both lines
would generally parallel the Alaska Railroad. Power would be carried
from Watana to Devil Canyon via two single circuit 230 kv transmission
lines, a distance of 30 miles. Total length of the transmission lines
would be 364 miles. The general locations of the transmission lines are
shown on Figure 3. Transmission line corridors would require a right-
of-way of approximately 186-210 feet in width totaling slightly more
than 8,200 acres of which about 6,100 acres would require clearing.
Towers would be either steel or aluminum and of free-standing or guyed
type, depending upon final design and local conditions.
Access to the Devil Canyon and Watana sites would be determined by
siting studies that would include consideration of the environmental
impacts for roads and transmission lines. Preliminary studies indicate
an access road ~pproximately 64 miles in length would connect the Watana
site with the Parks Highway via Devil Canyon. A factor considered in
location and design of access roads would be their subsequent use for
public recreational purposes.
Project-oriented recreational facilities would include visitor
centers at the dams, boat launching ramps, campgrounds, picnic areas,
and trail systems. Some of these facilities would be developed in
cooperation with Federal, State or private owners of land adjacent to
the project. Housing would also be provided for operations personnel.
The total first costs of the proposed hydroelectric project based
on October 1976 prices are estimated at $1.86 billion, including the
transmission system. Overall, Devil Canyon costs are estimated at
$527,000,000, and Watana at $1,327,000,000. Watana Dam would be con-
structed first and Watana's costs would include the total cost of the
transmission system.
The benefit-to-cost ratio compared to the coal alternative at 6-1/8
percent interest rate and 100-year project life is 1.3 using Federal
financing.
6
. ~.
Detailed power and economics, hydrology, project description and costs,
foundation and materials, transmission line, and recreational information
are available at the Alaska District, Corps of Engineers, office in Anchorage,
Alaska.
Various studies, reports, and articles provided background data and infor-
mation for this Environmental Impact Statement. (See Selected Bibliography.)
Environmental studies by the Corps and other State and Federal agencies
will continue, in order to provide a detailed and exhaustive evaluation of
project impacts. The water Resources Development Act of 1974, Public Law
93-251, sets forth a two-stage post-authorization preconstruction planning
process prior to Congressional authorization for construction. When a
project is authorized and funded for preconstruction planning, the process
requires the Corps of Engineers to report their findings for Congressional
approval before advancing to final project design and construction. During
this interim period, additional studies will be undertaken to further assess
environmental impacts of the project. The EIS will be supplemented during
this phase to reflect the changed conditions which normally prevail several
years later when planning and design studies are undertaken, and to more
fully address impacts on those resources for which detailed information is
presently limited. Since supplements to the EIS will again be fully coordinated
with all reviewing entities, Congress will be fully apprised of the latest
thinking and the fullest possible consideration of environmental impacts
in det~rmining ~hether or not to authorize con~truction of the ·project.
The environmental studies will include investigation and evaluation of
possible ecological and socio-economic impacts of the project. As specific
areas of concern are identified during preconstruction studies, they will
be investigated more intensively. Problems to be addressed during the
detailed design study phase include identification of significant adverse
impacts to the environmental, cultural and recreational resources of the
area and specific actions which should be taken to prevent, ameliorate,
or mitigate these impacts. Inventory and evaluation of fish and wildlife
resources affected by the project will continue. Intensive hydrological
studies will be made to determine the effects of altered stream flow on
the fish and wildlife habitat downstream of the project. Mineral resource
potential will be assessed for the impoundment areas. Also reconnaissances
and surveys will be made for historical and archeological resources which
may lie within the proposed project sites and transmission corridors .
FIGURE 3
8
UPPER SUSITNA RIVER PROJECT
TRANSMISSION. SYSTEM LAYOUT .~,
SCALE
0 50 IOOMile•
APA-1975
2.0 ENVIRONMENTAL SETTING WITHOUT THE PROJECT
2.01 Physical Characteristics
2.01.1 Description of the Area. The Susitna River, with an overall
drainage area of about 19,400 square miles, is the largest stream
discharging into Cook Inlet. The Susitna River basin is bordered on the
south by the waters of Cook Inlet and the Talkeetna Mountains, on the
east by the Copper River plateau and the Talkeetna Mountains, and on the
west and north by the towering mountains of the Alaska Range. The upper
Susitna River upstream from the proposed Devil Canyon damsite drains an
area of approximately 5,810 square miles (see Figure 2).
Three glaciers flow down the southern flanks of the Alaska Range
near 13,832-foot Mount Hayes to form the three forks of the upper
Susitna River. These forks join to flow southward for about 50 miles
through a network of channels over a wide gravel flood plain composed of
the coarse debris discharged by the retreating glaciers. The cold,
swift, silt-laden river then curves toward the west where it winds
through a single deep channel, some 130 miles through uninhabited
country, until it reaches the Alaska Railroad at the small settlement of
Gold Creek.
After the Susitna escapes the confinement of Devil Canyon, the
river•s gradient flattens. The river then turns south past Gold Creek,
where it flows for about 120 miles through a broad silt and gravel~
filled valley into Cook Inlet near Anchorage, almost 300 miles from its
source.
Principal tributaries of the lower Susitna basin also originate in
the glaciers of the surrounding mountain ranges. These streams are
generally turbulent in the upper reaches and slower flowing in the lower
regions. Most of the larger tributaries carry heavy loads of glacial
silt during the warmer summer months.
The Yentna River, one of the Susitna•s largest tributaries, begins
in the high glaciers of the Alaska Range, flows in a general south-
easterly direction for approximately 95 miles and enters the Susitna
24 miles upstream from its mouth.
The Talkeetna River originates in the Talkeetna Mountains on the
southeastern part of the basin, flows in a westerly direction, and
discharges into the Susitna River 80 miles upstream from Cook Inlet and
just north of the community of Ta ·1 keetna.
The Chulitna River heads on the southern slopes of Mount McKinley,
the highest point in North America, with an elevation of 20,320 feet.
The river flows in a southerly direction, joining the Susitna River near
Talkeetna.
9
Susitna Glacier on Susitna River drainage. Glacier melt in
summer months contributes to hieh sediment"in the river.
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UPPER SUSITNA RIVER BASIN
AlASIU. DISTRicT, CORPS Of EHGINEfllt _ ........
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The principal tributaries of the upper Susitna basin are the silt-
laden Maclaren, the less turbid Oshetna, and the clear-flowing Tyone
(Figure 4). Numerous other smaller tributaries generally run clear.
Streamflow in the Susitna River basin is characterized by a high rate of
discharge from May through September and by low flows from October
through April.
Much of the Upper Susitna River Basin is underlain by discontinuous
permafrost. Permafrost is defined as a thickness of soil, or other
surficial deposit, or of bedrock beneath the ground surface in which a
temperature below 320F has existed continuously for two years or more.
Such permanently frozen ground is found throughout much of Alaska.
The area above and below the Maclaren River junction with the
Susitna is generally underlain by thin to moderately thick permafrost.
Maximum depth to the base of permafrost in this area is about 600 feet.
Around the larger water bodies, such as lakes, permafrost is generally
absent. In some areas of the lower section of the upper Susitna basin, _
permafrost is not present. Additional data is required before permafrost
areas can be specifically identified upstream from Devil Canyon.
Because of the length of the proposed transmission system, and the
diversity of terrain and ecosystems bisected by a corridor extending
from Anchorage to Fairbanks, the system is divided into six major
segments which lend themselves to discussion in terms of generally
similar ecological characteristics. The route extending south from
Watana Dam to Point MacKenzie is referred to as the Susitna Corridor.
The route north from Gold Creek to Ester is called the Nenana Corridor
(both corridors share the line from Watana to Gold Creek). The corridor
for most of its length generally parallels the Alaska Railroad.
The Susitna Corridor is subdivided into three major segments: (a)
Point MacKenzie north to Talkeetna, a distance of 84 miles; (b) Talkeetna
to Gold Creek, 38 miles; and (c) Gold Creek to Watana, 44 miles. The
Nenana Corridor is also divided into three segments (continuing north):
(a) Gold Creek to Cantwell, 62 miles; (b) Cantwell to Healy, 39 miles;
and (c) Healy to Ester, 97 miles. These locations are shown on Figure 3.
Relevant physical and ecological features of individual transmission
line segments are described in the following paragraphs.
2,01.2 River Characteristics. The upper Susitna River is a scenic,
free-flowing river with very few signs of man 1 S presence. The extreme
upper and lower reaches of the Susitna occupy broad, glacially scoured
valleys. However, the middle section of the river, between the Denali
Highway and Gold Creek, occupies a stream-cut valley with extremely
violent rapids in Devil Canyon.
12
1
I
-' w
Confluence of the Tvone and Susitna Rivers several miles above
the upper reaches of the proposed Watana reservoir.
)
The Susitna River is one of three major whitewater rivers in Alaska.
Portions of all three are Class VI (on a scale of I to VI) boating
rivers at the upper 1 imit of navigability. Few kay akers have completed
the challenging 11-mile run through Devil Canyon. One who has success-
fully kayaked it, Dr. Walt Blackadar, has described it as the 11 Mount
Everest 11 of kayaking (Anchorage Daily Times, March 28, 1973).
The Susitna·was one of the Alaskan rivers recommended for detailed
study as possible additions to the National Wild and Scenic Rivers
System in 1973, but was not one of the 20 rivers recommended for inclu-
sion in the system by the Secretary of the Interior in 1974. The
Susitna River has not yet been studied as recommended.
About 86 pel"cent of the total annual flow of the upper Susitna
occurs from May through September, with the mean daily average flow from
late May through late August in the range of 20,000 to 32,000 cubic feet
per second. In the November through April period, the mean average
daily flow of the river is in the range of 1,000 to 2,500 cubic feet per
second. On 7 June 1964, the recording station at Gold Creek measured a
flow slightly in 1excess of 90,000 cubic feet per second, which was the
highest flow recorded for the upper Susitna River since recording started
in 1950.
High summer discharges are
glacial melt. The main streams
during the high runoff periods.
retard water flows, streams run
caused by snowmelt, rainfall, and
carry a heavy load of glacial silt
During the winter when low temperatures
relatively silt-free.
2.01.3 Cook Inlet. All of the major water courses which flow into Cook
Inlet either originate from glaciers or flow through erosive soils;
either type of stream carries a high suspended-solids load. The natural
high flow period in steams tr·ibutary to Cook Inlet occurs during the
summer months of May to September, the main period when sediment is
transported to tbe Inlet.
Freshwater runoff into the upper Inlet is an important source of
nutrients and sediments. Large quantities of nitrate, silicate, and
surface-suspendect sediment with particulate organic carbon enter the
Inlet with fresh water. Concentrations are especially high in the
initial runoff ec;tch spring and summer. These additions decrease in
concentration down the Inlet upon subsequent mixing with saline oceanic
water and with tidal action. The large input of fresh water dilutes and
tends to reduce $a 1 i nity and phosphate concentration around river mouths
and in the upper reaches of Cook Inlet.
2.01.4 Geology/Topography
2.01.4.1 General. The Railbelt area is characterized by three lowland
areas separated by three major mountain areas. To the north is the
14
Tanana-Kuskokwim Lowland, which is delineated by the Alaska Range to the
south. The Susitna Lowland is to the southwest, bounded to the north by
the Alaska Range, and to the east by the Talkeetna and Chugach Mountains.
The Copper River Lowland in the east is bounded on the north by the
Alaska Range, and the west by the Talkeetna Mountains. Each basin is
underlain by quaternary rocks surfaced with glacial debris, alluvium,
and eolian deposits. The mountains are primarily metamorphic and sedi-
mentary rocks of the Mesozoic, with several areas of intrusive granitic
rocks in the Talkeetna Mountains and the Alaska Range, and Mesozoic
volcanic rocks in the Talkeetna Mountains. Figure 5 delineates the
major features.
2.01.4.2 Susitna Basin. The Alaska Range to the west and north and the
Talkeetna Mountains to the east make up the high perimeter of the Lower
Susitna River Basin. The Alaska Range is made up of Paleozoic and
Mesozoic sediments, some of which have been metamorphosed in varying
degrees and intruded by granitic masses. The Talkeetna Mountain Range,
with peaks up to 8,850 feet, is made up of a granitic batholith rimmed
on the Susitna basin side by graywackes, argellites, and phyllites.
Much of the interior portion of the basin is fluvial-glacial overburden
deposits. Glaciers, in turn, carved the broad U-shaped valleys.
Glacial overburden covers the bedrock, which is composed mainly of shale
and sandstone with interbedded coals, Paleozoic and Mesozoic sediments,
and lava flows.
The Upper Susitna River Basin is predominantly mountainous, bordered
on the west and south by the Talkeetna Mountains, on the north by the
summits of the Alaska Range, and on the south and east by the flat
Copper River plateau. Valleys are floored with a thick fill of glacial
moraines and gravels.
2.01.4.3 Transmission Line Corridor. Beginning at sea level at Point
MacKenzie, the transmission line corridor rises to an elevation of 500
feet at Talkeetna. The corridor traverses a wide river valley with
rolling terrain east of the Susitna River and extremely flat land to the
west. The valley flattens and widens to the south, is poorly drained,
and has many bogs and lakes.
From Talkeetna to Gold Creek, the corridor follows a moderately
narrow valley floor narrowing toward the northern end. Maximum elevation
is 900 feet.
The corridor from Gold Creek to Watana rises to an elevation of
about 2300 feet on the plateau south of Devil Canyon before descending
to the Watana damsite.
15
---------~---~----~----·-"""""'1'1'----~---~-----------·-·
LEGEND
SEDIMENTARY A.l\!D META..\!ORPHIC ROCKS
[
QCATER"JARY
Surficial deposits", alluvium, glacial debris,
eolian sand and silt
TERTIARY
Sandstone, conglomerate, shale, mudstone;
nonmarine and marine
MESOZOIC
Sandstone and shale; marine and nonmarine;
includes some metamorphic rocks
PALEOZOIC A..'\D PRECA~IBRIA.l'.J
Sandstone, shale, limestone; mostly marine;
includes some early 1-.!esozoic rocks
PALEOZOIC A..\'D PRECA!-.!BRIAN
Metamorphic rocks: schist, gneiss, etc,;
mainly Paleozoic
IGNEOUS ROCKS
()'I I <:II f\ I Quaternary and Tertiary volcanic rocks
~~~1~ Mesozoic intrusive rocks; mainly gr_anitic
f + + + +jMesozoic volcanic rocks
Paleozoic volcanic rocks
~~ ".;."~> :1 Paleozoic intrusive rocks; granitic and ultramafic
~---------
Fault
(Dashed where inferred)
Source: U.S.G.S.
APA-1975
)
--~
GEOLOGY
OF THE
RAILBELT AREA ------~LE
0 50
)
Between Gold Creek and Cantwell, the corridor rises to a 240~-foot
elevation. It traverses a wide valley with moderately incised rivers in
the south, becoming a very wide depression in Broad Pass with rolling
valley bottom continuing to the northeast.
From Cantwell, elevation 2200 feet, the Nenana River valley narrows
to the north into a series of tight canyons separated by the wide valley
of Yanert Fork. The corridor emerges from the canyon into a wide
rolling plain south of Healy, with stream terraces adjacent to the
Nenana River. The corridor is bisected by the Denali Fault at Windy
Creek. Elevation at Healy is 1400 feet, dropping to 350 feet at Nenana,
and rising again to 1500 feet in the Goldstream Hills southwest of
Ester.
2.01.4.4 Seismic Areas. The southcentral area of Alaska is one of the
world's most active seismic zones. In this century, 9 Alaskan earth-
quakes have equalled or exceeded a magnitude of 8.0 on the Richter
Scale, and more than 60 quakes have exceeded a magnitude of 7.0.
Several major and minor fault systems either border or cross the Susitna
River basin. The March 1964 Alaska earthquake, with a magnitude of 8.4,
which struck southcentral Alaska, was one of the strongest earthquakes
ever recorded. A total of 115 lives were lost, 98 by quake-associated
tsunami (seismic sea waves). The Richter scale is a logarithmic scale
where a 7.0 earthquake would be ten times stronger than a 6.0 quake and
an 8.0 quake would have one hundred times the intensity of a 6.0 earth-
quake.
Much of southcentral Alaska falls within seismic zone 4 (on a scale
of 0 to 4) where structural damage caused by earthquakes is generally
the greatest. This area of Alaska and the adjoining Aleutian chain are
just part of the vast, almost continuous seismically and volcanically
active belt that circumscribes the entire Pacific Ocean Basin.
2.01.4.5 Minerals. Most of the Susitna basin above Devil Canyon is
considered to be highly favorable for deposits of copper or molybdenum
and for contact or vein deposits of gold and silver. One known deposit
of copper of near-commercial size and grade is near Denali. Also, the
Valdez Creek gold placer district, from which there has been some pro-
duction, is within the proposed project watershed.
Though a number of mineral occurrences are known and the area is
considered favorable for discovery of additional deposits, much of the
drainage basin has never been geologically mapped. Thus, geologically,
the basin constitutes one of the least known areas in the State except
for a few areas in the vicinity of Denali where some geologic mapping
has been done.
Geologic information for the project area is not detailed enough to
assess mineral resource potential within the proposed reservoir impoundment
areas.
17
--------~-----------------------------------~----------------------------------------
The Alaska State Department of Natural Resources states that there
are 11 active 11 and 11 non-active'' mining claims in the upper Susitna River
drainage area between Devil Canyon and the Oshetna River. Many of these
claims are in upper Watana Creek above the maximum reservoir pool
elevation, and in the surrounding drainage areas where copper activity
is moderately extensive.
2.01.5 Climate. The Susitna basin has a diversified climate. The
latitude of the region gives it long winters and short summers, with
great variation in the length of daylight between winter and summer.
The lower Susitna basin owes its relatively moderate climate to the warm
waters of the Pacific on the south, the barrier effect of the Alaska
Range on the west and north, and the Talkeetna Range on the east. The
summers are characterized by moderate temperatures, cloudy days, and
gentle rains. T~e winters are cold and the snowfall is fairly heavy.
At Talkeetna, at an elevation of 345 feet, which is representative of
the lower basin, the normal summer temperature ranges between 440 and
680F, with winter temperatures ranging between oo and 40oF. The extreme
· temperature range is between -48° and 9loF. The average annual precipi-
tation is about 29 inches, including about 102 inches of snowfall.
The upper Susitna basin, separated from the lower basin by mountains,
has a somewhat colder climate and an average overall annual precipi-
tation rate of approximately 30 inches.
The climate of the transmission line corridor from Devil Canyon to
Point MacKenzie is transitional, with mild, wet conditions prevailing
toward the southern end of the segment. The northern corridor has
extremely variable climate related to differences in elevation. From
Gold Creek to Cantwell, the annual temperature averages 25.9oF and
annual precipitation 21.85 inches. From Cantwell to Healy, the annual
temperature is 27.7°F and annual precipitation 14.5 inches. High winds
are reported in this segment. North from Cantwell, the climate is
typical of the interior, with an average temperature of 26.4°F and
annual precipitation 11.34 inches.
2.02 Biological Characteristics.
2.02.1 Fish.
2.02.1.1 Anadromous Fish. Fish inhabiting the Susitna basin are
divided into two major groups: resident and anadromous. The anadromous
fish spends a portion of its life cycle in salt water, returning to the
freshwater streams to spawn. In this group are included five species of
Pacific salmon: sockeye (red}; coho (silver); chinook (king); pink
(humpback); and chum (dog} salmon. Juvenile salmon of sev~ral of these
soecies spend several years in fresh water before migrating to sea. All
five species of salmon die soon after spawning. Dolly Varden, a char,
is widely distributed in the streams of Cook Inlet and is present in the
Lower Susitna River Basin with both anadromous and resident populations.
18
.~.
Smelt runs are known to occur in the Susitna River as far upstream as
the Deshka River about 40 miles from Cook Inlet.
Salmon are found to spawn in varying numbers in some of the sloughs
and tributaries of the Susitna River below Devil Canyon. Salmon surveys
and inventories of the lower Susitna River and its tributaries have been
made over a number of years, resulting in considerable distributiOn
data; however, population studies and additional resource studies are
needed. The surveys indicate that salmon are unable to ascend the
turbulent Devil Canyon, and, thus, are prevented from migrating into the
Upper Susitna River Basin.
The 14 million pounds of commercial salmon caught in Cook Inlet
during 1973 comprised about 10 percent of the 136.5 million pounds of
salmon harvested in Alaska during the year. Chum, red, and pink salmon
totaled about 94 percent of the salmon catch for Cook Inlet during 1973.
1973 Catch and Production--Commercial Fisheries Statistics--Leaflet
#26, State of Alaska Department of Fish and Game .
The 1973 commercial catch figures do not approach the maximum
sustained yields for Cook Inlet, but do present the latest available
commercial catch information, and except for chinook salmon are rep-
resentative of the last several years of commercial salmon fishing.
Sport and subsistence fishing for salmon in Cook Inlet and in the
Susitna basin are also important considerations.
According to the Alaska Department of Fish and Game, a significant
percentage of the Cook Inlet salmon run migrates into the Susitna River
Basin. Although all salmon stocks are important, data from earlier 1950
and 1960 fish and wildlife reports added to the latest 1974-75 studies
indicate that only a sm~ll percentage of the Susitna Basin salmon
migrate into the 50-mile section of the Susitna River between the pro-
posed Devil Canyon damsite and the confluence of the Chulitna River to
spawn in the river•s clearwater sloughs and tributaries. Further studies
should determine more specific information on salmon numbers and habitat
impacts. A 1974 assessment study, by the Alaska Department of Fish and
Game, of anadromous fish populations in the Susitna River watershed
estimated 24,000 chum, 5,200 pink, 1,000 red, and between 4,000 and
9,000 coho salmon migrated up the Susitna River above the river•s con-
fluence with the Chulitna River during the 7-week study period from 23
July through 11 September when most of the salmon were migrating up the
river. The report indicated that chinook salmon were also present.
According to the 1974 assessment by the Alaska Department of Fish
and Game, a minimum of 1,036 pink, 2,753 chum, 307 coho, and 104 sockeye,
and an undetermined number of chinook salmon spawned during the August
and September spawning period in the streams and sloughs of the Susitna
River between the Chulitna River tributary and Portage Creek as deter-
mined from peak slough and stream index escapement counts. The assess-
ment also indicated that a portion of the pink salmon spawn in the study
area may have been destroyed by a late August-early September flood.
19
---·~----·--~.
I
Chinook (King Salmon). The king salmon spends from one to three
years in fresh water before migrating to sea. It is not unusual. for
this species to attain a weight of over 40 pounds. The maximum age is
8 years. In 1973, over 5,000 kings were caught in Cook Inlet; the total
commercial catch comprised about 1.5 percent of the total weight of
salmon caught in this area. The 1973 catch figures for king salmon were
very low when compared to the average yearly catch for this species.
Sockeye Salmon (Red). The sockeye salmon averages between 6 and 8
pounds, with a range of from 2 to 12 pounds. This species spends from
1 to 3 years in a river system in which there are connecting lakes. The
maximum age attained by this salmon is 7 years, but most return to spawn
at 4 or 5 years of age. The landlocked variety of this species is
called a kokanee and usually attains a length of from 12 to 15 inches.
In 1973, almost 700,000 sockeyes were caught in Cook Inlet, with a total
weight of over 5 million pounds, or 37.0 percent of the total weight of
the Cook Inlet commercial salmon catch. About 14.5 percent of the
sockeye salmon catch in Alaska occurred in Cook Inlet.
Coho Salmon (Silver). The coho or silver salmon spends from 1 to
2 years in fresh water and returns from the ocean to spawn at 3 or
4 years of age. Mature coho average about 10 pounds; some reach weights
of over 30 pounds. The 106,000 cohos caught in Cook Inlet during 1973
weighed just over 648,000 pounds and comprised about 4.5 percent of the
total commercial salmon catch for the area.
Pink Salmon (Humpback). The pink salmon migrates to sea immediately
after hatching and returns to spawn at 2 years of age. The average
weight of a mature pink is 3 to 4 pounds, with some pinks weighing up to
10 pounds. The 624,000 pink salmon caught in Cook Inlet during 1973
weighed over 2,260,000 pounds and comprised about 16.2 percent of the
total weight of the commercial salmon catch in the area. Historically,
odd-year catches of pink salmon are poor. Even-numbered year catches
average about 2 million pinks.
Chum (Dog Salmon). Chum salmon attain weights of up to 30 pounds,
with an average mature weight of 8 to 9 pounds. This species migrates
to sea immediately after hatching and matures between 3 and 6 years of
age. The 742,000 chums caught in Cook Inlet during 1973 weighed almost
5,800,000 pounds and made up over 41.0 percent of the total commercial
salmon catch for the area, the largest percentage of any of the 5 species
of Pacific salmon. About 12.5 percent of the 1973 Alaskan chum salmon
catch occurred in Cook Inlet.
Salmon eggs hatch in late winter or early spring following the
summer and fall spawning periods. The eggs incubate in gravelly stream-
beds and cannot tolerate high levels of siltation o~ low flows that
dewater the streambeds during the incubation or alevin (pre-emergent)
stages. Low flows, especially critical during the winter months, can
dewater many of the spring-fed freshwater sloughs that are available to
spawning salmon (see Table 1, page 45.)
20
/~.
,,_. -----------------------------------------------------
2.02~1.2 Resident Fish. Grayling, rainbow trout, lake trout, Dolly
Varden, whitefish, sucker, sculpin, and burbot (ling) comprise the
principal resident fish population of the Susitna River basin. Although
distribution studies have been made in the past, the magnitude of
resident fish populations in the Susitna drainage is largely unknown.
During the warmer months of the year, when the Susitna River is
silt laden~ sport fishing is limited to clearwater tributaries ~nd to
areas in the main Susitna River near the mouths of these tributaries.
Resident fish, especially grayling, apparently inhabit the mouths
of some of the clearwater streams on the Susitna River between Devil
Canyon and the Oshetna River; however, most of the tributaries are too
steep to support significant fish populations. Some of the upper sections
of these clearwater tributaries, such as Deadman Creek, support gray1 ing
populations. Lake trout are also prominent in many of the terrace and
upland lakes of the area.
2.02.2 Birds.
2.02.2. 1 Waterfowl. The east-west stretch of the Susitna River between
the Tyone Rive'r and Gold Creek is a major flyway for waterfowl. The
majority of the waterfowl nesting areas in the Upper Susitna River Basin
are on the nearby lakes of the Copper River Lowland region, on the Tyone
River and surrounding drainage areas, and on the ponds and lakes of the
wide flood plain in the Denali area.
The Upper Susitna River Basin has a moderate amount of use by
waterfowl when compared with the Lower Susitna River Basin. The. lower
basin has a substantially greater amount of waterfowl habitat, and a
greater number and variety of waterfowl seasonally use the thousands of
lakes and ponds in this area to nest and to raise their young. Large
numbers of migrant birds also use the Susftna River basin for feeding
and resting during spring and fall flights to and from Alaska•s interior
and north slope. Distribution and density of waterfowl habitat within
the Railbelt area is shown on Figure 6.
2.02.2.2 Raetors. Raptors, including golden eagles, bald eagles, and
various spec1es of hawks, owls, and falcons, occur throughout the entire
Susitna River basin but in smaller numbers in the river canyon between
Portage Creek and the Oshetna River. A June 1974 survey of cliff-
nesting raptors conducted by the U.S. Fish and Wildlife Service, deter-
mined that the population densities of these birds between Devil Canyon
and the Oshetna River are low and that no endangered species of per-
egrine falcons, American or arctic, appear to nest along the upper
Susitna River. Peregrines have occasionally been sighted within the
area of the upper Susitna basin and along migration routes through the
Broad Pass area of the upper Chulitna River.
21
~ ~r·
~JliJJJlTif~i?h. Density.\
[IT[[[] Methum Dens1ty
[II] Low Density
Source• Joint Foderoi·Sidta L.an -
lin Plonnlno tM"lmHslon
{f;l~
FIGURE 6
22
WILDLIFE
WATERFOWL HABITAT
I
A.P.A.-JULY 1975
/-.,.
. ,.-....,.
On.the basis of the 1974 U.S. Fish and Wildlife Service findings,
other raptor populations in the canyon area of the upper Susitna River
were determined to be minor, although minimal data were acquired on the
tree-nesting raptors. Several nesting pairs of bald eagles and gyr-
falcons were observed in or near the canyons of this area, and golden
eagles frequently occupied upland cliffs in the vicinity of Coal Creek.
Substantial populations of ravens were found in reaches of th~
Susitna River above Gold Creek. The nests of this large bird are often
used by raptors, including peregrines and gyrfalcons. However, there
was no evidence that the nests observed were being used by raptors.
2.02.2.3 Other Birds. Unknown numbers of game birds, such as spruce
grouse and willow ptarmigan, inhabit the Upper Susitna River Basin.
Some incidental game bird hunting takes place along the Denali Highway,
but such hunting pressures are practically nonexistent in most of the
area.
Various other species of birds including songbirds, shorebirds, and
other small birds are found throughout the Upper Susitna River Basin in
varying numbers.
2.02.3 Mammals.
2.02.3.1 Caribou. One of the most significant wildlife resources of
the Upper Susitna River Basin is the wide-ranging Nelchina caribou herd.
This herd, a major recreational and subsistence resource in the south-
central region, declined from a population high of about 71,000 in 1962
to a low of between 6,500 and 8,100 animals in 1972. This spectacular
decline has been attributed to various factors, including migration to
other areas, bad weather, predation, and overhunting. Motorized all-
terrain vehicle access to the backcountry has improved hunting success
even in the face of a rapidly declining caribou population.
Segments of the Nelchina herd periodically range throughout much of
the Upper Susitna River Basin (see Figure 7). The major calving area
for the herd is on the northeast slopes of the Talkeetna Mountains on
the upper reaches of the Kosina Creek, Oshetna River, and Little Nelchina
River drainages. Calving generally takes place between mid-May and mid-
June. Except for intermittent seasonal migration routes across the
Susitna River in areas upstream from Tsusena Creek, caribou are not
resident to the main Susitna River canyon between Devil Canyon and the
Oshetna River.
Caribou depend upon climax range, especially for winter forage; any
alteration of the vegetation, especially of sedges and lichens, has a
detrimental impact upon their distribution and numbers. A trait of the
Nelchina herd is an almost constant change of winter ranges, a phenomenon
that has undoubtedly characterized Alaska•s caribou populations for
centuries .
23
MAP
EW?J Caribou· Winte; Range
-~ Caribou Summer Range
. . . . . . . . . ' . ' ' ' . ' . . . . . .
oo~t~·~ii.
FIGURE 7
24
WILDLIFE
CARIBOU AND BISON
A.P.A.-JULY 1975
The Alaska Department of Fish and Game considers the Nelchina herd
to be one of the State•s most important caribou populations. Several
thousand hunters from Anchorage and Fairbanks participate in the annual
hunting of this species. Additional thousands of non-hunting recrea-
tionists view the migrations of caribou as they cross the State•s major
highways. In addition, the herd provides sustenance to predators and
scavengers such as wolves, grizzly bears, black bears, wolverines, lynx,
and various species of birds. ·
Caribou are essentially limited in distribution within the trans-
mission 1 ine system to the 136-mile segment extending north from Cantwell.
In the mountainous area between Cantwell and Healy, they concentrate
south of canyons. They are found in concentrations on the west bank of
the Nenana River north of Healy and south of Clear Air Force Base,
2.02.3.2 Moose. Moose range throughout much of the Upper Susitna River
Basin (Figure 8). Wide fluctuations of populations have occurred over
the years. A 1973 Alaska Department of Fish and Game fall aerial count
resulted in sighting of approximately 1,800 moose in the upper Susitna
River drainage. Numbers of moose in the southcentral region of A~aska
have been reduced in recent years due mainly to weather conditions,
hunting pressures, wolf predation, unbalanced age-sex ratios, and elimi-
nation of habitat.
Much of the Upper Susitna River Basin is at or above timberline,
resulting in large amounts of 11 edge 11 at timberline which produce con-
siderable quantities of willow, an important winter forage for moose.
Successional vegetation changes following fire also contribute heavily
to areas favoring moose habitat.
Limited numbers of moose inhabit the Susitna River bottom between
Devil Canyon and the Oshetna River, because of a restricted amount of
suitable habitat. However, the available habitat provides critical
winter range for moose that do utilize this area.
Moose inhabit the entire length of the transmission line corridor
but are more abundant in the lower valleys. In mountainous terrain,
they are more commonly found in more open parts of canyons.
2.02.3.3 Grizzly/Brown Bears. Grizzlies, also referred to as brown
bears in Alaska, are common throughout the Susitna River drainage and
are fairly numerous in the upper Susitna despite the absence of salmon.
Alpine and subalpine zones are the habitats most frequently used by
grizzlies, although the more timbered areas are seasonally important.
Denning begins in October, and all bears are in dens by mid-November
(see Figure 8). Bears usually reappear during May, depending on weather
conditions. Important spring foods include grasses, sedges, horsetails~
other herbaceous plants, and carrion when available. On occasion,
25
MAP
~Brown/Grizzly Bear Denning Areas
1)//::l Moose Concentra1ion
WILDLIFE
MOOSE, DALL SHEEP, BROWN BEAR
FIGURE 8
26
' -----..---.;;.;.;,.~!-E_ ~ --
0 50 100 Miles
A.P.A.-JULY 1975
moose or caribou calves are taken. Berries--lowbush and highbush
cranberries, blueberries, and bearberries--provide major summer food
supplements. A prime consideration for grizzly bears is to minimize
direct conflict with humans as the grizzly is adversely affected by
contact with man.
Hunting for grizzly bears in this area often occurs incidentally to
other hunting during the short fall open season.
Within the transmission line corridor, mosf grizzly bears are
1 imited in distribution to the higher areas, primarily between Cantwell
and Healy although they are found throughout this part of Alaska.
2.02.3.4 Black Bears. The Upper Susitna River Basin supports fair
black bear densities. The larger populations are in semi-open forested
areas with readily accessible alpine-subalpine berry crops. River
bottoms, lake shores, and marshy lowlands are favorite spring black bear
areas. Black bears generally eat many of the same types of food as are
eaten by grizzlies. Denning habits are also somewhat similar to the
grizzly bear 1 s.
Natural fires generally benefit black bears, especially when dense
mature spruce stands are burned. Most other land uses do not seriously
affect bear numbers in this area, and black bears are not as adversely
affected by contact with man as are grizzlies.
Black bears are found in forested areas throughout the length of
the transmission line corridor.
2.02.3.5 Dall Sheep. These sheep are present in many areas of the
Alaska Range, Talkeetna Mountains, and in the higher elevations of the
Susitna River basin (Figure 8). The greatest concentrations of Dall
sheep in the Susitna basin occur in the southern portions of the Tal-
keetnas; herds become scattered on the northern portion of the range,
where parts of the mountains are uninhabited by sheep. Dall sheep are
also found in the Watana Hills. Because of the relatively gentle nature
of much of the Talkeetna Mountains and Watana Hills, predation in this
area has more effect on sheep numbers than in more rugged habitats~
Sheep have always furnished some of the diet of wolves and other carni-
vores in this area.
Within the transmission line corridor, Dall sheep are essentially
limited to the mountainous area between Cantwell and Healy.
Hunting pressure for rams is fairly heavy due to relatively good
access from highways, by air, and by ATVs (all-terrain vehicles).
Nevertheless, as is true elsewhere in the State, ram-only hunting seems
to have little effect on overall numbers. Sheep populations are almost
entirely controlled by natural factors such as habitat, weather condi-
tions, predation, and disease. Conflicts between man 1 s activities and
27
critical sheep habitat, such as lambing or wintering areas, can adversely
impact Dall sheep populations.
2.02.3.6 Mountain Goats. Goats occur in low numbers in various areas
of the Talkeetna Mountains and in the Watana Hills area, and do not
provide a signif,icant amount of hunting in the upper Susitna basin.
The goats generally inhabit rougher terrain than do Dall sheep, and are
thus less susceptible to man's activities.
2.02.3.7 Wolves~ Wolves occur throughout most of the Upper Susitna
River Basin. Populations are subject to rapid fluctuations, and esti-
mates should be viewed with extreme caution. Wolf numbers have been
estimated from a low of 13 in 1943, after predator control efforts, to a
high of 400 to 450 in 1965. Currently an estimated 300 wolves populate
the area encompassing the upper Susitna, the Talkeetna Mountains, and
the upper Copper River drainage area. The wolf has been removed from
predator classification and is now classified as a game animal in Alaska.
Alaska Department of Fish and Game management studies concluded
that, from 1957 to 1967, wolf.predation neither adversely affected other
game populations, nor reduced hunting success for sportsmen. However,
absolute conclusions were uncertain since moose and caribou populations
may have reached their highs during this period. The study proved that
wolves and men can often coexist while competing for game animals, but
that at times man must accept reduction of available game by wolves.
2.02.3.8 Wolverines. This area of Alaska has consistently produced
more wolverines than any other area of comparable size in the State.
Wolverines are seen regularly throughout the area, and it is not unusual
for a hunter returning to a kill site to ffnd a wolverine feeding on his
moose or caribou. Wolverines have withstood human encroachment and
trapping without any noticeable reduction in numbers or range.
2.02.3.9 Other Mammals. Fur animal species of the upper Susitna in
addition to wolf-and wolverine include beaver, muskrat, otter, mink,
Canada lynx, fox, marten, and weasel. Found in varying populations
throughout much of the Upper Susitna River Basin and transmission
corridor, each of these species has its own unique habitat requirements.
However, except for a limited number of beaver, the river canyon area
between Devil Canyon and the mouth of the Oshetna River is not con-
sidered good quality fur animal habitat for most of these species.
Other mammals found in this area include coyotes, snowshoe hares,
ground squirrels, tree squirrels, pikas, marmots, and several species of
voles, shrews, and mice. As with other animals, the populations of the
various species vary as adverse or beneficial factors are encountered.
28
Susitna River between Watana and Vee damsites.
Heavier vegetatiort, in this case upland spruce-
hardwood forest, is ,Limited to the valley slopes,
the vegetative biome on the upper plateaus is
generally moist tundra, muskeg, and alpine tnndra.
29
2.02.4 Threatened Wildlife of the United States. The only species in
the U.S. Fish and Wildlife Services publication, Threatened Wildlife of
the United States, that might be resident in or migrate through the
Upper Susitna River Basin are the two subspecies of the peregrine falcon:
Falco peregrines anatum (American) and Falco peregrines tundrius (arctic).
Although no peregrines appear to be nesting along the upper Susitna
River~at present, there have been occasional sightings within the area
and along known migration routes for this species as they move through
the Broad Pass area on the upper Chulitna River. These migrating
peregrines are occasionally reported to include members of the two
endangered subspecies.
Several species of wildlife that are considered threatened or
depleted in the Lower 48 States have substantial populations within
Alaska. Such species include the American bald eagle, the wolf, and the
grizzly bear.
2.02.5 Vegetation. The major ecosystems of Alaska are divided into
marine and land groupings, with the land group divided into fresh-water,
tundra, and coniferous systems. The freshwater system includes glaciers
and ice fields, lakes, and riverine ecosystems; the tundra system is
subdivided into moist, wet, and alpine tundras; and the coniferous
systelTI. is divided into six plant-related classifications.
The Upper Susitna River Basin includes the following four broad
land ecosystem classifications: moist tiJndra; alpine tundra; upland
spruce-hardwood forest;.and lowland spruce-hardwood forest. The largest
percentage of the basin is classified as moist or alpine tundra with
most of the area in and adjacent to the main river channel below the
Maclaren River classified as either upland or lowland spruce-hardwood
forest. ·
At Gold Creek, the bottomland forest of white spruce and black
cottonwoood is very much in evidence on well drained banks. Ascending
the river, balsam poplar replaces the tottonwoods arou~d Fog and Tsusena
Creeks. Thin hardwoods and white spruce become less and less in evidence
but still occur in small stands on well drained river bars and tributary
fans upstream to Butte Creek. Above this tributary, only scattered
stands of black spruce occur, growing up tothe glaciers. The lower
hillsides have a low brush cover with moist tundra in the lower areas.
The periodically flooded river flats are in willow, sedges-high brush,
and wet tundra. Since much of the drainage basin is uplands, alpine
tundra is one of the most prominent vegetation types.
Alpine tundra is composed of low mat plants, both herbaceous and
shrubby. Moist tundra usually forms a complete ground cover and is very
productive during the growing season. Plant types vary from almost
continuous cottongrass with a sparse growth of sedges and dwarf shrubs
to stands where dwarf shrubs dominate. Tundra ecosystems are especially
fragile and are very susceptible to long-term damage or destruction from
overuse. Regeneration is extremely slow, with some lichens requiring
more than 60 years to recove~.
30
Most of the timber ecosystems in the upper Susitna basin are located
adjacent to the river and tributaries on the canyon slopes and on the
surrounding benchlands. The major timber species include birch, balsam
poplar, black cottonwood, white spruce, and black spruce~;;;,Qverall, the
timber quality ·in this area is not goodo with a wideiv~rtety of sizes,
mostly smaller and noncommercial. ~1uch of the birctr and spruce is more
suitable for pulp than for sawtimber; however, a fairyield of sawlogs
could be obtained from stands of black cottonwood and balsam poplar.
The transmission 1 ine corridor transects five generally distinct
vegetation types. Three of these--upland spruce-hardwood, 1 owl and
spruce-hardwood, and alpine tundra--are common within the upper Susitna
basin, as discussed above. Two are related to distinctly different
land forms. Bottomland spruce-poplar is confined to broad flood plains
and river terraces, and warmer slopes of major rivers. Characteristic
vegetation is white spruce, balsam poplar~ birch, and aspen. Low
bush, bog, and muskeg are another distinct type usually formed on
outwash, and old river terracest in filling ponds and sloughs, and
throughout lowlands. Characteristic plants are tamarack, black spruce,
alders, willows, and berries.
Progressing northward from Point MacKenzie, the corridor is
pr·incipally characterized by bottomland spruce-poplar, lowland spruce-
hardwood, and muskeg bog to Talkeetna. From this point to Gold Creek,
bottomland spruce-poplar is interspersed with upland spruce-hardwood.
The segment leading from Gold Creek to Cantwell is typically bottom-
land spruce-poplar interspersed with upland spruce-hardwood, and
low brush-bog/muskeg. Through the Alaska Range between Cantwell
and Healy, the vegetation is a mixture of upland spruce-hardwood,
lowland spruce-hardwood, alpine tundra, and some low brush-muskeg/
bog. From Healy to Ester~ the vegetation is characterized by bottom-
1 and spruce-poplar, upland spruce-hardwood~ 1 owl and spruce-hardwood,
and low brush-muskeg/bog.
2.03 Cultural Characteristics.
2.03.1 Population. The Southcentral Railbelt area of Alaska contains
the State 1 s two largest population centers~ Anchorage and Fairbanks, and
almost three-fourths of the State 1 s total population. The Anchorage
area alone has over half the residents in the State. Recently revised
estimates for 1975 indicate over 386,000 people will be in Alaska by the
end of the year, compared to slightly over 302,000 counted in the 1970
census, an increase of about 28 percent in that period. Other estimates
by the Alaska Department of Labor indicate an expected State population
of almost 450,000 for the year 1980, an additional 16 percent increase
over 1975, and a population increase of nearly 50 percent in 10 years.
The largest growth in the State has been in the Southcentral Railbelt
area, and this trend is expected to continue. With the possible relo-
cation of Alaska's capital from Juneau to the Railbelt area 9 an addi-
tional population impact will be exerted on this area of the State.
31
w
N
)
Looking upstream at Susitna River near Gold Creek about 15 miles below Devil
Canyon. Note Alaska F.ailroad bridge.
At the present time, only a few sma 11 settlements are 1 oca ted a 1 ong
the Parks Highway between Anchorage and Fairbanks and the Alaska Rail-
road in the Susitna River valley. Except for the small settlement at
Denali, there are few, if any, permanent full-time residents in the
Upper Susitna River Basin above Devil Canyon.
2.03.2 Economics. Both Anchorage and Fairbanks are regional economic
centers for the Southcentral Railbelt area. Government, trade, and
services comprise the major portion of the area's total employment.
Construction and transportation are also important. Making relatively
less significant contributions are the financing, mining, and manufacturing
industries, while agriculture, forestry, and fisheries contribute less
than one percent of the employment dollar to the economy of the Railbelt
area. In 1972 the wages and salaries for the southcentral region of
Alaska amounted to more than $704,000,000.
In the government groups, employment is divided more or less equally
between Federal, State, and local sectors. The area's major Federal
employer is the Department of Defense, with most of its employees con-
centrated in four military installations. State and local government
employment includes employees from agencies of the State of Alaska and
the cities and boroughs within the area.
After government, the two groups having the largest employment are
trade and services. Their importance as sources of employment for the
Railbelt area residents is a further manifestation of the region's two
relatively concentrated population centers and of the high degree of
economic diversity, as well as levels of demand for goods and services,
which are substantially higher than in most other parts of Alaska. The
importance of construction is largely due to the high level of expansion
experienced by the Anchorage and Fairbanks areas since 1968. This
growth can partly be attributed to the trans-Alaska pipeline project,
which is encouraging much new construction in both public and private
sectors.
High levels of employment in the region's transportation industry
reflect the positions of Anchorage and Fairbanks as major transportation
centers, not only for the Southcentral Rail belt area but for the rest of
the State as well. The Port of Anchorage handles most of the waterborne
freight moving into southcentral and northern Alaska. International
airports at Anchorage and Fairbanks serve as hubs for commercial air
traffic throughout Alaska and are important stopovers for 37 major
international air carriers. Anchorage also serves as the transfer point
for goods brought into the area by air and water, which are then distri-
buted by air transport, truck or by Alaska Railroad to more remote
areas.
33
Although exerting relatively little direct impact on total employ-
ment, mining, finance, insurance, and real estate play important roles
in terms of the secondary employment theygenerate in the region. Most
people employed in mining engage in activities relating to petroleum
extraction from fields in Cook Inlet and the Kenai Peninsula. A sub-
stantial portion of the royalties and taxes collected by the State as a
result of oil production in the area is returned to the area in the form
of jobs in State government and through revenue sharing with various
local governments. The total value of oil and gas production in the
southcentral region for 1972 was almost $240 million. Similarly, the
Anchorage financial sector, in spite of its small employment, exerts
considerable economic leverage as the banking center for Alaska.
Most agricultural activities in the Southcentral Railbelt area take
place in the Matanuska, Susitna, and Tanana Valleys. The potential for
agriculture in these areas of Alaska is considered favorable, although
development of the industry has not been extensive.
Commercial fisheries activity is the oldest cash-based industry of
major importance within the region. The industry has changed substantially
during the past 20 years and continues to be modified as a result of
both biologic and economic stimuli. The salmon industry has always been
a major component of the industry in terms of volume and value. Since
1955, the king crab, shrimp, and Tanner crab fisheries have undergone
major development, and halibut landings have increased substantially in
recent years. The total wholesale value of commercial fish and shell-
fish for the southcentral region of Alaska in 1972 was just over $100
million including a catch of almost 110 million pounds of salmon with a
wholesale value of nearly $38 million.
The southcentral region of Alaska includes the Kodiak-Shelikof
area, the Cook Inlet area, and the Copper River-Gulf of Alaska area.
The Southcentral Railbelt area is that portion of the southcentral and
Yukon subregions that is served by the Alaska Railroad.
The region•s timber output is less than 10 percent of the total
timber harvested commercially in Alaska. The timber industry is shifting
from supplying the local market to production aimed at the export market.
Stumpage value of timber cut from State and National forest lands in the
southcentral region during 1972 was about $130,000.
The tourist industry plays an increasingly important role in the
economy of the region. Precise data on tourism are not available, but
the numbers of Alaskan visitors have increased from about 130,000 in
1971 to approximately 216,000 in 1973. A forecast by the Division of
Tourism in 1973 estimated 288,000 people would visit Alaska in 1975 and
about 554,000 in 1980.
34
r
I
w
01
Looking north along the Denali Highway to the .Amphitheater Mountains.
Morainal ridges nm across the middle of the photo. The biome along
most of the eastern half of the Denali Higlnvay is moist tundra.
)
With population trend projections showing a substantial increase in
the number of future residents in the State and espcially in the South-
central Railbelt area, there will be a related increase in the demand
for jobs, goods, energy, and services. Alaska has a wealth of reserves
in renewable and nonrenewable resources that will have to be addressed
in the very near future.
The world consumption of nonrenewable resources for energy produc-
tion such as oil and gas has reached or will soon reach a critical point
in time where alternative means to produce energy must be developed. The
need for the development and utilization of those renewable resources
must be weighed against the adverse effects that these developments
would have on an ever-decreasing regime of natural environment.
2.03.3 Transportation.
2.03.3. 1 Rail. The Alaska Railroad runs from Seward on the Gulf of
Alaska, past Anchorage, up the Susitna Valley, past Mount McKinley
National Park, and down to Fairbanks on the Tanana River, a distance of
483 miles. The Federally constructed and operated Alaska Railroad was
built between 1914 and 1923.
2.03.3.2 Roads. Paved roads in the Railbelt area include: the 127
mile Seward-Anchorage highway which includes 38 miles of the 174 mile
Sterling Highway between Seward and Homer; the newly-constructed 358-
mile Parks Highway between Anchorage and Fairbanks; a 205-mile section
of the Alaska Highway that connects Tok Junction with Fairbanks; the
328-mile Glenn Highway connecting Anchorage with Tok Junction; and the
266-mile Richardson Highway from Valdez, on Prince W"illiam Sound, to its
junction with the Alaska Highway at Delta Junction, 97 miles southeast
of Fairbanks.
The only road access through the upper Susitna basin is the 135-
mile gravel Denali Highway between Paxson on the Richardson Highway and
Cantwell on the Parks Highway, and the 20-mile gravel road from the
Glenn Highway to Lake Louise. The Denali Highway is not open for use
during the winter months.
2.03.3.3 Air. In addition to major airlines within Alaska, there are
numerous small commercial operators plus the highest per capita ratio of
private aircraft in the nation. Many small remote landing strips are
scattered throughout the Susitna basin, and float planes utilize many
lakes and streams to ferry freight and passengers to the remote back-
country areas. In many areas of the State, the only access is provided
by the airplane.
2.03.3.4 Other Forms of Transportation. ATV's and other types of
off-road vehicles provide transportation into areas in the upper Susitna
basin where there are no developed roads. Several developed trails are
36
shown on maps of the upper basin. Trails are utilized by ATVs, trail
bikes, hikers, horseback riders, and winter travelers.
Shallow-draft river boats, small boats, canoes, rubber rafts, and
kayaks utilize sections of the upper Susitna River, a few tributary
streams, Lake Louise, and some of the other lakes for recreation purposes.
Except for these few areas, boating use is practically nonexistent
within.much of the upper basin.
2.03.4 Recreation.
2.03.4.1 Access. The greatest constraint on recreation activities for
most of the 5,800-square-mile Upper Susitna River Basin is the shortage
of road access. Except'for a 20-mile gravel road from the Glenn Highway
to the southern shores of Lake Louise on the upper drainage of the Tyone
River, the main access to the area is by way of the gravel Denali Highway
through the upper part of the basin.
Float planes are used to fly in hunters, fishermen, and other
recreationists to various areas within the basin, but, except for a few
larger isolated lakes, this form of access is relatively minor. All-
terrain vehicles and snowmobiles also provide off-road access to areas
within the upper Susitna basin. Boats are used to some extent to provide
access on the Tyone River drainage and to areas of the Susitna River
between the Denali Highway and Devil Canyon.
IV!uch of the Upper Susitna River Basin has very 1 ittle recreational
activity at the present time. Great distances, rough or wet terrain,
and lack of roads limit use of most of this area to a few hardy souls
who enter these wild lands for recreational purposes, or to the wildlife
residents and migrant birds and animals that pass through the region.
2.03.4.2 Hunting. A major recreational use of the upper Susitna area
is big~game hunting and associated recreational activities. The greatest
hunting pressures are exerted from a few fly-in camps, and from areas
along the Denali Highway. Most wolves and bears harvested are taken
while hunting caribou or moose. The increased use of ATVs to provide
access and to haul big game is a significant factor in improved hunting
success, even in the face of declining game populations. The mechanized
ATV can penetrate deeply into previously inaccessible country, leaving
few areas that provide havens for the reduced numb~rs of caribou and
moose. It appears that the use of ATVs for hunting, already prohibited
in some areas, may have to be further controlled.
The hunting of Dall sheep, mountain goats, and waterfowl is minimal
in the upper basin even in areas of road access such as the Denali
Highway.
37
2.03.4.3 Fishing. Access is again the major factor in determining.
areas that are utilized in fishing for grayling, rainbow trout, white-
fish, and lake trout. The Susitna and Maclaren Rivers are silt laden
throughout their entire courses during the warmer months of the year.
Therefore, sport fishing is limited to lakes, clearwater tributaries,
and to areas in the main Susitna near the mouths of these tributaries.
Sport fishing pressure in the upper Susitna basin is light. Many
lakes and some areas of the river afford landing sites for float-equipped
aircraft. A few areas along the main Susitna and some tributaries, such
as the Tyone River and Lake Louise, have some pressure from boat fisher-
men. An increasing number of hunters use ATVs to get into and out of
the back country, exerting incidental fishing pressure in some areas.
As previously stated, salmon do not migrate into the upper Susitna
River above Devil Canyon so are not a factor in the sport fishery of
this area.
2.03.4.4 Boating. A minor amount of recreational boating occurs in the
waters of the upper Susitna basin. Some lakes such as Lake Louise have
a heavier amount of boating activity, and some rivers such as the Tyone
and the Susitna have a lighter amount of boating activity. Some kayakers
utilize portions of the main Susitna River, but very few have braved the
difficult waters of the Susitna through the area known as Devil Canyon.
2.03.4.5 Camping. Most camping use in this area is incidental to other
recreational activities such as hunting, fishing, boating, and highway
travel. Some developed campground facilities are located at Lake
Louise and at three campgrounds along the Denali Highway outside the
upper Susitna basin. Tourism during the summer months involving the use
of campers, trailers, and similar recreational vehicles is increasing at
a dramati~ rate in Alaska. Many of these vehicles camp along the roads
where adequate facilities do not exist and where these activities are
creating ever-increasing adverse impacts upon the land.
2.03.4.6 Other Outdoor Recreational Activities. Most other recreational
activities in the upper Susitna River basin exert varying environmental
impacts on the area. Many activities such as hiking, backpacking, and
photography take place incidentally to other recreational pursuits such
as hunting, fishing, boating, camping, and driving for pleasure. Trail
bikes, snowmobiles, four-wheel-drive vehicles, and other mechanical
equipment can cause extreme adverse environmental damage to the fragile
ecosystems of the basin when used in a careless, uncontrolled manner.
At the present time, recreation is one of the major uses of the
upper Susitna River drainage area, but the overall utilization of this
area by humans rema·ins comparatively 1 ight.
38
2.03.5 Historic"Resburces. The current National R~gister of Historic
Place~ has been consulted, and no National Register properties will be
affected by theproject. A historical-archaeological study recently
completed for the Corps of Engineers by the Alaska Division of Parks
(Heritage Resources Along the Upper Susitna River, August 1975) indicates
11 historic sites within the study portion of the upper Susitna basin.
These are all essentially related 'tothe discbvery of gold .. Most of the
early mining activity occurred on Valdez Creek, where the town of Denali
was e~tablished. Nine of the sites are located in that general area~ ·
Two sites, both designated as cabins, are located on Kosina Creek, one
near its mouth, and one about six miles upstream. The apparent dearth
of historical locations between Devil Canyon and the Maclaren River is
explained by the following excerpt from the Alaska Division of Parks'
report (in discussing the first mapping of the area in 1912): "Except·
for a ·few prospects on the Oshetna River, the USGS never received any
reports of gold being found on the Susitna between Devil' Canyon and the
Maclaren in significant quantities. Though the Tanaina and Ahtna Indians
did a great deal of hunting and fishing on the river in this area, the
white man found lit~le gold, an almost unnavigable river, and no reason
to settle anywhere near the 'Devil's Canyon'.11
· · ·
In 1920 the Alaska Railroad was completed, giving general access lo
Mount McKinley National Park. Highways followed in the 1940's and
195o•s, and the primary use of the area became recreational .. The road
approach to Mount McKinley Park was by way of the gravel Denali Highway
until the recent completion of the Parks Highway between Anchorage and
Fairbanks.
2.03.6 Archaeological Resources. Only one archaeological site has been
examined within the study area portion of the upper Susitna basin, and
it has never been excavated. This is the Ratekin Site, located near the
Denali Highway several miles east of the Susitna River. Three other
late prehistoric archaeological sites have been reported, one on upper
Valdez Creek, and two on the Tyone River. Very little information is
presently available on the aboriginal uses of the Upper Susitna River
Basin. Based upon the knowledge of the prehistory of contiguous areas,
the Alaska Division of Parks' report concludes thatthe Upper Susitna
River Basin was likely inhabited as early as 10,000 years ago, during
Late Pleistocene/Early Holocene times, with use continuing in intensity
during Late Prehistoric/Early Historic times.
One archaeological site within the general vicinity of the proposed
transmission line corridor is listed in the National Register of 4
February 1975. This is the Dry Creek site.
Extensive arch~eological remains have been found in the Tangle
Lakes area outside the Upper Susitna River Basin near the Maclaren River
drainage, and the area has been entered on the National Register of
Historic Places. The remains are apparently associated with a large
39
proglaeial lake-that existed during and after the last period of glacia-
tion, dating back some 10,000 to 12,000 years. It is reasonable to
expect further remains to be found around the lakebed margins when more
detailed investigations are made.
2.04 Energy Needs. Power requirements for the Railbelt are increasing
rapidly, and substantial amounts of new generating capacity and addi-
tional transmission system development will be needed in the near future.
The Rai"lbelt now::derives most of its power from oil and natura.l gas.
Past planning has contemplated that natural gas and, eventually, fuels
from the Alyeska Pipeline would continue as long-range energy sources
for Railbelt power systems. Howev.er, recent changes in the national and
international energy situation indicate that other alternatives such as'
the abundant coal and hydro resources of the Railbelt should be recon-
sidered.
The energy demand curve used in the hydropower study is based on
1975 projections provided by the Alaska Power Administration. The curve
represents the combined demand of the areas that could be served directly
from an interconnected Railbelt system, and is premised upon assumed
growth rates after 1980 that are substantially below existing trends.
These growth rates assume substantial savings through increased efficiency
in use of energy and through conservation programs.
Hre load projection used in the hydropower study is depicted in
Figure 9 along with the other estimates provided in APA 1 s 1975 analysis.
The "hi:gher" range anticipates significant new energy and mineral
developments from among those that appear most promising, along with an
annual growth rate in residential, commercial, and light industrial uses
that remains throughout the study period somewhat above recent electri-
cal energy consumption growth rates in the U.S. The "lower" range
presumes minimal'industrial development, a load growth rate for the
remainder of this decade well below current actual rates of increase,
and energy growth over the next twenty years that barely matches the
latest population growth rate projections for that period. This lower
estimate generally assumes a significant slackening of the pace of
development almost immediately and continuing throughout the period of
study. The "mid;range" appears to be a reasonably conservative estimate,
with annual rates of increase in power requirements less than 7 percent
after 1980 as compared to an historical annual growth rate of 14 percent
during the period 1960 to 1971. This adopted "mid-range" projection
assumes steady but moderate growth after the present boom period coupled
with more efficient energy use.
Because of lead time needed for coal and hydroelectric development,
immediate needs for the next decade will have to be handled by additional
oil and gas-fired units. However, the opportunity exists for hydro and
coal to become the main energy sources for Railbelt power by .about 1985,
if. priority is attached to these resources. ·
40
Studies by the advisory committees for the current Alaska Power
Survey provide estimates of costs for alternative power supplies from
coal, natural gas, and oil-fired plants. Indications are that power
from Susitna hydroelectric development would be comparable in cost to
present gas-fired generation in the Cook Inlet area and would be less
expensive than alternatives available to other Southcentral Railbelt
power markets.
There are many questions concerning future availability and costs
of natural gas and oil for power production. Oil prices have increased
dramatically in the past few years, and there are many pressures to
raise natural gas prices. There are also arguments that natural gas
reserves are needed for petrochemical industries and for other non-power
uses. Many people in Government and industry question the us.e of
natural gas and oil for long-range power system fuels.
On 31 December 1974 the Congress enacted Public Law 93-577. This
act established a national program for research and development in non-
nuclear energy sources. One of the sections of the law stip~lated that
heavy emphasis should be given to those technologies which utilize
renewable or essentially inexhaustible energy sources.
41
40,000
ct: 30,000
:X:
~
X
z
0
..J 20,000
..J
2
10,000
0
1970
I
r
IL<O'"CI:· .· -!. __ ,._; -~" -~ .i~_j~
·.
'
I
-k 1--:
I
I
PRCJ.JECTIQN·S ~ ~
~f;;:~./ v v I
v
J v v )/ ... 1--
I:== F= f:::-.: -
1980
FIGURE 9
42
I
' I
~
'(\. .,
"
1/ v I' v v
I ' I
1/ l
,.
l
v ,, Q~v ~~ .......
1-~ L~~
·' J.....-1---f-1-" I' . , 1--~ I-I-I-1--
1..-
I I;
1990 2000
YEAR
PROJ.EG.TEO
ENERGY/ DEM·,AND
SOUTHCENTRAL RAlLB.ELT
/~.
3.0 RELATIONSHIP OF THE PROPOSED ACTION TO LAND USE PLANS.
3.01 Pres~nt Land Status. Lands in the general project area of the
proposed Upper Susitna River Basin hydroelectric development at Devil
Canyon and Watana are under Federal jurisdiction and administered by the
U.S. Bureau of Land Management. These lands have been classified as
power sites by Power Site Classification Number 443, dated 13 February
1958. The project areas are designated in the Power Site Classification
by approximate damsite locations and contour designations as follows:
Devil Canyon: This area begins approximately 1.4 miles upstream
from the mouth of Portage Creek and includes all lands upstream from
this point below the 1500-foot contour.
· Watana: This area begins approximately 1.5 m"iles upstream from
Tsusena Creek and includes all lands upstream from Tsusena Creek and
from this point below the 1,910-foot contour.
Transmission Corridor: Most of the route segments lie in lands
that are pending or tentatively approved State selections, native
village withdrawals, and native regional deficiency withdrawals, all of
which are in a state of flux at the present. There is very 1 i ttl e
privately owned land with·in the proposed corridor. Most of the affected
lands between Point MacKenzie and Talkeetna are potential State selections.
Native v·illage withdrawals relevant to the settlements of Montana Creek,
Caswell, and Knik are indeterminate. From Talkeetna to Gold Creek, the
corridor transects State selected land and borders on Denali State Park.
Between Gold Creek and Devil Canyon, the lands are 50/50 State selections
and native regional deficiency. From Gold Creek to Cantwell, the lands
are comprised of native withdrawals and State selections. From Cantwell
to Healy, the route is State selected land bordering on Mount McKinley
National Park. Route lands between Gold Creek and Healy also fall
within the 1"1ount McKinley Cooperative Planning and Management Zone.
From Healy to Ester, the route primarily transects State selected land
with some existing Federal withdrawals and native village withdrawals.
Land status described above is subject to change as determinations are
made for ultimate disposal.
3.02, Alaska Native Claims Settlement Act. The Power Site Classifi-
cation withdrawals are in an area designated under the Alaska Native
Claims Settlement Act (Public Law 92-203) for village deficiency with-
drawals: lands which can be selected by village corporations which
cannot meet their selection entitlement from withdrawals in the areas
immediately surrounding those villages as provided in Section ll(a)(3)
of PL 92-203. Lands within the power site withdrawal may not be selected
as Native Village deficiency lands. Accordingly, the effect of PL 92-203
concerns only the lands lying above the contours designated in the Power
Site withdrawal. A proposed exchange of lands is presently being considered
43
by the Cook Inlet Native Regional Corporation, the State of Alaska, and
the Bureau of Land Management. This proposed exchange would result in
the State•s becoming owner of the lands above the contours designated in
the power site withdrawal in lieu of the Native Village corporations.
The proposed exchange, however, necessitates an amendment to PL 92-203,
and possibly to Alaska statutes, to permit such an exchange to proceed.
3.03 Utility Corridors. The U.S. Bureau of Land Management has pre-
pared a report suggesting a Primary Corridor System for the State of
Alaska. The report was prepared in accordance with the provisions of
Section 17 (b)(3) of the Alaska Native Claims Settlement Act (Public
Law 92-203).
The Primary Corridor System is defined as a network of corridors
intended for the systematic transport of high-value, energy-related
resources from their point of origin to processing or transshipment
points in other regions of the State. The network is intended to
identify transportation routes for resources of national or statewide
significance and is ana 1 ogous ~:;o the transportation network that a 1 ready
exists in conterminous stat~s consisting of navigation, highway, rail-
road, and pipeline systems.
The Susitna project is one of the hydroelectric power developments
sufficiently advanced in the planning phase to warrant corridor consider-
ation for high-voltage power transmission lines. The transmission lines
from the proposed Susitna project have been identified as a portion of
Corridor No. 29 in the suggested Primary Corridor System.
44
4.0 ;ENVIRONM[NTAL IMPACTS .Of THE PROPOSED ACTION
4.01 Hydrology and ltlater Quality. Abo[Jt 86 percent of the total annual
flow of the upper Susitna River occurs from May through September.
Average daily flows from the latter part of May through the latter part
of August fluctuate in the range of 20,000 to 32,000 cubic feet per
second (cfs). November through April the average daily flows range
between 1,000 and 2,500 cfs. The river also carries a heavy load of
glacial sediment during the high runoff periods. During the winter when
low temperatures reduce water flows the streams run relatively s;ilt-
free.
!Some of the impacts that could be caused by the project downstream
from Devil Canyon Dam are discussed below.
Stgnificant reductions of the late spring and early summer flows of
the river and substantial increases of the winter flows would occur.
The flow of the river during the period 1950 through 1974 ave~a~ed about
9,280 cfs. The projected average regulated downstream flows for .a Devil
Canyon-Watana system computed on a monthly basis would range between
about 7,560 cfs in October to almost 15,100 cfs in August. In extreme
years, the monthly averages would range from about 6,300 cfs to nearly-
28,300 cfs. The average monthly regulated flows compared to the average
unregulated flows based on the period from 1950 through 1974 are as
fol1ows:
TABLE I -FLOWS
Regulated Unregulated
Month cfs cfs
January 9,905 1 ,354
February 9,429 1 '137
March 9,026 1 ,031
Apri 1 8,278 1 '254
May 8' 158 12,627
June. 8,329 26,763
July 9,604 23,047
August 15' 091 21 '189
September 10,800 13,015
October 7,560 5,347
November 8,369 2,331
December 8,968 1,656
The heavier sediment material now carrie~l,py the river durimg high
runoff periods between Devil Canyon and the jtmction of the Chulitna and
Talkeetna Rivers with the Susitna River would be substantially reduced,
and a. year-round, somewhat mil ky...,textured .. glacial flour 11 (suspended
glacial sediment) would be introduced into the controlled water
releases below the dam. Preliminary studies by the Corps of Eng.ineers
indicate that the suspended sediment in releases at Devil Canyon Dam
would be at low levels (15-35 ppm). According to fishery investigations
during the winten of 1974-75 by the Division of Commercial Fisheries of
the Alaska Department of Fish and Game on the Susitna River between
Portage Creek and: the Chulitna River, suspended solid samples of river
water at Gold Creek, Chase and the Parks Highway bridge, indicated a
range of from4 to 228 ppm, and that these suspended solids are within
anadromus fish to1Terances. Although the average sediment load in
summer months is Tess than 1000 ppm, loads sometimes reach a maximum of
5000 ppm in the U'flregulated river. Reduction of existing summer sedi-
mentation pea.ks S!hould have a beneficial effect on anadromous and
resident fish populations for some distance downstream from Devil Canyon
Dam.
On occasions when spilling water over Devil Canyon Dam would be
necessary during late summer periods of extreme high flows, nitrogen
supersaturation could be introduced into the river below the dam. Fish
exposed to high levels of this condition can suffer gas-bubble disease
(like bends to a deep-sea diver) which can be fatal.
The combinedl high level regulating outlets and powerhouse capacities
(30,000 cfs and 24,000 cfs respectively) at the Watana Dam are adequate
to accommodate floods with recurrence intervals of up to approximately
50 years. At the, Devil Canyon Dam the hydraulic capacity of the initial
four generating units is approximately 25,000 cfs at normal maximum pool
elevatioon of 1,450 feet. The low level outlet works at Devil Canyon
are not designed to generate at pool elevation 1,450 feet, therefore,
total 6utflow without spill is limited to a maximum of 25,000 cfs. Of
the 25 years of streamflow record, spills were estimated to occur in 11
of the operation years, with the average spill lasting 14 days with an
average flow of an additional 8,500 cfs. However, any nitrogen supers-
aturation and dissolved oxygen thus introduced should be reduced sub-
stantially in the turbulent river section just downstream from Devil
Canyon dam. The proposed spillway at Watana Dam is not conducive to
high levels of nitrogen or oxygen supersaturation, and spills would
occur very seldom, only on the occasions of extreme flooding conditions
in late summer. Few fish, under existing conditions, are believed to
occupy the two and one-half mile section of Susitna River between the
proposed Devil C~nyon damsite and the mouth of Portage Creek. This
situation could change with a decrease in regulated flows during the
summer months. ·
Temperature of the water released from Devil Canyon Dam would be
adjusted to approach the natural river water temperatures. This would
be made possible ,by the proposed incorporation of selective withdrawl
outlets into the dam structure. ·
Variations in water releases at Devil Canyon Dam would cause less
than a one-foot daily fluctuation of downstream water levels in the
river during the May through October period since the reservoir would
46
~~.
·~.
not be used for peaking purposes. The regulated daily fluctuations
during the winter months could range up to one foot under normal oper-
ating conditions. According to U~S. Geological Survey studies, the
natural normal daily fluctuations in the Susitna River below Devil
Canyon range up to about one foot.
Stratification conditions within the reservoirs could cause some
temperature and dissolved oxygen problems in the river for some distance
downstream from the Devil Canyon Dam and within the reservoirs them-
selves. These conditions could have an adverse impact on the downstream
fishery. However, this problem can be minimized by mult·iple-level water
release structures which are proposed for incorporation into both dams.
This would provide the capability of selective withdrawal of water from
various levels within the reservoir to moderate release temperatures and
dissolved oxygen content. Spillway designs will also be considered to
reduce supersaturation of downstream water flows with atmospheric
gases.
There would be a period of channel stabilization in the 50-mile
section of the Susitna River below Devil Canyon Dam in which the river
would tend to adjust to the stabilized flow with low sediment levels. But
general channel degradation caused by a river 1 s attempt to replace the
missing sediment load with material picked up from the riverbed is not
expected to be a significant concern along the coarse gravel bed reaches
of the Susitna River between Talkeetna and Devil Canyon. However, this
phenomenon would be the subject of future detailed studies to determine
the distance at which sediment loads would become reestablished.
Upstream from the dams the major environmental impacts would be
caused by the reservoir impoundments. Under the proposed two-dam
system, the reservoir behind the Devil Canyon Dam would fluctuate up to
5 feet during the year, while Watana reservoir would fluctuate between
80 and 125 feet during the year under normal operating conditions. The
maximum daily fluctuation at Devil Canyon reservoir under normal operating
conditions would be less than two feet.
Devil Canyon reservoir would cover about 7,550 acres in a narrow
steep-walled canyon (1/4 to 3/4-mile-wide) with few areas of big game
habitat and a minimal amount of resident fish habitat near the mouths of
several of the tributaries that enter the Susitna River in the 28-mile
section above the proposed damsite. The reservoir would also flood
approximately 9 miles of the 11-mile, whitewater section of Devil
Canyon.
Watana reservoir, with a structural height of 810 feet and a pool
elevation of 2,200 feet, would flood about 43,000 acres in a 54-mile
section of the Sus itna River that would reach upstream about 4 miles
above the Oshetna River confluence. Except in a few areas near the
mouths of tributaries such as Deadman Creek, Watana Creek, Jay Creek,
and Kosina Creek, the Watana reservoir would be contained within a
fairly narrow canyon l/3-mile to 1 mile in width for much of its length.
47
The spillway design at Watana diverts the excess river flows into
the Tsusena Creek drainage approximately 2.5 miles above the creek•s
confluence with the Susitna River. On the occasions (approximately once
every 50 years) when it would be necessary to divert excess river flows
over the spillway during extreme flooding conditions in late summer, the
adverse environmental impact on fish and vegetation resources in lower
Tsusena Creek could be significant.
Watana reservoir would flood reaches of the Susitna River upstream
from Tsusena Creek that are sometimes used as caribou crossings. It
would also flood some moose winter range in the river bottom. The
reservoir would also cover existing resident fish habitat at the mouths
of some of the tributaries in this section of the river and possibly
would create other fish habitat at higher elevations on these tributaries.
Potential water quality impacts caused by construction of trans-
mission facilities are the increased siltation of rivers and lakes;
alteration of stream flows; eutrophication (increased nutrient levels)
and pollution of lakes and streams; and disruption bf aquatic habitat
due to gravel borrow, fill, and excavation. Eliminating or minimizing
these potential adverse impacts would be emphasized during the design,
construction, and maintenance of the proposed project.
4.02 Fish. One of the environmental impacts caused by the proposed
Devil Canyon-Watana project would be the substantial reduction of
natural river flows during the latter part of June and the early part of
July when salmon start migrating up the Susitna River. The projected
average monthly regulated flows during periods in August and September,
when the majority of the salmon are spawning, approach the average
natural flows of the river during this period.
In a 1974 study by the Alaska Department of Fish and Game on
surveys conducted to locate potential salmon rearing and spawning
sloughs on the 50-m"ile section of the Susitna River between Portage
Creek and the Chulitna River, 21 sloughs were found during the 23 July
through 11 September study period. Salmon fry were observed in at least
15 of these 21 backwater areas. Adult salmon were present in 9 of the
21 sloughs. In 5 of the sloughs the adult salmon were found in low
numbers (from l to 24 with an average between 6 and 7). In 4 other
sloughs large numbers were present (from 107 to 681 with an average of
just over 350).
During December 1974 and January and February 1975, the Alaska
Department of Fish and Game investigated 16 of the 21 sloughs previously
surveyed during the summer of 1974. Of the 16 sloughs, 5 indicated
presence of coho salmon fry. The numbers of fry captured in the 5
sloughs at various times ranged from 1 to 21 with an average of 5. Many
of the 16 sloughs surveyed were appreciably dewatered from the summer/fall
state.
48
~' '-_l
The report also stated that a number of coho fry were captured in
the Susitna River near Gold Creek indicating that some coho salmon fry
do overwinter in the main river.
The winter investigations indicated that the Susitna River between
Devil Canyon and Talkeetna was transporting suspended solid loads
ranging from 4 ppm to 228 ppm.
It may be reasonable to assume that one of the most critical
factors in salmon spawning is the dewatering of areas in which the
salmon have spawned. If winter flows are insufficient to cover the
spawning beds it would be of little consequence if high summer flows
allowed salmon to spawn in some of the sloughs that are dewatered during
the egg incubation or alevin stages. According to a Hydrologic Reconnaissance
of the Susitna River Below Devil 's Canyon, October 1974 by the National
Marine Fisheries Service when comparing regulated flows to natural flows
(see Table 1 on page 45), "It is reasonable to conclude that during the
months of October through March spring flows may be enhanced in the
river valley bottom, during the months of May through mid-September
these springflows may be depressed.''
It is reasonable to assume on the basis of existing data that there
will be some changes in the relationship between the regulated river and
access to existing salmon rearing and spawning sloughs and tributaries
downstream from Devil Canyon Dam. It appears feasible to develop a
program to improve fish access to and from some of the sloughs and
tributaries in the Susitna River as a consequence of the project's
stabilizing effect on summer flows. Such a program would be a project
consideration.
Flooding, which occurs frequently under natural conditions and
presently destroys salmon eggs in this stretch of the river would be
almost completely eliminated by regulation of the upper Susitna River
flows.
Reduction in flows and turbidity below Devil Canyon Dam might cause
some disori~ntation of salmon migrating into the section of the Susitna
River between Portage Creek and the Chulitna River during an initial
period after construction of the dams and until future salmon stocks
readjusted to the change in regulated river conditions.
During the period of construction, river flows will be diverted
through tunnels in the canyon walls and past the construction areas at
the damsites with minimal changes in existing water quality.
During the periods in which the newly-constructed reservoirs would
be filling with water, downstream flow maintenance would be coordinated
with the fish and wildlife agencies to prevent unnecessary damage to
downstream fishery resources. It is proposed to initiate construction
of Watana Dam in about 1981. and Devil Canyon approximately five years
later.
49
According to a study discussed in the Journal of Fisheries Research
Board of Canada--Volume 32, No. l, January 1975, Ecological Consequences
of the Proposed Moran Dam on the Fraser River, some of the beneficial
downstream impacts of the dam could include the following:
The higher regulated winter flows might increase the survival of
salmon eggs in the sloughs and backwater areas of the river downstream
from the dam. The increased flows could insure better coverage and
better percolation through the gravel and presumably increase egg and
alev.in survival. Salmon alevin are young fish with attached egg-sacs
that remain in the gravel beds until they emerge as fry.
An additional consequence of reduced turbidity below the dam might
be a gradual reduction in the percentage of fine materials in the salmon
spawning areas near the mouths of sloughs and tributaries as they enter
the Susitna River. This could also lead to improved percolation t~rough
the gravel in the streambed and possibly improve survival of eggs.
Reduced siltation during the summer months should prove beneficial
for both anadromous and resident fish species for some distance down-
stream from the proposed Devil Canyon Dam. It is also reasonable to
expect that some additional salmon spawning and rearing habitat would
develop within some sections of the Susitna River between Devil Canyon
and Talkeetna.
According to the Moran Dam study, reduced turbidity during the
summer months or during the periods of seaward migration could lead to
an increase in visibility within the river and therefore an increase in
predation of salmon fry. A slight increase in turbidity during the
winter months might also increase the survival of young salmon due to a
decrease in visibility during that period. Another impact on juvenile
salmon could be the extention of the seaward migration period due to
less turbid water in the 50-mile portion of the Susitna River below
Devil Canyon.
Other hydrologic factors previously discussed would also affect the
fishery resource downstream from the dams. These and other changes
could also influence the food and life cycles for fish in this section
of the river. Biological and physical changes likely to occur are the
subjects of ongoing studies by State and Federal agencies under the
direction of the U.S. Fish and Wildlife Service. Results of these
studies will be used in determining needs for more detailed final design
phase studies, feasible project modification, and mitigative or ameliorative
measures.
50
Upstream from the dams, the major impact on the resident fish
populations would be caused by the reservoir impoundments. Under the
proposed plan, Devil Canyon reservoir would fluctuate very little. Even
though the steep-walled canyon of this reservoir might prove less than
desirable for a ptpgram to develop a resident fish population, some
species of fish may be able to adapt to this reservoir and provid~
future sport fishing benefits. ·
Watana Dam would have a widely fluctuating reservoir which would
generally prove detrimental to the development of resident fish popu-
lations. Suspended glacial sediment could be a factor in both of the
reservoirs after the heavier glacial sediments have settled out; how-
ever, some natural lakes in Alaska such as Tustumena and Skilak, with
heavy inflows of glacial debris sustain fish populations under similar
conditions, so to develop populations of fish under related conditions
may be feasible.
Most resident fish populations, especially grayling, utilize some
of the clearwater tributaries of the Susitna River or areas near the
mouths of these streams as they enter the glacially turbid main river
channel during periods of high runoff. Many of these tributaries would
be flooded in their lower reaches by the proposed reservoir impound-
ments. The resident fish populations would be affected by the increased
water levels in the proposed reservoirs; but in some areas, access to
tributaries for resident fish may be improved by increased water elevations.
It appears highly unlikely that anadromous fish such as salmon
could be successfully introduced into the Upper Susitna River Basin.
With the succession of very high dams and the related problems and costs
of passing migrating fish over and through these dams, such a program
appears infeasible (Report, Ecolo ical Conse uences of the Pro osed
Moran Dam on the Fraser River . This report states in reference to high
dams: 11 The choice is clearly between upstream salmon stocks or dams.11
However, the introduction of a resident salmon species, such as sockeye
(kokanee) or others to some waters of the upper Susitna basin might
prove feasible with further studies.
Other problems re.lated to the introduction of anadromous fish into
the Upper Susitna River Basin would include the following: Fish would
experience high mortality rates if they attempted to move downstream
through turbines or outlet works in the proposed series of high-head
dams. According to Corps of Engineers studies, a 35 percent mortality
rate could be expected on fish such as young salmon at each high dam.
Perhaps even more significant than turbine loss is the experience
background that juvenile salmonids will generally not migrate out of
1 arge storage type reservoirs. Reverse currents, temperature strati-
fication, etc., apparently disorients the migrants and causes them to
lose their migrational motivation. As a result many never even reach
the dam and they spend their lives as residuals in the reservoir.
(Example: Brownlee Reservoir, Snake River, Idaho and Oregon)
. 51 .
Impact upon aquatic life from the transmission line should be small
because of the care that would be taken to prevent degradation of
streams within the corridor. However, the aquatic food chain in the
taiga {boreal forest) and tundra is extremely simple, and as a result,
disruption of habitat for one species quite often indirectly affects
many other species. Potential impacts are: increased siltation of
rivers and lakes; alteration of flows; eutrophication and pollution of
lakes and streams; and disruption of habitat due to gravel borrow, fill,
and excavation~ All construction and maintenance activities would be
controlled to prevent or minimize adverse environmental impacts.
4.03 Wildlife. Reservoir impoundments, transmission line corridors,
and access roads would have varying degrees of environmental impact on
wi 1 dl He.
The Devil Canyon reservoir would be located within the confines of
a narrow, steep-walled canyon with few areas of big-game habitat and on
no major migration routes for big-game animals. In some cases, animals
such as moose and caribou may find it easier to cross the narrow reser-
voir than they would the present fast-moving river at the bottom of a
deep, steep-sided canyon.
The proposed Watana Dam would be generally contained within a
fairly deep and narrow river canyon. Watana reservoir would lie across
one of the intermittent seasonal caribou migration routes between the
main calving area of the Nelchina caribou herd, located south of the
river in the northeast foothills of the Talkeetna Mountains, and some
caribou summer range on the north side of the Susitna River. Calving
generally takes place during a month-long period starting in the middle
of May and most of the caribou move out of the calving area in June and
July.
Ice-shelving conditions caused by winter drawdown on Watana reser-
voir or spring ice breakup conditions on the reservoir could cause
problems for caribou, moose, or other animals if they attempt to cross
this reservoir when these adverse conditions exist. Warmer weather and
a rapidly filling reservoir should eliminate any adverse ice conditions
at Watana during the month of May. As caribou are strong swimmers, they
should have fewer problems crossing the narrow 2/3 to 1 mile wide section
of the reservoir in the historic crossing areas in the vicinity of
Kosina and Jay Creeks during July after calving than they would crossing
the swollen glacial river during periods of high runoff. Some caribou
could also migrate around the upper reaches of the proposed Watana
reservoir area as indicated in existing spring migration patterns.
Caribou migration patterns for the Nelchina herd are continually changing,
as stated in Alaska Department of Fish and Game study reports. Their
studies also indicated the use of the Watana reservoir site by Nelchina
caribou for grazing and crossing was ~inimal during the period November
1974 through April 1975. Under adverse ice conditions, the reservoirs
could result in increased problems for some segments of the herd. Also,
there could be some permanent changes in historical herd movement patterns .
. 52 '
Within the transmission line corridor system, impacts to caribou
would be limited to the 136-mile segment extending north from Cantwell.
There is no significant caribou use of areas to the south. Although the
transmission line and related access roads would not impose a physical
barrier to migration of caribou, construction and maintenance work
during certain seasons may inhibit herd movement. Since caribou are
primarily confined to the west bank of the Nenana River, they will not
be significantly affected in this area if the line runs along the east
bank. Although physical destruction of caribou habitat will not be a
significant impact of power line construction, there are indirect
consequences which could be significant. Increase of fires resulting
from manmade causes could destroy tundra lichen which is their prime
source of winter food. It is estimated that approximately 50 years are
required for a burned area to recover a usable cover of lichen for
caribou. Noise generated by the transmission lines could also modify
normal behavior, as could public accessibility provided by transmission
line roads.
A moose survey conducted in early June 1974 by the Alaska Depart-
ment of Fish and Game indicated that, although spring counting conditions
were less than ideal, a total of 356 moose were seen along the upper
Susitna River and in the lower drainage areas of the major tributaries.
A 1973 fall count in the same general area sighted a total of 1}96
moose.
Of the 356 moose counted in the June 1974 survey, 13 were seen in
or near the area of the proposed Watana reservoir below Vee Canyon.
None were sighted within the proposed Devil Canyon reservoir impoundment.
Althou~h limited moose habitat appears to exist within the pool areas of
the proposed Devil Canyon and Watana reservoirs, it is considered
critical to those moose now utilizing the area. Special studies will be
required to determine impacts upon moose habitat and populations.
During the June 1974 Fish and Game survey period, one grizzly was
sighted on the upper Oshetna and one on the Maclaren River. Five black
bears were sighted on the Susitna River. A total of 56 caribou were
sighted in the survey area.
Moose are found throughout the length of the transmission line
corridor. The greatest adverse impact to these animals would be the
increased hunting access provided by roads and the openness of the
corridor itself. Habitat, on the other hand, would overall be improved.
Subclimax growth within the transmission line corridor would increase
moose browse.
The proposed reservoirs at Devil Canyon and Watana are located
along a major flyway for waterfowl. Very few waterfowl appear to nest
on the sections of the river that would be flooded by these reservoir
proposals. On the other hand, the reservoirs would provide suitable
resting areas for waterfowl migrating through the basin.
53
------
)
Migrating birds would possibly suffer some mortality from collisions
with towers or lines, but such losses should be negligible. The line
would generally parallel normal north-south migration routes. The
cables would be large enough to have a high degree of visibility and
would be widely enough spaced to be ineffective snares. Electrocution
of birds is also unlikely since the distance between lines and between
lines and ground would be great enough to make shorting out by birds
almost impossible.
A transmission line per se will not have many impacts upon wild-
life; most of the impacts will be as a result of construction ~nd
maintenance. Direct destruction will affect the less mobile animals
such as the small mammals, whose territories may be small enough to be
encompassed by the construction area. The significance of this impact
to these animals is small in relation to their population in surrounding
areas.
The loss of habitat for bears, wolves, wolverines, Dall sheep, and
other animals also appears to be minimal. However, losses to any
significant element of the food web will affect consumers. Thus,
losses to moose or caribou would impact upon predator species. Other
birds, including raptors, songbirds, shorebirds, and game birds, do not
appear to be significantly affected by the reduction of habitat in the
area of the proposed dams and reservoirs and on the transmission line
corridor, although some habitat will be lost for all species of wildlife
that utilize the affected areas.
Road access to the two damsites and to the transmission line would
have a significant impact on fish and wildlife resources in areas
opened to vehicle encroachment. Specific areas such as Stephan Lake, Fog
Lakes, lower Deadman Creek, and the northern slopes of the Talkeetna
Mountains could be significantly impacted by hunters, fishermen, and
other recreationists by an access road to the Watana Dam. The same
would be true along various segments of the transmission line. State
game management policies could control some of the adverse impacts on
fish and wildlife in these areas. However, this increase in public
accessibility would significantly increase the necessity for intensified
law enforcement and fire prevention measures.
4.04 Recreation. Much of the Upper Susitna River Basin has little or,
in many areas, no recreational activity at the present time. A combi-
nation of poor road access, rough terrain, and great distances presently
limit the use of the 5,800-square-mile basin, especially the lands
directly impacted by the proposed project, to a few hunters, fishermen,
and other hardy souls who util~ze these wild lands for recreational
purposes.
The construction of the proposed hydroelectric project would have
an impact on a number of present and projected recreational activities
both in the immediate dam and reservoir areas and downstream from the
dams.
54
At the present time, the Susitna River upstream from Portage Creek
to the Denali Highway bridge is a free-flowing river with few signs of
man•s activities and minimal public use. The project would significantly
change both the present riverine setting and human use of the area.
Improved road access into the upper Susitna basin would substantially
increase pressures on all the resources impacted by outdoor recreation
activities within these areas. Along with a potential increase in
hunting pressure, the construction of project-oriented recreational
facilities would further increase public use in the immediate vicinity
of the proposed dams and reservoirs. These recreational developments
would eventually include visitor centers at the dams, boat launching
ramps on the reservoirs, campgrounds, picnic areas, trail systems, and
other related developments, as shown in Figure 10. It is estimated that
with the recommended development plan, the initial annual visitation to
the project area would be about 77,000 people.
The possible relocation of the state capital to the Lowet Susitna
River Basin could have a substantial impact on the extent of development
of recreational facilities within the Devil Canyon-Watana project area.
At the present time, few people reside within a 100-mile radius of the
project area, and day-use of the project by local residents would be
minimal under existing growth conditions.
Any project-related recreational development program would involve
cooperation between the appropriate Federal, State, and local interests
and would require State or local sponsorship, sharing of costs for
construction, and maintenance of the developed recreational facilities
by the appropriate State or local sponsor. The State of Alaska (Divi-
sion of Parks) has indicated an interest in sponsoring a program of
recreational development in the area of the proposed project.
4.05 Historical Resources. Although a preliminary investigation by the
Alaska Division of Parks (Heritage Resources along the Upper Susitha
River, August 1975) indicates the location of 11 historic sites within
the upper Susitna basin hydropower study area, only one of these would
be directly affected by the currently proposed two-dam development. This
site is located near the mouth of Kosina Creek and would be inundated by
the Watana reservoir. The significance of this site, a cabin, is not
disclosed in the State report. However, on the basis of the limited
early modern history associated with the upper Susitna basin, part-
ticularly the downstream portion above Devil Canyon, it is most likely
that the site is related to early exploratory mining in the area. The
Knik hjstorical site, although located in the vicinity of the trans-
mission line would not be affected by the transmission corridor.
55
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RAILBELT AREA. ALA3KA
UPPER SUSITNA RIVER BASIN
RECREATION PLAN
J---
Looking upstream at Susitna River near Denali. Tundra ecosystems with
scattered areas of black spruce.
4.06 Archaeological Resources. Of the four presently known archaeo-
logical sites in the upper Susitna basin, all lie upstream from the
influence of the Watana Dam and reservoir, according to the Alaska
Division of Parks report of August 1975. On the basis of probable
highest game diversity in early times, the report selects areas most
likely to have been inhabited by people, and thus identifies sites for
potential archaeolpgical exploration. These sites are m6st generally
designated as being near the confluence of streams where habitat diversity
was 1 ikely highest. The report co·ncl udes that 11 --the entire river
system should be regarded as an area of extremely high archaeological
potential.11 The report further states: 11 While it is difficult to
measure the amount of adverse impact each of the four dam complexes will
have on heritage resources~ it is possible to ascertain that the Devil
Canyon Dam will have the least effect. The Watana Dam will have the
second lowest adverse impact, followed by Denali Dam. The construction
of the Vee Dam site will have the most adverse impact on significant
heritage resources.•• (The Vee and Denali Dams are not in the proposed
plan of development.)
More intensive reconnaissance of the affected areas will be neces-
sary following project authorization to determine the actual existence
and locations of sites ..
The Dry Creek archaeological site is located in the vicinity of the
proposed transmission line corridor. The site will not be affected by
development within the proposed route.
4.07 Vegetation. All of the vegetation within the pools of the pro-
posed reservoirs and in the proposed road locations would be eliminated
if the dams were ~onstructed. Trees would also be cleared in areas
within transmission line corridors. Most of the trees and shrubs would
be cleared during construction operations, and some of the comm~rcial
timber would probably be marketed. Most of the residue slash material
and debris would be burned or buried. ·
Much of the existing tree and shrub cover in the Upper Susitna
River Basin is located in the river and creek bottoms and on the steep
canyon slopes above the streams and would be lost during dam construc-
tion. The operations to clear the vegetation within the reservoir
impoundments and other areas would require a network of temporary roads
and work areas for personnel, equipment, and vehicles within and around
the areas to be cleared. Controls over the clearing and related opera-
+ions would include provisions to reduce or prevent many of the adverse
enVironmental impacts of these activities including the possibility of
uncontrolled fires.
The major ecosystems of the upper Susitna basin include the upland
and lowland spruce-hardwood forest systems and the moist and alpit1e
tundra systems. All these ecosystems are susceptible to long-term
58
damage or destruction; the predominant tundra systems are especially
vulnerable. Particular care would have to be taken to protect the land
and the vegetation from unnecessary damage, and remedial actions would
also need to be taken to make feasible repairs to whatever damage should
occur. Except for the river itself the area within the proposed reser-
voir pool is dominated by the upland spruce-hardwood forest ecosystem.
Most of the direct impacts of the transmission line and required
access roads upon vegetation would be relatively small with respect to
the magnitude of surrounding unaffected land. Up to 6,100 of the
approximately 8,200 acres of right-of-way would have to be cleared.
The effect on scenic quality would be a major impact of the cleared
right-of-way. Regrowth beyond a limited height would be prevented by
maintenance, thus cuts through forested areas would be permanently
visible. This effect would not be as significant in more open areas at
higher elevations, such as Broad Pass, where no tree clearing is required.
On the other hand, in such areas the transmission line itself would be
more visible. This effect is more fully discussed under the heading of
Esthetics.
The disposal of slash and debris, whether by burning, burying,
chipping, or stacking has potentially adverse effects upon remaining
vegetation and other resources. Although stacked or dispersed slash may
provide habitat for small animals, there is a high potential that slash
may result in increased fire hazard and increases in insect populations
which could damage surrounding forests. Chipping is very expensive and
requires more machinery to travel along the right-of-way. Disposal of
chips is a problem because they should be dispersed to prevent killing
the plants on the ground. Since decomposition rates are slow, chips may
not revert to humus for quite some time. Vegetation along most of the
transmission line corridor is conducive to a high rate of fire spread
· and is considered to be of medium to high resistance to fire control.
However, with proper precautionary measures, burning would probably be
the most desirable method of slash and debris disposal from an environ-
mental viewpoint.
Significant impacts to wildlife would result from habitat modifi-
cation resulting from impacts upon vegetation. Transmission corridor
clearing in forest areas and maintenance of a subclimax plant community
of brush and low plants would improve habitat for some species by
increasing primary productivity in the cleared areas. Browse for moose
will be increased; the conjunction of good cover in the original forest
with a swath of browse creates a diverse 11 edge 11 habitat for many animals
dependent on subclimax growth. Animals dependent on climax or near-
climax vegetation will suffer loss of habitat; examples are the red
squirrel and northern flying squirrel, both of which depend upon white
spruce.
59
4.08 Mining. The U.S. Department of Interior, Bureau of Mines office
in Juneau, Alaska, has stated that the Susitna River basin in the pro-
posed reservoir impoundment areas is generally favorable for various
types of mineral deposits, but the area has never been mapped geologically.
4.09 Agriculture. No project benefits are anticipated for irrigation
at this time, and except for providing reasonably priced electrical
power to farms and agricultural activities, no other major impacts on
agriculture are expected.
Presently most agricultural activity in the State, from crop
farming to dairy farming, occurs in the Cook Inlet subregion. Of the
2.5 million acres of land that have soil characteristics conducive to
the production of cultivated crops in the Cook Inlet-Susitna Lowlands,
about 70 percent occurs in the valleys of the Matanuska and the Susitna
Rivers and their tributaries. Most of this land is as yet undeveloped.
4.10 Roads. Permanent roads would be built to provide access from the
Parks Highway to the Devil Canyon and Watana damsites and some segments
of the transmission line. Permanent roads would also provide access to
proposed recreation facilities within the project area. Temporary roads
for project construction and reservoir clearing operations would also be
constructed. No roads would be built within the transmission line
corridor in the 39-mile reach between Cantwell and Healy, and the 10-
mile reach between Gold Creek and Chulitna. No permanent roads would be
constructed upstream from the vicinity of Watana dam.
The impact of road access to areas within the proposed hydroelectric
developments would be significant; also, the roads themselves would have
a definite impact upon the land. Resource values impacted by proposed
roads include fish, wildlife, vegetation, recreation, scenery, water~
and soils. Air and noise pollution related to road construction and
dust generated by vehicle travel on unpaved roads could also be signifi-
cant adverse environmental impacts.
In sections where permanent transmission line access roads are
required, the road would be built and maintained to a standard suitable
for four-wheel-drive vehicles. Not all sections will have access
roads; in critical areas, winter construction or helicopter construction
wi 11 be used.
It is also expected that helipads and possibly an aircraft landing
strip would be provided within the project area for air evacuation of
injured workers and for the convenience of reduced travel time; any
temporary aircraft landing facilities would be rehabilitated after
project construction.
Proposed right-of-way restoration after construction includes
removal of temporary structures and temporary roads, disposal of slash
and refuse, and where necessary, revegetation.
60
.. ~ ...
Design, location, construction, rehabilitation, and maintenance of
a project road system will be given prime consideration with the utili-
zation of good landscape management practices.
4.11 Construction Activities. Proposed project-related construction
activities include the building of the dams and their related facilities;
the clearing of reservoir areas; the construction of roads, electrical
distribution systems, and recreation facilities; and the building of
facilities for workers. The construction of the Susitna project is
estimated to take 10 years to complete, with an estimated 6 years of
construction for the Watana dam and 5 years for Devil Canyon with a one-
year overlap.
The impact of these construction activities on the existing environ-
ment would be significant. The activities themselves would cause
varying degrees of physical pollution to the air, land, and water within
the project area and to some areas outside the development area. Fish,
wildlife, vegetation, visual resources, soils, and other resource values
would be adversely impacted by construction activities within the
project area .. General construction activities would intrude on existing
fish and wildlife habitat, cause soil erosion problems with related
reduction of water quality, clear areas of vegetation, cause noise and
dust problems, intrude on natural visual resource values, introduce air
pollutants into the atmosphere by burning slash and debris, and cause
other related environmental impacts. For instance, breaking the surface
mat of vegetation and disruption of surface drainage can result in wind
and water erosion, and melting of permafrost, resulting in subsidence
and disruption of groundwater tables, which in turn results in erosion.
Most of the damage to soils along the transmission line would occur
during the construction phase. The construction schedule would be
arranged so that work requiring use of an access road, such as delivery
of materials, could be done in winter and spring, when the ground is
least vulnerable to physical disturbances. This would eliminate the
need for extensive filling and consequent use of borrow pits or quarries.
To obtain materials from borrow sources and quarry sites for the
construction of the dams, roads and other facilities would be necessary.
Borrow areas would be located within the proposed reservoir pool areas
where feasible. Any borrow or quarry sites necessary outside of the
pool area would be rehabilitated. Areas will also be needed to dispose
of some materials and debris. All construction activities would be
controlled to minimize or to prevent adverse environmental im~acts.
4.12 Workers' Facilities. No communities within commuting distance to
the proposed project area could absor~ the number of workers required
for the construction of the dams and related facilities. Some type of
temporary construction camps with the necessary facilities would need to
be provided during the construction periods, and permanent facilities
would need to be built for maintenance and operational personnel after
completion of the construction phase.
61
··,--.---------·-··--·----------------·
The construction and operations of the workers• camps would comply
with State and Federal pollution control laws and standards, and all
activities would be controlled to minimize adverse environmental impacts
presented by the camps. Lands used for operating the temporary camp
areas would be rehabilitated when the project work was completed.
4.13 Esthetics. The proposed project would be located in areas that
presently have practically no permanent signs of man's presence. The
land between Portage Creek. and the Denali Highway is a natural and
scenic area which would probably qualify for wilderness classification
under most definitions of the term.
The construction of the proposed hydroelectric project would have a
significant impact on the existing natural scenic resource values
within the project area. Any dam construction on the upper Susitna
would change a segment of what is now a natural, free-flowing river into
a manmade impoundment. Within a 12-month period, Devil Canyon reservoir
could fluctuate up to 5 feet while Watana reservoir would fluctuate up
to 125 feet under normal oper1ting conditions. The proposed Watana
impoundment is located in a narrow, steep, isolated canyon where the
seasonal fluctuation would not have a substantial scenic impact. The
vioient, whitewater section of the Susitna River through Devil Canyon
would be substantially inundated by a dam at Devil Canyon. Roads and
transmission lines would also impact the natural scenic resource values
of the area.
Since it is expected that a considerable number of tourists and
State residents would visit the damsites, every effort would be given to
minimizing the adverse visual impacts of construction activities. A
great deal can be accomplished to maximize scenic resource values that
wi 11 remain after construction. Good 1 andscape management practices
would add substantially to the recreational experience of the project
visitor with facilities that are well planned and well maintained.
The proposed transmission line corridor would cross no existing or
presently proposed scenic, wild, or recreational rivers, nor would it
cross any existing or presently proposed wilderness areas or wildlife
refuges. In most segments, the transmission line would parallel exist-
ing ~orridors or traverse no significantly large areas of intact wil-
derness. However, in some segments where the transmission line would
pioneer a corridor through a previously intact area. the quality of
wilderness would suffer, especially where the transmission line is
easily visible. Location and design of the transmission facilities will
include maximum considerations to minimize the adverse esthetic impacts
within the transmission corridor.
62
The transmission line would have minimum impact on scenic quality
from Point MacKenzie to Talkeetna since it could be concealed or in some
areas be laid parallel and adjacent to existing line clearings. The
line would have a moderate impact on scenic quality between Talkeetna
and Gold Creek. The line could be hidden well from rail lines unless
the corridors were consolidated. From Gold Creek to Devil Canyon, the
line could either be largely concealed from the road or could be used as
the road access route itself. Between Gold Creek and Cantwell, a visible
line would have substantial impact, particularly if located west of the
highway and railroad. The line through this area could be somewhat
concealed, with the exception of Broad Pass which has the least veg-
etative cover. From Cantwell to Healy, the line would have a severe
impact on scenic quality; not only is the canyon an area of high scenic
quality, concealment of the line is difficult and the west bank of the
Nenana is Park land. The impact would be moderate near Healy and in the
Goldstream Hills and low along the lower Nenana River. Impact would be
less if Golden Valley Electric Association right-of-way were joined. It
would be more difficult to reduce the visual impact of the transmission
line corridor from the air traveler, but the design of the transmission
facilities would consider this important factor.
The installation of significant l~ngths of high voltage underground
electrical transmission cable is limited by present technology. From
the standpoint of esthetics, underground transmission cables would
definitely be preferred to an overhead transmission system. Should
technology of underground electrical power transmission become sufficiently
advanced prior to transmission line construction, it may be feasible to
ut·ilize underground cable in short reaches of the transmission system
where the visual obtrusiveness of an overhead system is particularly
objectionable.
In seismically active areas the reliability of underground cables
must be questioned where slicing of the cable can result from settling
or slumping of the soil; oil-filled or compress-gas filled cable may
rupture during soil movement; and it is more difficult to locate and
correct damaged underground cable. Overhead transmission lines also
have more inherent resiliency than underground cables.
4.14 Earthquakes. Several major and minor fault systems either border
or cross the Upper Susitna River Basin, and the southcentral area of
Alaska is in one of the world 1 s most active seismic zones. One of the
strongest earthquakes in recorded history struck southcentral Alaska in
March of 1964; the magnitude of the quake was 8.4 on the Richter Scale.
The quake was centered just north of the Prince William Sound area,
approximately 120 miles from the proposed damsites ,(see Figure 2).
Devil Canyon and Watana Dams will be designed to withstand a
Maximum Credible Earthquake of 8.5 magnitude with an epicenter of
40 miles at a focal depth of 20 miles, which is the approximate distance
. 63 .
of both damsites to the Denali Fault system, and is the most likely
source of a seismic event of this magnitude. The Susitna Fault, trun-
cated by the Denali Fault, bisects the region in a northeast to south-
west direction approximately 2.5 miles west of the Watini damsite. Due
to the relatively short length of the Susitna fault, a maximum credible
earthqupke of 6.0 is considered reasonable. An earthquake of this
magnitude along this fault will be considered in the design of Watana
and Devil Canyon dams.
4.15 Sedimentation. Reservoir sediment inflow would vary at each
reservoir. Under the proposed system, Devil Canyon reservoir would
lose approximately 6.5 percent of its total storage area to sedimenta-
tion during a 100-year period. Watana reservoir would have a 100-year
sediment inflow that would equal about 4.2 percent of the reservoir's
storage capacity.
Both proposed reservoirs have a dead storage area that is not
utilized for power production; therefore, much of the initial 100-year
sedimentation for the reservoirs would be contained within this "dead
storage space,11 which would not have any significant effect on reservoir
operations. Much of the heavier sediment deposited in Watana reservoir
would collect at the head of the 54-mile-long reservoir. Even though
the project-life is computed on a 100-year period for economic reasons,
with adequate maintenance, the useful life of the proposed project due
to sedimentation is estimated to be in excess of 500 years. If at some
future time a feasible program of sediment removal were developed, the
useful life period could be extended.
4.16 Climatic Conditions. The severe climatic conditions in the Upper
Susitna River Basin could have a substantial environmental impact on the
design, construction, and operation of the proposed hydroelectric
development. Permafrost conditions, extreme cold winter temperatures,
a long period of cold weather, and ice conditions on the reservoir and
river are some of the significant climatic conditions that would have to
be considered.
The Upper Susitna River Basin is underlain by discontinuous perma-
frost, so some project areas will have to contend with permafrost and
other areas will not.
Extremely cold winter temperatures and long periods of cold weather
will place substantial restrictions on many project construction activi-
ties and increase the time needed to complete the construction of the
project to a total of 10 years.
Icing conditions on the reservoirs and the river may cause a wide
range of adverse impacts both on project'construction activities and on
project operations. An ice-free stretch of warmer, open water below
. 64 .
. ,_ ____________________________________ .,,
Devil Canyon Dam could cause ice~fog conditions in that area during
periods of extremely cold weather .. Regulations of winter flows are not
expected to have any significant effects on river ice conditions neces-
sary forthe continued use of the stream for winter travel downstream
from Talkeetna.
The effects of possible high winds and icing conditions on the
transmission lines will be evaluated and design features will be incor-
porated into the construction of these facilities to reduce or eliminate
the adverse impacts posed by these conditions.
4.17 Air Pollution. Most of the existing electrical power in the
Southcentral Railbelt area is produced by gas, coal, and oil-fired
generating units which cause varying degrees of air pollution.
Cook Inlet gas is a clean fuel that causes few serious air pollu-
tion problems at the present time. The existing gas turbines have very
low efficiencies and emit visible water vapor during the colder winter
months. Also, nitrogen emissions could be of significant concern for
any proposed 1 a rger gas-fired p 1 ants. ·
Hydroelectric energy could replace the burning of fossil fuels for
electric power generation in much of the Fairbanks area and could help
to alleviate the severe winter ice fog and smoke problems in that area.
Hydroelectric projects provide a very clean source· of power with
practically no direct air pollution-related problems. This type of
electrical power generation could reduce a substantial number of future
air pollution problems associated with the burning of gas, oil, and
coal. It would be necessary to burn some of the residue slash material
and debris during project construction and clearing operations, and
fires would be controlled as necessary.
4.18 Social.
4.18.1 Population. Substantial increases in population are expected
within the Southcentral Railbelt area through the year 2000 and, with
the possible relocation of Alaska•s State capital from ~uneau to the
Railbelt, an additional population impact can be expected in this area.
The population of the area will increase with or w'ithout the
development of hydroelectric projects proposed for the Susitna River;
construction of the project is not expected to have ani significant long
range effect on overall population growth, but is rather designed to
fulfill presently projected needs of a growing populatibn as one alter-
native means of producing power which will have to be provided in one
way or another. Thus the total amount of power generated by the pro-
posed Susitna hydroelectric project would generally be an alternative
source, which would have as one of its major considerations a renewable
65
energy source, rather than being an additional power source. Projected
power requirements based on mid-range estimates show that the proposed
Susitna hydroelectric development program could supply a substantial
portion of the Railbelt•s projected electric power needs starting in
about 1985. The proposed upper Susitna River hydro projects will not
create large blocks of excess electric power for heavy energy-consuming
industries. If larger amounts of electric energy are needed for a
program of heavy industrial development, additional energy-producing
sources will have to be constructed. In summary, the project is designed
to serve projected population needs--not to stimulate population growth
as a consequence of industries which would be attracted by large blocks
of excess electrical energy.
A 10-year Devil Canyon-Watana hydroelectric development program
would have an economic impact on the Southcentral Railbelt area that
would be felt to a greater degree during the construction phase of
project development.
It is expected that this proposed project would have some stabilizing
influence on the overa11 economy of the Railbelt area during the period
of construction starting in about 1980, since construction would be
initiated several years after the Alaskan oil pipeline has been built
and about the time the proposed gas pipeline is scheduled for completion.
The number of men required to construct this project is estimated to
be about 1,100 men during the peak summer construction period.
Various community, borough, state, and private faci 1 i ties and
agencies would be impacted to varying degrees by the workers involved in
the construction of the proposed project. Workers• camps would be
constructed in the vicinity of some of the various construction acti-
vities, but additional impacts would be created by the families of the
construction workers living in various nearby communities who would
require additional facilities and services. It is also expected that
due to adverse climatic conditions, much of the construction on the
project facilities would be restricted to the warmer months of the
year--probably April through Octobef. The seasonal nature of the
construction work would have an adverse impact on the local economy
during the winter months.
After the construction of the project, a small number of people
would be required to operate and maintain the project and project-
related facilities--these people would not create a significant social
or economic impact on the railbelt area. ·
66
5.0 ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED
Approximately 50,550 acres of land would be flooded by the reser-
voirs (7,550 acres at Devil Canyon, 43,000 acres at Watana) at normal
pool elevation. This encompasses an almost continuous 84-mile reach of
the upper Susitna River. Approximately 2 miles of natural river would
remain unflooded between the two reservoirs. All woodlands and other
vegetation within the reservoir pools would be permanently lost. Trans~
mission line clearing would be required essentially the full lengthof
the 136~mile-long Susitna corridor for a total of about 3,700 acres~
Only about half of the 198-mile-long Nenana corridor would require
clearing, or approximately 2,400 acres.
Water released from the reservoirs would be slightly turbid through-
out the year, whereas under existing conditions the stream normally runs
clear from late fall until early spring breakup. Studies to date
indicate that the sediment in suspension would not be high in the
releases at Devil Canyon dam, ranging probably from 15-35 ppm .. On the
other hand, heavy sediment loads now carried by the stream during the
warmer months of spring through early fall would be significantly
reduced.
Downstream water quality problems related to temperature, dissolved
oxygen, and nitrogen supersaturation could occur. These would be held
to minimal, and possibly insignificant l~vels by spillway design and the
incorporation of multiple-level water withdrawal structures.
Approximately 9 miles of the existing 11-mile whitewater reach
through Devil Canyon would be lost through inundation.
The lower 2.5 miles of Tsusena Creek, which would be utilized as a
spillway for excess river flows (this would occur only on the occasions
of a period of excessive late summer flooding), will suffer adverse
impacts to fish and on-shore vegetation during such periods.
Some moose habitat within the canyon floor and adjacent slopes.
would be inundated by the reservoirs. Most of the present use is
upstream from Tsusena Creek, thus the greatest impact to moose would
result from the Watana reservoir. The amount of good habitat is limited,·
but its loss would be permanent.
The Watana reservoir would lie between the spring calving grounds
and portions of the summer range of the wide-ranging Nelchina caribou
herd. Mortality to caribou and other animals attempting to cross the
reservoirs could result from ice-shelving conditions ~hich might occur
into the month of May, on Watana reservoir, and other difficulties which
might be .encountered in swimming both reservoirs. The reservoirs could
conceivably alter historical herd movement and distribution, although
the animals do not exhibit any readily definable patterns, other than in
the broadest of terms, at the present time.
67
---·-·----·----·
During the average winter, Watana Reservoir would have a drawdown
of about 95 to 120 feet bel ow full pool 1 evel. This fluctuation would
create large mudflats adjacent to the reservoir in times of maximum
drawdown.
Although other major wildlife species, such as bears, wolves,
wolverines~ and Dall sheep are not expected to be directly affected by
the project to a significant extent, there will inevitably be some
secondary impacts resulting from disruption of existing predator-prey
relationships. Overall, terrestrial wildlife habitat will be reduced.
Small animals resident to inundated areas will be lost. Within the
transmission line corridors, those species dependent upon climax or.
near-climax vegetation will be the most adversely affected. Examples
are the red squirrel and northern flying squirrel.
Resident fish populations above Devil Canyon Dam (there are no
anadromous fish under existing conditions above this point) would be
adversely affected to some extent by the change from a riverine to lake
environment within the reservoir pools, particularly by the substantial
winter drawdown conditons at Watana. The resident sport fishery is not
significant within the main river channel. Primary impacts would occur
near the mouths of a few clearwater tributaries which provide some known
grayling habitat. The intricate changes expected to occur downstream
from Devil Canyon will result in both beneficial and adverse impacts to
resident and anadromous fishes. Adverse impacts could result from poss-
ible reduction in nutrients and primary productivity, cutting, and
erosion of existing steambe.d configuration, increased turbidity during
the winter months, and changes in the hydraulic and biological regime of
salmon repring and spawning sloughs. (As pointed out in Section 4, many
of the anticipated changes downstream from Devil Canyon Dam could prove
beneficial to both th.e anadromous and resident fishery. Determinations
as to the offsetting effects of these changes are the subject of ongoing
studies.)
Roads required for project construction, operation, and maintenance
would impair visual quality and permit general public access into a
largely pristine area. This would have the potential to increase pressure
on existing game populations through hunting, trapping, and general dis-
turbanc.e and harassment. This in turn would require intensified game
manag.ement and 1 aw enforcement practices and preventative measures for
the control of wildfire. Another harmful effect would. be the impact of
some of the roads themselves where delicate ecosystems are traversed.
Some o.f the inevitable consequences of road construction are destruction
of vegetation and wildlife habitat, reduced insulation of frozen soils,
and s.ettling.from permafrost degradation, resulting in both erosion and
alteration of the groundwater regime.
Degradation of visual quality in general would be a major adverse
effect of project construction. This would be attributable pr-imarily to
roads, dam construction, right-of-way clearing for the transmission line,
and the obtrusiveness of the transmission line itself. Although care
68
would be taken to minimize these impacts to the greatest possible extent,
the overall natural setting and scenic quality of the damsites and
transmission line corridor would be permanently impaired,
Although only one historical cabin site and no archaeological sites
are presently known to exist within the proposed reservoir pools or
transmission line corridor, ground reconnaissance of the affected areas
which would take place prior to any construction activity could result
in the discovery of such sites. Where determined necessary, sites would
be salvaged at project cost.
Disposal of slash and other woody debris result·ing from reservoir
and transmission line right-of-way clearing would have varying degrees
and duration of impact. Material in the reservoir pools would most
likely be disposed of by burning. This could increase the possibility
of wildfire in woodlands adjacent to the clearing area, and would affect
ambient air quality, and introduce ash and other material into the
Susitna River during reservoir filling. These impacts, while temporarily
harmful, would be .of short duration. Other methods of disposal, such as
stacking, burying, and chipping, have related adverse impacts, many of
which are more severe or of longer duration than burning. ·
Mineral resource potential within areas which would be inundated by
the reservoirs is not fully known. Inundation would obviate the practi-
cability of future mining or extraction of such resources.
Future options concerning any other use of lands within the reser-
voir pools would effectively be foreclosed. Impacts on land use related
to the transmission lines are more difficult to assess. There will be
unavoidable impacts on present and future land use with'foreclosure of
some alternative future uses. These could be both adverse and beneficial.
In potential farming areas, irrigation and tilling methods would have to
be adapted to the spacing of towers, and land occupied by the tower
bases would be unusable. Also, the transmission corridor could attract
future corridor.s. This would further increase visual impacts associated
with the additional corridors and structures.
Both temporary and permanent facilities would have· to be provided
for project 'workers. Impacts from temporary fac"il i ties, while adverse,
waul d be temporary. Permanent facilities would be 1 ocated and designed
to minimize adverse impacts. Small communities near construction
activities would be impacted by an influx of temporary construction
workers and their families, with resultant increased demand upon com-
munity services. The temporary nature of this influx of people would be
difficult to cope with~ and could well have community effects lasting
well beyond the departure of this transient population •. Another problem
related to work generated by the project would be its seasonality. In
many instances, construction activity would be limited to the warmer
season; thus many of these workers would be seasonally employed.
69
)
Susitna River at Vee damsite. · This demonstrates the typically in-
cised character of the Upper Susitna from Devil Canyon to the Tyone
River. Note that heavier vegetation is limited to slopes and creek
valleys.
)
6. 0 ALTERNATIVES TO THE PROPOSED ACTION
6.01 General. Alaska has a wide variety of energy alternatives to
produce electricity. .Each of the major energy resources--oil, coal,
natural gas, and hydroelectric potential could easily meet projected
power requirements well beyond the year 2000. The nuclear energy alter-
native is also available, and geothermal resources could be signiftcant
in some parts of the State. Present energy generation systems depend
heavily on fuel oils and natural gas with smaller amounts of electrical
energy coming from hydro powerplants and coal.
It is assumed that hydroelectric power from the Upper Susitna River
Basin could be operational by 1986 with the completion of the first dam
and powerp1ant; thus economic and financial feasibility should be
assessed in terms of realistic alternatives that could be made available
in about the same time frame. Such alternatives include power from Cook
Inlet oil and natural gas, coal resources in the Beluga and Nenana
fields, oil from the Alyeska pipeline, natural gas from the North
Slope, other hydro resources, nuclear power, and geothermal power .
. , Pub l.i c Law 93-577 passed by the Congress on 31 December 1974 has
emphasized the conservation of nonrenewable resources and the utili-
zation of renewable resources where possible. The construction of the
proposed hydroelectric dams on the upper Susitna River is a feasible
projectJhat utilizes a renewable resource to generate electrical power
while helping to conserve the use of nonrenewab 1 e resources such as oi 1
and natura} gas. Present Alaskan power systems have a significant
environmental impact on urban environments, but a relatively small
environmental impact outside the urban areas, Substantial increases in
Southcentral Railbelt power requirements will involve the development of
future electric power systems, larger facilities, and some alternatives
that have very important environmental implications.
Future power systems will also require approaches that include full
consideration of environmental values and alternatives and must antici-
pate :that .Alaska and the nation will attach increasing importance to
environmental protection, energy conservation, and conservation of
nonrenewable resources. Additional requirements must be anticipated for
long-range advance planning and site selection, public participation,
and full consideration of the environment in planning, design, construc-
tion, and operation of power facilities.
The significant environmental impacts of the various proposed
alternatives would vary depending on the location, design, construction,
and operation of the facilities for each of the alternatives.
71
Solutions considered in this investigation to meet electrical needs
in the Southcentral Railbelt area were grouped in three major categories:
alternative sources of power; alternative hydropower sources in the
Railbelt area; and alternative hydropower plans in the Upper Susitna
River Basin. The extent of study given to each potential solution was
established by first screening each alternative for suitability, appli-
cability", and economic merit in meeting needs. Each alternative was
tested for physical, political, financial, institutional, economic,
environmental, and social feasibility. Continuous coordination was
maintained with area State and Federal agencies which have related
interests. Alternative measures considered for power purposes are
discussed in the following paragraphs.
6.02 Alternative Sources of Power.
6.02.1 No Action. One of the alternatives to the development of
facilities to generate additional electric power would be not to build
any additional facilities. This approach would save the costs of
planning, designing, constructing, and operating additional facilities.
It would also avoid the adverse environmental impacts which would be
generated by the construction of dams or of other electrical generating
facilities; however, additional power sources are thought to be nec-
essary and would not be provided by this alternative. If a hydroelectric
system is not developed, alternative power sources would be required to
satisfy projected future growth needs of the Railbelt area. Because of
lead time involved in planning, financing, and construction of any
currently viable alternative, oil and natural gas must continue to
provide the bulk of the area's power supplies until the 1980's. On an
equivalent time-frame basis, coal is the most likely future electrical
energy source for the Railbelt area, if hydropower is not developed.
The impacts of the coal alternative are discussed in the following
paragraph.
6.02.2 Coal. Coal is the most abundant fossil fuel in the nation.
Southcentral Alaska has two known extensive deposits (Figure 11). The
Beluga River area northwest of Cook Inlet contains coal reserves of at
least 2.3 billion tons or, energy-wise, an equivalent of almost 6 billion
barrels of oil. Development of Beluga coals would enhance possibilities
for coal-fired powe~ generation at reasonable cost. Coal resources in
the Nenana Fields in the Southcentral Railbelt south of Fairbanks near
Healy, Alaska, are even more extensive than the Beluga River reserves,
totaling at least 7 billion tons, or equivalent of about 18 billion
barrels of oil.
In many cases, the major obstacle to increased coal usage is the
problem of removing the high sulfur content in order to meet air pollu-
tion standards when the coal is burned. Other problems include strip
and subsurface mining, with associated environmental impacts, and trans-
portation of the coal. The Beluga coals have low amounts of sulfur but
also have high ash and water content. Considerable refining would be
needed to enable its use in power generation.
72
MAP
111!1111111 Cool Areas
00@ Geothermal Areas
,t.~,
FIGURE 11
73
COAL AND
GEOTHERMAL AREAS
A.P.A.-JULY 1975
The coal alternative could be available on about the same time
frame as other major new power sources such as hydropower and possibly
nuclear power. It appears that baseload thermal plants could be utilized
in the Railbelt area by 1990. Coal and hydro potential for the South-
central Rail belt may be the least expensive alternatives for the new
power supplies in the l980 1 s and beyond, but coal would be more expensive
than'hydro. Coal-fired plants should also be given consideration in
remote areas which could be supplied by water transportation.
In the absence of major hydro development or the discovery of addi-
tional gas reserves, it is assumed that the Railbelt power system would
shift from oil and gas-fired power units to co a 1 as the pri nci pa 1 energy
source starting about 1985. It is further assumed that the coal plants
would either be conventional steam or steam and gas turbine units located
near the Beluga and Nenana coal fields.
In view of the quantities of coal involved and present-day mining
practice, it is presumed that strip min·ing would be employed to obtain
the coal. Without specific knowledge of the mining site, it is not
possible to project how much acreage would be affected; however, it is
assumed to be in the hundreds, possibly thousands, of acres. Much addi-
tional land would be required for stockpiling of overburden and mine
wastes until such time as a portion of the pit became worked out and
could be used for disposal. The immediate impacts would be the destruc-
tion ~f the overlying vegetation and thus loss of habitat for the resi-
dent animals and birds. Additional land would be altered for roads or
other routes for ~orking the mine(s) and transporting the coal to
generation facilities. Air quality could be expected to suffer from
large inputs of dust. Water in contact with coal and mine wastes
generally become acidic and toxic to vegetation and animal life. It is
difficult to prevent such water from entering either the underground
water table or the natural drainage streams in the area and thus impact-
ing water quality to some distance from the actual mine. Any scenic
values in the mine area would be lost at least until the mine was
exhausted and restoration completed.
Environmental qualities would also be affected .at the power gen-
erating facilities. Considerable land would be occupied by the struc-
tures and more by the operating coal stockpiles and access routes. The
associated vegetation, habitat, and scenic values would be lost. Even
with emissions controlled to legal levels, there would be an input of
particulate matter and chemical compounds into the atmosphere., Large
amounts of water would be needed for cooling ponds requiring either land
for installation of the ponds and the removal of the water frorn natural
sources or the use of a natural water body (lake or river) for the
cooling element. In the latter case, the effects of "thermal pollution"
on the receiving water would be substantial, especially as regards
stimulation of vegetal growth and adverse impacts on fish, if present.
Disposal sites for the waste combustion products would be needed and
could require alteration of large quantities of land and its natural
values. ·
74
Social impacts would be mixed in effect. The operation of the
minepowerplant would provide long-term employment for many more people
than for hydroelectric facility of the same size. Because of this, the
visible economic effects related to disposable income and the multiplier
effect of additional cash circulating in the economic community would be
much more evident than with a hydropower system. However a coal-thermal
facility would forego the recreational and possible flood control
benefits provided by a hydropower project.
The adverse effects of coal mining will occur eventually regardless
of the presence of hydropower development as this resource will be
utilized for other purposes.
Using coal as a power source involves extensive adverse impacts to
the environment, both in the magnitude of the effects and in the size of
the areas affected. Development of hydropower sources would allow for
other, more beneficial uses of our coal resources. Therefore, coal is
determined to be a less desirable source of electrical energy production
than hydroelectric development. Coal was the economic standard by
which each of the hydro alternatives was tested.
6.02.3 Oil and Natural Gas. In the period following the 1967 Depart-
ment of Interior report, Alaska Natural Resources and the Rampart Project,
most studies by Federal agencies and area utility companies focused on
the Cook Inlet supplies of natural gas and, more recently, on pipeline
fuels for Railbelt power. Location of potential oil and gas reserves in
the Southcentral area are shown in Figure 12.
Cook Inlet gas is a clean fuel, and few serious air pollution prob-
lems exist for gas-fired units. Gas turbine exhaust is noisy, but
modern noise suppression equipment can reduce this impact. Energy
conservation aspects of gas-fired units may become significant because
existing gas turbines have low efficiencies and emit visible water vapor
during the colder winter months. Also, nitrogen emissions could be of
significant concern for any proposed larger gas-fired plants.
Existing plans for the Cook Inlet area involve additional large,
advanced-cycle gas turbine units at Beluga and additional turbines and
waste-heat-recovery units in Anchorage. The Fairbanks area utility
companies plan additional gas turbine units using pipeline fuels~
Plans for the near future include a number of measures to increase
efficiency, including the advanced cycle and waste-heat-recovery units
mentioned previously. However, because of lead time involved in planning,
financing, and constructing alternatives, oil and natural gas must
provide the bulk of the area•s power supplies, at least until the mid-
198o•s.
Cook Inlet natural gas has provided low cost power benefits for the
surrounding area in the recent past and, with substantial reserves under
contract, should handle area power requirements for several more years.
75
MAP
l#ffkiJ High Potential for Oil and Gas
~ Moderate Potential
IIIIJ) Low Potenf.ial
FIGURE 12
76
OIL AND GAS
POTENTIAL
Also, additional reserves may be found in future exploration to meet
future demands. It appears reasonable to assume that there will be sub-
stantial increases in costs for future oil and gas supplies as U.S. do-
mestic reserves decline, worldwide demand increases, and foreign oil
prices remain high.
Higher costs for fuels in the future, especially for oil and gas,
should be considered in all future planning, and should anticipate
serious national efforts to develop alternative energy sources that
limit the use of oil and gas for power generation. To a very large
extent these factors invalidate many previous power studies which were
made on the assumption that cheap, long range oil and gas fuel sources
would be available.
Alaska power systems now depend on oil and gas for about 60 percent
of total energy production, and by 1980 about 90 percent of the State's
electric energy will come from these premium fuels. Estimated 1972 fuel
use for Alaska's power systems included 1.4 million barrels'of oil and
16 billion cubic feet of natural gas. If recent trends continue, the
use would increase to about 26 million barrels of oil and 134 billion
cubic feet of natural gas annually by the year 2000 under mid-range
1 evel estimates.
Since low cost natural gas became available for power production in
the Cook Inlet area, the Upper Susitna River Basin hydro power develop-
ment has not looked attractive to the area utilities.
Now the long range outlook for availability and cost of gas is
changing; this, coupled with high power costs in the Fairbanks area,,
possibilities that pipeline fuels will also be quite expensive, and
broader new interest in conservation of nonrenewable resources has
created renewed interest in Susitna hydro potential.
A concentrated effort to develop alternatives for power generation
such as coal, hydro, and eventually nuclear power could result in sub-
stantial reduction in demand for oil and natural gas. The lead times
and large investments required to develop alternatives reinforce the
point that oil and natural gas must supply near future requirements.
For most smaller power systems, basically no economically feasible
alternatives to diesel generation exist, at least for the present.
The availability of fuels in Alaska will undoubtedly improve as
reserves and facilities are developed, which should lead to reduced
dependence on costly imported diesel fuels and other petroleum products
for power generation and other uses within the State. However, there is
no longer any reason to anticipate that Alaskan oil and gas will provide
an abundant, cheap energy source for the long term. These fuels will be
77
expensive, if only because of pressures to export the fuels to areas
where higher prices can be obtained. The present use of oil and natural
gas as a source of electrical energy is viable for Alaska; however, a
higher and better future use of these resources can and, in a 11 prob-
ability wi 11, be made.
In view of the national efforts to develop energy sources that
limit the use of oil and gas for power generation, this alternative was
. rejected.
6.02.4 Nuclear Power. The use of nuclear power as a commercial elec-
trical energy source for the nation is expected to increase considerablY
by the year 1985. Adverse environmental impacts are associated with
surface and subsurface mining of uranium, changes in land use, disposal
of waste heat, risk of accidents, and safe storage of highly radioactive
wastes. In spite of these factors, more than 50 percent of the elec-
trical power of the nation is expected to be generated by nuclear power
by the year 2000. By the end of this century, breeder plants, which
produce additional fuel while they produce power, will gradually take
over a larger share of the production of electricity. Possibly at some
time in the next century, nuclear fission plants and proposed nuclear
breeder plants will be replaced by nuclear fusion reactors and by central
generating stations running on solar power.
Nuclear power should be considered a likely long-range source of
baseload power for the Railbelt area and is generally considered a
distant option because of size of power markets, cost and environmental
factors, and the availability of more favorable coal and hydro alter-
natives. The foreseeable future for nuclear power generation in Alaska
should become materially more favorable only if there is either a break-
through incosts and technology or significant new development in small-
sized plants.
Because of the size of power markets, costs, and environmental
factors, nuclear power development in Alaska is not considered to be an
attractive alternative to cheaper, readily a~ailable power sources
during this century. ·
6. 02. 5 Geotherma 1. Geotherma 1 resources may eventually provide
significant power generation in Alaska; the Southcentral Railbelt area
has substantial geothermal potential (see Figure 11). This source of
energy is not considered a reasonable short term alternative to other
more proven types of power generation, as increased utilization of
geothermal resources depends upon additional technological development
and economics. Geothermal power generation is also considered to be a
future supplement to other power sources rather than an alternative
method of producing electricity.
78 /~
·.
Some of the possible p~oblems associated with the generation of
electric power from geothermal resources include siting of facilities,
brine disposal, and corrosion. This renewable resource could also
provide usable side products such as heat, water, and chemicals.
This is not considered a realistic alternative to other energy
sources within the foreseeable future.
6.02.6 Solar. The radiant heat of the sun is another renewable
source Df energy that has considerable potential for generating power in
this country and the world. Practical use of solar energy to produce
electric power on a large scale is primarily a question of developing
the technology to generate and to store large amounts of electricity
produced by the sun's radiation. A major disadvantage wherever such
development is pursued is the large land area required for reflector
installation to provide usable amounts of power and thus the large
environmental disturbances inherent in such a change in land use.
A second concern especially in Alaska is that during the winter,
when demand for electrical power is greatest, the sun is either absent
from or at best a brief visitor to local skies. Solar power generation
is not considered a feasible planning alternative for Alaskan power
systems in the near future.
6.02.7 Wind and Tidal. Research and development proposals for wind
generators should improve future capabilities of wind-powered electrical
generating systems. With increased diesel fuel costs, wind-generated
electrical power is a possible alternative power source for remote areas
with small loads. The extreme costs and environmental effects involved
in most tidal flow hydroelectric proposals are major factors opposing
this alternative method of generating electrical power. Neither alter-
native is considered feasible for provision of large amounts of energy
at this time.
6.02.8 Wood. In parts of southeastern Alaska, wood is used to fire
steam-generating power plants. Ala.ska does have vast forest reserves
that could be used; however, these.same trees have far higher and better
alternative uses in wood, paper, and other industries .. In addition, the
esthetic, ecological, and environmental impacts of the large harvests
necessary to allow production of large amounts of energy appear to be
massive. Wood as an energy source is not considered a major alternative.
6.02.9 Intertie. Alaska could purchase surplus power from sources in
Canada or the "Lower 48;" however, the cost of transmission facilities
and the uncertainty of available dependable power would be major factors
opposing such a scheme. Therefore, an intertie does not appear to be
feasible at this time.
79
6.02.10 Solid Waste. The burning of solid waste products to produce
electrical power has potential in some areas of the country, but there
does not appear to be an adequate supply of solid waste products in the
railbelt area to produce substantial amounts of energy. Associated air
quality and odor problems would also appear to be severe. This alter-
native is not considered feasible to meet the energy needs in the
railbelt area, but could supplement the total power needs for the area.
6.02.11 Hydropower. The reconnaissance report on potential development
in the State of Alaska made in 1948 by the U.S. Bureau of Reclamation,
included hundreds of potential power development sites located through-
out the five study regions of the State: Southeast, Southcentral,
Yukon-Kuskokwim, Seward Peninsula, and Arctic. In 1969 and again in
1974 the 1948 report was updated, and in May 1974 the latest revision
was published as the 1974 Alaska Power Survey. The two largest market
areas for power are located in the Southcentral Railbelt, particularly
the Anchorage-Cook Inlet area, and the Fairbanks-Tanana Valley area.
The large amount of the available renewable water resource which could
produce electric power has excellent potential to answer the energy
needs of the Southcentral Railbelt area.
6.03 Alternative Hydrologic Basins in the Southcentral Railbelt Area
6.03.1 Rampart Canyon. Considerable study has been made of the
possibility of developing hydroelectric power in the Upper Yukon Basin
with a damsite located in Rampart Canyon on the Yukon River approximately
140 miles northwest of Fairbanks, Alaska. The project has one of the
greatest hydroelectric potentials in North America. The proposal would
create a reservoir with a water surface area of approximately 10,600
square miles, with a maximum length of 280 miles and a maximum width of
about 80 miles. The project would provide firm annual energy of .34.2
billion kilowatt-hours (the energy equivalent of over 74 million barrels
of oil per year). However, the impacts on fish and wildlife resources
in the Yukon Flats would be significant. Implementation of such a
project would also be extremely controversial.
Rampart is engineeringly feasible and the proposed project would
provide enough excess energy to encourage further industrial dev~lcpment
in Alaska, but it would introduce a number of secondary impacts not
associated with the recommended alternative. Excess energy could also
be transmitted to the 11 Lower 48 11 through an intertie system. However,
this would be a major action not directly applicable to energy ne'eds of
the Railbelt Area. Justification would have to be based on a nation-
wide plan which included Rampart as a recommended alternative to the
development of other energy sources. Within the time-frame criteria
established for fulfillment of projected growth needs in the Railbelt
Area, this is not considered a viable alternative.
80
SOUTHCENTRAL RAILBEL T
KEY HYDROELECTRIC AND
TRANSMISSION ALTERNATIVES
FIGURE 13
. 81 .
I
SCALE
~~---·------------------·-······a
0 . 50 IOOM(Ies
The tremendous financial investments, the substantial environmental
impacts, the limited opportunities for marketing the enormous amounts of
power, and the availability of more favorable, less costly alternatives
preclude recommending construction of the Rampart project at this time.
Rampart Dam could be developed if future national needs recommend the
project's construction.
6.03.2 Wood Canyon. Another possible location for significant
hydroelectric power development is Wood Canyon on the Copper River. The
damsite would be located about 85 miles above the mouth of the Copper
River in the Chugach Mountains of southcentral Alaska. A "high dam"
would develop firm annual energy of 21.9 billion k·ilowatt-hours. A "low
dam 11 would provide 10.3 billion kilowatt-hours of firm annual energy.
The construction of a dam at Wood Canyon would force relocation of
two communities and would create serious environmental problems affecting
both fish and wildlife values, especially to the large salmon runs on
the Copper River. Unless the problem posed to migrating salmon could be
solved satisfactorily, the project wduld have an extremely adverse
effect on the major commercial fishing industry in a wide area of the
Gulf of Alaska. This alternative is not considered feasible at this
time.
6.03.3 Chakachamna Lake. The possibility of developing hydroelectric
power from Chakachamna Lake was investigated. The lake is located on
the Chakachatna River which empties into the west side of Cook Inlet
approximately 65 miles west of Anchorage. The facility would generate
1.6 billion kilowatt-hours of firm annual energy. The project would
require the erection of transmission facilities over difficult terrain
to tie into a Southcentral Railbelt transmission system and the con-
struction of a high-cost 11-mile tunnel for power generation. The
adverse environmental impact would be substantially less than for many
proposed Alaskan hydroelectric projects. However, the low energy output
and the high costs render this alternative infeasible at this time.
6.03.4 Bradley Lake. The site for this authorized hydroelectric
project is at Bradley Lake on the Kenai Peninsula at the head of Kachemak
Bay near Homer, Alaska. The proposal would generate 0.4 billion killowatt-
hours of firm annual energy and could serve as a southern peaking in-
stallation for a Southcentral Railbelt power system. Adverse environ-
mental impacts of this proposed project would be relatively minor com-
pared to the other hydroelectric development alternatives which were
considered. If an economically feasible plan can be developed for
Bradley Lake, the project could be integrated with future development of
the Susitna River basin. By itself, this project would fulfill only a
small portion of the projected electrical needs of the Railbelt area .
. 82.
Upstream view of Devil Canyon darnsite.
83
6.03.5 Susitna River. Surveys for potential hydropower development
in the Susitna River basin were reported by the Corps of Engineers in
1950 and by the U.S. Bureau of Reclamation in 1948, 1952, 1961, and
1974. The 1952 USBR report indicated 12 potential hydropower sites in
the basin; of these, the five damsites studied in the upper Susitna
basin showed the highest potential. These studies showed the environ-
mental impact from projects in the Upper Susitna River Basin would not
be as severe as those from other basins, and the firm energy potential
could contribute substantially to satisfying the needs of the South-
central Railbelt area.
6.04 Alternative Hydroelectric Plans in the Upper Sus1tna River Basin:
6.04.1 General: Eight plans for hydroelectric development of the
Susitna River basin including the proposed actions were studied as
follows:
6.04.2 Devil Canyon. The possibility of a single dam development of
the Upper Susitna basin locat~d at the Devil Canyon damsite was investi-
gated. The proposed thin-arch dam with a structural ·height of about
635 feet would have a water surface area of about 7,550 acres at the
normal maximum pool elevation of 1,450 feet, m.s.l. The project would
produce 0.9 billion kilowatt-hours of firm annual energy from an installed
capacity of 220 megawatts. Because of the very limited storage capacity,
the project has a low firm energy capability and is not considered
economically viable.
6.04.3 Watana. This single dam development of the upper Susitna
basin located at the Watana site would be an earthfill dam with structural
height of about 810 feet. The reservoir would have a normal maximum
pool elevation of 2,200 feet, would have a surface area of approximately
43,000 acres, and would extend about 54 river miles upstream to a point
between the Oshetna and Tyone Rivers. The annual firm electrical pro-
duction of Watana would be 3.1 billion kilowatt-hours from an installed
capacity of 792 megawatts. Although feasible, the project develops less
than half of the basin potential and is not viable in itself since more
productive feasible plans are available.
6.04.4 Devil Canyon High Dam. In September 1974, Henry J. Kaiser
Company prepared a report proposing an alternative hydroelectric develop-
ment project on the upper Susitna River. The report states that pre-
liminary investigations indicated that an 810-foot-high, concrete-faced
rockfill dam located about five miles upstream from the proposed Devil
Canyon site would provide 3.7 billion k-ilowatts of average annual
energy, or 2.6 billion kilowatt-hours of firm annual energy (figures
converted to standard Corps of Eng·ineers evaluation parameters). This
dam would inu·ndate about 58 miles of the Susitna River with a reservoir
of approximately 24,000 surface acres at a full pool elevation of l ,750
feet.
84
This proj.ect would be located in much of the same area of the
Susitna Rivet:' .. canyon occupied by the proposed Devil Canyon-Watana project
and would haVe similar environmental impacts with some exceptions. ·
Whereas the Devil Canyon reservoir in the two-dam proposal would remain
nearly full all year, the Kaiser reservoir would fluctuate substantially.
Kaiser's proposed Devil Canyon High Dam, located about 25 miles
downstrea~ from the Watana site, would have prpportionately fewer miles
of permanent roads and transmission 1 ines than the Devil Canyon-Watana
project, therefore less environmental impact on resources affected by
+hese facilities.
The r~creation opportunities would be fewer for the one-dam proposal.
The substantial fluctuation of the reservoir would reduce some recre-
ation potential and reduce resident fish populations while increasing
the adverse visual impact associated with reservoir drawdown. The plan
was found to lack economic feasibility.
6.04.5 Devil Canyon-Denali. This alternative two-dam system would
include the thin arch concrete dam at Devil Canyon and a 260-foot-o-high ..
earthfill dam in the vicinity of Denali. The Denali Dam would provide
storage only and would have no powerhouse. This system would generate
2.5 bill ion kilowatt-hours of firm annual energy from an installed
capacity of 575 megawatts at Devil Canyon Dam. The surface acres flooded
would total about 62,000 acres (Devil Canyon, 7,550; Denali 54,000). The
plan would entail significant environmental ·impacts on waterfowl nest·ing
areas, moose range, and archaeological/historical values in the Denali
reservoir area. Economic feasibility is lacking.
6.04.6 Three-dam System. A three-dam Devil Canyon-Watana-Denali
hydroelectric development on the upper Susitna River could be built as
an extension of the two-dam Devil Canyon-Watana project if the Denali
storage site proved feasible. Such a dam system would provide a total
of 6.8 billion kilowatt-hours of firm annual energy.
If a three-dam Devil Canyon-Watana-Denali project were constructed,
it would include Devil Canyon and Watana dams previously described, and
a 260-foot storage dam at Denali. This three-dam system would inundate
approximately 104,550 acres and would take 13 to 17 years to construct.
With a thre.e-dam system, the 100-year storage capacity ·in Watana reser-
voir would be reduced by less than 3 percent due to sedimentation.
Environmentally, this plan would result in the adverse impacts
associated with the Devif Caljyqn-Denali two-dam system, plus the added
impact of inundating some adtli':tfonal moose range and bisecting a sea-
canal caribou:migration route. Though the latter impact should not
seriously ;mpede summer caribou migration, it could result in some
caribou mortality if animals attempted to cross the reservoir during
adverse ice conditions, including the possibility of ice-shelving during
peri ads of reservoir drawdown. ··
. 85 .
------------------------
TABLE II
DATA ON THE· PROPOSED PROJECT AND SELECTED SUSITNA ALTERNATIVES
Type Normal Mi·les of Billion Kilowatt-
of Structural Full Pool Surface Total-Storage River Hours of Firm
Construction
Selected Plan:
Height Elevation Acres Acre-Feet Inundated Annual Energy
De vi 1 Canyon Concrete, 635' 1,450' 7,550 1,050,000 28
thin-arch
Watana Earthfill 810' 2,200 1 43,000 9,624,000 5.4
Totals 50,550 6.1
A1ternatives:
Kaiser's High Earthfill 810' 1 '750 I 24,000 4,700,000 58 (2.6)
Devil Canyon
Olson Concrete, 200'+ 1 ,020' 1 ,000 83,000 8
00 gravity
0'1 . Vee Earthfi 11 455' 2,300' 9,400 920,000 32
Denali Earthfi 11 260' 2,535' 54,000 3,850,000 34
Totals 88,400 5.6
Devil Canyon Concrete, 635' 1,450' 7,550 1,050,000 28
thin-arch
Watana Earthfill 810' 2,200' 43,000 9,624,000 54
Denali Ea rthfi 11 260' 2~535' 54,000 3,850,000 3.4
Totals 104,550 6.8
De vi 1 Canyon Concrete, 635 1 1, 45Q I 7,550 1,050,000 28
thin-arch
Watana Earthfill 515' 1,905' 14,000 2,420,000 40
Vee Earthfi 11 455' 2,300' 9,400 920,000 32
Denali Earthfill 260' 2,535' 54,000 3,850,000 34
Totals 84,950 6.2
)
,.--.
/
This alternative has significantly greater total adverse environ-
mental impacts than the recommended plan(Devil Canyon and Watana
development) and is economically feasible.
6.04.7 Four-dam System. In May 1974, the Alaska Power Administration
updated a March 1961 report of the Bureau of Reclamation which proposed
development of the hydroelectric resources of the Upper Susitna River
Basin. The report proposed an initial plan to build the Devil Canyon
Dam and powerplant and an upstream storage dam and reservoir at Denali.
Subsequent development of a four-dam system would include dams at both
the Watana and Vee sites. The four-dam system would generate a total of
6.2 billion kilowatts of firm annual electrical energy. The Watana Dam
under this plan would be about 300 feet lower than in the selected Devil
Canyon-Watana proposal, and the Vee Dam would be about 55 feet lower
than in the original Bureau of Reclamation 4-dam proposal.
Initial development of the four-dam system, Devil Canyon-Watana-
Vee-Denali, would include only the construction of the hydroelectric dam
at Devil Canyon and the storage dam at Denali. This combination of two
dams would produce 2.5 billion kilowatt-hours of firm annual energy.
This initial two-dam stystem would also be compatible with the three-dam
Devil Canyon-Watana-Denali, alternative proposal.
The four reservoirs considered in this development would inundate
approximately 85,000 acres of land and river in the upper Susitna basin,
compared with about 50,550 acres flooded in the selected two-dam proposal.
The two reservoirs proposed in the lower section of the upper Susitna
River would have substantially fewer known adverse environmental impacts
than the two upper area reservoirs at the Vee and Denali. Generally the
further upstream a reservoir is located in the four-dam system, the
greater the overall adverse environmental impact would be on fish,
wildlife, and esthetic resources.
In a four-dam plan, Watana reservoir would cover a surface area of
about 14,000 acres behind a 515-foot-high dam with a pool elevation of
1,905 feet. The reservoir would extend over 40 miles upstream from the
damsite and would be contained in the narrow canyon for most of its
1 ength.
Under either Watana alternative, the reservoir would flood areas
used by migrating caribou and would flood some moose winter range in the
river bottom. It would also cover existing resident fish habitat at the
mouths of some of the tributaries in this section of the river and
possible would create additional stream habitat at higher elevations.
The 455-foot-high Vee Dam would be built only under the four-dam
plan in conjunction with the lower height Watana Dam. Vee reservoir
would inundate about 32 miles of glacial river and would have a pool
87
elevation of 2,300 feet with a surface area of approximately 9,400
acres. The reservoir would flood a substantial amount of moose habitat
on the ma4n Susitna and on the lower reaches of the Oshetna and Tyone
Rivers. Caribou migration routes along the south bank of the Susitna
River would also be affected as would some waterfowl habitat of minor
significance. Present resident fish habitat, especially grayling, would
be flooded at the mouths of many of the clearwater tributaries in the
area covered by the Vee reservoir.
Any road to the Vee damsite would open up larger areas of wild
lands that are prime wildlife habitat and escapement areas (inaccessible
to man) for caribou, bear, and moose, and would have a significant
impact on these and other fish and wildlife resources within these
areas.
Denali Dam, with a structural height of 260 feet, would form a
54,000-acre storage reservoir with a pool elevation of 2,535 feet. Large
areas of wildlife habitat, especially for moose, caribou, and waterfowl,
would be inundated in an area between 2 and 6 miles wide and approxi-
mately 34 miles long. Many clearwater streams entering the Susitna
River in this area have varying populations of arctic grayling; how the
fluctuating reservoir would affect this fishery is generally unknown at
this time. Substantial areas of lands would be exposed during the
seasonal drawdowns of this storage reservoir; from an esthetic stand-
point, this would be a substantial adverse environmental impact, espe-
cially when viewed from the well-traveled Denali Highway during th.e
earlier summer months when the reservoir would be low.
The relocation of 19 miles of the Denali Highway necessary with the
r.onstruction of a dam at the Denali site would provide additional access
to this area with increasing pressures on the fish and wildlife resources
inCoal Creek, Clearwater Creek, lower Maclaren River, Butte Creek, and
the eastern slopes of the Watana Hills. There would be substantially
less developed recreational potential at the Vee and Denali sites than
at Devil Canyon because of travel distances involved and reservoir draw-
down, especially at the Denali damsite.
It is expected that construction of the Vee project would take 5 to
6 years, while the Denali dam and reservoir would take between 3 and 5
years to constru.ct. The construction period of the four-dam system
would be between 18 and 23 years, if the dams were constructed in
sequence. The magnitude of environmental impacts resulting from a four-
dam system in the Upper Susitna River Basin clearly makes this a less
desirable alternative than the one-, two-, or three-dam plans, although
H is economically feasible ..
88
Nenana-~
ALTERNATIVE
TRANSMISSION 1 CORRIDORS
I
Scale in miles
50 75 100 125
A.P.A·Morch 1975
14
-------------------·--------------·-----------------~·------------------------------------
6.04.8 Kaiser Four-Dam System. An additional study of a four-dam
sys tern was made by the Corps of Engineers uti 1 i zing the Kaiser Dev i 1
Canyon High Dam as the main component in. an upper Susitna basin system.
This alternative included both the Vee and Denali Dams and a low reregu-
lating dam (Olson) just below the confluence of Portage Creek. This
four-dam system could provide an estimated 5.6 billion kilowatt-hours of
firm annual energy.
The environmental impacts of this four-dam system are a combination
of the impacts of the Kaiser Devil Canyon High Dam, the Vee and Denali
damsites, and a low reregulating dam downstream.from Devil Canyon just
below Portage Creek. The system would inundate about 88,250 acres. One
of the major additional impacts would include anadromous and resident
fishery impacts caused by the reregulating dam just below Portage Creek.
The plan is not economically feasible.
6.05 Alternative Power Transmission Corridors. Any development of
hydroelectric power in the upper Susitna basin would require development
of electric transmission facilities to the Railbelt load centers. In
determining the preferred system, the Alaska Power Administration
studied all feasible corridors joining the upper Susitna complex to
Anchorage and Fairbanks. The most feasible corridor was selected on the
basis of cost, reliability, and potential environmental impact; the
remaining corridors represent alternatives of varying degrees of feasibility.
Four groups of alternatives were considered: first, those that
lead from Devil Canyon-Watana to Anchorage via the Susitna watershed;
second, those that lead to Fairbanks via the Nenana and Tanana drainage;
third, those that lead to Fairbanks via the Delta and Tanana drainages;
and fourth, those that lead to Anchorage via the Copper and Matanuska
drainages. Within each of the four basic corridor systems, a number of
alternative corridor routes were considered. Figure 14 displays these
various routes. Susitna 1 and Nenana 1 are the selected routes~
6.05.1 Alternatives to Susitna l. As shown in Figure 14, a common
corridor is shared by all Susitna alternative alignments from Point
MacKenzie to Talkeetna. From Talkeetna to the reservoir sites, four
alternative corridor segments were considered. Impacts attributable to
Susitna 1, the selected corridor, are discussed in Sections 4.0 and 5.0
nf the EIS. The other three corridors are discussed as follows:
Susitna 2 This corridor is 140 miles long, 4 miles longer than
Susitna 1. It differs from Susitna 1 in that from Talkeetna it crosses
the Susitna River, leads north into Denali State Park, then northwest
ov~r Troublesome Creek and on to Gold Creek where it rejoins Susitna 1.
90
,·.·~
This alternative segment is 42 miles long. Alpine and moist tundra are
crossed in addition to those ecosystems crossed by Susitna 1; however
these3are limited in extent. In comparison to Susitna 1, this alternative
also requires clearing lDO more acres. It traverses 26 miles of Denali
State Park, and conflicts with trail systems in the Park.
•'
Susitna 3; This corridor is 129 miles long, 7 miles shorte~ than
Susitt'la 1. It is basically a more direct corridor from Talkeetna to
Devil Canyon, bypassing the Alaska .railroad between Talkeetna and Gold
Creek. The length of the alternative segment is 45 miles. It crosses
o~er a plateau of almost 4,000 feet elevation as compared to maximum
elevations of about 2,000 feet for Susitna 1 and 2. It also crosses
about 25 miles of moist tundra and 20 mi 1 es of upland spruce-hardwood.
In comparison to Susitna there would be 1,610 acres less clearing of
vegetation required, there would be possible impacts on caribou winter
range, sizeable amounts of land would be opened up to vehicular ~ccess,
primitive values would be adversely affected, and the transmission line
would be highly visible.
Sus i tna 4. This corridor is 147 miles 1 ong, 11 mi 1 es 1 anger than
Susitna 1. It leads from Talkeetna, up the Talkeetna River and Prairie
Creek to Stephen Lake, then west to Devil Canyon dams1te. This segment
is 63 miles, versus 52 miles for the comparable Susitna 1 segment. This
segment traverses upland spruce-hardwoods for most of it~ len~th, and ·
crosses a few miles of moist tundra. Permafrost ii pres~nt ~t the
higher elevations, which rise to about 2,200 feet. Comparedto Susitna
1, this alternative would result in permafrost and soil erosion problems,
75 atres less vegetative clearing, penetration of a moose toncentration
area,, impact upon recreational use near Stephen Lake by creating vehicular
access, and be highly visible in the upland area which is relatively
intensively used by recreationists.
6.05.2 Alternatives to Nenana 1. There are five alternative corridors
connecting the project area with Fairbanks by way of the Nenana River.
Nenana 1 parallels the highway and railroad and comprises the northern
half of the selected corridor system. Nenana 1 is described in Section
2.0 and impacts are discussed in Sections 4.0 and 5.0 of the EIS. The
other.four Nenana corridor alternatives are discussed and compared to
Nenana 1 as follows:
Nenana 2. This corridor is 220 miles long, 22 miles longer than
Nenana l. It departs Nenana 1 at Cantwell, leads east to Wells Creek,
northcto Dean Creek and the Wood River, and follows the Wood River
north to Ester. This segment is 158 miles. The corridor rises to
4,000 feet on the Dean Creek-Wood River pass. A wide variety of
91
ecosystems is traversed, from alpine tundra to bog and muskeg. Perma-
frost can be assumed to be prevalent. For 25 to 30 miles the corridor
runs adjacent to or through the Blair Lake Air Force Range. Habitats of
moose, caribou, and Dall sheep are traversed. The following conditions
or impact~ are of greater magnitude along this corridor than along
Nenana 1: Peaty, permafrost soils are more prevalent and would cause
greater problems related to access road construction and erosion prevention
or control; about 90 more acres of clearing would be required; and dis-
turbed areas in moist and alpine tundra would be very slow to recuperate.
Dall sheep and caribou, in addition to moose, would be disturbed by
construction activity, and most of the corridor would provide vehicular
access to areas now accessible only by foot. Viewer contact would be
relatively low because of the isolation from existing transportation
routes.
Nenana 3. This corridor is 231 miles long, 33 miles longer than
Nenana 1. It is identical to Nenana 1 from Devil Canyon to Cantwell
where it then loops east and.north through the Alaska Range, rejoining
Nenana 1 at Healy. This segment is 72 miles long while the comparable
segment of Nenana 1 is 39 miles. Terrain along the alternative segment
varies from rolling hills and valleys to high passes and sharp ridges,
the highest of which is about 3,900 feet. The alternative segment
traverses moist and alpine tundra, upland spruce-hardwood, muskeg, and.
bog; however, rocky thin soils and bedrock predominate. Erosion would
general'ly be low. Valley floors have continuous permafrost. As com-
pared to Nenana 1, nearly 200 acres less clearing would be required, and
inc~ea~ed access would cause a potential increase in hunting pressure on
Dall sheep, caribou and moose. Construction of the transmission line
within the alternative segment between Cantwell and Healy would be
technically difficult and expensive, and it would be difficult to
maintain. HoweVer, since it would not be visible from existing trans-
portation routes, it would have low viewer impact.
Nenana 4. This corridor is 223 miles long, 25 miles longer than
Nenana 1. From Devil Canyon it leads east and north, tying in at Healy
to Nenana 1. The length of this separate segment is 126 miles; the
comparable segment of Nenana 1 is 101 miles. From Devil Canyon, the
corridor leads east to Watana Damsite and then north up Deadman and
Brushkana Creek to Wells Creek where it continues over a 3,900-foot
pass to Louis Creek and Yanert Fork, then over another pass (2,900 feet)
to Moody Creek which it follows to Healy. Ecosystems traversed are
moist and alpine tundra, muskeg and bog, and upland spruce-hardwood.
Moose, caribou, and Dall sheep inhabit this corridor. Between Watana and
Wells Creek, soils are very vulnerable to permafrost degradation and
frost heaving. Erosion would be a serious problem related to powerline
and road construction and would result in degradation of water quality
in the clearwater streams encountered. From Wells Creek to Healy,
92 .~.
soils are rocky and thin. Erosion would be relatively low in this
reach. Permafrost is continuous in the valley floors. As compared to
Nenana 1, this corridor would require about 380 acres less clearing.
Little modification of habitat would be required on this differing
segment. Vehicular access waul d be provided which waul d potentially
increase human pressures on Dall sheep and caribou~ and to a le~ser
degree on moose. Most of this segment would have low viewer contact
because of its isolation from existing transportation systems.
Nenana 5. This corridor is 212 miles long, 14 miles longer than
Nenana l. It is totally separate from Nenana 1, being a parallel
corridor lying to the east of the proposed corridor. ·It is identical to
Nenana 4 from Devil Canyon to Yanert Fork where it becomes separate as
'it leads up Dean Creek and crosses over a 4,000-foot pass into the Wood
River drainage. It then leads north along the Wood River to Ester.
Permafrost is prevalent. Alpine and moist tundra, upland spruce-lowland
spruce-hardwood, and bog and muskeg ecosystems are traversed by the
segment which differs from Nenana 4. Significant numbers of Dall sheep
and moose are encountered as well as ·important winter range for caribou.
Construction problems along the Wood River and Tanana River valleys
would result from the lack of well drained soils and the presence of
conti riu:Ous sha 11 ow permafrost. Soi 1 erosion and permafrost degradation
would pose serious siltation threats to clear-water streams. This
corridor would require clearing of about 100 acres less than Nenana 1;
Dall sheep and caribou habitat would be adversely affected. Increased
access to relatively inaccessible areas would be provided. Viewer
contacts would be relatively few as a result of the remoteness of the
corridor.
6.05.3 Alternatives to S~sitna and Nenana Corridors. lh addition to
the Susitna and Nenana alternative corridors previously described,
consideration was given to an alternative routing system for transmitting
electricity to the two major load centers, Anchorage and Fairbanks (see
Figure 14). Two other corridors were considered as access to Anchorage
via the Matanuska Valley. These are referred to as Matanuska Corridors 1
and 2: Essentially only one other corridor is deemed feasible from the
hydropower sites at Devil Canyon and Watana to Fairbanks. This is
called the Delta Corridor.
Matanuska 1. This corridor differs radically from Susitna 1 in
that it loops to the east and south, and approaches Point MacKenzie from
the east. Its total length is 250 miles, 122 miles longer than Susitna
1. A considerable portion, 125 miles, parallels the Glenn Highway or
other secondary roads or planned transmission corridors. From Devil
Canyon the corridor leads east to Watana Damsite thence southeasterly
over a sparsely forested, poorly drained plateau to the head of the
Little Nelchina River. Here, the terrain is fairly open and gentle
93
with predominantly rolling hills. The corridor, on passing just to the
west af Slide Mountain, turns west to parallel the Glenn Highway. It
crosses over Tahneta Pass into the Matanuska drainage, which it follows
to the flat land at the mouth of the Matanuska Valley. It continues
southwest along the northern shore of Cook Inlet, traversing considerable
amounts of forest and muskeg as it approaches Point MacKenzie. Perma-
frost in this corridor is continuous from the upper end of Watana
reservoir to Tahneta Pass, discontinuous in the Upper Matanuska Valley,
and sporadic in the lower valley. Ecosystems traversed include spruce-
hardwoods and meist tundra between the Watana Damsite and the Little
Nelchina River, and upland spruce-hardwood in the lower valley. Between
Devil Canyon and the Little Nelchina River, the corridor generally runs
between cariboutcalving and wintering ranges. Also, some wintering
range is traversed along the Little Nelchina River and Glenn HighWay to
Tahneta Pass. Some Dall sheep habitat exists in Tahneta Pass and Moose
concentrations are encountered in the Point MacKenzie area. Between
Watana reservoir and Slide Mountain, the potential for permafrost
c!egradation is very high. Frost heaving in the poorly drained fine-
grained soils w9uld require heavy maintenance of both line and access
road. Erosion would contribute sediment to clearwater streams in the
area. Erosion potential is relatively low along the remainder of the
corridor. This route would require approximately 750 acres more clearing
than Susitna-~mostly in the lower Matanuska Valley. Moose would gen-
erally benefit from clearing, whereas caribou range would suffer loss.
Lake Louise and some other high recreational use areas would be impacted
upon. Increased access would be provided to areas north of the Glenn
Highway. The scenic quality along the highway would generally be
lowered, since concealment of the line would be a problem along most of
its· ·route.
Matanuska 2. Alternative corridor Matanuska 2 is 385 miles long,
120 miles longer than Matanuska 1 and 249 miles longer than Susitna 1.
From Watana Damsite it loops much further to the east than Matanuska l,
rejoining it at Slide Mountain. This segment of Matanuska 1 is 217
miles long, versus 97 miles for the comparable segment of Matanuska 2.
Frbm Watana Dam~ite the corridor crosses the Susitna River and leads
northeast toward Butte Creek and the Denali Highway, which it parallels
to Paxson. Here it turns south, paralleling the Richardson Highway and
the Aleyska Pipeline to Glennallen. From Glenallen it parallels the
Glenn Highway up the valley of the Tazlina River to Slide Mountain and
the junction with Matanuska 1. ~1ost of the corridor traverses flat
terrain. Highest point on the corridor is a plateau of about 4,000 feet
elevation in the Tangle Lakes -Rock Creek area between the Maclaren
River and Paxson. This area is poorly drained and covered with post-
glacial features such as eskers and terminal moraines, and many small
lakes. Permafrost is prevalent. The predominant ecosystem is moist
tundra. From Paxson to Slide Mountain the corridor lies within tlile
Copper River lowlands, a basin underlain by nearly cont·inuous permafrost.
. 94 .
i .. ~\
Generally poorly drained, this basin is dominated by upland and lowland
spruce-hardwood and muskeg ecosystems. Except for the area around
Glenallen, the entire corridor runs through the winter range of the
Nelchina caribou herd. l~oose concentrations are found along the Copper,
Gulkana, and Tazlina Rivers. Most of the corridor traverses medium
density waterfowl habitat. Within the segment from Watana Damsite to
Slide Mountain the potential for permafrost degradation is very high.
Frost heaving would entail high maintenance of this line and road.
Subsequent erosion could cause significant impact on clearwater streams
in the area. Clearing would be required for about 2,200 acres more than
the Susitna 1 corridor. Moose would generally benefit from clearing
while some caribou range would suffer damage and loss. Existing recreational
uses in the Lake Louise area would not be significantly impacted by this
corridor. ·The archaeological richness of the Tangle Lakes area makes
it likely that presently unknown sites would be discovered, and possibly
disturbed, as a result of the project. Impact on scenic quality along
the Denali Highway to Paxson would be high as a result of large numbers
of viewer-contacts and little opportunity for line concealment.
Delta Corridor. This corridor is 280 miles long, 82 miles longer
than Nenana 1. From Devil Canyon, it follows essentially the same path
as Matanuska 2 to Paxson. Here it turns north, following the Richardson
Highway -Alyeska Pipeline corridor over Isabel Pass, a wide, gentle
divide at 3,000 feet of elevation. It continues along the pipeline
corridor through the Alaska Range, following the Delta River. North of
Delta River canyon the terrain consists of rolling hills until the
Tanana Valley is reached. The terrain here is flat to Fairbanks.
Shallow rocky soils dominate the Delta River Canyon stretch, followed
north by mixed poorly and well drained soils. This segment traverses
upland spruce-hardwood northeast of the Delta and Tanana Rivers. Along
the Tanana floodplain, bottomland spruce~poplar forest predominate.
Some lowland spruce-hardwood occurs immediately south of Fairbanks.
Bison range would be traversed between the Delta River Canyon and Big
Delta. Sporadic moose concentrations occur along the Tanana River.
Dall sheep range occurs in the Delta River Canyon. Ice-rich permaftost
is found throughout the corridor, and the soil is vulnerable to perma-
frost degradation, frost heaving, rutting and scarring. Generally well
drained upland soils between Shaw Creek and Fairbanks a~e subject to
gulleying, unstable slopes, and wind erosion. Clearwater streams are
subject to sediment pollution from construction and maintenance activity.
Thixotrophic soils in Isabel Pass would expose transmission towers to
higher than normal seismic risk. Clearing required in this corridor
would be about 430 acres more than in Nenana 1. The Nelchina caribou
herd south of the Alaska range would be adversely impacted by this
alternative. Additional access to hunters would be provfded. The areas
of highest scenic value along the Denali and Richardson highways coincide
with the least opportunity for transmission 1 ine concealment.
95
)
Denali Highway bridge across upper Susitna River. This area would have
been inundated by a dam at the Denali site.
)
/""-~-
7.0 RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT
AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY
'The project as presently conceived could have a useful life span in
excess of 500 years based .on the 11 dead storage space 11 (space bel ow the
lowest water intakes for the powerhouses) within the reservoirs·for
sediment accumulation. Individual components would be replaced as
necessary, but the over a 11 system waul d remain essentially the same.
Should the system last this long, or for any number of reasons be made
inoperative at an earlier date (an example would be development of more
desirable alternative sources of electrical power), many of the resources
described above in Sections 4 and 5 would have been, for all practic~l
purposes, committed to permanent foreclosure of options for alternative
future uses.
In this sense, the long-term productivity of the directly affected
environment will have been sacrificed for a shorter-term alternative
use~ since impacts attributable to the reservoirs will be of much
longer duration than the useful life of the project for hydroelectric
power production. By the same token, the project would contribute to a
savings in nonrenewable energy sources with an energy equivalent of
about 15 million barrels of oil, or approximately 11~ billion cubic
feet of gas per year. Although this sav·ings is a principal factor in
the consideration of a hydroelectric alternative, over the long haul,
hydroelectric energy must be viewed as an interim measure for conserving
the nation's nonrenewable energy sources until some more practical,
permanent method of produc-ing electricity is achieved which will not
overburden the nation's or world's finite resources.
Some features of the project will have less lengthy impact on the
environment than the dams and reservoirs. Many of the impacts will be
encountered during--and for a relatively brief time following--the
construction phase. Of the longer-term impacts, some would terminate or
lessen immediately or shortly after retirement of a given project
component. For instance, if the transmission line were to be removed,
many of its impacts would soon disappear. Maintenance activity, noise
and electromagnetic interference, and visual impacts associated .with the
lines and towers would be immediately eliminated. Roads could be
removed, top soils replaced, and eventually natural revegetation proc-
esses would largely obscure the previous existence of the transmission
system. Other impacts would, to varying degrees, be 11 imprinted" into
the environment. Wildlife patterns may have been affected by continual
hunting or habitat modification. Vegetative patterns, altered by
continual maintenance or introduction of nonnative plants, may continue
for a 1 ong time. Land use patterns ·influenced by the project waul d
linger after it ceased to function. ·
No extremely short-term benefits from the project are the basis for
justifying the long-term, if not permanent, commitment of the productivity
of the affected areas. The trade-off is essentially a long-t~rm benefit
which can be achieved only at the expense of an even more extended
commitment of the affected resources.
97
MAP
~ VERY HIGH POTENTrAt'J
61111111111 HIGH POTENTIAL
FIGURE 15
gP
POTENTIAL MINERAL
DEVELOPMENT AREAS
SCALE' ~~..,;,;,;;;;...--_... ~ _ .. ____________ ?
0 50 100 Milos'
A.P.A.-JULY 1975
8.0 IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS OF RESOURCES IN THE
PROPOSED ACTION.
8.01 Changes in Land Use ... The development of hydroelectric dams on the
uppe~ Susitna River would present an irreversible change of land'use
from 2an existing wilderness type land-use situation, along a. free-
flowing river with limited access, to a land-use situation where public
access would be provided to a series of manmade lakes created by the
construction of hydroelectric dams within the river corridor and to
recreation sites within the project area.
Proposed transmission lines and permanent roads would also be
located in areas of existing wild lands or where transportation corri-
dors presently exist.
8.02 Destruction of Archaeological or Historic Sites. At the present
time, no archaeological sites are known to exist within the areas of the
proposed impoundments, damsites, power line routes, or road locations.
Should such sites be located during on-the-ground reconnaissance during
the detailed study phase, measures will be taken to avoid disturbance
where possible. Should they fall within the reservoir pools, salvage
will be undertaken. In the latter event, however, the sites would be
permanently lost to alternative future uses.
One old cabin site, probably related to early mining exploration,
is located at the mouth of Kosina Creek within the Watana reservoir
impoundment area. This site is designated as a historical site by the
Alaska Division of Parks.
8.03 Change in River Use. If the proposed project is developed, the
84-mile portion of the river above the dams would be converted from a
free-flowing river to a series of manmade lakes totaling about 50,000
surface acres. Such development would preclude any consideration for
Wild and Scenic River classification.
The 11 Whitewater'' section of the river through Devil Canyon would be
substantially inundated, as would sections of the river bottom now used
for wildlife habitat.
Downstream the initial 50-mile section of the river would be
changed from an uncontrolled natural river, with very high summer flows
and heavy glacial sedimentation and low winter flows with practically no
sedimentation, to a river with regulated flows and a small amount of
suspended glacial sediment. The 80-mile section of the river between
Talkeetna and Cook Inlet would be affected to a lesser degree because of
major·tributaries.
99
8.04 Construction Activities.
8.04.1 Fuel Requirements. Significant amounts of fuel oils and gasoline
for use in transportation and construction activities related to project
construction would be irretrievably conmitted.
8.04.2 Manpower. Manpower resources during the construction and
operation phases of the project would be irretrievably committed. The
majority of these man-hours would be committed over a 10-year period,
depending on the final development program.
8.04.3 Material. All the material used in project-related construction
would constitute an irretrievable commitment of resources, as this
material would not be available for other uses. Some amounts of material
might be salvaged if the facilities were removed at some later date.
8.04.4 Land. Any land corrunitted to project development such as reser-
voir impoundment areas, damsites, roads, etc., would be unavailable for
other than project-related uses until such time as the facilities were
no 1 anger needed.
100
9. 0 COORDINATION WITH OTHER AGENCIES
9.01 ,General. A public participation program was maintained throughout
the investigation. Coordination with various agencies and groups was
made to provide and to obtain pertinent information, and the following
methods were used: public meetings, workshop meetings, and informal
meetings. ·
9.02 Public Participation Program. A workshop meeting was held in
Anchorage on 30 Apri 1 1974 to discuss the study with interested environ-
mental groups. Representatives of the consultant firm of Jones and
Jones,,which was contracted by the District to conduct an inventory and
evaluation of environmental, esthetic and recreational resources of the
study area, presented and discussed results of their studies. A similar
workshop meeting was held with Federal and State agency representatives
on 29 October 1974, and another was held with Native Corporations on
12 March 1975.
Initial public meetings were held on 6 May 1974 in Fairbanks and
8 May 1974 in Anchorage to notify the public that the study had been
·initiated, and to furnish available information and receive comments.
Several environmental groups stated that they would reserve judgement of
the project until the Draft Environmental Impact Statement was available
for review. Concerns expressed by these groups (the Alaska Center for
the'Environment and the Sierra Club) included impacts upon the future
quality of life in Alaska which would be caused by hydroelectric development.
They also questioned the Alaska Power Administration's projection of
power needs, the examination of alternatives, and the shipping of Alaska's
fossi1 fuels elsewhere. They stressed the need for coordination with
the Alaska Land Use Planning Commission, and suggested public hearings
on the Final Environmental Impact Statement.
Imterim public meetings were held in Anchorage on 27 May 1975 and
Fairbanks on 29 May 1975. Environmental groups represented included the
Alaska Conservation Society, the Sierra Club, and the Alaska Center for
the Environment. Comments of these groups included the opinion that the
project waul d spur more growth, but that nuclear energy was bel i ev,ed not
to be an acceptable energy source at this time. They further recommended
the alternative of burning solid wastes to produce power. They were
troubled by the location of transmission lines, and stated that we may
have a'greater need for hydroelectric power in 50-75 years. They
questioned hydroelectric power as being a renewable resource. Other
concerns included land status of the affected areas, siltation, costs of
power, and the need for considering alternative sources of power. ,
101
Late ~tage public meetings were held in Anchorage on 7 October 1975
and Fairbankson 8 October 1975 to present and discuss the selected
plan. A number of environmental groups were represented at one or both
of these meetings. They included: the Isaac Walton League, the Mountain-
eer·ing Club of Alaska, the Alaska Conservation Society, Knik Kanoers and
Kayakers, and Fairbanks Environmental Center. Comments included the
need forCorps funding for fish and wildlife studies and data processing
of environmental information. Expressed concerns included the inuncjation
of a scenic, white-water river, location of the project area too close
to a proposed Talkeetna State Park, too much human use in the area,
impacts on moose habitat and downstream salmon runs, differences reflected
in the 1960 and 1975 £Ost estimates, the low interest rate used in
computing project benefits, who would operate the dams and sell the
power, reservoir siltation, turbidity, fluctuations in stream flows,
impacts on permafrost, the possibility of earthquakes, the formation of
frazil ice, the geology of the area, benefits claimed for flood control,
the location of transmission corridors and construction of transmission
lines, land status, impacts upon population growth, recreational development,
the production of secondary energy, and others. Most of these group?
voiced either strong opposition to the project or reserved judgement
pending further studies and specific project recommendations.
Many organizations, groups, and individuals expressed support of
the selected plan. An informal poll of people attending the late sta9e
public meetings indicated support for the project by about 5 persons for
each person who opposed. it.
9.03 Letters of comment. Letters received as a result of coordination
of the draft and the revised draft, with responses thereto, have been
attached to this environmental statement.
102
SELECTED BIBLIOGRAPHY
"Devil Canyon Rapids Beaten,n Anchorage Daily Times, March 29, 1973.
Dames & Moore Consulting Engineers. Subsurface Geophys i ca 1 Exp 1 oration
for Proposed Watana Damsite. Anchorage: U.S. Army Corps of
Engineers, Alaska District. 1975
Federal Energy Administration. Project Independence. A main report,
summary, seven task force reports and the Draft Environmental
Impact Statement. 1974
Federa:l Power Commission. Advisory Committee reports, 1974 Alaska
Power Survey (with 1975 update):
Report of the Executive Advisory Committee. December 1974
Economic Analysis and load Projections. May 1974
Resources and Electric Power Generation. May 1974
Coordinated Systems Development and Interconnection. December 1974
Environmental Considerations and Consumer Affairs. May 1974
Geen, Glen H. 11 Ecological Consequences of the Proposed Moran Dam
on the Fraser River,11 Journal of the Fisheries Research Board of
Canada, Vol. 32, No. 1 (Januaryl975).
Jones and Jones. Upper Susitna River, Alaska -An Inventory and
Evaluation of the Environmental Aesthetic and Recreational
Resources. II.~ Army Corps of Engineers.~aska District. 1975
Kellerhals, Rolf, and Don Gill. 11 0bserved and Potential Downstream
Effect of Large Storage Projects in Northern Canada, .. Commission
Internationale Des Grandes Barrages, Onzieme Congres des Grandes
Barrages, Madrid, 1973
Little, A.D. Underground Power Transmission.Report to the Electric
R~search Council. 16 October 1971
Ray, Oix.y Lee, Chairman, U. S. Atomic Energy Commission. A speech
given at 25th Annual AIBS meeting at Arizona State University,
Tempe, Arizona. 17 June 1975
State of Alaska, Department 'bf Fish and Game. Alaska's Wildlife and
Habitat. January 1973
.. Alaska 1973 Catch and Production Commercial Fishery Statistics.
--=st,-. a-:-t-.-'istical Leaflet No. 26 .
----:--. Various letters, review comments and reports.
·1 03.
--~-:-:-An Assessment Study of the Anadromous Fish Populations
~ the Upper Sus itna Watershed Between Devi 1 Canyon and the
Chulitna River, by Bruce M. Barrett. 1974
--.,---Spring 1974 Moose Parturition Counts of the Proposed D~vil
Canyon Dam Area, by Donald Calkins. 1974
State of Alaska, Division of Parks. Heritage Resources Along the
Upper Susitna River. August 1975
State of Alaska, Joint Federal-State Land Use Planning Commission for
Alaska and the University of Alaska. Coordinated by Lidia L.
Selkregg. Alaska Regional Profiles-Southcentral Region. 1974
U.S. Department ,of the Army, Corps of Engineers. Analyzing the
Environmental Impacts of Water Projects. Prepared by Institute
of Water Resources. March 1973
U.S. Department of the Army, Corps of Engineers, North Pacific Division.
A CompendiumQ!!_ the Success of Passage of Small Fish Through
Turbines. May 1967 (out of print}
U.S. Department of the Army, Corps of Engineers, Alaska District.
~Report on the Rampart Canyon Project, Yukon Basin, Alaska. 1971
-~=----=---Offshore Oil and Gas Development i!!_ Cook Inlet, Alaska -
Environmental Impact Statement. September 1974
---==---Southcentral Railbelt Area, Alaska, Interim Feasibility
Report -Hydroelectric Power and Related Purposes for the Upper Susitna
River Basin, with technical appendices. December 1975
U.S. Department pf Commerce, National Marine Fisheries Service. A
Hydrologica,l Reconnaissance of the Susitna River Below Devil
Canyon Dam. October 1974
U.S. Department of the Interior. Alaska Natural Resources and the '--'--'--~=-.:...:..:..;....:_"---..::.-.:... -'-'-'-----'-----Rampart Project. June 1967
----,r.---..,... Alaska Power Administration. Devil Canyon Status Report.
May 1974
Cultura:l Al~ska ~ower Administration. Supplementary Information Concerning
and H1stoncal Resourc~s. A supplement to In~erim Feasibility Report,
Electric Power, Southcentral Ra1lbelt Area Alaska, Upper Susitna River Basin,
Appendix l, Part 2. Juneau, Alaska: Alaska Power Administration. June 1976
-:::----,-~--=-Bureau ?f Land Management: ~ultimodel Transportation and Uti 1 ity
Corridor Systems 1n Alaska -A Prel1m1nary Conceptual Analysis. October 1974
. 104 .
--....,----Bureau of Reclamation.. Potential Development of Water
Resources in the Susitna River Basin of Alaska. August 1952
---::::---'--;-Bureau of Reclamation .. Feasibil Hy Report. Devil Canyon
Project, Alaska. March 1961
---..----Bureau of Reclamation. Engineering Geology of the Vee.
Canyon Damsite. November 1962
'----..---::=-Fish and Wi 1 dl ife Service. Survey of the Peregrine Falcon
and Other Raptors in the Proposed Susitna River Reservoir Impoundment
Areas.
Fish and Wildlife Service, Bureau of Sport Fisheries and
Wildlife. Threatened Wildlife of the United States Resource
Publication No. 114. Washington: --,-g-73
---::;-----:;-Geological Survey. Water Resources Data for Alaska, Water-
Supply Papers. Washington: 1950 through 1974-
--...,...,....--..,--:-National Park Service National Register of Historic Places
Washington: 1975
Various Fish and Wildlife Service letters, review comments and -----reports.
105
t
I
~
I
ECONOMIC DATA EXTRACTED FROM
U.S. ARMY CORPS OF ENGINEERS INTERIM FEASIBILITY REPORT
COMPLETE DOCUMENT IS AVAILABLE AT U.S. ARMY
. ENGINEER DISTRICT,. ANCHORAGE, ALASKA
Estimated First Cost (Includes Non .. Federal Recreation)
Estimated Value of Public Domain (Land transferred
without Cost)
Average Annual Cost
Average Annual Benefits
Power (Includes Transmission Line Intertie)
Recreation
Flood Contra l
Area Redevelopment
Net Annual Benefits
Benefit to Cost Ratio
106
$1,520.000,000
$ 11 ,800,000
$ 104,020,000
$ 137,876,000
$ 128,153,000
$ 300,000
$ 50,000
$ 9,373,000
$ 33,856,000
1. 3 to 1
PROPOSED TRANSMISSION LINE CORRIDOR
(Photos courtesy of Alaska Power Administration)
I
Lower Susitna River Valley. This area is charac-
terized by extensive muskegs, intermingled with
bottomland spruce-poplar forests. Permafrost is
absent or discontinuous in this area, although the
soils are generally poorly drained.
-----
Susitna River Valley. Lakes are prevalent and assoc-
iated with muskegs, which succeed them in formation.
Muskegs are succeeded in turn by forests dependent
upon well-drained soils. The three stages of success-
ion are shown here.
\
)
Tm~ of Talkeetna. This town is at the confluence of the Talkeetna,
Susitna, and Chulitna Rivers. The Alaska Railroad can be seen cross-
ing the Talkeetna River near the right edge of the picture.
)
Near Honolulu on the Anchorage-Fairbanks Highway. Biomes shown on
low brush muskeg in foregrotmd and upland spruce-hardwood in back-
ground. Black spruce in foreground are associated with poorly drain-
ed soils and/or shallow permafrost tables.
Alaska Range from Anchorage-Fairbanks Highway near Broad Pass, late
spring. Vegetation biome is lowland spruce-hardwood. Soils here are
basically glacial deposits.
)
Looking south along Nenana River to Upper Nenana
Canyon. The Anchorage-Fairbanks Highway parallels
the left bank. Motmt McKinley National Park and
the Alaska Railroad are on the right bank of the
river.
Very restricted canyon along Nenana River north
of HcKinley Park. Alaska Railroad is off left-
hand edge of photo. Land left of river is
within Mount :McKinley National Park.
111e Tanana River flood plain. This area is extreme-
ly flat and poorly drained. 1hrce types of biome
are represented in this picture: muskeg, lowland
spruce-harmvood, and bottow~and spruce-poplar. The
dark forests are mainly black spruce. The sinuous
lighter forest is white spruce, aspen and birch.
This forest type prefers well-drained soils, and
so is found on old levees of existing and extinct
channels.
DISTRICT REVIEW
LETTERS RECEIVED BY THE DISTRICT ENGINEER
ON THE
DRAFT ENVIRONMENTAL STATEMENT
AND RESPONSES THERETO
• 1 07 •
FEDERAL COMMENTS AND RESPONSES
U.:S. IDe:p.artment of Agriculture
Soil Conservation Service
U.S. Bepartment of Interior
Aa,aska .Hower At!lmintstrati on
Fish and :Wildlife Service
Ge.nl:o§ tea 1. :Survey
;Bureau of lndi:an Affairs
Bure.au of Land Na.nagement
National Park Service -Anchorage
. N.ati.llnal Park Service -Seattle
Bureau ·of Dutdo~or Recreation
.u.s. Department ·of Commerce
Na tion.al Weather Service
· National Qcean Survey
Nath::mal 1Mirri·ne Fi shedes Service
U.S. Bepartme'nt of .Housing and Urban Development
U.S. Department of Transportation
Fe!;Ieral .:Aviation Administration
Feder.a1 Highway Administra·tion
Urnited States Coast Guard
Department of the Army
.Cold Regi•tms Research and Engineering Laboratory
U.S. Environmental Protection Agency
Federa 1 P.ower Gon:uni ss ion
108
· .C!ll.mments
1-4
14·..;:21
25...,35
.3£)~40
141
112-78
19-90
91..;94
.95-'97
5
6
7-12
13
:22-24
.22~24
98-100
101
'102-.103
104-108
109
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
204 East 5th Avenue, Room 217, Anchorage, Alaska 99501
Charles A. Debelius
Colonel, Corps of Engineers
District Engineer
Alaska District, Corps of Engineers
P. 0. Box.7002
Anchorage, Alaska ~9510
Dear Colon~l Debelius:
December 2, 1975
.We have reviewed the draft en.vironmental impact statement, "Hydroelectric
Power Development, Upper Susitna River Basin, Southcentral Railbelt Area,
Alaska." We offer the>fOllowing comments for your consideration: This
represents all conments of the Soil Conservation Service ..
GENERAL COMMENTS
The statement represents considerable effort 1~ the assembly of available
data and in effective presentation of pertinent facts throughout the re-
port. The statement appears to appraise impacts adequately for a feas-
ability !,tage study. We have previously reviewed and conmented on the
environmental assessment of the transmission line proposal that is an
integral part of this proposal.
SPECIFIC COMMENTS
The caption of the second photo, implying that well drained soils succeed ~·
The. statement contains no information on soils involved with the proposal, I
except for some brief statements in the captions at the end ,of the volume.
muskegs, is erroneous. The absence of soils information at ~he dam site
or in the transmission corridors is a serious. deficiency of the statement.
In the discussion of aesthetics, mention is given to landsca'pe management ~-
3 practices being considered. It is suggested that following construction,
consideration be given to mitigating unpleasant aesthetic re·sults by planned
use (landscaping} of adaptive plant species. The ,.Vegetative Guide for
Alaska", attached, may be of value to you.
·This discussion of 11 adverse environmental eff,ects which cannot be avoided .. '
notes the need for temporary and permanent facilities for project workers.
We.suggest that a soil survey, and the interpretations therein should be
useful in locating facilities on suitable soils.
~
109
--~-A-----·---
4
Charles A. Debel ius
12-2-75
We a'pprec.iate the opportunity to comment.
Sincerely, / ~e:. ' :7/y>~"'l/fy/:£7
Weymeth E. Long (
State Conservationist
enclosure
cc: Council on Environmental Quality (5 copies)
Office of Coordilla'tor of Environmental Quality Activities
R. M. Davis,·Administrator, SCS, Washington, D. C.
K. L Wi 11 iams, Director, WTSC, SCS, Portland, Oregon
District Conservationist, SCS, Fairbanks, Alaska
2
1 Comment noted.
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
2 Comment noted. Detailed soils information at the damsite and·
in the transmission corridors is not presently available. Such
studies would be the subject of future investigations required
for facilities siting, construction techniques, etc. The SCS
letter was received too late to change the referenced photo cap~
tion, since that portion of the EIS had already gone through final
pr·inting. However, the statement that 11 muskegs are succeeded
in turn by forests dependent upon well-drained soils 11 is acknowl-
edged as an error. Obviously, muskeg areas do not rapidly, if
ever~ evolve into well-drained soilsi. They may, however, eventually
support water-tolerant tree species.
3 Concur. Unavoidable construction scars related to project features,
such as roads and borrow areas, will be rehabilitated, including
dressing with topsoil and appropriat~ landscaping and vegetative
planting. The Soil Conservation Service will be consulted with
regard to these efforts.
4 Concur. Temporary and permanent facilities will be designed and
located with a view to aesthetics, erodibility of soils, and other
relevant factors.
111
November 25, 1975
Colonel A. Debelius
UNITED STATES DEPARTMENT OF COMMERCE ·~t.
The Assistant Secretary for Science and Technology
Washington, D.C. 20230
District Engineer -Alaska District
Corps of Engineers
U. S. Department of the Army
P. O. 7002
Anchorage, Alaska 99510
Dear Colonel Debelius:
This is in reference to your draft environmental impact .
statement. end .. tled "Hydroelectric Power Development, Upper
Susitna River Basin, Southcentral Railbelt Area, Alaska".
In opder to expedite transmittal of the enclosed cormnents
·from the National Oceanic and Atmospheric Administration,
we are sending them to you as they were received in this
office.
Thank ;youfqr g1.v1.ng us an opportunity to provide these
cornrne.n:ts, which we hope will be of assistance to you .. We
would appreciate receiving eight (8) copies of the final
statement.
Sincerely,
rd~a~~
Deputy Assistant Secretary
for Environmental Affairs
Enclosures: Memo from NOAA -National Marine Fisheries Servic·e
Memo from NOAA -National Ocean Survey
Memo from NOAA -National Weather Service
11.2
Date
To
From
Subject:
U.S .. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL WEATHER SERVICE
Silver Spring, Md. 20910
Reply to Attn. of:
Dr. William Aron
Director, Office of Ecology and Environmental Conservation (EE)
Ortilii·;f\L SlGf~ED BY
Dr. George P. Cressman R. £. 1-li\LlGREN.
,Director, National Weather Service (W)
DEIS 7509.61 ~ Upper Susitna River Basin, Alaska
The plan proposes the construction of dams and power plants on
the upper SUSITNA River. The operation of these facilities will
impact upon the public river and flood forecast warning service
provided by the National Weather Service in this basin. These
services emanate fr~n NWS offices at Anchorage and Fairbanks as
described in the enclosures. This should be made a part of the
EIS.
'Encl.
113
W2x2/A'E
5
I
I.
I
lle:l ther S~r·1 icc S t~ t;;.'!r.ent on Fl cod U.arni nl] ?rog dun
· ·rn~ ,':ational Oc!!anic end: At!ilasp~le:-ic Ad~inistration (t:O;\.~) National l·:eathe;-
S~r·:'ice pro•tic2s f1co.:J foreci!Stir:c;. s~·r·:i..:~ fer majn:--dve·~ basins. This
syitf!.n i~v::lh2; prcd icti0;;::; ~_,; .:!ntiC'ip.lt2.J st.19.:~ <lt il p;:rticuler ~!~~~ cr.
S3£:~s .in th;.! L~~!s·in. 1'f:.::5e fa:·~~r;.Jsts.(~~·c· b:~';:!d nn oJ~~·r·;c-=d ·~';-t~c"ip·it~tia;t
=-r.rf ~.&..;"11.--,-:"1•-':'1,_ ••n-!---t-~·~·";"1 -.,""'1.:(:\.,"" ,...,..; •''"~""·.;-; ... ,;,•··-li ,~~":ti.\>!.,f.?:":\r cc·--:•:·J--':'.0,.,,.. ··~· ._·,,r.•. c ..... ..:~' ... t~ ... \.,-., "'·-.... ; .. .,::,. ..... ~ ........ ~~~· .• ... ::,_ -•·L! ................. ~J-""'-··· ,,.._ ... !1,.. •• •... ..J.~.:.a. ........ _ ·•.::... •ri.e :: l'C:J:d·
fcrecust is transmitted to City officials~ n~H5pcpers» 2nd redio and tele-
. visi.on stC!tio:1s ·;r. the bJsir:~ These media clisset:iin~te the infc:--mation to
residents of the.flood pli!in in the form of a flocd Harning. This tim~ly
fc;~~~:rn~r;g _p:rmits PCO~ectiv~ n:c~sures to ~e·~n~ertak2n_ by industrial plcu:ts~
puoi1C·ut.ll1tle5, l'iiUn1clpal.o•flclals, and 1ndi't1duals ~nth prc;Je'i""ty in the
lo•,.,lar.ds.. Services available are of th~ 'fol im.,.ing typ~s: . .
~ .: . .
l.
.:•
Fla,srr Flood: . The responsible Heath~:-Service Forecast Office
su~plies \'/cath2r forecJsts blic~ daily fc:-the State. In additicn
tot::.:! routin~ forcCJ$tS~ special forecast~ of severe storms and
geri<e,.al flash flood \'latches for sr.rall streams ·are issued as required ..
USR:-57 Heather Radar· installations have capability for ir:::n~iate ·
de~ction and evaluation of rainfall intensity,. location,. and stern
tna 1i~1lent ... Informat.ion is pro~ptly relayed by teletypa·circui'ts· and
tel~phone to ne\'iS media and ccr.;mur.ity officials and Ja~.; enforcement ,
age~cies. Ilia-.Heather Service Office··.issues Flash F1 cod Harnir:gs :as
reqJired foJ7 sm~1l streams in its area of responsibility. . , · · ·
• ~tT . .. . . · .
2. · Naj'br Floods: River stage forecasts are based on radar coverage,.
rep.orts frcm river and rainfall reporting .stations and telemetry in
.o·r nearJthe basin'. : .. The River Fm·ec;:4!:tt ,Centers ~re staffed \•lith
.· professional hydrologists responsible for· the preparation of river.
.'forecasts based 'on \·later equivalent of sr.9~.., co•Je·r~ rainfa11-·runoff
relations, stream flo•,., routing,. and a \·IOrbng ~nmo~l edge of anticipated
. \·Jeathe·:-cond,i.tions. The lead time bet·t~~en distribution of. the fore-
.··. casts and the flood crest may be srlO·.-t; ho·,·tever, lead time normally
ranges from 12 hours for rainfall and up·to several \·:e.el<s for snohr.lelt.
Specific crest forecasts are issued as required. River District
Offices. are respansi bl e for the interpretation and di stributioli of
. · flood f.oreca sts and the opera ti on., .. of the hydrologic reporting sub-
. ·.station neb10rk in its area of respon'sibility. . ·· · .
......
3. Hydrocl i~atic Data: f·~ost of ~he data. f·rai11 the netw~rk is published.
·These r2cords provide the bas1s for. forecasts as \·Jell as for the .
plar.n~~~ and des{gn of protective \·:arks and their o'perat1on during
floo~s-·River. and flood forecasting is fur.dam~ntal i'n the design.
and esse:-:tia 1 in tht? operation of a l_evee or-res.ervoi r system.
114
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF COMMERCE
NATIONAL WtATHER SERVICE
~Comments of Or. George P. Cressman, Director of the National
Weather Service, are acknowledged. As suggested, the Weather
Service Statement on Flood Warning Program, as appended to Or.
Cressman's letter, is reproduced in the EIS.
115
6
OCT 311975
TO:
FROM:
Dr. William Aron
Director
Office of Ecology and Environmental Conservation
Dr. Gordon L 111 (signed) GOR
Deputy Director DON LILL
National Ocean Survey
SUBJECT: DEIS #7509.61 -Upper Susitna River Basin South Central
Railbelt Area, Alaska
The subject statement has been reviewed w1th1n the areas of NOS
responsibility and expertise, and in terms of the impact of the
proposed action on NOS activities and projects.
The following comment is offered for your consideration.
Geodetic control survey monuments may be located in the proposed
transmission line routes. If there is any planned activity which
will' disturb or destroy these monuments, NOS requires not less
than 90 days notification in advance of such activity in order to
plan for their relocation. NOS recommends that funding for this
project includes the cost of any relocation required for these
monuments.
C52/JLR
~ ..
i-
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF COMMERCE
NATIONAL OCEAN SURVEY
f>· We concur. Every effort will be made to avoid disturbing geodetic
control survey monuments in locating the proposed transmission
lines. In the event that disturbance is unavoidable, the N~tional
Ocean Survey will be given at least 90 days advance notice, and
costs of relocation will be borne at project expense.
1.1.7
November 19, 1975
Colonel Charles A. Oebelius
District Engineer
U.S. DEPARTM'ENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
P. 0. BOX 1668 -JUNEAU, ALASKA 99801
Alaska District, Corps of Engineers
P. 0. Box 7002
Anchorage, Alaska 99510
Dear Colonel Debelius:
The National Marine Fisheries Service has reviewed the draft environ-
mental impact statement for 11 Hydroelectric Power Development, Upper
Susitna River Basin, Southcentral Railbelt Area, Alaska.11
In order to provide as timely a response to your request for c0fl111ents as
poss'ible, we are submitting the enclosed comments to you directly, in
parallel with their transmittal to the Department of Commerce for incor-
poration "in the Departmental response. These comments represent the
views of the National Marine Fisheries Service. The formal, consolidated
views of the Department should reach you shortly.
Sincerely,
Jl_;c; ;lid~
/ Harry L. Ri etze · r Director, Alaska Region
Enclosure
118
U.s. OJ'Ek<a<~Ufi'MENr CF C!J~MERCE
Na'!;iar.a~ O~sanic 11nd. A:moapharlc Administration
National Marine Fisheries Service
P. 0. Box 1668 3 Juneau~ Alaska 99802
Date November 19, 1975 Reply to Attn. of: FAK/RJM/
To : Director, Office of Ecology & Environmental Conservation, EE
Thru: Associate Director for/)ReTour7' Man,agement, F3
From fl~arry L. Rietze g..~d/ H~ T Director, Alaska Region
Subject: Comments on Draft Environmental Impact Statement--Hydroelectric Power
Development-Upper Susitna River Basin, Southcentral Railbelt Area,
Alaska. Corps of Engineers DEIS #7509.61
The draft. environmental impact statement for Hydroelectric Power
Development, Upper Susitna River Basin, Southcentral Railbelt Area,
Alaska, that accompanied your memorandum of September 30, 1975, has
been received by the National Marine Fisheries Service for review and
comment.
The statement has been reviewed and the following comments are offered
for your consideration:
General Comments
It is estimated that approximately 3,300,000 salmon, which include all
five Pacific species, are produced in the Susitna River for the Alaska
commercial catch. Based on 1975 prices, the annual value to fishermen
would be nearly $9,000,000. 1/ It should be noted that the Southcentral
Railbelt Area plays a significant role in the recreational activities of
the resident and tourist fishing industry. Presently, there is no data
available on salmon recreational fishery values accruable to the
Susitna River. However, we would expect this value to increase
proportionately to projected increases in population and tourism in the
project area.
As outlined by the Alaska Department of Fish and Game at recent public
meetings regarding the DEIS, much of the information needed to make a
systems analysis of the living resources of the river environment has
never been collected. We believe it would be imprudent to make any
objective comments regarding the fishery aspects within the various
sections of the DEIS, because of the lack of any substantial data on
which to base our conclusions and because inventories and evaluations
are still being conducted by resource agencies.
l.f U.S. Fish and Wildlife Service. 1975. Southcentral Railbelt Area
Upper Susitna River Basin Hydroelectric Project Two Dam Plan.
U.S. Department of the Interior. October 1975. 28 pp.
' 1i9
I~
;,
8
Specific Comments
4.0
4~02
Environmental Impacts of the Proposed Action
Fish
I Page 49, paragraph 7. We believe the collection of one field season~ s
9 data is not sufficiently definitive to make any a.ssu. mpt.ions . regarding ..
the relationships between salmon spawning and rearing sloughs and any
regulated flows within the proposed project.
10
Page 49, paragraph 8. The statement regarding the elimination of
salmon egg destruction should be qualified by noting that it is based
on an inconclusive single-year observation. J:.../ ·
Page 50, paragraph 1. The statement regarding salmon disorientation by
initial project startup should be expanded to include the effects of
project construction. Water quality degradation, diversion, etc., would
all serve to confuse salmon returning to their natural spawning areas.
I Page 50, last paragraph. This paragraph should be written to qualify
the status of future fisheries studies noted. The Corps of Engineers
1,.:,1 has n. o assu.ran~e. that ~ny t:'roposed fish and w~ldlif: studies wi:l be
· funded or carr~ed out ~n t~me to be of value ~n mak~ng any feas~ble
project modifications.
6.0 Alternatives to the Proposed Action
6.02 Alternative So.urces of Power
6.02.3 Oil and Natural Gas
· Page 72. Because the proposed El Paso Alaska natural gas line could be
. ·.~constructed to bring fuel from the known Prudhoe Bay field to the . · ·1 ~· Anchora. ge-Fairbanks area, it should be given consideration as a possible
alternative source of power.
We would appreciate receiving two copies of the final environmental'
impact statement.
'!:.I Barrett, Bruce M. 1974. An Assessment of the Anadromous Fish
Population~ in the Upper Susitna River Watershed Between Devil
Canyon and the Chulitna River. Alaska Department of Fish and
Game,. Division of Commercial Fisheries, Anchorage. November 1974.
56 pp.
lZO
-/ '
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF COMMERCE
NATIONAL MARINE FISHERIES SERVICE
,. I -Comment noted.
tJThe need for additional environmental data to make an objective
analysis of the proposed projects is a recognized concern of the
Corps. During the post-authorization phase, environmental studies
will be made to obtain the needed data to develop both design and
mitigation measures to minimize or delete the chances of environ-
mental impact. The preliminary data presently available is a
basis for identify·ing areas of concern that need detailed analysis.
As post-authorization studies proceed, supplements to the statement
will be prepared and coordinated.
!'J Noted .
.iti Water quality degradation during construction would be limited to
possible increase in turbidity. However, this condition would only
be minor since the runoff in ~hose areas that would produce turbid
conditions will be diverted 'into settling basins prior to returning
to the river. During construction natural river flows will be
diverted around the construction area above any known spawning
areas and would have no impact on downstream fish populations. At
the time of initial storage, the fish and wildlife agencies will
be requested to furnish necessary flow releases to prevent any
downstream impacts.
~1. Future studies identified in referenced paragraph are those that
would be considered if congressional authorization is received
for the proposed project. These studies would be accomplished
during the post-authorization and design phases of the projects.
No assurances can be given at this time that these studies would be
funded since funding will be dependent upon congressional appro-
priations;
~~;The proposed new natural gas pipeline from the Prudhoe Bay field,
although not specifically identified in the alternative discussion
of Oil and Gas, was taken into consideration when this alternative
was investigated.
REGION X
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
SEATTLE, WASHINGTON 98101
Office of Community
Planning & Development
IN REPLY REI
Charles A. Debelius
Colonel, Corps of Engineers
Alaska District Corps of Engineers
PO Box 7002
Mchoiage, AK 99510
Dear Colonel Debelius:
Subject: Draft Environmental Impact Statement
lOD
Hydroelectric Power Development, Upper Susitna River Basin
We have reviewed the draft statement submitted with your september
22, 1975 letter requesting comments within 45 days.
The propOSed action is to construct dams on the upper Susitna River
at Watana and Devil Canyons, power plans, transmission facilities,
access roads, and operating and recreational facilities.
I At this point we do not see any significant impact in our areas of 13 . concern. As plans develop, we would like to be kept up on possible
changes in population projections and related.housing and community
facilities needs. Your plans appear to be consistent with the
Alaska water Study Connnittee' s assumptions that there would be
initial and continued hydropower development in the Susitna River
Basin. Since both our agencies as well as the State, is represented
on this Committee, there should be no problem in adequately coordinating
water related project plans.
Thanks for the opportunity to review your statement.
Since. re~. y, . £· /~ ,.-11). ' /,~~~Ac~~~
I . :kf~. ~ii~
ssistant Regional Administrator
J.2Z
.~.
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
i3 Comment noted.
United States Department of the Interior
ALASKA POWER ADMINISTRATION
P. O, B.OX 50
JUNEAU, ALASKA 99802
IN REPLY REFeR TO:
December 1, 1975
14
15
16
700
Colonel Charles Debelius
District Engineer
Corps of Engineers
Box 7002
Anchorage, AK 99510
Dear Colonel Debelius:
The Interior Department, Office of Environmental Project Review, requested
that we furnish you comments on your draft EIS , "Hydroelectric Develop-
ment, Upper Susitna River Basin, Southcentral Railbelt Area, Alaska. n
General Comments
We believe the draft statement does not provide adequate information on
the proposed project transmission system, and impacts, alternatives
considered, and measures to mitigate potential adverse impacts of the
transmission system. Such material could be included by extract or by
appropriate reference to the Alaska Power Administration's Environ-
mental Assessment of the project transmission system.
I The statement includes a list of references cited, but for the most part,
the text of the statement does not indicate sources of data. We believe
a more complete citation of data sources is needed.
We believe the draft substantially overstates potential adverse impacts
of the identified upstream dam and reservoir sites at Vee and Denali
(see, for example, the 1965 report of the Fish and Wildlife Service,
11 A Detailed Report on the Fish and Wildlife Resources Affected by the
Vee Project, Alaska"). We believe it is very likely that a full development
of the Upper Susitna River hydroelectric potential, including one or both
of the upstream reservoirs, would result in significantly less adverse
environmental impacts than would development of available alternatives
outside the Susitna basin.
t24
Save Energy and You Serve A me rica!
~--·
2
If the Corps 1 proposed development plan is authorized (Devil Canyon
and Watana) , we believe it is probable that the Denali Darn would
receive further consideration as a potential additional development. The
data generated in your current studies indicates additional reservoir
capacity would be beneficial; we feel this is particularly significant in
view of very heavy winter energy demands in the Railbelt. We believe
this matter should be discussed in the final statement.
Specific Comments
These are referenced to section numbers in the draft EIS.
1.03; >Description of Action. Suggest including a concise description
of actions involved in constructing and operating the transmission system
(clearing, access , towers, lines, substations, maintenance) .
2. 02. 2. 2. Raptors. The Fish and Wildlife Service made aerial surveys to
determine relationships of the proposed transmission facilities to raptors.
The data should be referenced in the EIS. The attached letter of July 14,
1975, from Dr; Clayton R. White discusses findings.
2.03.6. Archeological Resources. Based on informal consultation with
the Alaska Division of Parks on the transmission corridor studies, we
understand that there are known and potential archeological and histori-
cal sites along the proposed transmission corridors. To avoid possible
disturbance, these sites cannot be identified in the project reports. We
believe the project report and EIS should recognize needs for pre-con-
struction archeological surveys under applicable regulations.
4.03. Wildlife. We believe that experience with the existing Healy to
Fairbanks transmission line, and CEA and AP A lines in the lower Susitna
Valley and Anchorage-Palmer areas is pertinent with respect to potential
impacts on caribou and waterfowl. We are not aware of any experienced
or alleged problems with caribou on the Healy-Fairbanks line. Similarly,
the existing lines in the Cook Inlet area have apparently not caused
significant problems for migrating birds.
6.02.11. Hydropower. The referenced 1948 report of the Bureau of
Reclamation was but one of the early evaluations of Alaska hydro potential.
Subsequent studies, including the Statewide Inventory published in the
1969 and 1974 Alaska Power Survey reports, and the June 1967 Interior
Department report, "Alaska Natural Resources and the Rampart Project,11
provide a great deal of further definition. of these resources.
20
21
3
We believe these more recent studies should be referenced as the basis
for selecting the Upper Susitna project as the most desirable near-future
major hydro project for the Railbelt. The existing data are adequate to
. demonstrate that the very large alternatives such as Rampart andWood
Canyo:n would involve greater environmental problems. An alternative
plan to replace Susitna with equivalent power supplies from other poten-'··
tial hydro projects would require developing several projects in different
basins with attendant impacts.
6.04. 5. Devil Canyon-Denali, and 6. 04.6., Three-Dam System. We do
not concur in the statements that economic feasibility is lacki:ng for these
plans, since we believe this finding is premised on unreasonably conser-
vative evaluations of costs involved in the Denali Dam. As indicated i:n
the "General Corotnents, 11 we believe the Denali Dam may ultimately prove
to be a desirable future addition to the proposed Watana-Denali Canyon
, Pli:lllt considering need for winter energy, environmental aspects, and
availa;ble alternatives.
EnClosure
Sincerely yours,
Robert J. Cross
Acting Administrator
cc: Office of Environmental Project Review
1875 ·Brigham Young University Centennial·1975
July 14, 1975
Mr. Melvin Monson
U. S. Fish and Wildlife Service
813 "D" Street
Anchorage, Alaska 99501
Dear Melvin:
I am sending this brief letter for your use in discussion with the
Alaska Power Administration concerning the proposed Susitna Dam Site and
associated Power transmission lines. A full report will be sent to you
which will include the entire surmner's findings. This~ however, will
require some time to complete and I am desirous of you and the power
administration receiving the following information as early as possible.
We use both helicopter and fixed wing (helio) to search for falcons.
The transmission lines that form the basic figure 8 configuration of the
Alaska-Fairpanks, Fairbanks-Big Delta~ Big Delta-Anchorage, Denali
Highway were investigated. These routes basically parallel existing
highways.
Within this area there is considerable habitat for cliff nesting
raptors. However, as I indicated in my 1974 interim report to Fish and
Wildlife Service~ I found no nesting Peregrine Falcons within the confines
of any of the 4 proposed dam sites. Historically there may have been
Peregrines there~ but in the year of the survey none was found. The
transmission routes also traverse areas that look excellent for Peregrine
Falcons, however, the only area of concern at the moment, as regards
Peregrines, would be that portion of the proposed transmission line
route which basically parallels the highway and Tanana River from Fairbanks
to Big Delta. There are several historical Peregrine sites along ·":he ·
Tanana River and Sulcha River.
One should be mindful, however that aside from the Peregrine~ the
Gyrfalcon is also found in limited nUmbers within that portion of Alaska
and because of its overall restricted range in the Arctic, one should be
cautious of this species. Several nesting pairs are found from Sum~it
Lake region to the D~nali Highway region, thence, north along the
Anchorage-Fairbanks Highway in the area of the Healy-Cantwell region.
To produce least impact in terms of raptors, the transmission lines.
should probably be placed along the south side of the Denali Highway and
the west side of the new Fairbanks-Anchorage Highw~y. ,
127
Department of Zoology, 575 WIDB, Brigham Young University, Provo. Utah 84602
(B01} 374-1211, Extension 2006
a~w·-
Mr. Melvin Monson
Page Two
July 14, 1975
The·only conceivable-area, then, of impact with the Peregrine
Falcon would be that part of the transmission route from Fairbanks to
Big Delta, thence, south along the Big Delta region to about Summit
Lake. In this region no recent Peregrine Falcon nestings (since 1972)
have been made. The Peregrine is indeed in trouble in this region.
Further impact can be avoided by perhaps running the transmission lines
across the flats south of the Fairbanks-Big Delta Highway keeping,
perhaps, 2 to 3 lines away from the Tanana River. ·
Hopefully J these data will .suffice until the entire report can be
submitted to you.
mp
Si;:L tv4
Cl~:~White, Ph.D.
Associate Professor of Zoology
~-.
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF THE INTERIOR
ALASKA POWER ADMINISTRATION
14 The portion on alternative transmission systems has been expanded.
The cooperation of APA in evaluating potential hydroelectric
facilities on the Upper Susitna River has been extremely helpful.
The environmental assessment of transmission facilities has been
used as a supporting document in compiling the EIS and has been
incorporated into the Appendix of the techn i ca 1 feasibility report.
15 The Selected Bibliography has been expanded to list sources not.
previously cited as well as additional sources utilized in revi.sing
the document.
16 The environmental impacts stated for the upstream damsites are in
relation to those in the lower portion of the basin. But when
compared to impacts of hydroelectric alternatives outside the basin,
i.e., Rampart and ~Jood Canyon, they are significantly less overall.
17 The alternative three-dam scheme does show a net benefit, but
· under an incremental analysis the third dam add-on is not economi.-
cally viable at this time.
l8comment noted ..
19 Comment noted. Referred letter is included in the EIS as an
attachment to APA's letter.
2 0 Comments noted.
21 Comment noted. See response number 17.
129
22
23
24
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
OCT 3 0 1975
Colonel Charles A. Debelius
District Engineer
Department of the Army
Alaska District Corp of Engineers
P. 0. Box 7002
Anchorage, AK 99510
Dear Colonel Debelius:
ALASKAN REGION
632 SIXTH AVENUE
ANCHORAGE, ALASKA 99501
TELEPHONE 272-5561
We have completed our review of the draft EIS on the Hydroelectric Power
Development for the Upper Susitna River Basin South.central Railbelt Area.
The following comments are offered for your consideration as you prepare
your final EIS.
I.
We recommend using the word "airplane" in place of the term "bush plane"
as it is used in paragraph 2.03.3.3 Air. The term may be misleading or
confusing since many of the locations that are only accessible by air
are served by large jet aircraft.
Section 2.0 Environmental Setting without the Project, covers the existing
Air Transportation in paragraph 2.03.3.3 Air. Section 4.0 Environmental
Impact of the Proposed Action, makes no mention of any aviation impact
related to the project. As a minimum, the potential impact of the heli-
copter construction mentioned in paragraph 4.10 Roads should be covered.
Also, we have noted that on other construction projects, even when there
is road access, there has been a tendency to provide helipads or landing
strips for air evacuation of injured workers or the convenience of ·
reduced travel time. If these aspects have been reviewed, it appears
that Section 4.0 would be enhanced by including some comment on the poten-
tial for impact or the lack of it from air operations.
Thank you for the opportunity to review and comment on your draft EIS.
Sincerely,
RESPONSE TO COMMENTS BY
U.S. DEPARTt~ENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
ALASKAN REGION
~~;~ The suggested change has been made in the appropriate section in
the Statement.
~~~J. Section 4.10 has been revised to indicate that any helipads constructed
would be of a temporary nature and would be rehabilitated when no
longer needed.
i.;.,'i Section 4.10 has been revised to discuss the need for facilities to
provide for air evacuation of injured personnel.
i3.1
----·------------·-·-· = ---
25
United States Department of the Interior
FISH AND WILDLIFE SERVICE
ALASKA AREA OFFICE
8130 STREET
ANCHORAGE, ALASKA 99501
Colonf'l Chnrle-s II. Dchel i.1!S
District En~ineer, Cor~s of En~ineers
Alrsl~11 Pistr.ict
P. 0. Box 700?.
!lnchora.~e, ArC 99510
PeAr Colonel Po:>heli.11s:
nov 1-~ ·~7 s
Upper Susi tna !T)•clroelec,trtc>
Power Development ER 75/9l~2
NPAEN-PR-EN
The AJ n.r>1 ~i"1 /\rP.rt n f the U. S. Fi. sh :tnn l·li.l.rlli ft Ser.vi ce hns the fo llo~rin~
comnents to offer on this environmental statement.
He re"ret tht1t ther-e \·ms no n:eneral di.scussion inclwler! on nossible r".iti?aUn~
measures to he emnloyed in the ~r.oject. He understa.nrl that cletailed studies
unnertn~<en hy the Cnr!JS lnter in the nt1thor:i.zati.on flroress will nrovirle the
h::uH~s on Hhir.h mitin:::!tin"' T"1"!.1S1lres \-Till hC! {\evC'loperl; however, fl .ro;enl"l"nl
011tlin~ of po~<:ihle mn~linrntiw• rnensurc-<: nt this !Joint \•ronln l~e i.nforrnlltiv('.
1,o<J'1 0f h-1h)t.11t, for er.n"'ple, l"l:,.,_ht he miti~,1ted hy ::!cr:uisition or fl't."OtP.r.tion
of rdni lnr. Arr~n~e C'l~e,·rhere. !lntic.f.pntcn he:wy use hy recreAtion-! sts rni~ht
he ~ll f'Vi :\ted h;t plnd.n~ nccess ro,1rls so RS to di scoura~e ~mch tJse or hy
ORV r.e;r11latfons enforced hy the Lmd-mnna~in?. n~cnr.y. J\.n outU.ne presentation
S\lr.h n!; thi.s '·TI'Hllrl clenrly {lemon~trnt.l:' the foreth011~ht ~iven thi.s suhject by
tl1e r:orps ~ri. thout ret1uirin3 clctai.l '-rhich is unavn:l.lahle yet.
26
~1e nre plf'l'l.SI'cl to note that r.ons:i.rleration will be r,ivcn to improvin~ fish
access to and from some of the sloughs and tributnries dmmstream from
Devil Canyon • We arc also 'pleased that the results of onr.oing studies
under the direction of the Fish and Wildlife Service will be used dorinr,
the final desi.P:n phn.sc studies for feasible project modification and
mitir;ati.n~ measures.·
SPECIFIC
Sttll1'1l.:trv, 3B nnrt pa::-:e 53, parll. 3 .,. the present document tenrls to minimize
impacts to moose habitat. Especially on paJ1e 53, the effects of the loss
2 ., of ~oosc hAbitat should be described in detail and thete-rMS11 preferred 11
I ltncl ''critical" defined. The number of acres to be inundated a~d secondary
adverse effects, if any, should be discussed. A small loss of habitat may
not nnncar to be sip,nificant' when assessed alone, but when added ..,lith all
~ . CONSERVI! th t t 'd 1 ' f ' ' 1 • th 1 b • fi ~ ,..~ e s a "'" e osses o nm> ar nze, e oss may e "'"" cant,
Save Energy and You Serve America!
Pa~.e 23, pnra. 3 -Otl~ Hirds. The stntement 11 Sm1e jncidental huntinr; '
takes place alan~ the Denali Ili~h\'lay" is misleadinf;, thou;-;h this is presumably 2 ~:;1
a reference to ·r,ame bird .Jmntinp;. Huntin.P; pressure p;enerally is ~eavy alonp; 0
the Denali Hip;hway and this statement needs .to tie more closely \'7ith bird
huntin": only.
Par,e 37, first para. -Other' For_!!~ of Tra~_EE.!_.:~~i_E_E:• The statcr;ent concernin~
shallow-draft river boats, small boats, canoes, rubber rafts and kayal•s
needs expandinr., since La',es Louise, Susi tna, Tyone and the T)•one River
cor'lnlex in the Upper ·Susi tna drainn~e receive heavy hoatino; and floatplane
use by hunters and fishcrmeni from the Glennallen nnd Anchoraf'e nrea.
Par.e 40, para. 3 -The r.tatc~ent " ••• and a rninimnl amount of resident fish
habitat at the mouths of a fe>'~ of the tributnries that enter the Susitna
Rive-r in the 2C-mile section of the proposed damsi te 11 shoulcl be e~cpanrled to
identify how many tributaries enter the Susitna ~iver in the nffected reach
of r:J.ver .1m1 to df.scuss more fully the 11mtnimal fiRh hahi tnt".
P.1r'e I~P., narA. 5 -Th:!.s )"lara~r:1ph. should he e>~)"lttmled to inc-l11ne the ,.,_nt:fc-.ipaterl I
numhcr of "rare occasfons" ,.,J)e;n excess \'Inter W01Jld he rliverted over the 31
!'l.)"lilh7:w, tl,.e clif'"!atic or en~ineeri.n<> factors "[lrecintt~,ti.no; these occ.<~si.ons, ·
anrl tho rlc<>roe of si-;ni f·i cA.nt adverse impllcts on f:i sh nnrl. ve""etnt"fon.
Pn":C lr.P. 1 prP"I'!• €i -T11"i.R "n!Jrr:'"'.rct)"lh should ~nocify tll(" ttc-res of mooRe hn.hi t11t
immt"lAt<'rl nnd its im)"lort:mce to mooRe. Li.kevd.c;e, the fish h.1hitnt i.mmdaterl
sho11lrl he rlcscriherl i.n .r>reater rlet:=til. HoH much fiRh h.qh"ftnt \dll he
immrlnte<'l ann \•lha.t SflCCies will he nffecter,? Hhl"lt t'TD('S o,f fi.sh hnbitttt wi.ll
he crenterl at hirher elevations and what s~ecics are expecte~ to use the
"new" hahitnt?
Pn~e 51, lnst p:1ra.-~.Je Sll""""CRt S11 1,stitution of tlw ~mni "fr . .,,.,.ile 11 for the
\ror.rl "RiT'lYJle" 1.n the stntement, 11Ho"tV'("Ver, the ctf!llAtic foorl c.hni n i.n the tai..<>.fl
(hore.1l forest) nnd tundr~ i.s extreMf'ly simple, :mr! a~ PI result, cti.srurtion
of hnhi. trt for on~ !':necfes f!lli. te often :l.nrU re~;tly nffcc.ts r1rmy other s:reci.e1:;. 11
p.., .... <' 53, ";~i"l.ri'1. 3 -",\} tho11~h nooRc hP~hi. tat noes exist ~,.; t"f-J:in the pool areas
of the flTOJ"lOSerl Devil c·nnyon and Hatana reservoirs, the over.1.J 1 loss of
nrcf<'rren or cr.i tic<'ll "t-7i.nter fornoe areas ~v-ould :r.ff0c.t hut;:~ r.mF~J 1 nercentl'\<"e
~f !b.£ Q2_n..£.!. .Susitna ~ population'-' 11 (F!mphasis aclded);-!-l~r.:;;"t!)Clieve
there is sufficient information avntlahle at this time on the Upper Susitnll
moose porulntion to cate~od.cally imply only a srnnll nerr.enta"',e of moose
will he affected. Anticipatei! stuclie~ hy the Fish nnrl Wilrll5fe Service in
coopernt:ton >d th the /\lP~s 1 cn Depr1rtmcnt of. Fi.sh nnrl Gnme should provtrle the
nccderl information for .1 dcter~int1tion with:in the next four ~1enrs.
Pa<>e 6l~, nnr."l .• 1-the hnckn:ro1!nrl rlatA. sunryortin~ the ;ossertion tlMt lar~e I
blocks of excess 1Jmrer >·liil not be created hy the proiect should he presented.
Obviously I the impact on the State of Alaska. would he profound .and lonr:-lastinr: ~~:-::-
i.f a l.nrr,e SUr!)lUS of "!JO'-Tet:' became availahle and industrial development ~.;rere u;J
stimulated by this. Since this· would be vte"t>rcd by many as ·nn adverse impact, ·
or at the least a secondary impact of rria{';nitudc, it s110uld be explored here.
Thnnk you for the O!l[')Ortuni tj' to revi.cN' this clrnf:t nt:~ten:ent. A~ .:'\n ancncv
\'Tith sP~cific rcsronsihilities related to the project, the fish and Hildlifc
Service looks for\·rard to reviel'Tinr; the ptr,er documents as the project r.oe.s
throw~h its autborizati.on procedure and offers to assist at a,ny tin:c.
134
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF THE INTERIOR
FISH·AND WILDLIFE SERVICE
f,.;J An outline presentation of possible ameliorating or mitigating
measures can not be made until a determination as to what types
and to what ~xtent such measures will be required. As stated at
the end of Section 1. 0: "Examp 1 es of prob 1 ems expected to be
addressed during the detailed design study phase include identifi-
catinn of significant adverse impacts to important fish and wild-
life sp~cie~, and specific actions which should be taken to prevent,
ameliorate, or mitigate ·these impacts.11 The provisions of the
1958 Fish and Wildlife.Coordination will be fully complied with in
the consideration of project damages to fish and wildlife resources,
and the implementation of appropriate ameliorative or mitigative
measures.
t""'· .,. f'..,.~v Comment noted.
~~.~~ True, past fish and wildlife. reports generally discounted moose f;.,;_
habitat in Devil Canyon and showed comparatively low moose )popula-
tions in the Watana reservoir area. A definition of "preferred"·
and "critical" in relation to moose habitat has not been defi.ned
in the EIS at this time. Future wildlife studies should determine
and define critical moose habitat and number within the proposed
impoundment areas.
}2J3The words "game bird" have been added to the statement to clarify
this discussion of hunting pressure.
;e,,;J In Section 2.03.3 (Transportation), the EIS indicates boating and
floatplane use in areas of the Upper Susitna River Basin.
;~~) The fish habitat at the mouths of clearwater tributaries which would
be inundated by the proposed impoundments is more fully discussed
in Section 2.0 under the heading Resident Fish. According to a
survey conducted jointly by the Fish and Wildlife Service and the
Alaska Department of Fish and Game in May and September 1974, only
Fog Creek and Tsusena Creek provide good resident fish habitat
within the reservoir impoundment areas. Some of the other tribu-
taries provide poor habitat, whil"e others indicated no presence of
fish.
': ··~ ~--The EIS has been expanded to indicate that excess water would be
diverted over the spillway once in approximately 50 years. The
factors precipitating these occasions would consist of a full reser-
vior concurrently with inflow in excess of the combined turbine and
regulatory outlet works capacity. Impacts on the 2.5-mile reach of
Tsusena Creek would consist of channel and streambank erosion,
flushing of fish and other stream organisms~ and damage to stream-
side vegetation.
32 A discussion of the importance of inundated moose habitat has been
added to Section 4.0 of the EIS. Acres of significant moose habitat
can only be determined from studies which are proposed to be conducted
during the pre-construction stage of planning. These studies will
determine the extent and types of ameliorating measures required to
offset any unavoidable damage to moose habitat and populations. As
stated in Section 2.0 of the EIS, grayling, rainbow trout, lake
trout, Dolly Varden, whitefish, sucker, sculpin, and burbot comp~ise
the principal resident fish population of the Susitna drainage. As
also stated, grayling is the principal sport species inhabiting the
mouths of clearwater tr'fbutaries. It is expected that this would
be the predominant species inhabiting any new habitat created at
higher elevations by the reservoirs, since habitat conditions would
probably be similar at the higher elevations. As with the case of
moose, such eventualities can only be ascertained by detailed future
studies.
3 3 ~le disagree. Admittedly, the taiga and tundra are "fragile" ecosys-
tems. However, an ecosystem could be fragile and still have a
complex aquatic food chain. Such a food chain would probably be
less severely damaged by a given action than would a 11 Simple" food
ch~in tn which loss of one link might directly affect the entire
syst,~m.• ·
3 4comment noted, but past studies indicate low numbers of moose are found
within the proposed reservoir areas.
35 See response number 255.
136
-~
~·. United States Department of the Interior
GEOLOGICAL SURVEY
RESTON, VIRGINIA 22092
OFFICII. O·P THE DIRECTOR
. ER-75/942
Colon~l Charles A. Debelius
Alaska District, Corps of Engineers
P~O. Box 7002
Anchorage; Alaska 99510
Dear Colonel Debelius:
NOV 1 7 1975
We have reviewed your draft env1ronmental statement on the Upper
Susitna hydroelectric development and offer the following suggestions:
It has been noted that impacts will be analyzed after project authorization·
and prior to project design (p. 8, par. 1). Information conspicuously
absent in the present statement, but which should be incorporated in
a revised or final ·environmental statement, includes the geology ·
of the proposed dam sites, including permafrost conditions, and related
impacts • Much pertinent information can be found in a recent Geoiogical
Surv~y report, "Preliminary geologic and seismic evaluation of the .
proposed Devil Canyon and Watana Reservoir areas Susitna River, Alaska,"
byJohn C. Lahr and Rueben Kachadoorian. That report notes that the
Devil Canyon damsite is underlain by argillite and graywacke of
Cretaceous age, and describes joint sets and shear zones in the damsite
area (p. 5-6). The Watana damsite is described as being underlain
by granitic rock.which has intruded the Cretaceous argillite and graywacke.
In discussing potenttal geologic and seismic hazards to the pr~ject,.
the Survey report states that "one must assume that the proposed
Devil Canyon and Watana Reservoirs could be subjected to earthqLlake
generated landslides" ( p. 14, par. 1). It has also been observed
that unconsolidated sediments high above the river on the canyon
walls would be inundated when the reservoirs are tilled and "durin.g a
major seismic event these sediments may slide and generate waves in
tht! reservoir" (p. 14, par. 2). Another hazard.discussed in the·
preliminary report is that of the runup against the dams of waves
that might conceivably be generated by blocks falling into the reservoi~s
·or by subaerial or suba~ueous landslides; additionally, the possibility
Save Energy and You Serve America!
13';
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36
3?
38
39
40
ER-75/942 2
of damage by seiches t·hat might develop· in the reservoirs during earthquakes
has been briefly discussed (p. 14-15). Possible hazards of earthquakes
induced by reservoir tilling have also been discussed (p. 15~16). It is
concluded that all of the foregoing possible hazards should be carefully
assessed in the siting and design of the proposed dams ( p. 17). Recommendations
are presented for geologic and geophysical studies (p. 18-19; p. 21-24).
Daily fluctuations of up to two feet in the river below the proposed Devil • s
Canyon dam are compared to the natural fluctuations of about one foot (p. 46,
par. 5). However, the natural daily fluctuations occur during the spring
and summer runoff of snow-melt at high flows while those after construction
of the project would occur at lower flows, be more abrupt, and occur in
winter. Thus, some different effects might be expected and these should
be discussed in the final statement.
The spillway design a't the upper dam would divert flows that cannot be
taken through outlet structure into Tsusena Creek, 2.5 miles above the
confluence with the Susitna River. It is indicated that on the Tare occasions
when this diversion would take place, the impacts on Tsusena Creek could
be significant (p. 48). The frequency at which damaging diversions might
occur should be given as well as estimates of extent of the resulting effects.
The occurrence of ground-water resources in the project area is not addressed
in the environmental statement, although bits of information on geology
(p. 14-15) and the suggested ground-water impacts of the coal alternative
·(p. 71) indicate that a~preciable ground-water resources exist in the area.
It is not possible to evaluate the impacts of the proposed project on ground
water without more information. Aithough we realize that this document
represents only a feasibility·stage, we believe that impacts on ground
water should be evaluated for each major component of the recommended development
plan, especially for the proposed dams, powerplants, transmission facilities,
roads and recreational facilities. These evaluations might be presented
in detail after the project is authorized, but current knowledge should ·
be sufficiertt for evaluation in general terms.
IThere is some apparent conflict in the interpretation of the Alaska Native
Claims Settlement Act which is not resolved (p. 43-44). A further statement
seems necessary to say that this difference between the intent of the law
and the understandittg of the Bureau of Land Management'is yet to be settled.
We thank you for the opportunity to comment on the draft environmental
stateml:!nt.
Sincerely yours,
.--
.. ~L-~t()~
:Act1ng ~i~~ tor {
· RESPONSE TO CONMENTS BY
U.S. DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
~~6 The geology of the foundations for Devil Canyon is a phyillite
complex with joint sets crossing the river at a slight diagonal.
· Due to the steep cliffs there is no overburden. Foundation rocks
at Watana are granitic types with joints crossing the river at a
slight diagonal. Overburden varies greatly and is expected to be
1 to 10 feet deep in the vicinity of the axis. Depth of bedrock
in the river channel could be as much as 70 feet according to
seismic studies. The bedrock formation of the canyon walls changes
from igneous complexis to metamorphized sediment complexes. The
exact boundaries will not be known until later design studies are
authorized. Detailed seismicity studies will be required in deter-
mining the exact siting and final design of the dams. The Corps
concurs with the Geological Survey that the geology of the project
area must be studied in depth to identify hazards which the dams
and reservoirs could be subjected to.
~:t: The hydro projects \'till be operated in a manner similar to the
normal load demand of the railbelt area which presently has an
annual load factor of 50 percent. Monthly load factors throughout
the year have ranged between 70 to 76 percent, and weekly load
factors are frequently above 80 percent. Therefore, under the
normal energy demand makeup, the Watana turbines would have ade-
quate capacity to meet all peaking requirements, and the Devil
Canyon project would serve the baseload, thus regulating the Watana
discharges and maintaining a relatively stable downstream diScharge.
However, if the Devil Canyon projects were operated within a 70 to
80 percent plant factor range on a monthly basis, the respective
river fluctuations would be minimal (on the order of less than a
foot on a monthly basis). Under extreme conditions when a rail-
belt system failure of existing thermal units may require heavy
hydro usage, abrupt fluctuations could oc~ur. Spring, summer, and
fall stage increases would have relatively the same effect as
natural stage fluctuations brought on by flooding. Generally,
however, system failures at this time of the year could be met by
other thermal units held in reserve. Therefore, a winter system
failure would probably provide the most adverse river effect.
In regard to premature ice breakup brought on by river fluctuations,
studies conducted by the Missouri River Division, Corps of Engineers.
have found that stage increases of up to 7 feet_ at moderate rate
can be tolerated without premature breakup. A 7-foot fluctuation
is far in excess of the maximum stage increases anticipated for the
proposed hydro projects.
~;.:8 This paragraph has been expanded on page 48 of the EIS. The spi 11
frequency is approximately once every 50 years.
----w-~~-------------·------------.-.w------------------
3~Groundwater within the confines of the proposed reservoirs and
dam structures is limited to the shallow aquifer which discharges
to the Susitna River and to local benches perched on bedrock.
The aquifer is roughly 80 feet deep and is underlain by bedrock.
Because the stream channel and subsequent bedrock are 11 river cut,11
the lateral extent of groundwater is intermittent and confined to
benches shaped by glacial scour. The flood plain of the Susitna
River upstream from the proposed Devil Canyon damsite but below
the upper reaches of the Watana reservoir is confined to a steep-
walled, narrow canyon.
Groundwater within the study area has no existing or planned
human use. From an engineering standpoint, few problems are
anticipated from groundwater interference during or after construc-
tion. Conversely, although inundated within reservoir areas,
downstream groundwater impact is expected to be minimal. Adequate
freshet recharge coupled with the influent nature of the winter
flow regime should maintain existing downstream water tables.
Access roads will traverse the basin on relatively high ground
outside of the canyon confines. While some groundwater may be
encountered, the general route of the roads has been chosen to
minimize design problems such as groundwater. The topography of
the area would not indicate that the roads would have any signifi-
cant groundwater impact. The same general observations hold for
the transmission system; however, considerably more terrain would
be crossed and a greater potential for groundwater impact may
exist. Much of the transmission system will follow existing
transportation and utility corridors and an analagous observation
of groundwater interference along these routes would indicate
few potential problems.
40The discussion of the Alaska Native Claims Settlement Act has been
expanded and updated in the EIS to reflect the latest status of
the lands in the project area and to indicate that some of the
matters concerning the ultimate disposition of these lands have
not yet been resolved. See Section 3.02 in EIS.
140
UNITED STATES
DEPARTMENT OF THE INTERIOR
BUREAU OF INDIAN AFFAIRS
Juneau Area Office
P. 0. Box 3-8000
Juneau, Alaska 99802
IN REPL v REf'"ER TO:
November 3, 1975
Memorandum
To: District Engineer, Department of the ArmY
Anchorage
From: Area Director
Subject: Review of draft environmental impact statement for Hydroelectric
Development, Upper Susitna River Basin, Southcentral Railbelt
Area, Alaska {ER 75/942)
General Corrments:
The document is presented in a good format so the document is readable I
and easy to follow through. There appear to be provisions made to avoid ·· 41
any future land conflicts under the Alaska Native Claims Settlement Act. · -·
Specific Comments:
We have no further corrments.
141
_____ ..,.,.... _______________ , o-------
~jL Comments noted.
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF THE INTERIOR
BUREAU OF INDIAN AFFAIRS
UNITED STATES
DEPARTMENT OF THE INTERIOR
BUREAU OF INDIAN AFFAIRS
Juneau Area Office
P. 0. Box 3-8000
Juneau, Alaska 99802
IN REPLY REF:"ER TO:
November 35 1975
Memorandum
To: District Engineer, Department of the Army
Anchorage
From: Area Director
Subject: Review of draft environmental impact statement for Hydroelectric
Development, Upper Susitna River Basin, Southcentral Railbelt
Area, Alaska (ER 75/942)
General Comments:
Thed documentfis
11
presehntedhin Tahgood formattsobthe do~u~nt isdreatdableid 1:·
4
·i ; an easy to . o ow t roug • ere appear o e prov1s1ons ma e o avo
any future land conflicts under the Alaska Native Claims Settlement Act.
Specific Comments:
We have no further comments.
141.
~jl Comments noted.
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF THE INTERIOR
BUREAU OF INDIAN AFFAIRS
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
State Office
555 Copdova Street
Anchorage, Alaska 99501
Colonel Charles A. Debelius
District Engineer
Corps of Engineers
Alaska District
P.O. Box 7002
Anchorage, Alaska 99510
Dear Colonel Deb eli us :
IN REPLY REFER TO:
1792.5 (911)
We have reviewed the draft environmental impact statement titled
"Hydroelectric PowerDeveloprnent, Upper Susitna River Basin, Southcentral
Railbelt Area, Alaska" ER 75-942. Our concerns basically center around
the lack of assessment of the effects of the proposed project on the
downstream portion of the Susitna River. We are also concerned that
since the project is only in the feasibility stage~ future design efforts
and ongoing studies may uncover additional environmental data. Thus,
another impact statement or an update would be desirable at the time the
project became more specific.
General Comments
The proposed Devils Canyon-Watana Dam project is being placed on one of I
the rna]· or river. drainages in south central Alaska. but the DEIS does not ··· . ·
provide a comprehensive overview of the impacts ~f this proposed hydro-~:)
electric complex on the streamecosystem and associated resource values.
Consideration of the environmental impacts of the project and affects on
recreation, navigation and fisheries, for example, need to be expanded
to include the lower Susitna River from Devils Canyon to its mouth on
Cook Inlet. In this regard, the DEIS is deficient, and adverse impacts tJ...J:
in the lower river may outweigh potential beneficial aspects of the
proposal in opening up access to the Upper Susitna Basin.
Specific Comments
Summary Page
2. Description of Action -The draft states that all impacts were not I
exhaustively evaluated since the project is only in the "feasibility
study" stage. However, it appears that the proposal has gone
45
3.
46
47
I far beyond the feasibility stage and should require a detailed EIS
•.
· .• Which evaluates all possible impacts. If another impact statement
will be prepared after design and further studies, this should be
so stated or explained.
a. Environmental Impacts -Increased turbidity of the Susitna River
downstream from the project area during the winter months is listed
as a major adverse environmental impact. Yet, no analysis is made
in any of the remaining. sections of the EIS of the potential
impacts of this water quality change upon overwintering resident
and anadromous fish in the main stem Susitna River below the site.
I The r. ecreational opportunities would more than likely be altered
rather than increased. Use patterns would shift from de facto
wilderness oriented activities to more intensive activities adjacent
· to the new roads and reservoirs.
4 8. I•_The project would also promote the development of adjacent private
(Native) lands •
. Page 1, .paragraph l. 02
I"It is suggested that it is premature to consider the subject
4 9 ·_ ·_project without_ first. completing the Stage. 2 comprehensive report
. "on the feasibility of developing other hydroelectric sites in the
area.
50
51
Page 6~ paragraph 1.03
.I .
.. ·.·._The dl·.· s.cussion of access r-oad design/location should be .strength. ened,
if possible. Mention is only made that such construction will
include consideration ,of environmental factors. It would appear
appropriate for. such considerations to be discussed in detail.
It is understood that the operation and maintenance of project-
related, recreational developments will be assumed by the land
managing a,gency having responsibility for the major portion of
:adjacent public lands; and, as such, it would seem best to resolve
that matter at an early date and incorporate that organization's
goals/plans into the design of any recreational developments.
Page 15, paragraph 2.01.4.3
52 I.
It is impossible to consider the environmental impacts of the
transmission corridor as described. A considerable expansion
this sec·tion is warranted.
of
144
2
.r-··
Pages 18-21, paragraph 2.02.1
The draft would benefit in this section by the inclusion of a
fisheries habitat map detailing the distribution and the spawning
and rearing habitat, ·by species, of both anadromous and resident fish
in the immediate area of the dam proposals (Chulitna River conflu-~:J
ence to the upper end of the Watana impoundment) •
Page 23; paragraph 2.02.3.1
Rather than state that ATV access to the back country has improved
hunting accessin spite of a rapidly declining caribou population,
it might be justified to state that increased access, whether via
ATV's or roads, coupled with an increasing human population, may be
a contributing cause of the rapidly declining caribou population.
Page 36; paragraph 2.03.3.4
River boats ·and airboats are a common form of transportation to
recreational cabins, homesites, and the hunting and fishing oppor-
tunities of the lower Susitna River. Due to the braided and often
shallow character of the Susitna River in the area between the
mouths of the Kashwitna and Deshka Rivers, the 3,252 and 19,160 cfs
reductions in flow created by the proposed project during May through
July (as shown in Table 1, page 45) could have a considerable impact
on the navigation of the lower river, particularly for boaters
using propeller-driven outboard craft.
The impact of flow reductions on current transportation to recreational
opportunities in the lower river should be examined and weighed against
the suggested advantages of increased access to the Upper Susitna Basin
(Page 54, paragraph 4.04).
In winter, the lower Susitna River is also a highway for travel by
snowmachine for homesteaders and recreational tract owners. It
should be determined if regulated discharges ranging from 6,038 to
7,428 or 481% to 657% increases over natural flows in January
through April will result in hazardous travel due to thinner ice
formations or their complete absence in the lower segment of the
river.
Page 37, paragraph 2.03.4.1
154
55
56
It is incorrect to state that floatplane access is relatively
minor and restricted to a few large lakes. Such use is actually
quite common and in all probability, most lakes large enough to
accommodate a Super Cub are utilized. · fs7
i:~~:;
3
----------------------------------------------------------------------------
58
It is also incorrect to say that the Upper Susitna River Basin
has very little recreational activity. ·As noted previously, float-
planes and ATV 1 s are utilized quite heavily by hunters, fishermen:
and other recreationists. Preliminary studies indicate significant
populations of hunters, fishermen and miners utilizing the Susitna
River Basin. Reference: Upiversity of Alaska 1975 ORV Study (report
being prepared) •
. ·Page 37, paragrd:ph 2. 03. 4. 2
5~1 Reference to the hunting of sheep and goats being minimal, even
along the Denali Highway, implies a general' lack of interest in
that direction; however, the real reason for minimal hunting
pressure along the highway is probably the result of minimal
sheep populations.
60
61
Page 43, paragraph 3.01
Although the general project area is presently under the jurisdiction
of BLM and the area to be inundated is classified as a power site,
the entire area is withdrawn under ANCSA for possible selection py
Native corporations. Selections have already been filed for lands
in the immediate area of the proposed sites. We suggest you contact
the Land o·ffice, 555 Cordova Street, for the specific locations.
Pages 45-52, paragraphs 4.01 and 4.02
The present relationship of food supply, water temperatures, turbidities,
velocity of flow and dissolved.ox:ygen levels currently found in the
lower Susitna River provide a balance which permits the existence of
overwintering fish populations migrant to the stream from clearwater
sloughs and tributaries which have diminished water flows or are
frOzen to the bottom. Alteration of any one of these conditions
produces changes in the others which degrade the lower Susitna River's
capability to support wintering and will result in a decline of
resident and anadromous fish populations.
Any attempt through engineering design and discharge management to
maintain the lower Susitna River is subject to failure because of.the
harsh climate anp. the complex interaction of the above factors.
I Assuming, for example; that discharges from the Devils Canyon Dam
are increased 657% above the natural flow level during the winter
period and all other of the above factors remain at the natural
level, the following will happen: .
1. Temperatures remain at natural level of 32° F. Fish, being
cold blooded organisms, have their basic activity level "set'~
by temperature--in this cas.e their lowest. Stream velocities
have been increased and fish cannot maintain their station in
the river currents. By their inability to maintain or produce
a higher activity level, they are subject to stress anq, mortality.
2. Food supply is presently limited, and for this exercise, is
presumed to remain the same. Utilization of available fOod supply
by fish is decreased because more of their basic energy expen-
diture must go into swimming rather than into the activity cos_t. G 3
to capture prey_organisms. Fish lose condition, are stressed and
subject to mortality. ·
3. Dissolved oxygen is presently above 5 mr,/lo At this level, oxygen ·
is in sufficient supply to maintain the low metabolic rate of. the
fish. Much lower levels would be required to cause fish stress
arid mortality. Discharge-stream veloCity would have no impact.
4. The waters are presently clear in the winter situation. With
increased flow, there would be no impact on fish life, adverse
or beneficial.
In the above case, alteration of stream velocities affects swimming
performance of fish and utilization of their food supply introducing
stress and mortality. If all the possible permutations and combinations
of change and interaction of the above factors are worked through,
it can be realized that construction of the Devils Canyon project 64
will affect the lower Susitna River's suitability as critical winter
habitat for resident and anadromous fish with little hope for
mitigation. This should be qlearly and positively outlined by the
Corps of Engineers as an adverse impact of the project. The effect
on fish production and stream ecology should be expanded to include
the entire lower Susitna River.
Page 50, paragraph 4.02
What is the basis for the readjustment of fish'? Presumably some sort I
of evolutionary adaptation is to be accomplished in a short period ·.
of time to complex habitat changes and klteration of natural biological (;!)
cues. More likely, the adjustment will be a substantial decline in
fish population numbers. This should be positively stated.
Page SO, paragraphs 4-6
Presently, it is doubtful that spawning by salmon occurs in the main I
stem Susitna River. This paragraph is irrelevant to ·the true fisheries
5
I value of the
6 6 , tribut. aries.
. provided the
available.
river, namely winter habitat for fish fl?om s-loughs and
Additional spawning habitat will not be of any value,
critical winter habitat for fish survival is not
67
68
69
Pages·ss-56, paragraph 4.04
.'fhe lower Susitna Basin encompasses one of the largest blocks bf
land currently patented to the State of Alaska. The area will
see increased public use in recreation due to the fact that many
·areas of the state w:ill shortly be turned over to th.e priva:t:e
ownership of Native regional corporations and villages which will
restrict access to lands previously used by recreationists from the
densely populated Anchorage area. Also, as suggested, a new capital
may be constructed close to the lower Susitna River. The impacts of
reduced discharges in the Susitna River during the summer months
should be exarrii.ned to determine the effect on current modes of
transportation and navigation for recreational purposes in an area
which has a growing demand.
I The draft estimates an annual visitation to the project area of
.
.. 77 ,000 peop. le. Th. e methodology. for arriving at th.is figure should
.be shown, since there are no previous similar situations or case
analyses in Alaska.
Page 59 , ··paragraph 4. 10
I It would be of value for the reader to know the actual locations of
.
.. propose. d roads an·d· the conditions under which it would be considered
necessary to accomplish revegetation of temporary roads and other
disturbed areas. ·
I
Page 61, paragraph 4.13
I ... Car>e .shoul. d be exercised in locating the transmission ll..'ne betWeen 7 0 · . Point MacKenzie and Cantwell so as to avoid a degradation of the
· .. scenic views of Mt. McKinley.
711· An expansion of the brief discussion of planned landscape management
techniques would be appropriate.
I The last sentence in the first paragraph should read positively, 7 2 ·.• "That would (delete probably) qualify for wilderness classification"
(delete rest).
6 148
~-.
We suggest qualification as to what extent roads and transmission
iines will impact aesthetics.
The third paragraph reads as a justification statement.
Page 68 * paragraph 6. a·
173
I 7~~:
.It is suggested that alternatives to the proposal might surface in 1•
the feasibility study (Stage 2) for the development of other hydro-t_/5
electric sites in the Southcentral Railbelt area which is scheduled
to be completed in 1978.
Pages 69 and 78, paragraphs 6 ~ 02, 6 ~ 03
Development of the Beluga Coal Fields will probably occur regardless
of the presence or absence of the Upper Susitna Hydroelectric
Project~ .. Considering the adjacency of the Beluga Coal Fields and the
potential Chakachanina Hydroelectric Project, some consideration
should be given to potential powel:lproduction based on a blend of
these two systems. Othel:l factors in favor of concentration of power
·production in the ar•ea are the potential for industrial development,
deepwater port capabilities and the presence of some power trans-
mission lines at present.
Oil and gas field development has already occurred throughout the
Beluga area and a major timber operation exists, so the projects
would not be affecting a de facto wilderness like the Upper
Susitna Basin. ·
Page 71; paragraph 6.02.2
Reference is made to the lack of recreational and flood control
·benefits in a coal-the'rmal facility. There are no known flooding
problems along the river which require control; hence the flood
control "benefits" of the two-dam proposal are of little value.
Page 89, paragraph 6.05
-~(6
A transmission corridor is indicated in figure 15 as possibly
passing thr.ough the Coppel:l River Basin served by the Copper Valley
Electric Association which. has plans to increase their service by a
new hydroelect):lic project at Solomon Gulch near Valdez with a . 1/'8
transmission line to the Coppel:l River Basin. The coordination of
these two transmission or power systems should be explained in the'
final.
s~Jk_
Curtis ~McVee
State Director
7
RESPONSE TO COtviMENTS BY
U.S. DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
42 The purpose of future design efforts and ongoing studies is to
obtain additional environmental data. The EIS will be amended or
ul)dated periodically during the course of these studies to reflect
all significant impacts identified.
43 As acknowledged in the first paragraph of BLM's letter, the project·
is currently in the feas i bi 1 ity stage. A corriprehens i ve and detai 1 ed
·overview of the impacts of the project cannot be ascertained until
the detailed, pre-construction stage of planning is authorized and
funded by the Congress. The FEIS will be revised and updated to
include all additional information received during the EIS review
process.
114 The need for further studies to determine deta i 1 ed impacts of the
· project is acknowledged in the EIS. The Corps does not view opening
up access to the Upper Susitna Basin as being beneficial. The EIS
fully addresses the general impacts expected to result from such
access--both adverse and beneficial. Any 11 benefits 11 from such access
are not weighed as a trade-off to adverse impacts which may or may
not occur downstream.
45 All Corps project studies are in a feasibility stage prior to being
authorized and funded by the Congress for advancement to detailed
studies, whi.ch are made prior to~-and results of which are a
determining factor in~-a determination by the Congress that the
project should be authorized and funded for construction. Thus,
this proposal is currently in a feasibility stage, and will remain
so until such time that Congress may approve authorization for pre-
construction studies and appropriation of funding therefore. On the
basis of detailed studies made during the next stage, the EIS will
be appropriately amended or updated.
1:k6 Increased turbidity which is expected to occur downstream from the
project during the winter months is not listed as a major adverse
environmental impact in the EIS. It is discussed as an unavoidable
adverse impact, the significance of which presently is not wholly
known. There is some evidence to support a view, however, that the
impact may be relatively minor. Estimates of 15 to 35 ppm of sus-
pended sediment are based on concentrations below glacial-fed natural
lakes in Alaska. One of these is Skilak Lake. The Kenai River,
which flows from this lake, is generally recognized as one of the
more important salmon streams in Alaska.
4/7 Comment noted.
·~.
4 8 Comment noted.
4~The most feasible alternative hydroelectric sites in the Southcentral
Rail belt and Yukon regions were considered during the Stage 1 Interim
Report. Stage 2 studies would consist primarily of a more in-depth
evaluation of the alternatives already considered.
50considerations of environmental factors related to road construction
will be considered in great detail when and if studies for such
roads are authorized and funded. At the present feasibility stage
of planning, the exact location of access roads is not known.
51concur. As soon as it is determined--as a result of consumation of
the provisions of the Native Claims Settlement Act--what agency or
organization will have the management responsibility for the major
portion of adjacent lands, efforts will be made to incorporate
recreational development into that organization•s plans and goals.
These lands are presently in a state of flux, having been designated
as Native Village Deficiency Lands.
52Impacts of the transmission lines, insofar as can be presently
predicted with a reasonable degree of accuracy, are discussed under
appropriate resource categories throughout the EIS. A comprehensive
environmental assessment of the impacts of all the alternative
transmission line corridors has been made by the Alaska Power Admin-
istration. This document is included in th~ appendix to the Corps•
interim feasibility report, and is available for pub,lic review in
the District office.
53we agree. Such a map would have been included had it been made
available by any of the responsible fishery resource agencies. This
type of information will not be available until fishery studies
currently underway are completed.
54The statement describes suspected and known impacts of ATV access to
basin moose and caribou herds. It also acknowledges that road
access will increase the potential for additional hunting pressure.
As stated by the Alaska Department of Fish and Game, in commenting
on the EIS, that agency has the statutory authority and capability
to control hunting pressure.
55This could conceivably happen, particularly during the early years
following project completion while the river is still divided
amongst a series of braided channels. However, the river is expected,
through regulated flow and elimination of high flood stages, to
eventually assume a basically single, meandering channel. When this
occurs, with water having been concentrated in a single channel, the
summer navigability of the stream might well improve. Concurrently
151
with this, downstream recreational opportunity may well improve
during the summer months. Heavy sediment loads and high flood
stages which now characterize the river during the height of the
outdoor recreational season will be significantly diminished, thus
making the area more attractive to general outdoor recreationists.
~(;As stated in the EIS, winter ice conditions are not expected to be
significantly changed downstream from Talkeetna. Above Talkeetna
the river may become more hazardous for winter travel. Such use
above Talkeetna, at the present time, is minor.
S:./The extent of floatplane use is described in more detail in a pre-
vious paragraph entitled Air. The terms 11 minor 11 and 11 Common 11 are
relative in context. In comparison to known areas of common or
high floatplane use in Alaska, such use in the Upper Susitna Basin
is considered to be relatively minor.
~3 Again, 11 Very little" is a relative term. The use of Arv•s and
floatplanes by hunters, fishermen, and other recreationists in the
remote setting of the Upper Susitna Basin is miniscule compared to
areas near human population centers where easy access is provided
by roads.
t~~ The first half of this comment is not clear as to what is meant by
11 implies ... It is agreed, however, that minimal sheep and goat
hunting along the Denali Highway may well indeed be the result of
minimal populations.
60 This section has been updated to reflect the current status of 1 ands
affected by the project. The status of filing on these lands is
not cogent at this time, since exchanges presently proposed are
subject to an amendment to PL 92-203 and possibly to Alaska statutes.
b~'t This is a purely conjectural statement. No such assertion has
been made by any of the responsible fish management agencies, since
such a determination can only be made based on detailed studies,
which are currently underway. It waul d be just as valid to state
that the opposite condition could occur; i.e., alteration could
improve overwintering capability of the main stream.
b. · . .., Comment noted.
' • .J
bJ Comment noted.
b:.'1 There appears to be a conflict between the first sentence of this
paragraph which states: 11
••• alteration of stream velocities
affect swimming performance of fish and utilization of their food
supply introducing stress and mortality.11 --and subparagraph 4 of
the previous paragraph which states: "With increased flow, there
---" --. .,.
would be no impact on fish life, adverse or beneficial.11 The content of
the remainder of this paragraph is noted.
6 5 The statement· has not been modified. Comment noted.
66 Comment ·noted.
67The subject of reduced discharges during the summer months as related to
recreational transportation (navigation) is discussed in response to an
earlier BLM comment. We agree that if lands in the project area are
turned over to the Natives, recreational usage in the Upper Susitna
Basin will.li:kely·be restricted, and that if a new State capital i.s
constructed close to the Susitna River, recreational demand will increase.
The project, by providing public use on lands which would otherwise be
restricted to such use by Native ownership, will contribute significantly
to the recreational needs of people living in the new capital.
68 The visitation figures were developed by a private consultant in coordi-
nation with the Bureau of Outdoor Recreation and the Alaska Division of
Parks, and are included in the Recreation Section of Appendix I of the
feasibility report.
6& Comment noted.
70 Comment noted.
71 Comment noted.
72 The sentence referring to "probable" wilderness classification is accurate.
73 It is stated in the EIS: "Degradation of visual quality in general
would be a major adverse effect of project construction. This would be
attributable primarily to roads, dam construction, right-of-way clearing
for the transmission line, and the obtrusiveness of the transmission
line itself.11 No meaningful qualification as to what extent roads and
transmission lines will impact upon esthetics can be made, since such
impacts are wholly subjective in nature. and are dependent upon each
individual's sense of what constitutes esthetic impairment.
74 Comment noted.
75 See response number 49.
76 Coal and other hydroelectric alternatives, including Lake Chakachamna,
are sufficiently addressed in the EIS to explain why they were not
selected as the recommended plan. Development of the Beluga Coal
Fields may indeed be developed regardless of the presence or absence of
the Upper Susitna hydroelectric project.
15:3
77 On the, contrary. there are existing flooding problems along the
Susitna River which require control. One ·involves the town of
Talkeetna which is being threatened by riverbank caving, and the
other involves nearly annual damage to the Alaska Railroad tracks.
11 Benefits 11 from flood control are indeed small, thus very little of
project benefits are attributed to it (0.03 of 1 percent of average
annua 1 benefits) ..
'i 8 The EI:S makes it perfectly clear that the depicted transmission
corridors are all alternatives which were considered and all but
one of which were rejected. There are no transmission line planned
for construction in relation to this project which would pass through
the Copper River Basin.
154
~~~
'
United States Department of the Interior
NATIONAL PARK SERVICE
IN REPLY REFER TO!
Alaska Task Force
524 West 6th Street, Room 201
Anchorage, Alaska 99501
November 11, 1975
Colonel Charles A. Debelius
District Engineer
Alaska District
Corp of Engineers
P.O. Box 7002
Anchorage, AK 99510
Dear Colonel Debelius:
We have been asked to submit our comments on the draft environmental
statement, "Hydroelectric Power Development, Upper Susitna River
Basin, Southcentral Railbelt Area, Alaska" directly to your office.
Our comments are as follows:
A section should be included to show projected future power require-
ments of the railbelt area. This section should provide a comparison
of existing requirements and projected needs.
The impacts concerning recreational opportunities need expansion. In
a land of so many natural lakes it seems that a reservoir of the
proposed design (long and narrow) would be of little recreational
attraction. The attraction would be the fish that were planted and
the facilities provided (which could be done for natural lakes, thus
not requiring the project).
The document states that very little recreational use is now made of
the upper Susitna basin. Future needs (1986) should be shown. This
area will receive increased pressure by 1986 and will be significant
when the Susitna flats are further developed. The summer draw down
of the Watane project will impair the recreation use of the project
and leave a barren area which will not be available for any use or
provide wildlife habitat. Does this activity balance the loss of
white water and river boating due to the impoundments? Aside from
access to a previously primitive area, how do the recreational improve-
ments compliment or blend with those of the region e.g., Mt. McKinley
National Park and Denali State Park? How was the figure of 77,000
potential visitors arrived at?
The power line should not be built to Fairbanks. Such an approach I
would eliminate the severe impacts of such a line through the Broad
-
B1
82
83
84
85
86
Pass area and the Nanana Canyon. vlhy is it necessary to transmit
power north to the Fairbanks area? The esthetic damage caused by
transmission line construction should be more carefully examined.
Consideration of underground lines in certain stretches should be
carefully considered. Economic costs should not be the only
consideration for those sections where ethetics are most important.
6.02 Alternatives
All alternatives need expansion. On page one of the draft EIS, the
resolution states in part an investigation of "any competitive
alternative." Can this really be done if on the one hand oil and
gas alternatives are dismissed in view of a "national effort," and
coal is discounted on the basis of extensive adversP. envirQII,Qlental
impacts even though statements such as on page 71 indicate '~t
extensive studies of the impact of coal mining have not been
conducted. An alternative consisting of the development of several
sources combined to produce the power requirements of the State
should be considered.
6.02.2 Coal
It should be stated that the Healy Coal fields have been developed
and that the strip mining damage in this area has been taking place
for a number of years.
Roads from the Healy coal fields have been built and the transporta-
tion problem is minimal when the generating plant is adjacent to the
coal source. Higher local employment will be realized by develop-
ment of coal energy sources.
6.02.3 Oil and Natural Gas
I These fuel sources need to be considered in more detail.
available in the Fairbanks area by 1986 and what are the
benefits in relation to the $1.343 billion 1975 required
dam project ...
6.04.2 Devil Canyon
What will be
cost
for the two
This alternative should be more carefully examined. Even with a low
firm energy capability it appears that this project would produce
power during the season when it is most needed. The impacts from
this single dam project are minor as compared to the two dam project.
I.ess transmission line construction would be required with this
alternative combined with other projects. This project appears to
have the highest recreation potential.
8 r; I· We recommend that the question of environmental impact versus cost
benefit of development for a number of energy sources be explored.
2
!56
~ ..
Not enough discussion of the intertie and the secondary social-
economic impacts of the intertie, i.e. encouragement of strip
development all along the power line. Do we really need/want an
intertie in Alaska? How much energy is lost through transmission
lines?
Water for domestic/agricultural use will soon be in short supply. log.
How does this use of water fit in with long range water needs. 0
Under section 4.0 the impact of the material sites to construct
the dams has not been evaluated. Gravel, limestone for cement, and
earth for land fill if taken from sites not be to flooded will have
a major impact on the areas esthetics and important sightseeing use.
If local limestone is used to make the cement necessary for the SO
Devil's Canyon Dam, this will create scar~ on the landscape and
considerable air and noise pollution in an area critical to the
visitor to this Mt. McKinley region. Limestone sources near Cantwell
if utilized and processed there would create visual and air pollution
impacts to the Mt. McKinley National Park visitor, as well as the
residents of Cantwell. This impact must be evaluated and mitigated
in this EIS.
AGHenson:jkm
Sincerely,
(\ t /-.. ~.\ .· .
·~· \}'.·.''.! I I .. ,!x·
\ ' ~:~,:. ·~
Albert G. Henson
Project Leader
157
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF THE INTERIOR
NATIONAL PARK SERVICE
ALASKA TASK FORCE
79 An entire section (2.04) is devoted to a discussion of energy needs.
Figure 9 is a graph which illustrates a five-year record of energy
consumption (1970-1974) plus projected load growth through the year
1999.
80 Recreation is not the purpose of the reservoirs. However, they will
ine~itably attract some visitation for recreational pUrposes. Recrea-
tional usage, as estimated in the EIS, is claimed as a project benefit,
but its contribution to project justification is infinitesimal--being
less than 0.2 of 1 percent of total project benefits.
81 The reservoirs, either directly or indirectly, afford more recreational
opportunity in the Upper Susitna Basin than would otherwise exist, both
asa result of the flatwater recreati.onal opportunity afforded by the
reservoirs, and access provided by the road system which wi 11 be necessary
to construct and operate the project. Most of the reservoir recreational
visitation will be associated with the Devil Canyon site. Watana will
be much less attractive as a result of its drawdown. The loss of white
water, itself, cannot be measured in terms of trade-offs to recreational
uses afforded by the hydropower project. Recreational uses of the white
water, on the other hand, can be directly related to post-project recrea-
tion. Present and future boating uses of Devil Canyon would not begin
to compare to other forms of recreation uses in the Upper Susitna Basin
(primarily hunting and fishing), with or without the project. The
visita.tion estimate was provided by a private consultant who closely
coordinated his procedures and methodology with the Bureau of Outdoor
Recreation and the Alaska Division of Parks, and is included in the
Recreation Assessment section, Appendix I, of the feasibility report.
82 The purpose of the hydropower project would be to provide projected
energy load requirements to the Southcentral Railbelt area and parti-
cularly to the two large demand centers of Fairbanks and Anchorage. The
esthetic impact of the transmission line will be carefully examined, and
every effort made to minimize its visual impacts in determining the
exact alinement of this facility. Consideration of underground cables
has been made, and a discussion of this alternative has been added to
the EIS.
83Achievement of national energy goals was not the only criterion upon
which the selection of the hydropower alternative was based. Neither
were environmental impacts the sole basis for the rejection of the coal
alternatives. Economic factors played a large role in these determinations.
158
84 The development of coal as a means of producing electrical power was the
economic standard against which each of the hydroelectric plans was
tested .. That is, the. power benefits used in computing the benefit-to-
cost ratio represented the cost of producing the same amount of power by
constructing and operating a generating system using coal as the fuel.
For purposes of simplification and more direct comparability to each
hydro system alternative evaluated, a single large coal-find complex
located in the Healy area was utilized. The Healy Creek coal district
has available reserves approximately equal to the energy production
requirements of the 100-year period of analysis. Since this coal field
has already been developed for this very purpose, it is a logical choice
for comparison. Socioeconomic impact would deve1op each time a generating
facility was constructed in the area, but the avera 11 permanent jobs ·
arising from operation would have a minimal effect on the overall
economy of the area.
85 Oil or natural gas, from whatever source, is expected to be an expensive
source of energy in the future. A major consideration in the hydropower
proposal is the conservation of nonrenewable resources. The benefit/
cost ratio of the proposed hydropower project would be comparable to
near future oil and natural gas alternatives.
86 As stated, the project--by itself--has a low firm energy capability and,
therefore, is not economically viable when compared with the economic
standard of coal. That is, in order for the project to pay for itself, ·I
the wholesale mill rate would be greater than that of an alternative
coal system. A fluctuating pool has less recreation potential than a
steady reservoir as proposed in the selected plan for the Devil Canyon
facility. This alternative is discussed in Section 6.04.02 of the EIS.
87 During the process of plan formulation, the objective of Environmental
Quality was considered along with the objective of National Economic
Development in the development and evaluation of alternative plans, as
prescribed by the Water Resource Council's Principles and Standards.
Thus, environmental impacts were weighed against the monetary benefits
for each of the alternatives explored.
88 The discussion of the transmission systems has been expanded in the EIS.
Since essentially all of the corridor system traverses either.public
lands or lands which may be assigned to the Natives, there should be no
significant potential for uncontrolled 11 Strip 11 development. An intertie
is essential if the proposed hydroelectric project is constructed. It
also has other advantages related to reliability of energy supply to the
State's two largest load centers. Average energy loss through the
transmission lines will be 0.7 percent of the total energy transmitted,
but the 6.1 billion kilowatt-hours of firm annual energy is the net
energy available at the delivery points near Anchorage and Fairbanks.
89 Should the proposed plan be implemented, the summer flows of the Susitna
River will be regulated, and water in excess of summer power needs
159
will be stored for release during the fall and winter months. There
would not appear to be any future water supply shortages for domestic/
agri cu ltura 1 use in the Lower Sus itna River Basin, and the proposed
dams only temporarily store the water for hydroelectric power generation.
90 Restoration of material borrow areas outside the reservoir pools will
be condocted to blend the sites into the surrounding area as much
as possible to minimize the esthetic impact. In compiling the construc-
tion tosts for all alternatives, the utilization of cement manufactured
outsi~e of Alaska was used. If local areas are developed as limestone
sources, appropriate measures will be taken to minimize the adverse
impacts of such action.
160
United States Department of the Interior
NATIONAL PARK SERVICE
IN REPLY REFER TO:
L7619
(PNR)CAE
Pacific Northwest Region
Fourth and Pike Building
Seattle, Washington 98101
October 22, 1975
Colonel Charles A. Debelius
District Engineer
Alaska District, Corps of Engineers
P .. O. Box 7002
Anchorage, Alaska 99510
Dear Colonel Debelius:
We have reviewed the draft environmental impact statement for
Hydroelectric Development, Upper Susitna River Basin, Southcentral
Railbelt Area, Alaska, and have the following comments.
We are quite concerned about the possibility of an above-ground,
high-voltage power line paralleling the eastern boundary of Mount
McKinley National Park. The statement does not give specific
information on.routing, tower design, or vegetational and scenic
impacts, so it is difficult to determine the extent of impacts on the ~Jl
Park and its visitors. We request that contact with our office in
Anchorage be maintained regarding the progress of this project and
that we be informed of decisions regarding the Cantwell to Healy
transmission corridor.
We feel that the alternatives for power transmission corridors on
page 89 are inadequate. Firstly, underground systems are not
considered--especially in the Cantwell to Healy section. Certainly
the cost for underground lines would be more, but the statement
should weigh economic considerations against the other impacts
involved. Impact on scenic values near Mount McKinley National Park
and in the Nenana Canyon will be substantial, and thus we feel that
undergrounding must be seriously considered.
The second reason we consider the alternatives for power transmission
corridors inadequate is that there is no analysis of impacts.
Figure 15 graphically presents the alternatives. The text then states
that the proposal was selected on the basis of cost, reliability, and
potential environmental impact, but none of the needed information is
presented. An environmental statement should present enough informa-
tion for the reader to understand why the proposal was selected over
the alternatives •
. ~.~~ . ~ ~
'<(' ~ ~ m a:. ~ ~ ~ 1-t.. ~
1;>?'6-19110 t6:1
92
93
'
The National Register Criteria (36 CFR 800) should be applied to the
9.4 cabi.n whic.h was identified by the Alaska Division of Parks and would
be inundated by the Watana reservoir. These procedures were printed
. in the Federal Register of February 4, 1975, and should be consulted.
Sincerely yours,
Edward J. Kurtz
Acting Regional Director
162
RESPONSE TO COMMENTS OF
THE NATIONAL PARK SERVICE
PACIFIC NORTHWEST REGION
91 A map has been added to the EIS which more clearly indicates the proposed
location of the transmission line corridor. The exact alignment
within this corridor, and tower design, have not yet been determined,
but esthetic impacts will be a primary consideration in powerline
location and tower design. In any event the transmission line
will be located on the east side of the George A. Parks highway
and the Alaska Railroad through the Broad Pass--r~ount McKinley
National Park area, and every effort will be made to either entirely
conceal the line or minimize its visual obtrusiveness. The
National Park Service will be kept fully informed of decisions
regarding the Cantwell to Healy segment of the transmission line
corridor.
92 The EIS has been expanded to include a discussion of underground
cables as an alternate made of transmitting electricity. Economic
considerations will not be the basis for selecting overhead trans
mission lines in lieu of underground cables. Other factors which
will be considered include environmental impacts, technical problems,
maintenance, and reliability.
93The EIS has been expanded to include a discussion of the relative
impacts of the alternate transmission line corridors.
94 As stated in the EIS, the current National Register of Historical
Places was consulted, and revealed no National Register properties
which would be affected by the project. National Register criteria
(36 CFR 800) will be applied not only to the cabin identified in the
preliminary reconnaissance study made by the Alaska Division of Parks
under contract to the Corps, but to the entire area affected by
the project. This includes thorough archaeological and historical
surveys along all access road routes, transmission line corridor,
and the dam and reservoir sites.
~163
UNITED STATES
DEPARTMENT OF THE INTERIOR
BUREAU OF OUTDOOR RECREATION
NORTHWEST REGION
IN REPLY REFER TO: 1 000 fi 5 GOb'D A\'EN!!E 91S S'"'CON"" A E3027 • · .. ... VENUE, RM. 990
SF 'TTIIiill, au: t!!IIIIU li'P8tl ?i'IQ4 SEATTLE, WASHINGTON 98174
Colonel Charles A. Debelius
District Engineer
Alaska District, Corps of Engineers
P.O. Box 7002
Anchorage, Alaska 99510
Dear Colonel Debelius:
N 0 \1 i_ ·1 1975
The Draft Environmental Statement, 11 Hydroelectric Power Development,
Upper Susitna River Basin, Southcentral Rai"lbelt Area, Alaska,11 has
been received in this office for review and comment. The following
comments are provided for your consideration.
We recognize that environmental studies are not complete; nonetheless,
we would like to mention two subjects which we feel should be covered
in more detail.
··1 The whole subject of roads to the hydroelectric developments, to the
95 rec.r .. e.at. ion fac·. ilities., a.nd to and along the transmission corridor has not
been adequately addressed. Locations and impacts of roads whether per-
manent or only for the construction period need to be discussed in
greater detail.
'
The intrusion of man as construction worker and later as recreationist
96 may have significant impacts on the ecology of this area. The effect ·
• of man and his machines and the impacts associated should be discussed
in greater detail also. .
I It should be noted that this is the view of our office and does not 97 necessarily represent the official view of the Secretary of the
Interior.
We appreciate the opportunity to comment and hope our comments will
assist in the preparation of the final statement.
Sincerely yours,
~1aurice H. Lundy
164 J;;;;;;:£(1 ~
.-,..
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF THE INTERIOR
BUREAU OF OUTDOOR RECREATION
~!)Specific location of roads, both permanent and temporary, has
not been determined at this stage of planning for the proposed
projects. · Deta·iled plann·ing and design for this transportation
network will be accomplished in the post-authorization stage. A
proposed road corridor has been identified for the approximate
64-mile road to the Watana damsite (Figure 4). Location, design,
construction, rehabilitation, and maintenance of the project road
system will be given prime consideration with the utilization of
good landscape management practices. When the specific road system
has been developed, this system and its related impacts will be
discussed in future supplements to the statement.
96 The opening up of the Sus itna Bas in to man and his machines is
considered one of the major adverse impacts of the proposed pro-
jects. This action will increase the need for institutional
regulations in an area that presently has few to control activities
that would be magnified because of easy access. This, in turn, will
have both social and economic impacts in that man may not be able
to do things in the future that he was used to doing in the past,
and would cost more because of the need to enforce the regulation
to protect the environment.
9 11 Noted.
1.65
98
100
U. S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
Room 412 Mohawk Building
222 S.W. Morrison Street
Portland, Oregon 97204
November 24, 1975
Colonel Charles A. Debelius
District Engineer
Alaska District, Corps of Engineers
P. 0. Box 7002
Anchorage, Alaska 99510
Re: Draft Environmental Impact Statement
Hydroelectri.c Power Development
Upper Susitna River Basin
Southcentral Railbelt Area, Alaska
Dear Colonel Debelius:
IN REPl.Y REFER TO
10ED.3
We have the following comments on the above DEIS which you may wish
to consider:
1. The report depicts that the general choice of the routes to place
the transmission lines is within the existing highway corridor
from Summit to Healy. At present, there is nothing to mar the
pristine beauty of the valley except for the railroad on one side
and the highway on the other. The Nenana River meanders through
a pass in the Alaska range. The beauty is stunning viewed from
both the railroad and the highway. To add a transmission line
through this corridor would certainly destroy the unusual natural
beauty. The Broad Pass area south of Cantwell is without trees
and transmission lines would be difficult to hide.
We have noted there is no mention of the recent archeo"logical
find near Carlo Creek. You may wish to include this in your
discussions on page 93.
3. A discussion of impacts to the existing highway system that may
occur as a result of this project is needed. This should include
the potential need for reconstruction or added maintenance costs
resulting from transporting necessary construction materials.
Also, any hazards to traffic that may occur during construction
should be discussed.
We appreciate the opportunity to comment on this draft EIS.
... 166
Si nee~ ly yours,
fi 2~~/1f~£iu:r-
Richard C. Cowdery, Direc~ ,
Office of Environment and Design
RESPONSE TO COMMENTS BY
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
98 Comment noted.
99
100
The recent archeological find near Carlo Creek was excavated in a
road cut on the Parks Highway near Mt. McKinley National Park.
The remains of both fossils and artifacts were found in this
buried site. Thorough archeological reconnaissance will be made
of the entire transmission line corridor prior to establishing the
exact alinement of the transmission line. It is expected that most
sites can be avioded by judicious alinement. If and where this
should be impossible, appropriate salvage or other mitigative
measures will be taken.
The total impact of this project on the existing highway system
has not yet been evaluated. the impact would include additional
vehicle travel due to the project construction phase. Only a mod-
erate increase in vehicle traffic over normal highway travel due
to the use of project facilities is expected after project construc-
tion. Studies required to evaluate the potential need for recon-
struction or added maintenance costs will be made during the
detailed planning phase. No such needs have been identified during
the feasibility stage of planning. Impacts on the highway system,
overall, should be minor.
1617
Form ::.or F 1320.1 (1-67)
UNITED ~-rATES GOVERNMENT
Memorandum
DEPARTMENT OF TRANSPORTATION
OFFICE OF THE SECRETARY ~\
DATE: November 11, 1975
SUBJECT;
Hydroelectric Power Develo[)ment, Upper In reply
Susitna River Basin, Southcentral Railbelt Area, refer to:
FROM
TO
Alaska
Secretarial Representative, Region 10
District Engineer
Corps of Engineers
Anchorage, Alaska
Attached is the only comment received from DOT agencies on the
subject EIS.
~
P . Regional Representative of the
Department of Transportation, Region 10
Attachment
168
DEPARTMENT OF TRANSPORTATION
UNITED STATES COAST GUARD
From: Commander, Seventeenth Coast Guard District
MAILING ADDRESS:
COMMANDER { rln 1'
17TH coAsT o.JA'Wb DISTRICT
FPO SEATTLE 11771
1 October 1975
To: Secretarial Representative, Region 10, Seattle, WA.
Attn: CAPT R. T. BROWER
Subj: Review of EIS for Hydroelectric Power Development, Upper
Susitna River Basin, Southcentral Railbelt Area, Alaska;
comment concerning
1. Subject ElS has been reviewed and the only significant Coast I
Guard impact would be the increase in recreational boating activity 101.
on the newly created 1 akes behind the dams. No other areas of
Coast Guard interest were revealed.
By
1.69
101 Comment noted.
RESPONSE TO COMMENTS B'U
U.S. DEPARTMENT OF TRANSPORTATION
COAST GUARD
170 ··-·'
.~ ..
DEPARTMENT OF THE ARMY
U.S. ARMY COLD REGIONS RESEARCH AND ENGINEERING LABORATORY
HANOVER, NEW HAMPSHIRE 03755
CRREL-RE 12 November 1975
SUBJECT: Review Draft Susitna Impact Statement
District Engineer
U.S. Army Engineer District, ALASKA
P.O. Box 7002
Anchorage, AK 99510
1. USACRREL staffs both in Fairbanks and Hanover have reviewed the
Draft Environmental Impact Statement, "Hydroelectric Power Development,
Upper Susitna River Basin, Southcentral Railbelt Area, Alaska." We
find the report a comprehensive assessment of the proposed project and
one which deals realistically with the adverse environmental effects.
2. Our comments are more specifically directed at questions requiring
further investigation and which should be kept in mind as the project
develops. These are briefly stated:
a. The influences and constraints of permafrost at the dam sites
for design purposes and in the reservoirs, particularly as related to
erosion along shorelines. The need for proper assessment of permafrost
conditions and how the impoundment will modify ground temperatures is
apparent.
b. The influence of a fluctuating river level below Devil Canyon on
winter ice formation. Ice production is likely to increase as a result
of the fluctuating water levels (breaking up of the ice cover due to
peak power releases). This may cause down river ice problems due to
natural or man-made obstructions.
c. The production of frazil ice in the white water section of Devil
Canyon and earlier ice formation in the reservoir. These may result in
restricted flow conditions and greater ice formation in the impoundment.
d. The change in reservoir and dom1 river water qualities particularly
under winter, ice-covered conditions. The question of modified sediment
load and its significance to both fish productivity and flood plain ecology
requires additional investigation.
1.71
102
' 103
CRREL-RE 12 November 1975
SUBJECT: Review Draft Susitna Impact Statement
e. Modification in flood plain and reservoir shoreline vegetation as
a source of high quality forage for moose and waterfowl and methods to
reduce adverse visual impacts. The question of large, seasonal fluctuation
in the Watana impoundment and how to stabilize the shoreline for wildlife
and recreational use and erosion control requires further investigation.
f. Site investigations related to transmission line corridors. These
are required to resolve questions of large mammal impacts and optimal
·restoration techniques for erosion control and visual impacts.
3. He also note an apparent discrepancy :i!n the calculation of the annual
production of 3.0 billion KWH for the Devil Canyon (180MW/44oo cfs/Francis
unit is given on p. 3; on p. 45, Table I, average regulated flow is
approximately 4200cfs/month; 9200cfs/4400cfs/180MV ::;:;: 376M\{ per month or
4.5 billion KWH per year). Is this a real difference or due to assumptions
made in arriving at the 3.0 billion figure?
4. I look forward to receiving copies of,the final statement and in pro-
viding the District with continued input from our staff.
ROBERT L. CRmiBY .;. / · .
Colonel, CE 7 .
Commander and Director
2 t72
RESPONSE TO COMMENTS BY
DEPARTMENT OF THE ARMY
CRREL
10"'> The Corps generally concurs with the needs for further investiga·
~ tions as itemized under paragraph 2 of the CRREL letter. All
necessary additional engineering and biological studies will be
conducted during the pre-construction stage of planning.
103 The 4,400 cfs relates to the maximum discharge per each 180 mw
(name plate) unit, and in no way enters into the energy potential
of the river. The actual dependable capacity of each unit is
roughly 171 mw based on the firm annual energy and a 50 percent
plant factor. It must be realized that only under peak load re-
quirements or heavy reservoir inflow would all 4 turbines be
operated simultaneously. For example, if all 4 turbines were
operated at full overload capacity for an entire year (4 X 180 mw X
1.15 = 828 mw), the energy produced would be 7.25 billion kilowatt
hours of energy. By applying the Devil Canyon maximum head to
the basic power equation, the resulting average monthly streamflow
required to produce the hypothetical 7.25 BKwh energy would be in
excess of twice the average monthly streamflow of 9,200 cfs.
Subsequent estimates of dependable capacity based on average annual
evergy have resulted in a re-sizing of the Devil Canyon units to
194 mw, each with a maximum hydraulic capacity o'f roughly 6,200 cfs.
-_1.73
U.S. EN VI R 0 N MeN T A L P R 0 T E C T I 0 N A G E N C Y
REGION X
1200 SIXTH AVENUE
.SEATTL.E, WASHINGTON 98101
IIEPLY TO
. ATTN OF: lOFA -MIS 623 November 13, 1975
104
Colonel Charles A. Debelius
Department of the Ahny
Alaska District, Corps of Engineers
P. o. Box 7002
Anchorage, Alaska 99510
Dear Colonel Debelius:
We have completed review of your draft environmental impact
statement, .. Hydroelectric Power Development, Susitna River Basin 11
and: submit th.e fo 11 owi ng corrunents.
The increased river turbidity during the winter months caused
by releases from the reservoir is of particular concern. The
statement, on page 46, says 11 preliminary studies by the Corps of
Engineers indicate that the suspended sediment would be at low levels
(15-35 ppm) ... These levels of suspended sediment are sufficiently
high to warn of potential violations of water quality standards.
These Joint Feder,al-State Water Quality Standards (18AAL· 70.020)
limit suspended solids by prohibiting deposits which adversely affect
fish and other aquatic life reproduction and habitat. The standards
limit turbidity to less than 5 Jackson Turbidity Units (JTU) above
background.
We recognize the high natura 1 suspended solids 1 oad carried by
the Susitna River. During the winter, however, the Susitna contains
relatively clear water. The absolute value of the solids level is
n6t as important as the change in timing of the higher solids level
from summer to winter. The magnitude of this change and potential
standards violations should be discussed in the final impact statement.
' .
I Another concern would be possible altered temperatures due to
releases from the reservoir. According to· the statement, by using
multiple level discharge outlets, the temperature of the released .
water could be made to approximate natural conditions. We are interested
·"'. ~··'4 i..l
..
2
in the operational details of this procedure. How will natural tempera-
tures be established once the project is in operation?
, The discussion of supply and demand of electric power on pages
40 and 64 implies no large excess of power not needed by the projected
population increase. That is, no large amounts of power~would be ·
available to promote large scale industrial projects with their
secondary environmental effects. A more quantitative discussion is
needed to show the approximate equivalence· of future demand and supply
of energy.
Under 11 Sedimentation 11 on page 62 mention is made of deposits of ·
heavier sediments in the upper reaches of the Watana reservoir. Would
the h.igher drawdown at Watana combined with gradual bottom slope and
sediment accumulation form large mud areas devoid of vegetation?
Would these areas tend to increase as the age of the project increased?
These questions and possible remedies need to be addressed.
Additional environmental studies are promised when congress.ional
authorization for the project is obtained. Because of the presen.t
insufficiency of information in some areas, the statement is not adequate
for review purposes at this time. Consequently, we are classifying
~;~ur comments on this project as ER-2 (Environmental Reservations-
Insufficient Infonnation). The ER rating is based on the potential
violation of Water Quality Standards. This issue must be addressed
in the final stat(Tiee'nt. The Insufficient Information rating is based
on the anticipated--future studies. This classification of the Environ-
mental Protection Agency's comments will be published in the Federal
Register in accordance with our responsibility to inform the public of
our views on proposed Federal actions. . . . · r··
Our rating of the project relates sol ely to its water qua 1 ity aspect's
and does not indicate either our opposition or support. The Environmental
Protection Agency's responsibility is to make certain that adverse impacts
within our area of expertise are clearly documented.
Thank you for the opportunity to comment on this draft environmental
impact statement. If you have any questions concerning· our corrments
or categorization procedures, please let us know.
Sincerely yours,
W ()iO c.-.D _j c~ '2-f-'--l~
Walter D. Jaspers
Director
Office of Federal Affairs
1.75
lios
06
1.08
RESPONSE TO COMMENTS BY
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
104 Due to the sediment retention characteristics of the reservoirs,
suspended sediments downstream from the Devil Canyon Dam would be
significantly reduced overall. This reduction would be most
apparent during the summer months when gl aci a 1 melt results in
extremely high sediment loads. This presently occurs during the
salmon spawning period, when siltation and turbidity are likely the
most critical to aquatic life reproduction and habitat. The EPA
estimated increase in turbidity during the winter months may be
high. These estimates of 15 to 35 ppm in the releases at Devi.l Canyon
Dam are based on measured suspended sediment concentrations below
glacial-fed natural lakes in Alaska, including rivers flowing from
Skilak. Tustumena, Eklutna, and Long Lakes. The proposed projects
will have multiple-level discharge outlets which will permit selective
withdrawal of outflows from a range of reservoir elevations. As
stated in Section 4.01 of the EIS, sediment samples taken by the
AlaskaDepartment of Fish and Game during the winter of 1974-75 in
the Susitna River between Gold Creek and Talkeetna indicated a range
of 4 to 228 ppm.
1tJ5 One of the major reasons, along with control of oxygen content, for
incorporation of multiple-level discharge outlets into the dam
structures is to provide for temperature regulation of water released
from the reservoirs. Since there will be thermal stratification
in these deep pools throughout the year, water can be released from
various heights, or combination of heights above the 11 dead 11 storage
space, to provide a mix of waters approaching natural streamflow
temperatures.
106 See response number 255.
ltf7 The answer to both questions is 11 yes. 11 These are phenomena charac-
• · teristic of any reservoir receiving heavy sediment loads and having
significant periodic drawdown. Mudflats would become most extensive
in areas immediately above the low-water pool. As the water level
falls from the high pool elevation, much of the sediment accumulated
within the inundated streambed would be flushed down into the
reservoir. Lands immediately above the low pool elevation would
become inundated too early in the spring for plant growth to establish.
However, the higher elevations within the drawdown area would probably
develop a growth of annual grasses and forbs prior to being inundated
late in the summer or early fall.
1lf8 Comments noted.
17fl
.~
)
FEDERAL POWER COMMlSSION
REGIONAL OFFICE
555 BATTERY STREET, ROOM 415
SAN FRANCISCO, CAL.IF. 94111
Colonel Charles A. Debelius
District Engineer
Alaska District, Corps of Engineers
P. 0. Box 7002
Anchorage, Alaska 99510
Dear Colonel Debelius:
December 4, 1975
We have reviewed your Draft Environmental Impact Statement on the
HYdroelectric Development Upper Susitna River Basin, Southcentral Railbelt
Area, Alaska, dated September 1975.
These comments of the San Francisco Regional Office of the Federal
Power Commission's Bureau of Power are made in accordance with the National
Environmental Policy Act of 1969, and the August 1, 1973, Guidelines of the
Council on Environmental Quality.
Our comments are primarily directed toward the need for power that
would be J?roduced by the Upper Susitna Development, the alternative power
sources, and the fUel situations relative to non-hydroelectric power
alternatives.
The recommended plan is to construct dams and power plants at the
Watana and Devil Canyon sites and electric transmission facilities to the
Railbelt load~enters. The proposed plan for the Watana site would include
the construction of an 810-foot high earthfill dam and power plant which
would contain three Francis turbines with a nameplate capacity of 250 MW
each. The firm annual generation would be 3.1 billion kWh. Development of
the Devil canyon site would include a 635-foot high thin-arch dam and power
plant with four Francis turbines, each rated at 180 MW. The firm annual
generation would be 3.0 billion kWh with regulated streamflow from Watana
storage. The electrical power generated would be transmitted to the
Fairbanks -Tanana Valley and the Anchorage -Kenai peninsula areas. The
recommended development is shown to be economically feasible.
177
- 2 -
(1) The Need :for Power
We agree with and endorse the subject report's assertion in Section 2.04
that substantial amounts of new generating capacity will be needed to meet
future power requirements of the Southcentral Railbelt area. Recent studies
o:f the Southcentral and Yukon region (which includes the Southcentral Rail-
belt as its main component), as defined in the 1974 Alaska Power Survey Report
of the .8xecutive Advisory ColTIDlittee, indicate that rapid rates of increase
in power requirements will continue at least for the balance of the 1970's,
reflecting economic activity associated with North Slope oil development
and expansion of commercial and public services. Estimates beyond 1980
reflect a range of assumptions as to the extent of future resources use and
industrial and population growth. All indications are that accelerated
growth will continue through the year 2000, with economic activity generated
by North Slope oil and natural gas development being a major :factor -but
only one of several important :factors. It is generally considered that the
Southcentral-Yukon regional population will continue to grow at a faster
rate than the national and state averages, that future additional energy
systems and other potential mineral developments will have a major effect,
and that there will be notable expansion in transportation systems. Signi-
ficant economic advances for all of Alaska and especially for the Alaska
Native people should be anticipated as a result of the Alaska Native Claims
Settlement Act. Other influencing :factors could be cited, but the general
outlook is for further rapid expansion of energy and power requirements in
the Southcentral-Yukon area.
A range of estimates for :future power requirements of the Southcentral
and Yukon regions is presented in the 1974 Report of the Alaska Power Survey
Technical Advisory Conunittee on E;conomic Analysis and Load Projections. The
range of estimates attempts to balance a myriad of controlling factors
including costs, conservation technologies, available energy sources, types
of Alaskan development, et cetera. The higher growth range anticipates
sig;ni:ficant new energy and mineral developments :from among those that appear
more pronuslng. The lower growth range generally asswnes an unqualified
slackening of the pace of development £allowing completion of the Alyeska
pipeline and, in our opinion, is not considered realistic. 'Ihe mid-range
growth rate appears to be a reasonable estimate which we adopt as most repre-
sentative based on recent manifestations and our assessment of future condi-
tions •. It should be noted that there are several responsible advisory committee
members who :feel that recent acceleration of mineral raw material .shortages
of all kinds indicates a possibility that eYen the high range estimates
could be exceeded. Table 1, which is a cond~nsed extract of information
contained in the aforementioned advisory committee report, summarizes load
estimates :for the Southcentral and Yukon Re~~ns. Indicated load increments
by decade are as follows:
j '"':"11..) ... to
Higher
Estimate
Mid-Range
-3 -
Increments of Southcentral-Yukon Power Requirements
1972-1.980
Peak Annual
Demand Energy
MV GWh
888
638
4 623
3 093
1980-1990
. Peak Ann:ual.
Demand Energy
MW GWh
4 460 28 110
930 4 570
1990-2000
Peak Ann~
Demand Energy ·
MW GWh
2 800 13 070
1. 95<> 10 240
.1972-2000
Peak Annu:U.
Demand. · Erl,ergy
Mil . GWh
8 148 45 803
3 518 17 903
According to the subject report, a total of 61.00 G!-lh of firm annual.
energy would be produced by the combined Devil. Ganyon-Watana system which
would have a nameplate capacity of 1470 MoT. .AJ.though the report does not ...
indicate proposed commercial operation dates, based on information in our
fil.es the project would be staged and the ini tia1 Devil Canyon installation
(3000 GWh and 720 MW) could become operable in 1985 and the ultimate installa-
tion in 1990. Under this timetable it is apparent that there is a need for
power in the Southcentral-Yukon Region by 1985 and 1990 in the order of' mag-
nitude of at least as much as the proposed subject development. Therefore,
operation of the proposed project would help meet the power needs of the
Southcentral Railbelt area by 1985 and beyond.
(2) .AJ.terDative Power Sources and Fuel Situation
OUr recent estimate of power values for the Devil Ganyon-Watana project
indicates that the most economical alternative to the project's output would
be power from a combined cycle generating plant using natural. gas as an operat-
ing fuel. We acknowledge the subject report's premise that there are many
questions concerning future availability and costs of natural gas and oil
for power production. It is the policy of this Commission to discourage use
of natural gas as an operating fuel for power generation in the contiguous
United States. Due to changes in requirements, other Federal and/or Stai;e
agencies may impose restrictions on the future usage of natural gas and oil
for electric power production throughout Alaska. Recognizing the undertainty
of the future availability of natural gas and oil after 1985 f'or new generat-
ing capacity, the possibility of its restrictive use if available, and its
sensitivity to worldwide pressures, coal may be the most likely alternative
fuel. for thermal-electric plants to be constructed in the mid-1980's and beyond.
Essentially, we agree with the discussion of alternative sources of power in
paragraphs 6.02.1 -6.02.10 of the subject report.
179
- 4 -
( 3) other Al terns. ti ves to the Proposed Action
· The Corps' DEIS discusses several potential alternative hydroelectric
developments within the Southcentral Railbelt Area. All of' these alternatives
either have a greater adverse envirorunental impact than the proposed plan,
or are not considered feasible at the present time.
Attachment
(Table 1)
Very truly yours,
ill// £1:/ (Deputy)
M. THOMAS
(Acting) Regional Engineer
180
TAGLE 1
Total Power Requirements .
Sot1thcentra 1 and Yukon Regi ens 1!
Actual Requirement~
.. 19.72
Estimated·Future. Requirements
1980 , 990
. Peak · .. Annua 1 Peak Annua 1 Peak Annual Peak
2000
Annual
Demand· Energy Demand Energy Demand Energy. Demand Energy
Region
Scuthcentral
Yukon (Interior)
I Tot a 1 l~
(l)
~'
Southcentral
Yukon (Interior)
Total
~~H .. · G·~/h
317 1 4·65
115 542
432 2 007
11 As defined in the 1974 Alaska Power Survey
~1YJ
990
330
1 320
790
280
1 070 .
m·Jh 1111~ G\·lh ~~~~ . G\tlh
Higher Rate of Growth
. 5 020 5 020 30 760 7 190 40 810
1 510 .. 760 3 980 1 390 7 000 .
6 630 .. 5 780 34 740 8·580 47 810
Likely Mid-Range Growth Rate
3 790 ·1 530 7 400 3 040 15 300
,• .......
1 310 470 2 270 910 ·4 610
5 100 2 000 9 670 3 950 19 910 .
)
RESPONSE TO C0~1MENTS BY
FEDERAL POWER COMMISSION
REGIONAL OFFICE
109Statements and coTTIJlents from the Federal Power Commission are noted,
including the general agreement on power needs and alternatives.
182
.;-.,..
STATE COMMENTS AND RESPONSES
State of A 1 as ka.
State Policy Development and Planning
Department of Environmental Conservation
Department of Commerce and Economic Development
Department of Fish and Game
Department of Natural Resources
Department of Public Works
183
Comments
110-111
112-125
126-128
129-160
161
162-169
JAYS. HAMMOND. SOVIRNOR
OJ4'FitE OF TilE GOVEilNOR
·STATE /101./CY DEVELOPMENT AND PLANNING POUtN AD-JUNEAU S!JIII
PHONE 4SUSIZ
C~lanel Charles A. Debelius
Corps of Engineers
Districj: Engineers
Department of the Army
Alaska District
P.O. Box 7002
Anchorage, Alaska· 99510
November 10, 1975
Subject: Southcentral .Railbelt Hydroelectric Project
State l. D. No. 75091103
I •
Dear Colonel Debelius:
The Alaska State Clearinghouse has completed review on the subject
project.
The following agencies were invited to review and comment:
State of Alaska
Department of·Community & Regional Affairs
Office of Planning & Research (H&SS)
Department of Environmental Conservation
Department of Fish & Game
Anchorage
Fairbanks
Department of Highways
Department of Law
Department of Natural Resources
Division of Lands
Division of Parks
Department of Public Works
Department of.Commerce & Economic Development
Alaska Energy Office
Division of Policy Development
Five of the above agencies responded and their comments are attached .
. .
. IThe State does not o~ject to this project at this time, however~ our final 110 position cannot be determined until a more comprehensive r,eview of this
project has 'been completed by the State. :
184
..
~.
Colonel Charles A. Oebelius - 2 -
November 10, 1975
It is obvious frn": ·Lilt• l'l~:;po11sas rcu~ivNl ·in this office that a great
deal of additional studies will have to be done before the real impact
can be determined. The Governor has created a multi-agency State Task
Force to conduct a thorough assessment of the Susitna River hydroelectric
. power development proposals. This group will make recommendations to
the Governor on a number of critical aspects of the proposal, including
an analysis of demand projections, a l.terna te energy sources, growth
impacts, and environmental effects. The Corps should consider this Task
Force as its basic contact with the State on this project .
• The Clearinghouse finds this project to be consistent with State long-range
planning goals and o~jectives. Therefore, this letter will satisfy the
review requi rentents of the Office· of Management and Budget Circular A-95.
Sincerely, . '
a~A~J;w.~ ·~~:d~. Estess
State-Federal Coordinator
Attachment
cc: Conmissioner Langhorne Motley
185
111
110
111
RESPONSE TO COMMENTS OF
STATE OF ALASKA
STATE COVER LETTER
Subsequent to receipt of the Alaska S~ate Clearing House letter
of 10 November 1975, the Corps met with the Governor·'s multi-
agency State Task Force on 12 December 1975. This group was
established to conduct a thorough assessment of the Susitna River
.hydroelectric power development propos a 1 , and to make recommend-
ations to the Governor on a number of critical aspects of the
ptoject. The purpose of this initial meeting, which was considered
very fruitful by Task Force members, was to provide a more comp-
rehensive review of the project. Subsequent coordination will
be conducted with the Task Force to provide them with additional
information on which to base their recommendations.
Detailed studies will be conducted in the future to evaluate, in
depth, the impact of the project before recommending funding of
construction should the additional studies indicate the project is
still viable.
186
~MEMO.RANDUM State of Ala~~-.~ I . ,~, ..
TO:
FROM:
• ""' ... , ... " ;J /·~( '1 1 '·.I I • ::·, :11 · ·:!J :?, ;f .. ; ·c" , ....
Raymond W. Estess
State-Federal Coordinator
Division of Policy Development
DATE ·. November 3 1975 I ·~·. ! "' ,, ·•., 1
-' 1 '""' • , • ....: I ' ·;·
FILE NO:·
'·~Jl Lt~~::~-~. f{d
. '( ·•.il~;
and Planning «· ' r • '. ~. . .... " . ~., ,, ... . " ·-~
... ~ i,. -~_ ..... , ~.7 {·· ...
~-~ ·"~"·r~
Of.fice oft~ G.~· . . TELEPHONE NO:
Ernst W. Muelle~U..U ~{JR. . SUBJECT:
Commissioner
Department of Environmental Conservation
Draft EIS--Hydroelectric Power
Development, Upper Susitna
River
The Department of Environmental Conservation is aware that the proposed
activity is a legislative action. However, if the Congress does authorize
the cons~ruction of this project as the Corps of Engineers is r~questing,
the Corps must initiate detailed studies culminating in the formulation of a
comprehensive environmental impact statement on the proposed hydroelectric
power project. Rather than.l?;i.mply commenting on the draft EIS, it is essential
that this Department and oth"er· interested, State and Federal agencies partici-12
pate in all stages of the planning, research, and construction review phases
of this activity.
To tmplement this proposal, the Department of Environmental Conservation
proposes that a joint Federal-State task force be formed and meet on a
regular basis to review, comment,) and advise the Corps on the environmental
implications of each phase of the proposed hydroelectric power project in
the Uppe·r Susitna Basin~ Members of this task force should include repre-·
ser:itatives from the Governor's Energy Office, the Department of.Environmental
Conserv~tion, the Department of Fish and Game, the Department of Natural 13 Resources, the United States Fish and Wildlife Service, the National Marine
Fisheries Service, the Bureau of Land Management, and the Ala.ska Power
Administration.
By utilizing such an interdisciplinary planning team, the environmental, k.
social, economic, and engineering aspects of this proje<:;:t can be fully 14 ..
analyzed and researched, and appropriate mitigating measures taken.
The following are our comments on the draft EIS:
The figure of 35'!; salmon 'fry mortality in turbines (p. 51, EIS} shoul~ be
footnoted and referenced as there are a large number of variables that may
affect this fig~re. In ·a:ddition to fish mortality in turbines, there are
several other project-associated conditions listed which, if considered
collectively, might represent potential for significant impact to resident
and anadrornous fish. They are as follows:
a.· The unspecified effects of cooler summer and winter water
temper'atures. on anadromou~ and resident fish (p. 67 of the
Feasibility Study).
b. The effects on migrating fish caused by the reduction of
natural river flows during late June and early July (p. 69).
187
115
116
117
nsf
119
Raymond w. Estess - 2 -
November 3, 1975
c. 'Effects of the spilling of water over Devil's canyon Dam
(pp. 66-67).
d. The possibility that reduction in flow, turbidity, and·
temperature below Devil's Canyon Dam might cause disorientation
of migrating salmon during an "initial period" during and
1 af.ter construction (p. 70).
e. The feasibility of passing migrating fish over and through
the high dams (p. 72).
r
On page 75 of the Feasibility Stud~, there is the possibility, however small,
that transmission lines might impede migrating big game through its inherent
·characteristics, such as constant noise (line hum) and "smell" (ozone). Any
in-depth studies of impacts resulting from this project's transmission line
routings~ including al,ternate routes, should be referenced. In addition to
direct impacts such as on scenic-visual quality and archeological sites, such
studies should deal with indirect impacts such as new residences, for example,
the new capital site and industries that otherwise could not locate in the
region without the available power.
The figure cited for frequency of spilling excess water at the Devil's Canyon
Dam on page 46 (once every 10 years, three-day duration) can also be con-
tested. The magnitude of the nitrogen super-saturated water problem on the
Columbia River suggests that resident and anadromous fishes could be adversely
affected on a much more frequent basis. The reduced flow velocity downstream
from the dam will more than likely allow passage of fish upstream into ·pre-
'ITiously inaccessible areas adjacent to the dam, subjecting them to the
problems cited above. Precautions taken to mitigate these problems are not
stat.ed and one has to assume that few, if any, measures will be taken in dam
construction to accotnmodate these concerns.
In reference to page 58,
case predominately white
important avian species.
EIS, the climax or near climax vegetation, in this
spruce, is also preferred nesting for a.number of
On~ major potential adverse impact not mentioned (p. 67, EIS) is failure of
the dam structure. With regard to this, more detail is needed on the high
potential in the region for severe seismic activity. What, in addition to
seismic shocks, are the chances for landslides generating surges·of dis-
placed water, fault displacement, and other responses to seismic activity
f!Xcecdinq·structural limits? The effect of inundated areas of seismic
activity is only now being understood, .and must b'7 fully addres.scd in the EIS.
Attention should also be giv~n to any landslide potential res}llting front
inundation arid subsequent saturation and/or erosion of slopes. This is
particularly true where permafrost exists. Little is known and less is
understood about the behavior of permafrost around and under an inundated
area, but one certainty is that it will thaw. under water and where exposed
·at' shoreline. This could lead to mass wasting on even moderate slopes.,
creating an unstable condition that could then migrate uphill. A detailed
188
..
Raymond w. Estess 3 -'November 3, 1975
treatise on the.behavior•of permafrost is strongly recommended for this pro-
ject. The threat of massive erosion resulting from liquification of perma-
frost constitutes a priority impact consideration.
What volume of sediment annually do the ppm load figures represent, i.e., what:
is the basis for projecting a "500 year" project life? (p. 91.)
One failin9 of the environmental impact statement is a more detailed analysis
of Alternative Hydrologic Basins in the southcentral Railbelt Area (6.03) and
Alternative Power Transmission Corridors (6.05) •. While the ease for the
Upper Susitna River site is convincingly and completely presented and acknowl-
edging that the OE!IS is written specifically for this site, the alternative
areas are not developed in sufficient detail. Phrases like "tremendous
financial .in\l'estments" and "sUbstantial environmental impacts" (p. 79) are
used to justify rejection of specific alternati\l'es. These comments are highly
subjective and should not be substituted for fact~al data.
It is also a point of conjer:ture that alternative exotic cner;gy 'sources~
particularly geotherm.:ll, should be categorically dismissed as be.ing economic-
ally and technologically impractical in th.is region. This is not necessarily
so and may represent a serious underestimation of their long-term potential.
For example, hydrogeneration from non-constant energy sources is showing much
promise. Also, tidal power was understated ·as there is potential for using
Cook Inlet's large tide range in an environmentally acceptable manner.
The us~ ofdifferent scales for the map series Figures 4-8 makes easy com-
parison of competing land use values difficult. This is especially true.
where.the major landmarks (e.g., Susitna River and tributaries) are not
included on the map. For example, compare Figures 4 and 7. The· Upper
Susitna River, Watana, Devil's Canyon Damsites, .and proposed transmi.ssion. ·
corr"idors should be highlighted on the habitat map so that the impacted area
can be. easily seen.. It would also be helpful to incorporate more detailed
information on wildlife distribution and seasonal movements in the final·
environmental statement than that provided by the map series of the Joint
Federal-State Land Use Planning Conunission. One major source in this regard·
could be the Alaska Department of Fish and Game's Alaska Wildlife and Habitat
Atlas. This information base could be further expanded through in'fO'rinal dis--·--cussions with wildlife biologists of the State and the u. s. Fish and Wildlife
Service.
One point that . has not been adequately addressed in th.e DEIS is the following
·question: Will the proposed hydroelectric• power dcvelopment·act; as a catalyst
for um-1anted growth in Southcentral.l\laska? The literature is replete with
cases which clearly indicate that highways and.scwer and water systems can
induce unwanted growth. Docs the smnc rationale hold true·for the proposed
hydroelcctr~c facility in the Upper Susitna Basin? These questions have been
only weakly addressed ori pages 63 and 64 of the DEIS.
189
fl20
J121
22
124
125
RESPONSE TO COMMENTS BY
STATE OF ALASKA
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
112 Concur.
11.3 Concur. We suggest that local government entities also participate.
11..4 Conment noted.
1. iS Tf~e 35 pbercednt mocrtalityf Erat~ on fish, s~ch as yountgh salh~onh,dis a 1gure .· ase on orps o ng1 neers expenence at o er 1 g . ams.
116
a. This will be a factor. Alteration of temperature regime
will certainly influence salmon egg development, and possibly
outmigration time~ As stated in Section 4.01 of the EIS, the use
of multi-level discharge outlets at the dams would allow for some
adjustment in temperature to approach the natural river temperatures.
b. The ·EIS acknowledges in Section 4.02 the possible impact on
migratory salmon.
c. Supersaturation of gases requires more than spill. Tem-
perature, distance, and volume are alsofactors. This impact is
discussed in the EIS and will be the subject of detailed design
studies.
d. Same as b.
e. Based on extensive studies on the Columbia River and in
British Columbia, cost, engineering, and biological considerations
cumulatively make fish passage over high dams infeasible.
Concur. These considerations will be studied and evaluated in
detail. prior to any recommendation for project construction.
117 A change in design of outlet and generating facilities at the
dam has revised the spill frequency at Devil Canyon as shown in
the EIS. Salmon are not likely to attempt to migrate to the dam,
even if passage is possible (which appears unlikely)since the last
tributary in which they are able to spawn is Portage Creek--
several miles below the dam. Contrary to the stated assumption~
fea·tures will be incorporated into the dam outlet works to mini-
mize nitrogen supersaturation.
118 Comment noted.
119 Dam design will incorporate features to withstand earthquakes of·
190
.~'
An extreme magnitude of 8.5 with an epicenter o~ 40 miles which is
greater than the maximum credible earthquake that could be expected to
affect these damsites. No dams designed by the Corps of Engineers have
ever failed, and the Corps has a record of being very conservative ·; n
designing safety features into dams.
120 For a discussion of landslide potential resulting from thawing of
permafrost, see response Number 173.
121 Additional sediment information can be found in Appendix I of the
feasibility report. Project costs and benefits are based on a standard
1 00-year period for this type of project. Actual useful life of the
project would be substantially more than 100 years, and, based on
sedimentation studies alone, the project would have a useful life in
excess of 500 years.
122 The alternative hydrologic basins and power transmission corridors were
studied in sufficient depth to determine their economic, social, environ-
mental, and engineering feasibility. All alternatives rejected for
further consideration failed to meet standards of acceptability under
one or more of these criteria. A more thorough analysis of each of
these alternatives is displayed in the Feasibility Report and its
technical appendices. Phrases such as .. tremendous financial invest-
ments .. and 11 Substantial environmental impacts 11 are supported by the
results of previous studies on many of the alternative damsites.
Reports of these studies are available in the District office. These
terms are not the basis for rejection of specific alternatives. The
Congressional mandate specifically directed the Corps to evaluate the
Devil Canyon Project.
12 3 11 Exotic energy sources .. were not categorically dismissed. The long-term
potential of geothermal energy is clearly acknowledged in the first
sentence of the discussion of this alternative, which states: "Geo-
thermal resources may eventually provide significant power generation in
Alaska; ..... 11 (emphasis added). However, as clearly stated in the EIS,
this alternative depends on technological development and economic
feasibility. Futhermore, it is considered to be a future supplemental
means of generating power. It is not considered to be a reasonable
alternative to proven types of power generation within the time-frame of
projected future electrical needs. Tidal power is not rejected on the
basis of technical feasibility. We do not agree that it could be
developed in Cook Inlet in either an economically or environmentally
acceptable manner within the fore~eeable future.
124 The Susitna River and the damsites have been emphasized in figures
showing the various resources within the Railbelt area. Information in
the Alaska Wildlife and Habitat Atlas is similar to data in the
191
125
Southcentral Regional Profile printed September 1974 in cooperation
with the Joint Federal-State Land Use Planning Commission for Alaska.
The Corps of Engineers also had the close cooperation of the State and
Federal· fish and wildlife agencies in developing the ElS.
As stated in Section 4.18 of the EIS: 11 The population of the area
wi11 increase with or without the development of hydroelectric ptojects
proposed for the Susitna River; construction of this project is not
expected to have any significant long-range effect on overall pop~
ulaUon growth, but is rather designed to fulfill presently projected
needs of a growing population as one alternative means o.f producing .
power which will have to be provided in one way or another.11 For further
respanse to this comment, see response No. 255,
192
-STATE
· of ALAS:<A
fROM,
Raymond w. Estess
State-Federal Coordinator
Division of Policy Development
and Planning
Office of the Governor
Ford
DATE October 16, 1975
Langhorne A. Motley ~
Commissioner · vg·
Department of Commerce and
SUBJECT, Southcentral Railbelt Hydro-
electric Project
State I.D. No. 75091103
Economic Development
The hydroelectric project proposed by the Alaska District Corps
of Engineers is a key element in meeting Alaska's future power
needs.
1126
At present, the project needs to receive an intensive and detailed~
study of several potential adverse impacts on the environment. iZ;~
These include further examination of the dam's effect on the n
anadramous fish, the increased turbidity of the Susitna River
during winter months, and the inhibition and higher mortality of
the caribou population. f
However we believe the project should, at this point, receive
the full support of the State for the following reasons:
a) It utilizes a renewable resource;
b) environmental impact is comparatively less than
alternative power sources;
c) federal approval would result in the Corps receiving
needed funding to obtain the answers to the necessary
questions of adverse environmental impac·t, · through
further detailed unalysis and study.
In summary, project is definitely necessary if Anchorage and
Fairbanks are to receive low-cost, dependable power, and the
subsequent lack of heat, noise, and air pollution problems
add to its.feasibility. The draft.environmental imp~ct
statement raises several pertinent questions, but ~he answers
will only be achieved through State and Federal support of the
project.
19~
RESPONSE TO COMMENTS BY
STATE OF ALASKA
DEPARTMENT OF COMMERCE AND ECONOMIC DEVELOPMENT
126 Comment noted.
1.27 Concur. Such studies are proposed for the pre-construction stage
of detailed planning.
128 Comments noted.
194
1VlEMORANDU.M State of Alaska
TO:
FROM:
01)1 I R~w. 517!:il
Pete Cizmich
Regional Supervisor
Habitat Protection ·
Department of Fish & Game
Anchorage
larry J~ Heckart
Mgt/Research Coordinator
Division of Sport Fish
Department of Fish & Game
Anchorage
DATE:
FILE .NO:
TELEPH01~E NO:
. SUBJECT:
October 2. 1975
Susitna (Devil's Canyon)
E. I.S. Comments
Following are the consolidated comments on the Corps of Engineers draft
E. I.S. pertaining to the Susitna River Hydroelectric development":
Page 18, last paragraph -It is significant that some salmon species rear
juveniles for several years in fresh water prior to seaward
migration. This paragraph implies they·originate in salt water.
The fresh water rearing segment may be the most critical ..
Page 19, paragraph 1 -Should mention what surveys and the year(s) they were
conducted to determine tnat fish do not migrate beyond Devil Canyon •
. paragraph 2 -This is not indicative of Northern District Cook Inlet
(Susitna River Basin) as a whole. . . . . .
paragraph 3 -ADF&G currently has escapement goals for Kenai. and
Kasilof rivers. We cannot conclude that adequate escapement occ~rs
into the Susitna River because escapement goals have been reached
in the· Kenai and Kasilof rivers. r·
paragraph 4 -This paragraph should be rewritten as it is misleading
as. written, i.e.,: according to the ADF&G. a significant percentage
of the Cook Inlet salmon run migrates up the Susitna River. Spawn-
ing is found to occur as far upstream as Portage Cr k, approximately
three mi 1 es downstream from the Devil Canyon dam site. Spawning
and rearing salmonids occur in many clearwater sloughs and tribu-
taries ft•om Portage Creek downstream to the confluence of the Susitna
Chulitna rivers. r .
Last two sentences in paragraph are okay.
'129
113()
J13l
paragraph 5 -Should identify study (first sentence) as 1974 assess-1·
ment study by ADF&G.
Omit last sentence.
Also. king salmon are excluded .. Barrett's 1974 repor;t indicates
king salmon present. ·. ·
195
Pete Cizmich - 2 -October 2~ 1975
Page 20, paragraphs 1-5 -Trying to relate Cook Inlet catch to Susitna River
. stocks may be misleading. The Department does not have a method of
differentiating salmon stocks in upper Cook Inlet that are landed
in the commercial fishery. We do know that the majority of salmon
landed in the Northern District convnercial fishery are produced in
the Susitna basin. However, we do not know what.proportion of the
corrmercial catch landed between the latitudes of Anchor Point and' 13 5 the Forelands are produced in the Susitna basin.
13 61 Page 21,
13?1 Page 23,
13 sl Page 24,
13 siPage 27.,
In certain years, primarily even years, a substantial per cent could
be from the Susitna River. Therefore, to use the Northern District
catch as an indicator of the Susitna production would be invalid.
The case pack for Cook Inlet as an indicator of Susitna production
is also worthless in that it reflects the total cases of salmon
packed in all distrids of Cook ·Inlet and in some years includes fish
packed from Bristol Bay and other areas.
In essence there is no present method of affixing a value to the
Susitna River salmon production. We do have a "gut feeling" based
on experience, that a substantial proportion of Cook Inlet salmon pro-
duction i~ from the Susitna watershed. ,,
paragraph 1..; Why not a life history sectionfor resident species~
as given for anadromous species?
paragraph 3-Omit 11 limited 11
• The numbers of game birds is unknown.
Figure 7 -The white (unmarked) area in the center of the caribou
range map is both summer and winter range. This area should be so
indicated.
paragraph 3 -Not true~ Bears occur in both directions along the
transmission corridor.
14 01 Page 37 & 38 -Recreat'ion in the areas affected downstream of Devi 1' s Canyon
would appear to warrant mention.
Page 46, paragraph 1 -What is the source of information indicating unregu~ated
summer silt loads? Again, while summer siltatlon is decreased and
theeffects may be beneficial, the increased winter silt load may
cause deleterious effects.
At what point is the (15-35 ppm) sediment load calculated and at
what seasonal period?
If multiple level discharge outlets are utilized to approximate
normal stre~m temperatures it may be implied that in ,the winter
water will be drawn from the bottom of the reservoir. It is logical
19G
Pete Cizmich - 3 -October: 2, 1975
i
to assume release from these levels wou1d carry a greater silt load
than those closer to the surface. ·
If this is so, di.scussions referring to a \<linter milky textured
11 glacial flow 11 may be extremely optomistic.
If the 15-35 ppm winter sediment load is calculated at the release
sits it can.be expected to increase rapidly as the downriver flows
replace the sediment load lost upstream in the reservoir.
Estimates of 15-35 ppm winter sediment load appear extremely low
and likely would not apply for any distance below Devel Canyon.
Winter turbidity may well exceed the indicated estimate.
141
Page 49, paragraph 1 -If regulated flows are not great enough adults may be ~
unable to enter sloughs and tributaries to spawn. Concern is ex-4 ">.; ·
pressed for extremely low water years and planned regulated flows ~
under these conditions.
Page 50,
paragraph 2-What flow reduct·ions will occur during construction and·J1'~' .. ,
the subsequent fi11 period and for what duration? ~
paragraphs 3 & 4 -More current data is now available re numbers of Ji 4 .:-' .. ,
sloughs and tributaries utilized by salmon and other 111ainstem migra-i-t
tional characteristics. ·
The clear water condition of the Susitna River during winter.months I
could be a contributing factor to salmon fry utilizing the mainstem.
If a year-round somewhat milky-textured "g-lacial f1oor" condition is
introduced because of controlled water releases below the dam. fry
may not be able to rear in the mainstem Susitna River. ··
145
paragraph 7-It is likely that a program to impr·ove fish access to I
the sloughs as a result of decreased summer flows ''.Ji 11 not only be 146
feasible but "necessary~~ and required.
paragraph 1 -Previously (page 46) it ~~as stated downstream water
temperatures would approximate normal winter regimes. This para-
graph implies decreased temperatures.
Green stated in his paper~ entitled Ecological Consequences of the
PrQP9sed Mofan Dam_..QD~_fraser Riy~!'-that reduction in downstream
discharge and resultant water velocities during the spring seaward
outmigration could adversely affect surviva! of young salmon by ex-
tending the period required to make the migration.
He also suggested reductions in turbidity would likely limit daily
migration to the darker hours. further extending the tota1 migra•
·tional period. ·
1_97
Pete Cizmich - 4 -October 2, 1975
14'7
1481
14
15~
Columbia River data indicates mortality of salmon increases with the
time required to complete the downstream migration.
'
(see further comments following re increased mortalities dependent
on silt loads).·· · .
Reductions in sunmer flow temperatures can be expected to reduce
the speed of upstream migrating salmon. The degree: to which this
may affect maturation and eventual spawning must be determined.
Increased winter temperatur~s downstream of Devil Canyon can be ex-
pected to increase the rate of development and may load to premature
fry emergence and downstream seaward migrations. These effects must
be determined •
. paragraph 2 -Should indicate what flows will be during this period.
What about other water quality parameters?
paragraph 4 -This agency currently has available little evidence of
significant mainstem Susitna River spawning downstream of Devil Canyon.
Therefore, unles.s f1ows are high enough to flood the slough and tri-
butary areas where spawning is known to occur, benef.its are likely
to be of litile value. ·
paragraph 5 -While Green made this statement as re improved egg
survival, he also suggested further increases in mortalities due to
predation were possible due to decrease in turbidity. ·
It was also suggested that altered temperature, discharge, and tur-
bidity regimes could significantly reduce the survival of outmigrant
juveni 1 e salmon. ·
There is no solid evidence available that adult salmon can adequately
adjust to altered flow, temperature, a!'Jd turbidity regimes.
paragraph 6 -final sentence -There is no evidence of mainstem
spawning so it is doubtful there is anything to enhance. The reduc-
tion in summer flows may cause a reduction in both tributary spawning
areas and tributary and/or mainstem rearing.
1 ~ lJPage 51, paragraph 7 -This also applies to downstream areas. Insects are
found to provide an important part of rearing fry diets.
l52fPage
15~Page
~2, paragraph 3-This sentence sounds theoretical. Cite evidence
supporting this statement.
53, paragraph 4 -Paragraph meaningless. Sample size too small to be
significant.
198
Pete Cizmich - 5 -October 2, 1975
paragraph 5 -Improvement of habitat quality through construction of 1,.54.
transmission lines is theoretical. JL
Page 56,. paragrap~ 1 .. Hunting.pressures will not increase, only the potential ~
. for hunt1ng pressure 1ncreases. ADF&G has the statuatory capabilities 55
· to control the actual pressures. ·
Page 65, paragraph 2 -Will the summer silt loads during the 10-12 year con-I
struction period actually be decreased, or perhaps increased as a _ 156
direct result of excavation, road b~ilding, etc.?
Page 66, paragraph 3 -Again, only the potential for hunting pressure is
increased.
General Comments:
Findings indicate the lower reaches of the Talkeetna River are very important
to adult and fry salmon. Changes in the Susitna River could potentially have
. a great effect on this area, too.
Another area not mentioned in the report is the possibility of the Susftna
River just north of Talkeetna being a major milling area for salmon spawning
downstream as is indicated by two seasons of tagging studies. The changes in
the Susitna River could affect fish returning to the Talkeetna, Chulitna, and
lower clearwater tributaries of the Susitna River.
f157
158
Mention is not made of the loss. of game habitat downstream of D~vil Canyon I
due to flow regulation, thus eliminating the periodic flooding necessary for
maintenance of ri' pari an bar areas. Moose habitat can be expected to be ad-159
versely affected due to resultant successional changes in the downstream
areas from Devil Canyon to Talkeetna.
This statement refers only to regulation versus non-regulation. The 12-year I
period of construction andtesultant effects on the fish, wildlife, and lGO;.
recreational resources are'1not addressed.
199
RESPONSE TO COMMENTS BY
STATE OF ALASKA
DEPARTMENT OF FISH AND GAME
129 A sentence has been added establishing the fact that juvenile
salmon may spend several years in freshwater before migrating to
saltwater. See section 2.02.1 of the FEIS.
130The paragraph is considered factual as presently stated. No data
have been provided from any authoritative source, including the
Alaska Department of Fish and Game, that salmon have ever been
recorded upstream from Devil Canyon.
jl~jl The statistics presented in this paragraph of the EIS are taken~
, as indicated by reference, from Leaflet #26 prepared by the State
of Alaska Department of Fish and Game.
132 Comment noted.
13·3A statement has been added that a significant percentage of the
' Cook Inlet salmon run migrates into the Susitna River Basin.
134The paragraph .has been revised as suggested with exception of
omitting the last sentence. The statement made in the 1975 Alaska
Department of Fish and Game assessment that a portion of the pink
salmon run may have been destroyed by a late August-early September
flood has not been omitted.
1.35There is no attempt anywhere in the referenced five paragraphs to
relate Cook Inlet catch to Susitna River stocks. Neither is there
any reference to case packs for Cook Inlet as an indicator of Susitna
production. We agree that there is no present method of affixing
a value to the Susitna River salmon production and have not attempted
to do so. We have added a statement that the Alaska Department of
Fish and Game accords a significant percentage of the Cook Inlet
salmon run to the Susitna River Basin.
136 The inclusion of a life history section for anadromous fish was
an optional decision made by the writers of the EIS. There is no
requirement by NEPA or CEQ guidelines that such a section be
included in an EIS. Salmon were included because of the great
significance {recreational as well as economical) accorded this
species. Also, project impacts are more subtly associated with
the life requirements of salmon than with any of the other major
fish species.
jl:l~Concur. The statement has been revised to indicate that the numbers
of game birds are unknown.
200·
138 Caribou range map is as shown from maps in the Southcentral
Regional Profile and the Alaska Wildlife and Habitat Atlas.
1.39
140
141
142
The statement has been clarified to indicate that grizzly bear
are also found throughout this part of Alaska.
Possible improvement of summer fishing conditions might occur
with reduced sediment loads downstream of Devil Canyon dam. Other
recreation downstream of Devil Canyon does not appear to be sig~
nificantly affected at this time.
Detailed information on hydrology, including sedimentation, can be
found in Appendix I of the feasibility report. Multi-level water
release structures do not draw water from the bottom of the reser-
voir storage pool (the so-called dead storage pool), but generally
from the upper one-half to one-third of reservoir storage.
Comment on the replacement of sediment load in water releases at
Devil Canyon is discussed in Section 4.01 Hydrology and Water Quality
of the EIS. We concur that sediment loads below the dam would probably
increase as sediment is picked up from the riverbed, but the 15 to 35 ppm
refers to the releases at Devil Canyon dam.
Comment noted.
jl~:l There will be no reduction of downstream flows druing construction.
Close coordination with the U.S. Fish and Wildlife Service and the Alaska
Department of Fish and Game will be undertaken to pre-determine
minimum flows downstream from the dams during filling.
1.44 The EIS will be updated or supplemented as significant new information
is acquired and provided to the Corps of Engineers.
145 This determination will be an objective of fishery investigations
as the study progresses.
146 Fish access to the ~1 oughs as a
will be improved if it is found
147 Comments noted.
result of decreased summer flows
to be necessary and required.
148 As previously stated, m1mmum flows required to maintain the fishery
will be determined in cooperation with U.S. Fish and Wildlife Service
and Alaska Department of Fish and Game. Impacts on other water
quality parameters which might result from withholding a portion of the
water during high flows for reservoir filling is not known at this time.
201
149 Comments noted. The EIS has included additional temperature and
turbidity information from the Moran Dam study.
150 If provisions are made to prevent hydraulic blockages to salmon
spawning tributaries and sloughs (as the EIS says there will be,
if necessary), it is not likely that tributary spawning areas will
be reduced. The EIS does not state that mainstem spawning will be
enhanced. We agree that little, if any, mainstem spawning occurs
un'der present natural conditions. HmJever, it is not unrealistic to
assume that some spawning habitat could develop in the mainstem within
the reach s.ubjected to s i gni fi cantly reduced summer sediment 1 oads
and flooding. ·
151 Concur.
152 The second sentence in the referenced paragraph does make a theoret-
ical statement. The evidence supporting the statement is contained
in the sentence itself where an example is cited of natural lakes
in Alaska which have heavyglacial inflo\'J, yet sustain fish populations.
153 The Alaska Department of Fish and Game is the source of these figures
(as indicated by reference in the paragraph). They are included
here only as a matter of offici ally recorded data--observations
made during one moose survey. The paragraph contains no allusion as
to the significance of the figures--they speak for themselves.
154 Disagree. Transmission line rights-of-way are known to improve
habitat for wildlife species which benefit from subclimax vegetation.
155 Concur. The sentence has been modified to indicate that there will
be a potential increase in hunting pressure.
156The paragraph which is the subject of this comment refers to sediment
and turbidity changes which would occur upon completion of the project.
Any increases in turbidity during construction would be of extremely
short duration, while small diversion dams were being placed to direct
river flow through bypass tunnels. Dam construction, itself, would
be done "in the dry," thus construction of the dams would have no
significant impact on water quality.
157 Concur. The sentence has been modified to indicate a ~tential
increase in pressure on existing game populations.
158 Comments noted.
159 Disagree. Until studies are made of this situation, no positive
conclusion can be made concerning the downstream impacts of flow
regulation upon moose habitat. However, there i.s a good possibility
202
160
that moose browse will be increased as ~ ~e~ult of regulation.
Bar areas within the braided stream channel are too frequently and
extensively flooded under natural conditions to support any signif-
icant amount of browse vegetation. When the flow becomes regulated,
the stream channel is expected to become more unified and will
probably assume a meandering pattern. Large, barren bar a~eas,
no longer subjected to intensive erosion from frequent flooding,
will probably establish permanent plant growth. As this ~rowth
evolves through the shrubby successional stages, moose browse will·
be incr~ased. · Eventually, much of these lands will establish trees~
mostly cottonwood, and thus evolve beyond the browse stage,. Moose
habitat will, at that time, decrease but will probably continue to
exist in greater quantity than is presently available within the
braided channel system.
There will be no significant effects on fish during the 10-year
construction period. As previously stated, there may be some very
temporary degradation of water quality through increased siltation
during the short period when the stream will be blocked with
temporary diversion dams required to divert river flow through
the bypass tunnels. This impqct should be minor. With regard to
terrestrial wildlife, construction activity will result in some
outright destruction of habitat and the evacuation, and probable
decimation, of species inhabiting the immediate and surrounding
construction areas. This impact, overall, will be much less signi-
ficant, however, than the subsequent impact related to habitat
inundation as the reservoirs are filled.
203
' SiATi:
of.~I.ASKA ;;f:.ft!:fl1ftl~#l;/f/1J!)~!J?II
t·
DEPARTh1ENT OF NATURAL RESOURCES
DIVISION OF LANDS
To. r RAYMOND W~ ESTESS .
State-Federal Coordinator
·Off Ice of the Governor .
Division of Policy Development and Planning
Pouch AD DAn •
Juneau, Alaska 99BOI
October 27, 'J975
FIOMr GARY JOHNSON, ActIng ChIef ~~
PJannlng & Classification Secfton
Aleska Division of Lands
SUBJECT a State 1.0. No. 75091103
Southcen·~ra I Ra II be It Hydro-
electrJc ProJect
323 E~ 4th Avenue
Anchorage, Alaska 99501
The above-noted project has been reviewed by the Division of Lands' staff,
with the tor lowing co~M~&nt considered appropriate:
"General Conment: This project appears to have favorable energy·
development b.:tneflts whlle.havtng a relatively low environmental
<Planning & Classtflcatlon. -G. Johnson) · : .
. . ·~ '
Thank you for the opportun ltY .. to review th J s project.
204
impact."
/~.
/,-...,,
161 Comment noted.
RESPONSE TO COMMENTS BY
STATE OF ALASKA
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF LANDS
205
·M.EMORANDUM State of Ala1~~~·~·.)'·1,1;. it,,,; r::.. ···~ ....
TO:
FROM:
Raymond W. Estcss
State-Federal Coordinator
Division of Policy Development
and Planning
· DATE:
FilE NO:
·Office of. the Governor TELEPHONE NO:
James E. Moody ~" n I
Chief Plannin'g Etlgine
1 V{ •
Division of Aviation
Department of Public Works
SUBJECT:
"' "" "!J ~ .u \1 r. 'n,
tn1. "' ·/ftl
October 21, 1975: OC! .2 ~ 1975 ··'" .. /
State I.D. No. '75091103
Susitna River Hydroelectric Proposal
. al"t-.
Following~ off-the-cuff comments on the subject project as requested
in your September 24 memo, and as related to the September 22 trans-
mittals from the Corps of Engineers.
Attached is a copy.of the'October 9 memo with Nr. Baxter's comments·
following his review of the material. ·
I
The d~ta, as Baxter note~ was too broad in scope and brief to allow us
162
to evaluate how the· project could effect our present and future operations.
Specifically, there is no inventory of the airports or recognized landing
areas, either public or privately owned, .in the immediate vicinity of the
project. The scale of the map~ and the quality of the printing supplied
with the data are such that it is not possible to ident·ifY the boundaries
of the project so that we can compare them against our inventory of landing
areas, although we doubt that very many fields would;be involved.
. 163·
The biggest question from the standpoint of transportation deals mainly
with surface transportation rather than aviation. That is, how would the
dams, lakes, and related facilities improve, and restrict, accessibility
to the Susitna Basin? The creation of an 80 mile long system of lakes
would certainly restrict the selection or alignment of road routes
traversing the area. On the other hand, the lakes themselves might offer
a certain degree of flexibility relative to surface transportation. ·
Perhaps the most important point is the fact that there would likely be a
spur highwayconstructed connecting the railroad and George A~ Parks
Highway to the dam system, thereby providing convenient public vehicular
access to what is now a relatively remote. region.
. constructed in the immediate proximity of each of the dams, to provide I It is also likely that some type of airport or landing strip will be
1,6 4 quick access during construction ~f for no other reason. It \Wuld be .
. interesting to k~ow whc:re these. strips might b.e, l)ow lar.ge they. w~uld . 1 l '?l
be, ~nd so on. crpftlf-lr:'-1 ~ lf;V+....-t. ~ ~/./!';" dJ,.., U.nsh·_.,..._ i.S C..-tt;Srt y
·1 Th. c. d· .. nms and .. the. :i,r related hydroelectric. plants will in them·selves create. employment opportunities. Since the projects will result in improved
surface access plus a major supply of electrical energy, and since the area
is J:Oelatively close to mineraliz~d zones, mineral and other r:esources may
206
Raymond l.Z. Estess -2-October 21, 1975
be developed thus conbributing to more employment, increased settlement f
or population~ and on increased need for both air ~nd su.r.face. tr. ansportation
The increased accessibility will likely attract considerable recreational
activity, whether or not any mineral or other industrial resources are
developed.
1.65
·Has anyone considered the alternative of private development of this I
hydroelectric resource? Which wou-ld benefit the State more -federal ::1._66
development of the resource, or private development?
The tone of the draft E1S and the draft Interim Feasibility Report seem
to indicate a relatively detailed revie\..r of the impact on the lands
actually encompassed by the proposed project. However, a project of
this scope which will create an 80 mile system of lakes with road access
(such that perhaps 7 5 percent of the State's population \-7ill be within
roughly 4 hours driving time) will have a significant impact on the
adjacent lands. The subsequent impact on air and other transportation
can only be identified ·after probable uses of this adjacent land have·
been. cataloged. . For example, if the National . Park Service, or t;,he .
Division of Parks of the State's Department of Natural Resources,desires
to preserve the surrounding area for recreational purposes, one type of Jl(i'£
aviation activity will predominate. That is, recreational flying or
'simple transportation for recreational purposes might be the prime
trnnsportatio.n mode. Seaplane traffic might comprise the highest percentage
of aeronautical activity and might result in heavy impacts at corresponding
seaplane baHes in Anchorage and elsewhere. On the other hand, should.
ther'e be extensive settlement of the area, and pnrticularly if this is.
associated with mineral or industrial development, a higher percent<:~ge
of aeronautical activity might involve commercial (scheduled airline)
operations -possibly with m~dium to heavy ai!craft.
A better map showing the lake system, probable surface access routes,
and surrounding area; plus more information on the wildlife, mineral,
and agricultural resources of the area from respective State offices
would help us better gauge the impact of the project. It is apparent
that the project itself will have less long range impact on air trans-168
portation than the secondary developments which will spring from the
proposed hydroelectric complex.
Attachment
20'7
·-----·~-------·------------
,,..;t;.l'ATC
'of AlASi<A
lo. r
169
.James E.· Moody
Chief Planning Engineer
Kinney R. Ba-~ .
Aosistont Pi~llngineer
·DAlE Octo~er 9, · 1975
suaJ£cr, Alaska Stote Clearinghouse
State I.D. No. 75091103
Upper Susitna River Basin
Southcentral Railbelt Area
After reviewing the Draft Enviro~ental· Impact Statements for the
llydroelectric Power Development, I have found t}Jat the way in which it
is written does not cr~ate much detail to analyze constructively or
destructively. Th~.approach is of a general nature and prohibits many··
comments being made towards the EIS. In the past EIS's that have~been
reviewed, -the author will commit himself to particu~ar controversial
topics, thus creating a flock of comments from the various agencies.
The only comments that I have to make are concerning the introduction of
two large lakes that will greatly influence the activities of float
planes and boats. This will open the adjacent land 'to huntirtg and
fishing camps as well as other recreational functio~s. Will the adjacent
land be open to public sale or will it be established into a lUldlife ·
Reserve, or whatever'l I am sure that with the introduction.'of visitor
centers that other people will follow and a community will more likely
be es!:ablished. :
208
RESPONSE TO COMMENTS BY
STATE OF ALASKA
DEPARTMENT OF PUBLIC WORKS
DIVISION OF AVIATION
162 Comment noted. Air transportation is discussed in the [IS to the
depth necessary for the feasibility stage of planning. During
detailed planning, all Alaska State agencies would be closely
coordinated with to insure consideration of resources or develop-
ments within their areas of purview. The Corps, upon request,
wi 11 be happy to provide the Di vision of A vi ati on with detai 1 ed
maps of the project study area.
163 Construction of the dams will not restrict surface accessibility
to the Susitna Basin, since no road access is presently available
through the canyon area. Construction of an access road leading
from the George A. Parks highway wi:ll provide public vehicular
access to what is now a relatively remote region. We agree, road
route selection will be restricted by the reservoirs. Also, the
reservoirs, themselves, may provide some benefit as landing sites
for amphibious airplanes.
164
:165
166
No landing strips related to project construction will be developed
in the area without prior consultation with the Federal Aviation
Administration and the Alaska Division of Aviation.
Comment noted.
Yes. The Devil Canyon High Dam alternative discussed in the EIS
is a proposed development by Henry J. Kaiser Company. Private
financing of electrical energy projects is one of the standard
tests in computing benefits of Federal projects. In the instance
of this study, coal, which was determined to have a lower benefit-
to-cost ratio than hydropower, could easily be a privately developed
power source. Either Federal or private development would be of
benefit to the State. If identical resources were developed to the
same degree, presumably the benefits would be approximately equal.
167 Cornment noted.
168The quality of maps has been improved in
they are still small in size and scale.
Corps will provide larger, more detailed
the revised EIS. However,
As previously noted9 the
maps upon request.
16S All public lands acquired for project purposes will be open to
the public. The status of wildlife on these lands would be deter-
mined by the Alaska Department of Fish and Game. Other comments
made by Mr. Baxter are noted .
.. 2QS
GROUP COMMENTS AND RESPONSES
Alaska Conservation Society -College
Alaska Conservation Society -Anchorage
Greater Anchorage Chamber of Commerce
Cook Inlet Region, Inc.
Knik Kanoers and Kayakers, Inc.
Orah Dee Clark Jr. High -7th Grade, 6th Peri'od
Sierra Club
210
Comments
170-182
183-199
200
201
202
203
204-257
-~.
"tadu. ~ s~,
1~~U~e~ (.c 196()
Box 80192 Colle&•, Alaska 99101
ALASKA CONSERVATION SOCIETY COMMENTS ON THE ALASKA DISTRICT, CORPS OF
ENGiNEER 1 S ENVIRONMENTAL IMPACT STATEMEI<.'T, HYDROELECTRIC POWER DEVELOP•
MENT, UPPER SUSlTNA RIVER BASIN, SOUTHCENTRAL RAILBELT AREA, ALASKA
dated: September 1975
GENERAL COMMENTS
Considering the magnitude of the proposed two dam project for the upper ,
Susitna River, the draft environmental impact state=.ent (deis) is wholly
inadequate in a great many respects, even as a feasibility. study. A
thorough analysis of its inadequacies would require considerably more
energies than we, as an organization dependent upon volunteer workers,
C_?~_tllust:et" in __ tbe _::;hort time period available _for st.:dy since _the_re-_
lease-of the document on September 22, 1975. Instead, we have chosen
to identify types of deficiencies and present examples of these types-
in the remarks that follow.
TYPE ONE: CONFUSING PRESENTATION
Is this or is this not a draft EIS, that is the question? According
to the title page, the document published in September 1975 is a draft
EIS and according to a cover letter sent with the document that is dated·
September 22, 1975 signed by Col. Charles A. Debelius, District Engineer,
the document received by us is THE draft EIS. "A final Environmental
Impact Statement, incorporating all comments received, will be prepared
and will be filed with the CoUncil on Environmental Quality11 (letter dated
Sept. 22, 1975 from Col. Debelius). However, at the public hearing held
by the Corps of Engineers on 8 October 1975 in Fairbanks, Alaska, Col.
Debelius and his. staff stated that the document entitled draft EIS was
in fact a preliminary draft EIS and that a draft EIS would be developed
later followed by a final draft EIS. To add to the confusion, the summ-
ary page, under item ?.. "Des<::ription of Action" states that 11 since th~f-'
current study is in the feasibility stage, impacts arenot exhaus@ y
evaluated. If the project is authorized and funded for detailed studies
environmental, social,economic, and engineering aspects of the project
will be studied at le.ngth prior to a recommendation to Congress for
advancement to final project design and construction." Later, on page 1
211
1'10
171
Alaska Conservation Society Comments
S~sitna Hydroelectric Power Development
Nbuember. 15, 1975
Page Two
of the document, under paragraph 1. 02, "Scope of the Study" a two stage
study is indicated wherein Stage 1 "is an interim report, to be comple-
ted by 1 December 1975, on the feasibility of hydroelectric development
on the upper Susitna River" and Stage 2 "is a comprehensive report. an-
ticipated to be completed in 1978, to determine the feasibility of
developming other hydroelectric sites in the Southcentral Railbelt area."
From this statement is one to conclude that the document we received is
a draft ( or preliminary draft) EIS for Stage 1 of a feasiblity study?
Will this then be followed by a final EIS on Stage 1? And this followed
by a draft EIS on Stage 2; followed by a final EIS on Stage 2; followed
by a draft EIS on the Devil Canyon/Watana authorized project; followed by
a final EIS on the authorized project????
What makes these questions relevant is the vast difference in importance
between being asked to comment on a draft EIS on Stage 1 of a feasibility
study versus a draft EIS on a project that is authorized. Although the
latter has not yet been accomplished, the Corps is recommending authori-
zation and Senator Mike Gravel has already introduced a bill to the u.s.
Senate "authorizing construction of Devil Canyon and Watana dams in order
to hurry the project along so thatit can be included in this sessions
''omnibus water resources development package". (Gravel, 1 August 1975
News Release.) If authorization is given by Congress, what happens to the
normal and proper sequence of environmental evaluation required by NEPA'l.
Will the two stage feasibility study of hydroelectic sites in: the rail-
belt area be continued even though construction of one .project (Devil
Canyon/Watana) has been authorized?
TYPE TWO: BIASED EVALUATION OF ALTERNATIVES
The resolution adopted by the Committee on Public Works of the u.s.
Senate on 18 January 1972 specifically requests that the Board of
Engineers for Rivers and Harbors include in its evaluation of materials
relating to developing power resources .in the Southcentral Railbelt area
of Alaska a review of the potential of "the Susitna River hydroelectric
power development system, including the Devil Canyon Project and ANY
tOMPETITIVE ALTERNATIVES THERETO ••. (p.l: caps are ours). Ten alternative
power sources are mentioned in the D EIS but all are dismissed as non-
competitive in the course of ten pages! Two of these sources, natural
gas and coal, are really viable alternatives in Alaska at this time, yet
the treatment in this EIS is, to say the least, biased and wholly inade-
quate. For example, in paragraph 2, page 71 the document states: "In
view of the quantities of coal involved and present-day mining practice,
it is, presumed that strip mining would be employed to obtain the coal.
Without specific knowledge of the mining site, it is not possible to pro-
ject how much acreage would be affected; however, it is assumed tobe in
the hundreds, possibly thousands, of acres •.. " If this isn't biased, I
don't know a biased statement when I see one. If it isn't deliberately
212
·~ ..
Alaska Conservation Society Comments
5t!sitna Hydroelectric Power Development
Nov~mbe~ 15, 1975
Page Three
biased, then it reflects a non-objective and incompetant review of existing
knowledge regarding coal as an energy source in Alaska.
In the first place t' := distribution of coal suitable for use in generating
electricity for the southcentral railbelt area IS KNOWN; the sites are '
few in number and there are reasonable estimates of the coal reserves
available in them. (See paragraph 6.022 USGS Report). Thus, the acreage
that would have to be disturbed to extract the coal to supply a given
amount of generating capacity can be calculated but apparently wasn't.
Seco11d, if we assummed that the acreage that would be affected was "in
the hundreds, possibly thousands," how does that compare with the 50,500
acres (=78.91 square miles) which will be inundated by the two dams to
say nothing of the roads, construction camps etc.!!! Furthermore, a
strip mined area can be recontoured and revegetated so they come back
into being productive habitat for at least some (and in the Nenana coal
field, perhaps most) of the species that inhabited the area before stripping
occurred. In addition, the total acreage disturbed is not affected all at
once,. whereas, inundation by a resevoir with the consequent siltation,
buries the total acreage in a few years, and, for all practical purposes,
completely eliminates its biological productivity or at least significantly
reduces it forever,
Later in thi.s. same paragraph the statement is made that ''Water in .contact:
with coal and mine wastes generally become aci.dic and toxic to vegetation·
and animal life.11 What does that general statement have to do with the
specific alternative of using coal to generate electricity in Alaska?
Coal in the Nenana coal field (near Healy, Alaska) is very low in sul:fur
and thus there is very little potential of a serious acid waste problem.
Furthermore, burning this coal produces very low emissions of sulfur
dioxide and that which is produced can be captured by appropriate stack
design. Thus, the impression given the uninformed reader that ill coal
produces bad .environmental conditions .is very misleading especially in the
case of the Alaskan situation. The final sentence in this same paragraph
appears absolutely ludicrous when compared with another sentence from this
same document·: "The construction of the proposed hydroelectic project
would have a significant impact on the existing natural scenic resource
values within the project area.11 (Draft EIS, page 61, paragraph 2).
Which is worse? The final paragraph of the coal alternative concludes:
''In view of the extensive adverse environmental impacts as_sociated with
the coal alternative, both in magnitude of effects and areas affected,
this is determined to a less (sic) desirable source of energy production
than hydroelectric development." (p.72) How could the Corps arrive at
this conclusion.when NO EVIDENCE is presented that using Alaskan
coal as an. energy resource would produce more "extensive adverse envir-
onmental impacts" than hydroelectric power from two dams on the Susitna
liver?
213
172
Al~ska Conservation Soc_ie.ty Comments
Susitna Hydroelectric Power Development
November 15, 1975
Page Four
TYPE THREE: LACK OF QUANTIFICATION OF MATERIAL DESCRIBING EXISTING
ENVIRONMENT
Throughout the draft EIS, meaningless adjectival descriptors are used
rather than numbers. Examples:
1 t"J3 ·a. Page 12, para. 2: "~of the upper Susitna River Basin is
underlain by.discontinouous permafrost." -How ·mueh is most? What is the
relationship of discontinous permafrost to the success or failure of the .
hydro project? What are the environmental consequences of building dams
in such terrain?
I b. Page 14, para. 1:" Few kayakers have attempted the dangerous 1''? 4 eleven mile run through Devil Canyon." How many is a few? Were white-
water canoer groups contacted and asked about their views?
c. Page 25, para. 2.02.3.: "Grizzlies are common throughout the
1 Y"' 51 Sus_ itna R __ iv.er drainage and are fairly numerous in t.h.e upper_ Susitna des-
1 pite the absence of salmon (see Fig.8)" "Common" and "fairly" numerous
. in relation to what other areas? How many per square mile?
17 6 1
M_a_ n_ Y_ ad_ ditio. nal examp.les could be c1._· ted but they a_ re almost too numerous to
· count! If the data are available, present them and if they are not
available, say so.
1'78
TYPE FOUR: IMPORTANT ISSUES NOT ADDRES-SED ANYWHERE OR VERY LIGHTLY
TOUCHED UPON
a. On page 17, paragraph 2.01.4. 5 the point is made that "much of the
drainage basin has never been geologically mapped," and the "the basin
constitutes one of the least known areas in the State" ••• yet NO WHERE
in Section 4.0, Environmental Impacts, does the EIS consider the con-
sequences of inundating 50,500 acres of geologically unmapped terrain.
The potential loss of mineral resources is dismissed in one sentence:
11 lnundatiori would obviate the practicability of future mining or, ex-
traction of such resources." {page 67).
b. The EIS makes the following statements:
page lO:"The Susitna River ..• is the largest stream discharging
into Cook Inlet."
page 14:"Freshwater runoff into the Upper Inlet is an important
source of nutrients and sediments"
page 45:"Significant reductions of the bte spring and early
summer flows of the river and substantial i,ncreases of winter flows would
occur" if the dams ere built. ·
In spite of these facts, no where does the EIS consider the impact on
Cook Inlet of modifying the river flow!
214
Alaska Conservation Society Comments
S~sitna Hydroelectric Power Development
November 15, 1975
Page Five
TYPE FIVE: INADEQUATE REFERENCING OF SOURCES UTILIZED
Although 31 pages of the draft EIS are devoted to a description of the
"environmental setting without the project", very few references are
made to the ·sources of the material presented and the few ·citations that
are given, are incomplete so that someone wishing to check with .. the
original source.would have a difficult time locating it.
1179
TYPE SIX: UNREADABLE OR INADEQUATE FIGURES
Figure 3 (page 7) is so sketchy as to be useless for assessing relation-
ships between the transmission corridor and even basic terrain features.
Figure 4 (page 11) is unreadable.
1180
SUMMARY
Following a review of the draft EIS for hydroelectric development in the
Upper Susitna River Basin, the Alaska Conservation Society found the
document to be a totally inadequate evaluation of the environmental impacts
likely to occur if the Devil Canyon and Watana dams were to be constructed
on the river.· Deficiencies in the document are so numerous that an item
by item enumeration of them would probably require a document equal to or
greater in-lengdr·than--the-draft EIS itself. In order to keep our, comments
to a =easonable level, we classificed the deficiencies into six types:
1. Confusing Presentation; 2. Biased Evaluation of Alternatives; 3. Lack
of Quantification of Materi-al Describing Existing Envrionment; 4. Important
Issues Not Addressed; 5. Inadequate Referencing; and 6. Unreadable Figures.
Sev.eral examples of the deficiencies noted for each category are presented
and referenced to their location within the draft EIS.
CONCLUSION
In view. of the inadequacy of·. the draft EIS • the Alaska Conservation Society
181
feels that the existing document needs to be completely revised and up-1.82
graded BEFORE any further recommendations are made to Congress by the
U.S. Army Corps of Engineers. In particular, the Corps should meet its
responsibility as mandated by the Committee on Public Works of the u.s.
Senate to evaluate "any competitive alternatives" to the Devil Canyon
and Watana Dam project in an unbia~~ manner and present this evaluation
to the public.
215
170comment noted.
RESPONSE TO COMMENTS
OF ALASKA CONSERVATION SOCIETY
COLLEGE, ALASKA
171 This comment indicates a lack of understanding of the procedural re-
quirements established by the Counci 1 on tnv ironmenta 1 Qua li.ty for ..
fed era 1 agency compliance with the Nationa 1 Environmental Policy Act.
Guidelines to Federal agencies for preparing detailed Environmental
Statements on proposals for legislation appear in the Code of Federal.
Regulations in Title 40, Chapter V, at Part 1500. In addition, pursuant
to Section 2( f) of Executive Order ll514, the Corps has developed agency
procedures in consultation with CEQ which even more specifically provide
guidance for the preparation of Corps Environmental Impact Statements.
Both CEQ guidlines and Corps regulations have been adhered to in the
preparation of the Draft Environmental Impact Statement. Following
coordination of the DEIS with other agencies, groups and individuals--
and incorporation of all comments received, responses thereto, and
addition to the EIS of any new or additional information received--
the Corps will prepare an updated revised Draft Environmental Impact
Statement. The RDEIS will then be subjected to intensive in-house
review at higher levels of authority, and the District will make any
necessary revisions. After such revisions are made, the RDEIS will
be submitted to CEQ and, at the same time, will be sent out to the
Board of Engineers.for Rivers and Harbors, the final review agency
of the Corps, and to Federal and State agencies for review and comment.
Greups and individuals commenting on the draft statement w·ill be furnished
informational copies. The District will prepare appropriate responses,
make necessary revisions to the main text due to comments received and.
forward a Final Environmental Statement to the Office of the Chief of
Engineers which in turn will forward the document to th~ Office,
Secretary of the Army. If the Chief of Engineers determines that new
information received is of such significance as to warrant recon-
sideration of previous recommendations of the Board of Engineers
for Rivers and Harbors, he will send the document back to the Board
for such reconsideration. When the Office, Secretary of the Army,
transmits the Final Feasibility Report and accompanying FEIS to Congress,
it will also transmit the Final Environmental Impact Statement to CEQ.
At the same time, the Division arid District office will be notified of
the transmittal for timely distribution of the FEIS to agencies, groups,
and individuals that have received and furnished comments at various
levels on the statement. The document commented on by the reviewer is
a Draft Environmental Impact Statement, as indicated on the cover and
in the text. The DEIS addresses Stage I of a two-stage study. Stage I
involves a study, as mandated by Congress (by resolution of the Committee
21G
on Public Works of the United States Senate on 18 January 1972), to
determine the feasibility of hydroelectric development on the Upper
Susitna River. Stage II will involve an additional study (not yet
undertaken) which will determine the feasibility of other hydroelectric
sites in the Southcentral Railbelt area. Thus, the second stage study
will be conducted to fully respond to Congress 1 directive~ There is a
vast difference in importance in being asked to comment on a Draft
Environmental Impact Statement of a feasibility study versus a Draft
Environmental Impact Statement on a project that is authorized. If this
project is authorized, extensive, detailed environmental studies will be
undertaken to identify unavoidable adverse impacts which will result
from project construction. Procedures will be studied whereby the
project can be modified to minimize adverse impacts or to otherwise
mitigate unavoidable damages. At this time the EIS will essentially be
rewritten and the review process initiated again. As a result of this
detiiled evaluation of project impacts, Congress will again have an
opportunity to consider the merits of the project and make a determination
as to whether or not it should be authorized for funding and construction.
The latter requires a distinct and separate action by the Congress.
17 2 In reference to the alternatives to the proposed Susitna River hydro-
electric development, the Interim Feasibility Report discusses in greater
detail the reasons that coal was determined to be a less desirable
source of electrical energy production than hydroelectric development.
The alternatives to hydroelectric development are also discussed ·in
section 6.0 of the EIS. The information was gathered from a wide
variety of sources and presented in a condensed form.
1 73Many unquantified--unquantifiable--resource values are described
narratively throughout the EIS. The statement makes it clear that
permafrost is primarily restricted to areas of the Upper Susitna
Basin upstream from the reservoir sites, though the Watana site is
known to have some permafrost. The exact extent of this condition
will not be known until proposed detailed geologic studies have
been completed. Permafrost will have no relationship to the success
or fa i 1 ure of the hydro project. It will, however, be a factor
(one of many geological considerations) that will have to be taken
into account in the design and function of the project. Permafrost
is not present in the Devil Canyon damsite but may be present within
a portion of the reservoir site. The Watana reservoir site contains
areas of intermittent permafrost, particularly on north-facing Slopes.
In these areas the overburden mantle assumes a steeper angle of repose
than would normally exist. It is expected that as the reservoir fills
and permafrost degrades, some slumping of natural slopes will occur.
These slumps or slides will be minimal in their effect on the capacity
of the reservoir, since very light overburden is found in the lower
elevations of the canyon where such slumping would occur. Above these
rocky walls the valley flattens abruptly into the high terraces of
,.,.~-g 1 aci a 1 deposits where the s 1 opes are genera 11 y stab 1 e. Permafrost
217
will not be a factor in the success of the dam since the foundation will
be established well below the level of permafrost conditions.
17~ There have been only two or three people, to our knowledge, who have
. · 'claimed to have run the 11 miles of "whitewater" at Devil Canyon; there
have been others who have kayaked portions of this section of the river
and portaged out of the deep canyon around dangerous sections of the
river. A copy of a report by Dr. W.L. Blackadar of Salmon, Idaho
is included. See response No. 257.
1~75 The words 11 Common 11 and 11 fairly" numerous are descriptions used from
. various State and Federal agency Wildlife statements and reports -
it is presumed that these terms were used in relation to the animals
in the State of Alaska.
1'76
177
The terms and numbers used in the EIS were from available data
from Fish and Wildlife Agencies. It is also stated that additional
fish and Wildlife data will be obtained during the preconstruction
planning process.
By selectively quoting portions of two sentences the reviewer conveys
the impression that absolutely not,h·ing is known about mineral resources
in the drainage basin. In their entirety, the two sentences which
are partially quoted read thus: "Though a number of mineral occur-
rences are known and the area is considered favorable for discovery
of additional deposits, much of the drainage basin has never been
geologically mapped. Thus geologically, the basin constitutes one
of the least known areas in the State except for a few areas in
the vicinity of Denali where some geologic mapping has been done.11
Additionally, the previous paragraphs states: "Most of the Susitna
Basin above Devil Canyon is considered highly favorably for
deposits of copper or molybdenum and for contact or vein deposits
of gold and s"ilver.11 The paragraph goes on to identify two known
mineral deposit sites -one for copper and one for gold. The
potential loss of know, suspected, and unknown mineral resources is
thus candidly acknowledged in the sentence as quoted wholly from
Section 4.0. Geologic mapping of the impoundment areas, required
to determine faults and foundation conditions, would be extensive
prior to any recommendation that the project be funded for con-
struction.
178 Although Cook Inlet is not specified by name in discussing the
downstream effects of modified river flow, the following statement
is made in Section 5.0: .,Adverse impacts could result from poss·ible
reduction in nutrients and primary productivity, cutting, and erosion
of existing streambed configuration, increased turbidity during the
winter months and changes in the hydraulic and biological regime of
salmd'Tl rearing and spawning sloughs." These impacts will diminish
with downstream distance, but some of them may well be felt to some
extent in Cook Inlet itself. A determination of any significant
218
impact on Cook Inlet can only be determined subsequent to lengthy and
costly detailed hydrological, biological, and water quality studies of
the entire downstream system. Such studies are planned if the project
is authorized and. funded for preconstruction planning. The magnitude and
cost of these and other studies which will be required prior to final
recommendations for construction authorizations are clearly beyond the
scope and funding constraints of the current feasibility study.
179 Many specific material sources are referenced within the body of the.
draft EIS and general information sources are listed in the bibliographic
references section of the EIS.
180 A new schematic drawing of the proposed transmission corridor has been
furnished by APA. The exact on-the-ground location of the proposed
transmission line will be determined in future studies that wil.l incorporate
environmental, economic and engineering considerations.
181 The word 11 if11 is significant in the context of the first sentence of
this comment. The Corps has clearly stated in the draft EIS that if the
project is authorized and funded for preconstruction planning, detailed
en vi ronmenta 1 studies wi 11 be undertaken prior to any recommendations
for construction authorization and funding. At the present time it is
not known if the project will even be funded for further studies, much
less construction. In response to the remainder of the 11 Summary 11 comment,
every deficiency that can be specifically identified has been given an
individual response and clarified in the RDEIS.
182 The Corps of Engineers is very aware of its responsibility as mandated
by the Committee on Public Works of the U.S. Senate. The public has
been kept fully informed throughout the progress of this study~ A
number of public meetings have been held, workshops with interested
environmental groups have been conducted, and the draft EIS has been
sent to everyone indicating an interest in it, along with a letter
specifically requesting their views and comments. See response No. 171,
for a discussion on procedures of updating the EIS prior to formal
submittal to Congress. ·
219
Charles Debelius
Col., Corps of Engineers
District Engineer
Box 7002
Anchorage,, Alaska 99510
Col. Debeliusa
AtASl\A CoNSERVATION
Soctm.
UPPER. COOK INLET
CHAPTER
BOX 3395
ANCHORAGE, ALASKA
. 99501
Oct. 17, 1975
The following are the comments of the· Upper Cook Inlet Chapter
of the Alaska Conservation Society on the Draft ~nvironmental Impact
Statement on "Hydroelectric Power Development -Upper Susi tna River
Basin Southcentral Rail belt Area, Alaska", Alaska District, Corps of
Engineers, Sept. 1975,
UCIC,ACS protests the short time frame in which this statement has
been brought out• The agencies much less the public asked to comment· on the
statement has scarcely enough lead time to identify what needed to be
183 done, much less to do it. ::>orne of the following .,;,uestions asked at the
. · · hearings were partially answered at the public meeting held by the Corps
in Anchorage Oct. ?(which was only 16 days before ·.vri tten comments were
due) but we wish to assure they are contained in the final ~Io:.~
1..
.
UCIC,AC;:, believes this D.C:l.:> to be generally inadequate and unacceptable.
·tie agree with the .:.tatement on pg. 8 " •• ,'1'he .c:r.., does not include a 18 4 detailed and exhaustive evaluation of pro'ject impacts ••• " •ie object
s:trenuously to the fact that the proposed project has to be authorbed
to be built be:fore adequate environmental stu·dies can be made,
The following are some general observations ani questions on the
DEI;:>a . .
Fish, Game, Habitat .
The most obvious :factor is the loss o:f 50,000 plus acres that will be
·inundated by the resevoir waters and lost as habitat. Talks with F dt G
personnel reveal that they need more time to do adequate game counts
(moose, caribou, etc.), range work to determine what kJilnj of habitat will
be lost, identify specific caribou migration routes through the area,
anj they need time to Uenti:fy exactly which streams the mixed stock!> of
. salmon spawn in. As we understand it, they had at the most a year to start
joing this work with only 2 full time regular staff people an::! the
DEDICATED TO THE WISE USE, PROTECTION AND PRESERVATION OF
ALASKA'S RENEWABLE AND NON-RENEWABLE NATURAL RESOURCES.
220
.~.
parttime help. of 2 aides. Also, money was not available to do the studies J
, ne. ed·e·d. This. mon··.e·y .• ·.·a.!'l we.· underst. and ·i·t.,. w·o··. uld be .proviled. un .. 1:r··.ena. blin. g.· .·. legislation should 1 t be passed, but aga1n, we protest that .th1s proposed
project shoul1 not be authorized until adequate stuHes are done. · ·
F & u as well as other concerned agencies, need time to initiate studi s 18 5
to .. de. f·i.·n····e .. i. mpa .. ct .. , reg. ul·a· tory. ch. ange·s.·a· .nd .. to defin·e· mitigation· to.·. com.pe .. nsa. tel fbr loss of habitat. They also need lllore speccific data from the Corps
in order> to evaluate jownstream effects on fish anJ other aquatic
in·habitants of the streams and tri tutarias affected by this proposed dam
systemo
uame counts sited in the llii-=> are completely ir·dequate -··i.e. pg. 5J
•curing the June 1974 survey, one grizzly was sighted ••• five black bears
were sited on the .:>Usi tna River •. .n. total of 56 caribou were sighted in the
survey area" What was. the survey area? Is one years data the Qnly ·
available? ,How many times during the year were counts made? Information
as basic as this does not seem to be available in the Dei-=>. Spe~ific studies need to be done to deteriii'I'Iie how increased river· 18 6
water temperature will effect such things as downstream icing co.nditions,
salmon egg emergence, and effects on other inhabitants of this syste.in.
The ef:fe.cts will not be limited to just the immediate area or the dams.
What will the. specific changes be in going from an unregulated river ,
to a regulated one? What effect will this have on the moose range? What will
th.e Corp. s. do to mitigate these effects? The Corps seemingly will have· to I
mitigate for the loss of moose range -will they give lands to the State
somewhere. else or provide money to increase management on other lands?
This question does not seem to be ajdressed at all in the DEI;;;.
Siltation . .
The problem of siltation raises many questions in our minds that are
not addressed in the statement. How will decreased siltation in the
summer effect primary productivity? If the nutrients are decreased during
the warmer months when life re-emerges in this northern latitude, what
Will be the result up the i;ood chain? ~specially in Cook Imlet into which
the. ;;;usitna drains? How will this effe.ct the zooplankton? And on up the
food chain? r;ventually, could this possibly effect -the salmon runs?
Also, as decreased siltation is predicted after completion of the proposed
dams, what about the increased siltation bound to result from the
construction phase (est, to be 10 -15 years)?. Other questions -How
much silt will be picked up after the water is released from the dam?
There may be a low sediment load spilled from the dam, but what are the •
figures say, 1 mile below the dam?
:i~d imen ta ti on
The factors that influence the rate of erosion, transportation of
materials to a reservoir and the trapping of sediment within a reservoir
are complex and highly variable.· The geology of an area, nature of the
soils, slopes, rain'fall, runoff, hydraulic characteristics, cover and
r;~ther con:li tions vary greatly.
However, given the glacial silt and other sediment content of the wate
of the Susitna River, the stated loss of storage capacity for a 100 year I
period (6, 5% for Devil Canyon dam, ).6% for the Watana dam} appear low.
The rEduction of suspended sediment to 15-35 ppm (pg. 46) means that much .
of the unregulated river sediment load (less than 1000 ppm in summer months)
wouldRhe retainej ~n· the proposel dams. I
ecor.JS" from u existing reservoirs in the U.;;>. having .drainage areas
greater than 1000 square mi.les and stora. ge capacities ranging from 0.05 .
to 2.06ib and averaging 0.72fo (Uottshalk, 1964). A couple of example.sa
221
-:1..-
Elephant Butte reservoir in New Mexico, lost 16% of its original storage
capacity (2.6 million acre-feet) in )2 years of operation. Uuernsey reservoir
in llyoming lost J9% of its storage capacity of 73,000 acre-feet in just -18'1 26 years. ...
. ·· ·. · 'l'J\E! data sourcgs a.rtd me thoda used to. compute those se•Hmenta tion
rates a:t<e not iric1ud:e·d in the Di::I.::i and are thus not available for
evaluation by reviewers of the statement. Also, there is no mention of'
.the construction of a sediment pool to mitigate t)'le estimate1 loss of
stor,age volumne over the years. ·
FtazU I.ce
Has the problem of frazil ice been conside,red? 'l'his phenomen o:r
northern c.limates is a great hazzard to power plants. It is essentially ice
fog that solidifies into a special crystal formation on the intake system
.as the eold (glacial in this instance) water .hits the warmer area nearer the 18 8 turbines. It solidifies instantly ,and when this happens, the fast
revolving turbines have a decreased water flow and could burn out. There is
supposedly technology to overcome this, but the problem is !!Q.! addressed
in the DEIS and we feel it is a very important environmental consideration.
(See '"'illiams, J.P. "Frazil Ice -A Review of its Properties with a
Selected Bibliography", Engineering , Nov. 1959, pg. 55-60). vie are. not
convinced this problem can be 1ismissed by saying the water temperature
in the reservoir will be "to high for this to occur•.
' · 'l'ihat will be the effect of essentially eliminating peak and low flows? l.i1ater Flows .
18 9. Providing f. low figures for the. Chulitna and other down stream areas we do
not feel "are beyond the effect of the project". Also, what will be the effect
of warmer water flow in winter and cooler in summer?
Permafrost .
.. There seems to be incomplete identification of permafrost areas. How
190 will melting ice on reservoirs .effect the permafrost? How much will erosion
.contribute to the sediment load and will wave action cause increased erosion
·on permafrost areas? Nhat will be the effect of· innundating large areas of
discontinuous permafrost? ~xactly how much permiifrost will .be under the
·impounded area?
~arthguakes
Pg. · 62 ·states t "Devil Canyon and .va tana Dams will be designed. to with-1.91 ,4stan~ a Maximum Creddible Eart 2hqua~e of 8~.5 m~gnitude with.an epi~anter of
· 0 mJ.les at a focal . epth of 0 ml.les whJ.ch l.S the approxJ.mate dJ.stance of
'both damsites to the Denali Fault system and is the most likely source of a
'.seismic event of this magnitude. The .;,usitna Fault, truncated by the Denali
:Fault, bisects the region in a tiE to ;.;tJ direction approximately 2.5 miles
west of the .va tana damsi te". As the ;:>usi tna Fault is par:t. of the Denali
raul t system, is it not possible that a quake could occur closer than
'40 miles? de feel this certainly .needs more study and further clari·fication.
19 2 .· ilhat is the geology of the founiation of the dams? How far to
'
Geology
beirock? What is the formation of the canyon sHes that will be innundatei
;with water?
I Flooi Control .
Pg .• 71 mentions unier Alternative Sources of Power~ "A coal-thermal 19 3 . ·.facility would f .. o·. rego the recreational and flood control benefits provided
by a hy1ropower project". H'here is the data Jocumenting flooding and the
need for f.lood control on the ::.usi tna? Is flooding a problem on the :.:;usi tna?
· · As moose and caribou habitat will be destroyel (thus lecreasing I Recreation
. hunting) and there will be no fish in the reservoirs, what will the great
recreatJ..· onal benefit of these proposed iams be to the publ.ic? i3.oating? ~ater sports? Nhat? As the area below the proposed dams will probab~y be
222
closei iue to safety reasons, kayakers will probably be excluded from I
using the.river. Also, will the access roads be open to the public
of will they be. closeJ due to safety reasons?-
Access Roads
~xactly where will these be built -it is very hard to telL by
the maps in the Del.;,. Also mileage estimates vary. Ifill they be open to the
· public? How wide will the right of way be? How will the dirt and gravel be
obtained to build these roads?
'l'ransmission lines and corridors
The statement is very unclear as to exactly where these will be.
How will right of way be obtained? It proposes to cross federal, state,
private, and native lands. l'l'ith increased pressure on land resource and use
of land for nonproductive purposes, has burying the transmission lines
been considered? Technology is available to do this and could cause much
less disruption of the land. Fewer trees would have to be destroyed and the
buried limes area could be revege ta ted • .>uch a corri::!or could have varied
edges in:stead of a straight swath cut thru the wilderness. We realize
this alternative is very expensive but we feel it should be consUered
as an alternative to overhead transmission lines in the DEI;;>. ·
1/e also note the effect or earthquakes on overheaJ transmission lines
has not been addressed. We have. some questions as to possible health ·
hazzads arounj transmission lines due to high wattage radiation. 765,000'
volts seems to be the critical point at which adverse impacts begin.
Some of the problems encountered includea
1. ozone formation
2. interferance with radio and T.V. signals
3. noise pollution ,.. humming anj crackling sound {up to 70 decibels
has been recordej -90 decibels is the legal noise limit)
4. possibility of electric shock
So possibly health hazzarJs -increaseJ b/p, chromosome damage,
nervous system damage)
we do not know if any of this would happen with this proposed project, but
we feel in the interests of public health, that this should be looked into
and addressed in the D~I;;>.
What studies have been done on strength of the wind in the areas for
transmission lines? ~e understand the project around Juneau has haj
incredible problems with wind blow-down of lines -not that there. are as
strong winds in the interior, but then who knows? 1\o data is presented on
this. What will be the energy as delivered to Anchorage and Fairbanks?
What will be lost in transmission? On pg. J it states& "A subsidiary purpose
in the cnnstruction of the electrical transmission line will be the
interconnection of the largest electrical power distribution grUs in the
State of Alaska ••• " What are these 2 power grids? Could they be interconnected
without the proposed :iam? 'l'lhy is it necessary to interconnect them?
Dam operation
'ilho will be charged with operating the dam if it is built? The Corps?
Utilities commission? The State? Also a very important question is what
is going to be lone with the "secon:iary power" produced? The proposed
project has a built in surplus of power -or in other worls, it is building
way ahead of the current needs of the railbelt. ·~hat is the purpose of
this seconlary power production? Is the purpose to attract industry?
If so, we feel that this is a sell out from the original stated purpose.
"Sxtra power" with no where to go will necessate carrying charges and as
~sual, tpe taxpayer will pay. Plus the fact that this overproluction
:u.J.be ,:aetel anl thus the rational to attract big in.1ustry to use it.
223
194
196
19'1
I
t98
-3-
Coet benefit ratio
This ratio is compute:i as 1.4 so suppose.ily there is more benefit
. than cost? But, looking at the interest rate which was computed at
.6 J/8~, we J.o not feel this is an accurate reflection of the realistl.c
inarket,. We need to know the cost of this proposeJ project in terms of how
much energy will be used to build the dam, how many barrels of oil will be
irretrevibly conuni tted, and how much energy will it "cost" to maintain
the dam? Let1 s look at the cost -as one of the benefits, the dam is
supposed to be "lower cost of power generation" (pg. J) how are we to
evaluate the following figures of estimated cost of the dam and .transmission
·lines&
1. When first propose1 in April 1960 -:P478,874,000 (Devil Canyon Project
Report of Commission of Reclamation, March 1961)
.2. Jan 1974-$682,000,000 (Devil Canyon .;)tatus Report,·May 1974, Dept.
of Interior, Alaska Power Adm.) · ·
J. Jan. 1975 -$1.343 billion (Corps, JEL:5)
To our way of thinking, this project is economically unfesible, How can
the Corps justify this outrageous expen1i ture -which almost amounts
to their total operating bu:iget for the entire Corps last year? We do
not feel all the alternative sources of power have been evaluate:i with'
an "open mind". Couli currently available power sources developed to their
fullest supply the needs of the railbelt? How much energy will really be
needed in the railbelt? What will be the net energy ':Jenefit analysis?
!Hill other energy resources be developed concurrently an1 be available
by the time the dams are on line?
I Inconclusion, we. have very serious questions about the lack of
factual content of the 0.::1.:., the potential attraction of big industry 19 9. due .to overproduc. t.io·n· of power, a. nd socio-economic impact that would
be inevitable. We see no proven need for this project and certainly cannot
see that it is economically fesible. ·
~.;)4,;u;:;;;.C./ £:: -<'~/ h,cl ;;·_,'( c; ") .. -,--,
C:-,?'ll./)>,_t:7&:..: · {/L" / (' /ij'{· '::,' Cl
~11,.,_ la·J~<r.,.·..._.
;1,_ t.c'.-t n' ~ cl ~-J~/;~ .,
(/( ~ 1;', au l;d:i
224
RESPONSE TO COMMENTS BY
ALASKA CONSERVATION SOCIETY
UPPER COOK INLET CHAPTER
183 Formal public meetings to discuss the selected plan for hydropower
development on the Upper Susitna River Basin were held in Anchora~e on 7
October 1975 and in Fairbanks on 8 October. The public was given.l~
days to. include written comments they wished to be inserted into the
public record for those meetings along with any statements.tbey·made at
the meetings. ·
The District Engineer stated that all written comments•:.(m the.Draft
Environmental Impact Statement for the proposed project, :which was
distributed by the Corps of Engineers on 22 September 1975,. should be
made to the Corps by 17 November 1975 so that these comments could be
included in the Environmental Impact Statement due to be completed in
earlyDecember 1975. Actually, environmental commentsdated through 3
December are included in the Comment and Response Section of the EIS.
. ~ 18 4 As stated in Section 1.03 of the Draft Environmental Impact State~ent
. · for the proposed De vi 1 Canyon-Wa tan a hydroe 1 ectri c project on the j upper
Susitna River, the study is in the feasibility stage, andthe EIS•does
not include a detailed.and exhaustive evaluation of project impacts,
. many of which .cannot be fully ascertained prior to congressional authori-
· zation and funding of detailed economic, environmental, and engineering
st·udies (including additional fish and game studies). The two-stage
authorization process requires congressional approval before advancing
from the detailed studies stage to final project design and construction
stage when the actua 1 project funding would be authorized and project
construction would begin. Many projects have preliminary authorization
from Congress, but for one reason or another they are not a 11 funded or
constructed.
185 As indicated in Section 4.03 (Wildlife) of the EIS, the numbers of big
game and the amount of habitat are minimal within the proposed Devil
Canyon impoundment area·~· and preliminary data indicate that low populations
of such animals presently utilize the proposed reservoir area. If the
project is authorized, it is expected that construction on the first dam
would start in 1980 or 1981. Authorized fish and wildlife studies would
be funded to continue during the interim study period and the information
would be used to prevent, ameliorate, or mitigate the adverse impacts to
important fish and wildlife species.
186 All project data, including river regulatory information. are available
to the fish and wildlife agencies at the District Engineers• office in
Anchorage, and these agencies are aware of this coordination
225
of information. Althoughup-to-date ·information on fish and wildlife is
somewhat limited, past data--including information from the 195o•s and
1960's--indicate that these are low game populations in the proposed
Devll Canyon-Watana project areas. One survey study made during the .
winter of 1974-75 does not constitute a reasonable scientific study, as
such~ but it further indicates that the numbers of various ~nimals -fn
this area are relatively low. ·
187 Sedimentation studies to determine the significant environmental impacts--
both adverse and beneficial--that would be generated by the proposed ·
project, will be continued. Preliminary studies, including A Hydrologic
Reconnaissance of the Susitna River Below Devil's Canyon, October 1974,
preparedfor National Marine Fisheries Service atJuneau, Alaska, and
various detailed U.S. Corps of Engineers and Bureau of Reclamation
hydrological studies and other studies .on sedimentation are 'available
for review at the Alaska District, Corps'of Engineers' office 1n Anchorage,
Alaska. During the construction phase, the river's flows would be
diverted through tunnels around the dam construction areas and should
n'ot significantly affect sediment below the dams. Other activities,
such as building roads and bridges and clearing vegetation in the
proposed reservoir areas and transmission line corridors, could cause •·
some s ilfation or sediment problems. These activities would 'be done in
such a manner as to minimi.ze possible adverse impacts {see Section
4.11). Preliminary sedimentation studies and post-Bureau of·Reclamation
studies indicate the rates ofsediment deposition in the reservoirs as
stated in the EIS. These ,chmputations are available for review at the
Corps' office in Anchorage. The sediment load one mile below the Devil
Canyon dam should be substantially the same as the releases at the dam
dueto the rocky nature ofthe.riverbedin this seictionofthe Susitna
River and with no significant tributaries in this section of the river
that could contribute higher sediment loads. There would be a· period of
channel stabilization in the>pO-'mile section below the proposed Devil
Canyon dam in which the rive~ would tend to adjust to the stabilized
regulated flows with low sediment levels. Some channel degradation in
some sections of the river would occur as the river would attempt to
replace the missing sediment load with material picked up from the ·
riverbed, but this is not expected to be of significant concern along
the. coarse gravel bed reaches of the river between Devil Canyon and ·
Talkeetna. Projected studies should further clarify and define deg-
radation of the riverbed in this section of the Sus itna.
18'8 Yes, the p•roblem of frazil ice has been considered.' Also see response
number 298.
226
189 The detailed effects of altering the present flow regimen of the river
can only be determined by studies which have not yet been made, but
which are proposed during the pre-construction stage of planning when
detailed studies are normally made. Effects of flow changes will be
studied as far downstream as they can be measured, including Cook Inlet.
Winter and summer water temperatures will not be significantly affected
by the project. Multiple outlet structures will permit withdrawal from
the reservoirs (in which water will be thermally stratified) at any
level .required to maintain near-natural stream temperatures.
19U See response number 173.
191 See response number 240.
192 See response number 36.
l93The quoted sentence is a statement of fact. The Corps has a wealth of
data, available for public perusal in the District office, documenting
flood damages to the Alaska Railroad and the town of Talkeetna. Bene-
fits attributable to reducing damages to the Alaska Railroad are com-
puted in the project cost-benefit ratio. Benefits to Talkeetna are not.
Benefits resulting from increased recreational opportunity are also
included in the cost-benefit analysis. Benefits attributable to flood
control and recreationcomprise about 0.2 of 1 percent of the total
project benefits, thus neither is a factor in project justification.
19 4 The recreational benefits ascribable to the project are summarized in
. the EIS. The detailed recreational analysis is contained in Section F
to Appendix 1 of the Interim Feasibility Report. This document is
available for public inspection in the District office. Access roads
and all other facilities will be open to public use unless some areas or
operational procedures of the project are determined to be dangerous to
public safety.
1~5 Exact locations of the roads are not presently known, nor have mileages
and right-of-way widths been exactly determined. It is anticipated that
the majority of access roads will be open to the public. This is a
basic premise in the estimate of public recreational usage on project
waters and lands. Dirt and gravel will be obtained in the vicinity of
road construction. Necessary borrow areas, where possible, will be
screened from view from the access road. These areas will be rehabili-
tated as necessary.
227
196 Transmission line right-of-way will be obtained through standard real
estate procedures. Very little of the line will cross private property,
and, wherever possible, private lands will be avoided altogether.
In the event some private .lands are. traversed, property w.ill be acquired
where possible by negotiation. If this cannot be a.ccomplished, the
government will exercise its power of eminent domain •.. Yes, burying
the transmission line has been considered, and .. a discussion. of this.
alternative has been added.to the EIS. It is th:Ei. conclusion of the.
Alaska Power Administration.that underground cable is much more sus-
ceptible to damage from seismic activity than are overhead transmission
lines, and that the installation of significant lengths of high
voltage underground electrical transmission cable is limited by present
technology (see Section 4.13 of the EIS). A number of studies
have been made concerning health hazards associated with radiation
from high-power transmission lines. It is generally concluded that
lines transmitting less than 500 kv pose no threat to human h~alth.
One of these studies was made by Battelle Pacific Northwest Laboratories
and is entitled Measuring the Social Attitudes and Esthetic and
Economic Considerations Which Influence Transmission LineRouting.
·The report is dated July 1974 and is identified by index number
NW-l837UC-ll. There are very few climatic data for the area tra ..
versed by the transmission line corridor, particularly in regard to
wind speeds. The Interior Zone (north of the Alaska Range) is domi-
natedby high pressure air masses resulting in relatively m"ild winds.
The Transition a 1 Zone (south of the A 1 as ka Range) has generally ca 1m
winds, although high winds over 50 m.p.h. can be expected. The Mountain
Zone (Alaska Range) can be expected to have the highest winds. High
winds are reported to have knocked down 138 kv towers i.n the area.
lyitng between Cantwell and Healy. As stated in the EIS, the net·
firm annual energy delivered to Anchorage and Fairbanks waul d be 6 .. 1
billion kilowatt-hours .. This is net of losses in power transmission,
which amounts to 0. 7 percent of the energy generated at the p.ower
sites. The two referenced power grids are comprised of existing networks
of transmission facilities which separately serve the greater Anchorage
and Fairbanks areas. Yes, they could be interconnected without the
proposed dam; however, it is not necessary to connect them .. The
advantage to interconnection is largely related to the greater relia-
bility of electric energy supply to the two separate communities.
They wou1d automaticallY be interconnected if the proposed hydropower
system is developed.
197 The marketing agent and operator of the system would be the Alaska
Power Administration. For a detailed discussion of secondary energy
and attraction of industry, see response number 255.
198 Ideally, the interest rate shown reflects the opportunity cost of
the funds committed to the project. It should not necessarily
reflect current financial market conditions, but rather the approxi-
mate return to savings and investment over the 100-year project
228
life. Current high interest rates are very possibly a short-term
aberration. By law, the interest rate is annually set equal to
the average interest rate on long-term government securities,
limited by a maximum increase of 0.25 percent per year. A sensi-
tivity analysis using a range of interest rates is described in
Section C of Appendix 1 to the Interim Feasibility Report which is
available for public review in the District office. The costs
mentioned are costs of different systems with different capabilities;
they are not altered cost estimates of the same project. Currently
available power sources (coal and natural gas) could supply the
needs of the ra"ilb.elt but at higher cost than the proposed plan.
The energy needs of the Railbelt area are discussed in the revised
main report. If constructed, the selected plan is to meet increased
energy loads during the period from about 1986 to 1997. During
this time, if the load ~projections are not exceeded, the existence
of the hydro project would take the place of any net addition to
thermal plant capacity that would otherwise be added in the Railbelt
area.
199 Comnent noted.
229
Greater AilohoJ:"age
CHAMBER of COMMERCE 1(6>···
.A'
! '
i
October 22, 11!75 Crossroads of the Air World
Colonel Charles A. Debelius
District Engineer
Corps of Engineers
P.O. Box 7002
Anchorage, Alaska 99510
Dear Colonel Debelius:
On. behalf of the Board of Directors and membership of the Anchorage Chamber·
of Commerce , I wish to ex;press our total support for the development of hydro-
electric power in the Upper Susitna River area.
The Chamber would like to offer its services in helping to promote the con-
struction of the Devil's Canyon and Watana dams as soon as possible. Please
call on us for any further help we may provide.
, Sincerely yours,
2 0 0 ·1 ~H~~~~~
President U
sww
GREATER .O.NCHORAGE CHAMSE!'t OF COMMERCE-612 F STREET. ANCHORAGE. ALASKA .1111501 -[1107) 272·2401
230
RESPONSE TO COMMENTS BY
GREATER ANCHORAGE CHAMBER OF COMMERCE
200 Comment noted.
231.
,)hn COlberq, Jr:
·~ of 1M Bocz:rd
Roy Huhndorf
itR~Jolk,l~~
Alaska District, Corps of Engineers
Attn: Colonel Charles H. Debelius,
District Engineer
P.O. Box 7002 , ·
Anchorage, Alaska 99510
Dr3.r Sir:
Pro.ddent
October 9, 1975
This is to notify you of a possible error in the impact·statement "Hydroelectric
Power Development Upper. Susitna River Basin Southcentral Railbelt Area,
Alaska." On page 39 the second paragraph.under Archeological Recources
states that, "two archeological sites within the general vicinity of the
proposed transmission line corridor are listed in the National Register of 4
'February 1975. These are the Knik and Dry Creek Sites." According to Doug
Reger, State Archeologist, the Knik site is not an archeological site, but
an historic townsite. It i's not listed in the National Register as an
archeological site (p. 5250). However, Dry Creek is listed as an archeological
site.
Employed as a research assistant with the Cook Inle~ Historic Sites Project,
I have encountered this apparent inconsistency. The Project is involved in
compiling an invent·ory of Native histor.ic and cemetery sites in the Cook
Inlet Region.
If you have any comments on this matter, please direct them to:
201 I
Thank you.
MW/mr
Mary Weirsum
Cook Inlet Historic Sites Project
1211 West 27th Avenue
Anchorage, Alaska 99503
Sincerely,
232
Mary Weirsum, Research Assistant
Cook INlet Historic Sites Project
1211 W. 27th • ANCHORAGE, ALASKA • 99503 • PHONE 274-8638
/~
I
RESPONSE TO COMMENTS BY
COOK INLET REGION, INC.
201 The correction has bee~ made in the EIS.
233
Knik Kanoers & Kayakers, Inc.
3014 Columhia
Anchorage, Alaska 99504
17 November, 1975
Cdl. Charles A. Debelius, District Engineer
Alaska District, Corps of Engineers
Department of the Army
P,O. Box 7002
Anchorage, Alaska 99510
Dear Col. Debelius:
The Knik Kanoers -& Kayakers wish to go on record as opposing
the construction of any dams on the Susitna River. Such
development would destroy a major wilderness whitewater river:,
termed "the biggest in North America" by its first paddler,
Dr. Halter Blackadar.
In the 1 fifties and 'sixties the Corps dammed a number of
the nation's finest whitet>tater rivers in the name of 11 progress.11 ·
Yet each new dam served only to spur on further profligate
use of energy. In other words, these beautiful rivers were
sacrificed to no useful purpose. Nm.radays such economic
boondoggles would never \>•lin approval, yet the Corps is attempt-
ing to start the same destructive, wasteful process _here with
one of the country's most spectacular, ~tlildest, loveliest
rivera. The Susitna.must be left to run free for future
generations.
2021
234
Sincer~_~Y yours,
)-? .. " . (~~v---P--~~-
~--,.,.A."_..... ~-
Ed Swanson
President
202 Co11111ents noted.
RESPONSE TO COMMENTS BY
KNIK KANOERS & KAYAKERS, INC.
23>5
---------··~-·-·-----·~------------------------------
From:
Orah Dee Clark Jr. High
.150 South Bragaw
Anchorage, AK
To whom it may concern,
October 8, 1975 '
The seventh grade sixth period class took a· p~ll, '~nd ·has decided,
at the rate of seventeen to·threo,. against the series ·of dams, beginning
with the Devils Canyon Dam .. He decided against it for.v11.'1"ious reasons;
{1) th~t it 'rrould harm the ecology, (2/ That it 'rrould h~m the natural
'habitat of rnoose··i· and ·other.-wildliff=l,~d (J). that it would damage the
scenery, '..fhich we feel ha.s been damaged enol~t;h.
He vere appointed to this corrunitee by our tea,cher Hrs. Stark of
Drab Dee Clark Jr. High. She gave us·the pro!s and con's of the issue,
~· '1 ~~t-o,
and took.the poll. · I Respectfully yours,
2.0 3 · Kris Ashley
Theresa Rusnak
ft·O~ ~~-q
.. ~
203 Comments noted.
RESPONSE TO COMMENTS BY
SEVENTH GRADE
ORAH DEE CLARK JR. HIGH SCHOOL
237
204
205
Sierra Club
330L~ Imlla, !l5
Anchora:3e, Alaska 99503
15 November, 1975
c61. Charl~s A. Dcbelius, District Engineer
AJa slca District, Corps of Engineers
D~partment of th~ Army
P;.O. Box 7002
Anchorage, Alaska 99510
Re: NPAEN-PR-EN
Dear Col. Debelius:
The followinc; are ... the comments of the Sierra Club on the Corps
of Engineers' draft environmental statement on Susitna River
hydropower development.
The draft statement is inadequate. Its basic fault is that.it
i::J .one lone; propaganda piece, Vli th a notable laclc of hard
data presented. Such date must be supplied in the final docu-
ment so that readers can make a rational choice as to whether
the proposed Susitna darim·are economically and ecologically
juttifiable. ·
There has been a serious failure to discuss alternatives to
the project. The Federal Pm1er Commission did the scopine;
analysis·to select the least-cost alternative for.comparative
evaluation with the hydro pr9ject. In doing so, the FPC elimi-
nated from consideration sev~ral alte~natives which could, if
allocated the $1.5 billion projected hydro cost or even lesser
amounts, compare favorably to the dams. These al terna.tives
include solar, wind, geothermal, and tidal power generation
s~r::;tems· and investment in conservation measures.
I '
I The DEIS rcco(jnizes that oil, natural ·gas, and. coal will be ·
Alas 1m 1 s major power sources for at least the next decade. During ·2 0 6. this time it mal.<es muc. h more sense to invest in technologies
which the seeping analysis ruled out and have them on line by
the end of the decade. · ·
1
.. · A major advantage of non-hydro alternatives is their flexibility.
Coal plants, for example, can come on and off line in response to 20'7 demand. Once a hydro project is built it will generate large · ·
· amounts of electricitt regardless of need. The effect. of this .
• will be to attract iQdustries that need large blocks of electricit-y
·1· On page six, it is stated that 11 The benefit-to-cost ratio compared
·. to the coal alternative at 6 1/8% interest rate and 100-year ~
238
2
project life is 1.4 using Federal financing." Surely 'the
writers of the DEIS understand that a benefit-cost ratio is
meant to indicate whether a project's costs outweiGh ita
expected benefits. It is an internal relationship and the coal
alternative should not have entered into the calculation at all,
though it is proper, once the B/C ratio is computed, to compare
it· to the B/C ratio for other projects. Furthermore, tne DEIS
gives no information on how this figure was arri\,!ed at. What
are the project•s. expected benefits?. On page 71 recreation and
flood control are mentioned as benefits, but within the body of
the D~IS f'lood control is' otherwise never referred to.
2oa
The Corps accepted the FPC scopine study and proceeded to
evalu~te coal as the lea~t-cost alternative. Coal was evalu-
ated at a 8. 7796 discount'! rate while the hydro project was evalu-
ated at the 6 1/8% interest rate prescribed by the Principles
and Standards Act (which, . while a vast improvement over' the 209
ridiculous interest rates the Corps used to assume, is still
extremely low in terms of today 1 s money market). The draft
interim feasibility report gives a B/C ratio of 1.4 for hydro
and 1.3 for coal. But the difference in interest rates seems
to account for the reason the B/C for hydro is more than that
for coal. Even with that favorable interest rate, the ratios
are almost the same! Furthermore, the B/C analysis gives no ..
weight to flexibility and responsiveness of the power generating
systems. The coal alternative is a flexible system which the
private sector would .finance, and coal is a resource which can
be developed ton by ton as it is needed. The hydro project
would be an inflexible commitment of resources underNritten by
. the federal government; its 11 front-ei7-d 11 costs are extremely ·
high and represent bills which fall due before any energy is
produced at all. ·
Another flaw in the B/C study in the estimate for recreation .
benefits. Recreation benefits are.estimated at $300,000 annually.
In fact, there are virtually no recreational benefitD for the
pro,ject and there arc very hic;h recreation losses. Accordinc;
to the draft interim feasibility report (p. F-3), 11 Pew places
in the world offer the variety of outdoor recreation resources Z""l.\
available in Alaska.-. Both residents and visitors alike have .LV
unexce1led opportunities.for recreation activities among a pro-
·rusion of beautiful lakes, rivers, and mountains, largely un-
touched by modern civilization. 11 Given these fortunate -circum•
stances, why would anyone want to visit a narrow, murky, arti-
ficial lake? 'l'he \vatana reservoir, with its annual drawdown of
from 80 t.o 125 feet (which would be at its worst in early June,
then r·ise steadily throughout the sununer), would be virtually ·
unusable for recreation purposes. A boat-ramp which can allow
for a 125-foot variation in water level in a steep, narrow canyon
wo~ld be difficult indeed to design. · ·
The Susitna flows 11 some 130 mil~s through uninhabited.countryu I
(p.. 10). This is another, roundabout way of stating that it ·
.flows 130 miles through wildernesS:. .l:'lere the wr1 ters of the DEIS
211tafraid that the \'lord '\·;ilderness 11 might mal{e the river in its
undamrned state sound too valuable?
3
212
213
The statements at the top of page 14 are misleading. It should
be noted that none of thes·e rivers is Class VI in its entirety.
Turriback Canyon on the Alsek can be portaged; the rest of the
river has been run by inexperienced l<:ayakers. Devil Canyon on
the Susit'na can also be portaged; here a(jain, the river above the
canyon can be and has· been run by kayakers of limited experience.
Less is known of the Bremner, but the heavy whitewater" is con-·
fined to its two canyons. The~ point i~ that even a very diffi-
cult river can be utilized by /inexpert kayakers and rafters if
the rapids can be portaged. As for Devil Canyon itself instead
of making value judgements and using loaded words like r'dangerousJ 11
the final EIS should emphasize that it is attractive to·lmyakers
precisely BECAUSE it is difficult. Walt Blackadar, the·first
person to run it and a heavy-water paddler of extensive ex~er-
_ience, termed it 11 the biggest whitewater in North America. 1 ·
r mtion is made here that the Susi tna was recommended as a BOR
study river "but "VIaS not one of the 20 rivers recommended for ·
inclusion in the (Wild & Scenic Rivers) system by the Secretary
of the Interior in 197l~.n True, as far as it goes, but it doesn't
go far enough; Interior 1 s d-2 bill· is only one of seve'ral. The
Susitna is indeed proposed as a wild river in the conservationists'
d-2 bill, as the authors of the DEIS were surely well aware.
'
I Page 23. "Several" ne,sting pairs of bald eagles and gyrfalcons 214 v1ere observed in the·. canyon area. Hovt many is "several 11 ? vler e
there so many that they could not be counted? .
215
On the same page,· it is noted that 11 Motorized all-terrain vehicle
access to the bacl<eountry has improved hunt'in13 success even in
the face of a rapidly declining caribou population'' (Nelchina
herd). A critical factor has been til inter maintenance of the
Nabesna road, which permits snmtmobilers to haul their machines
in as far as they wish in comfort, then take off. Caribou--
especially preenant cows--are not able to withstand the_resultant
noise and harassment. Roads vastly increase the activity of off-
road vehicles, and the Susitna dams will require roads (built at
. state ex12ense?), presumably maintained in. winter (also at state
expense?). The final EIS should investigate the·probable con-
sequences to an already threatened caribou herd. '
PD.f3C 24. 'l'hc maps throuc;h the entire document are poor. Only
nome one Who recoc;nizcs the. shape of the Sus i tna ~rould be able
216 • to locate it on the .maps, since it is not labeled. Yet presumably
the relntionship of the river to the habitat being mapped is
critical--far more so, for instance, than the location of Cordova
. (~rh~ch appears on each map). Without knowing which line represents
the river, and the ldcation.of each dam, the graphics are quite
:literally meaningless. ·
-· I: Hunting, pressure for rams in the Cantwell-Healy area is: 11 fairly
240
heavy due to relatively good access from hight-tays, by · air, and
by ATV 1 s" (p •. 27). The statement is true, and the Susitna
4
hydro project would provid·e equally easy access for an area that
1a now wilderneaa--a roadJ which can also be used to haul ATV'e
on, and two o~ more enormous lakes to land a floatplane or ski-
plane ,on. The effect on moose, caribou, and bear ohould be noted
in the final EIS ..
The Susi tna area "has consistently produced lllOt'C \'lolvc.l.'li\C:J tlmn
any other area of comparable size in thc.State •••• WolverD\eB
·have withstood human encroachment and trapping tdthout any
noticeable reduction in numbers or range" (p.·28). Yet it has
already been admitted that the area is presently wilderness, so
any "encroachment" so far hao been hunting lode;cs and trappers•
cabins-..:.not 70 1 000 visitors a year. ~lould the DEIS have us be-
lieve that wolverines won't !!!1ru! the dams, roads, people, noise,
etc.? Absurd. The wolverine is an extremely secretive, wary ·
wilderness species which cannot coexist with highways and
industrial development.
Pa'ge '37: · 11 Float planes are 'USed to fly. in hunters ••• but this
form of access is relatively minor.; .•• A major recreational use ••• ·
is big":"game hunting •••• The greatest pressures are.exerted from
a few fly-in camps. 11 If fly-in access is "minor ,'1 then how can
it produce the "greatest 11 pressure in a 11 major 11 recreational use?
The statements are inconsistent, a frequent problem in the DEIS
''It appear·s. that the use of ATV's for hunt.ing, already prohibited
in some.areas, may have to be further oontrolled.11 This state-
ment misleadingly implies that such use ~ be controlled, when
in fact it is very difficult (and expensive) to do. What Nill
be the costs of the extra wild.life protection officers needed to
enforce such a closure in an area where".easy access has newly
been created? Who will pay these costs~
Par;e· 38. Again, the superlative, huge whitevtater of Devil
Canyon is implied to be very unattractive, equivalent to
implying that Mt. St. Elias is "no eood'1 for climb inc; because it
is very difficult nnd oucccsof'ul nttcmpts hnvc been J.'c:w.
He find 1 t cxcceclinc;ly odd that the DIGS· was rushed' to publication
just before the Corps was due to receive the Jones and Jones
·s·tudy on recreational use and potential of the Susitna. Although
as a consequence \·m have not had the benefit of reading the study
itself, we understand that it recommends that the whitewater of
Devil Canyon not be inundated, because of its great value as a
scenic and recreational resource.
Page 40, enerWy needs. Again, these are mere unsubstantiated
statements. . 1Because of lead time needed for coal and ·hydro-
electric d!3Velopment, immediate needs for the next decade will
have to be handled by additional oil and ~a~-fired units.11 True,
even· too generous, as regards hydropm'ler {the Corps fact sheet of
Oct. 23 1 1975 estimates c·onstruction time at 14 years), but Beluga
coal has already been leased and is ready to be mined, and Healy
coal is already in production and ~as been for years.
·241
218
219
221
2~3
224
225
Page 41. "Heavy emphasis should be ~iven to those technologies
which utilize renewable or essentially inexhaustible energy
sources. 11 It is preposterous to imply, here as else~th;ere in the
DEIS, that the Susitna dams represent the use of renewable re-.
sources. A wilderness river is not a renewable resource. Once
developed, it is destroyed forever. And great wilderness white-
water rivers are not only nonrenewable, they are exceedingly
rare, thanks largely to the Corps of Engineers. ·
Page 42. More ~arbage g~aphics. \'That on earth do the fiGures
on the left reprenen t? 50,000 tVHA'l'? On what information is the
graph based? Here again, we are to·accept it on fclith. And it's
an old, old tricl\: to. set forth one absurdly high figure to make
one 1 s preferred alternative look more reasonable by comparison.
vlhatever those left-hand numbers symbolize, the high range
indicates we'll use 19 times as many of them in the year 2000
as we did in 1970. Even hamsters dC?n't multiply .that fast.
Page 45. There are some interesting implications on sedi-.
mentation here, although the. DEIS wrongfully fails to make them
explicit. The avera~e natural flow in the five high-flow months
of f"/lay-Sep tember is 19,328 cfs. If we ass.ume an average sediment
load of about 1000 ppm (the DEIS says it is 11 less than 1000, 11
leadinc; the cynic to believe that it must be very close indeed
to 1000 ppm), .then 19.3 cubic feet of silt would be flowing into
the Wa tana reservoir. every second during those five months for
a total of.255,130,560 cubic feet (9,l~49,280 cubic yards), Just
in the Ma.y ... September period, every year. We will charitably
assume that no silt enters the reservoir from October-April.
Meanwhile, of course, a small amount of silt-is leaving the
system: 15-35 ppm year-round in an avcr~gc flow of 9300 cfs.
Ac;ain gcnerou::;ly asnuminc; that n llJ.rr,h 32 ppm leaves the
system,, that's .3 cul.Jic feet of ::;cc.llmcnt lost per second or
9,J~60,t500 cubic feet each year (350_,1~00 cubic yards). 'In short,
9,449,280 cubic yards of silt, sand and gravel entering the
system every year, 350,400 cubic yards going out~ and a net
yearly gain of 9,098,880 million cubic yards. That's a formidable
amount of silt. Can the Corps guarantee that reservoir siltation
problems will not occur here as they have at other dams?
I Pac;e h6. If whitewater can 11 reduce substantially 11 the"super-
. saturated nitrogeh and dissolved oxygen introduced into the 2 2 6 wa.,ter in pa. ssin. g o. ver the spillway., then why not leave more
whitewater available for this useful purpose, instead of sub-
• merBing nine of the 11 miles of Devil Canyon? ·
22?
Page 48. 11 Futurc detailed studies 11 will be necessary to make
sure e;cneral channel dce;radation won't occur below the ctam as
the river attemp:ts. to regain its normal sediment load. These
·studies are to be part of 11 pre-construction plar'ming, 11 ·which the
Corps would have us believe does not necessarily commit us to
building the dams, despite the name.
I We are told that the Watana would flood existing fish habitat
but might create -11 0ther fish habitat at higher elevations on
242
6
these tributaries. 11 Perhaps. But it's certainly not going to I >·
replace spawning habitat~ which requires clean~ \'iell:-oxye;enated . ·_
·gravel; not while the Watan,a reservoir is fluctuating 125 feet 228
every summer! · ·
. .
Page 49. The Susitna carries \'linter silt loads of 4-228 ppm;
earlier the.DEIS had termed the winter water 11 c1ear.11 Yet the
discharge below the dams· would be "milky" at l5-35 ppm •. ·
. Both statements can't be true.. The problem may be that the DEIS 2.29
tends to use fi~ures distorted by extreme circumstances when the
mode \'lould be more useful. Trivial here~ perhaps,. but"not so
elsewhere--as regards energy demands, for instance.
Page 51, the question of fish habitat in lakes with heavy silt I ·
inflow •. The DEIS · admits that it could be a problem, but mel'}tions ·
the many natural lakes \'/here there is fish habitat despite heavy .
inflows of silt. But these lakes have equally heavy silt flows ·.· 230
back out, as anyone knows who has paddled the Tazlina. The lal<:es
don't simply silt up. as the Watana reservoir will eventually.
Also on thi.s pac;e is the first hint ("the proposed series of
high-nead dams 11 ) that the Corps does indeed intend to bui,ld all
four dams once it gets its foot in the door, despite the
pious assurance on page 89 that "the mag~itude of environmental
impacts resulting from a four-dam system in the Upper Susitna 231 ·
River Basin clearly makes this a less d~·sirable· alternative
than the one:-, t1;10-1 or three-dam plans. 11 The final EIS should
make· explicit the Corps 1. intention to build .all four dams.
Page 52. The problem of ice shelving in the Watana resel'voir
and the attendant difficulties for caribou and moose attempting
to cross it ls a serious one and there is no justification for
glossing ove:r-it, as the DEIS does. Studies indicate tha.t cari-232
bou use of the Watana site.for grazing and crossing "was minimal
during the period November 1974 through April 1975.11 One five-
month study, on a migratory species like caribou, is of very
limited utility, yet the reader of the DEIS might well recieve
the· impression that it proved that caribou do not and \'lill not.
use the area. No such conclusion is possib;Le on the basis of
a single winter's study.
·Page 53. Couo,tin£5 condi tiona in June 1974 were "less than ideal."
ADF&G saw only 356 moose, whereas they'd seen 1796 the~previous
fall. Unless the winter was inordinately severe, we can assume
that countinc; conditions were not merely 11 leG3 th.an id.c. al": t(ley
were totally inadcqua, te •. Yet the DEIS mentions the fic;ureo as 233 •
thouc;h they were rnc<:mingful. 1\DF&G has rightfully resented the.
unreaoonable haste \'lith which it has had to curry out its SUsi tua
dam studies, anq on a ·meager budget. Cooperation from the Corps
has been very poor. '• ir .
Page 54, transmission line. impacts. The DEIS states tpere will I
be "not many per se; most ••• will be as a result of construction
and .maintenance." In fac·t the growth the Susitna dams will
foster., and the e~sy access i't will provide, will· cause major ·
243
·7
2 3 4limpacts. And as any hunfter can attest, wildfowl tend to avoid
. · transmission line corridors.
235
Page 56. "Initial annual visitation to the project area would .
be about 77,000 people 11 ! Is this figure part of the source of
that inflated 1.4 B/C ratio? Hov1 was it derived? If 77,000.
people really did use the· area (as opro:1ec1 to merely (~r-:tv:tn~~
by out of curionity to elnnct~ nt t.h~· d:un, .wh\.,,h \~,,ltld hal'dl~t
provide a sic;n:Lficnnt rcc.rocntJ,.HHtl hcncl.'.l.t), ·the :l.tlll'l.\1.!\; Nould
be· tremendously heavy. Ccin .'l':dlcectntl (pop. 200) handle such ·a
visitor load?
I Pa~e 57.. "r"luch of the cx:lstlne tree and shrub cover .in the Upper 236 .S. us,itna Riv.· e.-r Basin is .. located in the river and creek bottoms .. ·
· and on the steep canyon slopes above the s.treams and would be lost
· during dam construction. 11 This is important moose habitat.
237
23
Pag·e 61. Land along the Susi tna 11 is. a natural and scenic area
that would probably qualify for wilderness classification under
~definitions of the term.11 (Emphasis added.) Under what
definition could it possibly fail to qualify? The proposed Corps
proj~ct wo~ld definitely destroy a wilderness river and area of
high quality. That fact should be admitted forthrightly in
·the final EIS.
"The proposed transmission line corridor would cross no existing
or presently proposed scenic, wild,· or recreational rivers, nor
would it c~oss any existing.or presently proposed wilderness ,
areas or l'lildlife refuges." True, but what of the darns •them-:
selves, and the proposed Susitna-National Wild River of conser-
vationists t .d-2 legislation now pending before Congress?
2.39
"Between Gold Greek and Cantwell, a visible (power) line would.
have substantial impact, particularly if located \'test of the
high,.my and railroad. 11 It could not be concealed through Broad
Paos. This area provides some of the most strilcinr;ly scenic ·
viewsof Mt. McKinley and the impact of such a transmis:::>ion
240
line would be devastating. It is appalling that the CL>rpr. would
even consider placing the line on the west side of the.hie;hway
and railroad.
Page 62. How fortunate that the 11 most likely 11 source of an 8. 5
earthquake would be a safe 40 miles distant. Yet it is also
admitted that 11 the Susitna·Fault, truncated by the Denali
F~ult 1 biaects the rc~1on in a northeaat to aouthwcat direction
approximately 2.5 miles wcat of the \'Jat~na dumu1tc.11 ~Jhut
::>tudica of the fault sy3tcm and "most .likely•• quakes have been
done by ;Lndcpcndcnt selmnic experta? Why docs the DEIS contain
no maps or graphic.: displays nhowing the location of these
faults? vias it feared that it would look a little too graphic
only 2. 5 miles from an 810-foot-high earthfill dam?--,
'
Page 63.: There could be ice-fog conditions in the area below
Devil Canyon Dam 0 during periods of extreme cold weather." The
implication is that ice fog is a rare occurrence indeed, happenine
244
dollars. The same fact sheet mentions a 14-year construction
period •. If the project were already in progress today,: it
coul"d not be finis,hed until late 1989. The whole DEIS is filled
with speculative projections on dubious grounds; why was there
·no projection of costs in Oc.tober 1969 dollars? If inf].'ation
~ontinues at its current 13% rate--note that \..re are playing the
Lorps 1 own game here--the final cost will be $8.33 billion, a
staggering sum.
But let us assume that inflation will be nonexistent for the
·next 14 years and that there will be no cost overruns. A
modest proposal: instead of building the Susitna dams, that
$1.5 billion could be invested. Even ata mere 6%, it would
produce $90 million a year. It could be split up among some·
400,000 people· expected to live in the rail belt area at $225 .
J?er capita. Surely most Alaskans would prefer to have the cash..;.-
:P900 yearly for a family of four would go far toward paying the
gas billl--and the ~enerous u.s. taxpayer would be sure to .
approve, since the $1.5 billion principal would remain untouched.
A beautiful wilderness whitewater river·would not have to be
destroyed, and Alaskans would not have to suffer through still
another wracking construction boom.
10
The hydro project not only makes little sense for Alaska, it·
makes little sense in terms of a wise national energy policy~ The
opportunity cost of investing $1.5 billion to produce power fo~
approximately 400,000 people is extremely high. This large an
investment inprojects other than hydropower could provide more
energy for more people at lower environmental cost. ,
The DEIS suggests that Alaska would be dependent on .oil and gas
during the dams' 14-year construction time~ Hhen thy dams come
on line, the hydropcMer would theoretically replace oil a.nd natural
gas generatipg facilities thus freeing up the oil and gas to
be shipped to the Lower 4~. (This scenario is unlikely to occur,
as earlier noted, because the hydropower would probably attract
large block industrial users and stimulate demand, rather than
meeting existing and projected demand.) But even if oil and
natural gas were no longer needed.for electrical generation, the
yearly savings would be insignificant compared to national oil
consumption. The DEIS states that estimated 1972 fuel use for
Alaska's power systems included 1.4 million barrels of oil. For
purposes of comparison, in 1972 the nation as a whole used 5.99
billion barrels of oil. (Source: Ford Foundation Energy
·Policy Project, Preliminary 'Report.) Thus Alaska represented .
less than one four-thousandth of the total demand.
A major goal of the project is to conserve fossil fuels· (p. 91) •·
11 By the· same token, the project \"IOUld contribute to
a savings in nonrenewable energy resources with an
energy equivalent of about 11.3 million barrels of.
oil, or approximately So billion cubic feet of gas·
per year. Although this savings is a principal factor
in the consideration of a hydroelectric alternative,
qver the long haul hydroelectric energy must be viewed
52
253
255
256
as an interim measure for conserving the nation's
nonrenewable cner~y sources until some more prac-
tical, permanent method of producing electricity
is achieved viliich will not overburden the nation 1 s
or. world's finite resources.11
11
But *1.5 .billion invested novT in new enerc;y sources and con-
servation measures would yield ~uch greater benefits than the
dams. '£he Corps is pushinc; for 11 pre-construc tion planninc; 11
funding an though an enerc;y emergency oituation, rather than a
surplus, exists or vrill exist within the next couple of.decades.
There is no'emergency, however. Alaska is well supplied with ·
energy resources in the process of being developed. The just-
released study by the state Pivision of Geoloc;ical and qeophysicaJ
Survey shows. that vli th the Prudhoe Bay gas owned by the ·state we ·
vrill have an. embarrassment of enerr;;y riches. Since there is time,
the·$1.5 billion or $3 billion or $8 billion of the federal
taxpayers' money. vrhich ·the dams will cost should instead be
invested in research for alternative, better means of energy
production, research which would be a godsend to the whole
nation.
Sincerely yours,
Jack Hesnion
Alaska Representative
248
only under "extrem~ 11 conditions. Alaskans know better. ~fuy I
did the DEIS not frankly state that ice fog would. be present? . 2 4.1
It's hardly a critical point. Of course, the defensive attitude
carries through elsewhere in the DEIS to.more important matters.
Page 64. "The proposed projects will not create large blocl{S
of excess electric power f'or heavy energy-consuming industries.11
An amazing statement!· . Without some good demand f'igures, how
are we to believe this? What of the Healy and Beluga coal and
the Cook Inle~ and Prudhoe gas? Are these other entrepreneurs
expected to give up .. their markets and go elsewhere? · More
plausibly, there will be a vast surplus and industry will be
encouraged to come up to Alaska to use it. And in fact the ·
Corps' .own Joe Auberg (western Planning Division, Washii<tgton
office) says that the final EIS will recognize that construct:ton .. '
of the hydro project would mean commitment to a growth policy ·
for the southcentral region.
Can the town of Tall<:cetna handle the impact of 500 to 1000
construction workers? 'l'he construction period :::h auld be
mentioned here. · 'l1he reader should not have to look up a
separate Corps fact sheet to find that the project will take
14 ycaro.
Puc~ a G5. Problema wl th tcmpcrn turo, . d.J.oool vcd oxyc;cn,: and supcr-
oaturatcd nitroecn "would be held to minimal, and possiuly
insienificant levels by spilhmy design ••• " If the problem is
really that easy to solve why does it still exist on other
major dams (e.-g. Columbia)? The final EIS should not imply
that the.Corps has the answer to all.the questions on super-
saturated nitrogen, etc. It doesn 1 t.
Page 68. "Future power systems 11 (but not this one?) 11 will also
require approaches. that include full consideratbn·ar environmental
values and alterna.'tives and must anticipate that Alaska and ·the
nation will attach increasing importance to environmental pro-
tection, energy conservation, and conservation of' nonrenewable
resources.'' Again the DEIS fails to recognize that huge wilderness
whitewater rivers are nonrenewable resources, and scarce, too.
Nor is a dam, rapidly filling up with silt, truly a 11 renewable"
resource.
Pages 70, 73. It. i.s int.eresting to note the close proximity of'
major coal and petroleum resources to the cities of Anchorage
and Fair\banks. Since the concept of the "rail belt" as having
high ene.rgy needs is fallacious (the two widely-separated cities
of Anchorage and Fairbanks are heavy energy consumers,·and so to
a much smaller extent are the towns of the Kenai Peninsula, but
the handful of homesteaders, dodge-owners and railroad•workers
living along the 11 railbelt" a'ccount for a minute share of the
total energy demand), why not simply utilize these nearby re-
·sources, which are already being developed, and without the need
for federal funding?. Or is the Corps telling Alaskans;that we
245
.. :·
242
244
245
. 9
the stress of pipeline booms, but are not to be permitted to 246 ~ain any benefit from the development of our state's resources? lmust endure the environmental costs of strip-mining for coal, and
Must all our coal, oil and gas be shipped to the Lovter 48 for
others to use?
247
Pag.e 75. The forecast of energy needs is. absurd. Having used
1.4 million barrels of oil and 16 billion cubic feet of natural
gas ·in 1972, . we are expected to use (under "mid-range 11 estimates!)
26 million barrels of oil (19 times as much) and 134 billion ·
cubic feet of ~as (eight times as much) in the year 2000 11 1f
recent trends continue." Without further documentation of
these ainazing figures, the reader must inevitably think them
equivalent to saying, "If recent trends continueJ the teenager
will be 10 1 6 11 by the time he 1 s 33 years old.11
2 .4 in most ~idal flow hydroelectric proposals are major factors i Page.. 77. The ".ext. reme costs and environmental effects involved
opposingn tidal power. True enough; very few places in.the
'.'rorld are sui table for the development of tidal power. Cook
Inlet happens to.be one of thebes~ however.
I It i·s notable. that the DEIS. finds us· "too small 11 for nucl.ear power-2 4 9 or solid ;."/aste burning, but 11 too big". to be allowed to use our
own oil and gas. . . ,
IPaG;e 67. The transmission line "right-of-way would pro~ide 2 5O cleared land at little or no ef-cpensc tC? the farmer. 11 A danger-
ously irresponsible statement ~hat should be deleted from the
finnl IUS. Radiation from high-voltage power lines is hazardous
251
to living tissues. •
Pa~e.75.· The difficulty of safe disposal of radioactive wastes·
is noted. Many people question the wisdom of a system that must
rely on many future generations to deal responsibly with the by-
products of energy used by this generation. But the.same argu;..
n :nt can be raised in connection with this hydropovwr project.
Even if it becomes obsolete:, even if it silts up and can no longer
produce power, a huge dam must be maintained and repaired ·
forever, else downstream residents will be at risk of horrendous
floods or mud .... slides. A dam is a sword of Damocles hanging over
the heads of our great~granchildren.
Page gil. He concur with the .Alaska Energy Office criticism that
the final EIS should ipclude a net energy benefit analysis for
the whole systemj including the energy used during construction
and losses during long-distance transmission.
.~.
Page 6, cost. Total first cost ·(January 1975} prices of $1.343
billion. There was no justification for:-us'ing January l975 prices
in the DEIS. Tpe Corps 1 Ootober' 23 fact sheet already shO\'/S a
price jump to $1.5 billion (a $157,000,000 riae.,.-more than enough
to build Senator Gravel's federal office building: L but even. tn1s ·~"
figure is ludic:rouFl, The contpactors will not-be paid in 1975
Z46
2 0 4 Comment noted.
RESPONSE TO COMMENTS BY
SIERRA CLUB
205 The Federal Power Commission, in carrying out its functions under the
Federal Power Act, is concerned with all elements in determining power
values. The Corps cooperates with the Federal Power Commission in
evaluating power benefits on the basis of unit power values developed
by theCommission. Project power benefits include financing factors
related to the alternative source of power, public or private, that
would most likely be utilized to serve the same market area in the
absence of the project. The alternative is usually a new, privately
financed, modern, and efficient thermal powerplant. However, all.
alternatives are carefully examined. In the case of this stud~both
natural gas and coal were chosen as the most reasonable potential
alternatives. Gas was eliminated on the basis of projected availability
at the time hydropower would go on line in 1986, and by the direction
of Congress to conserve nonrenewable resources and to utilize renewable
resources for po~er generation where possible. There is no longer
any reason to anticipate this fuel will continue to provide an abundant,
cheap energy source for the long term as has been exercised in the past.
In calculating the benefit/cost ratio of coal and hydropower alternatives,
the latter was determined to have the greater benefits.
2 0 6 Comment noted.
207 It is true that some non-hydro alternatives, such as coal, are more
flexible than hydropower in response to fluctuation in demand. However,
the hydropower project presently proposed will not meet energy demand
projected to exist within a relatively few years following project
completion. Thus, existing or future coal or gas plants may well be
used to provide the flexibility to cope with fluctuation in demand above
the level of baseload requirements fulfilled by the hydropower project.
For a thorough discussion of the effect of the project upon industrial
development, see response number 255.
208 The coal alternative does enter into the hydro project cost-benefit
calculation, because this alternative is the economic standard against
which each of the hydropower plans is tested. That is, the power benefits
of a given hydro system represent the cost of producing the same amount
of power by constructing and generating a conventional, state-of-the-
art generation system using coal as fuel. Thus, the coal alternative,
by definition, has a benefit-cost ratio equal to one. The interest during
construction was added to project costs, and those expenditures accruing
after 1986 were discounted to the 1986 power-on-line date at 6-l/8 per-
cent to give the total investment cost. The present worth of the benefits
was calculated .also by discounting at 6-1/8 percent to 1986. The invest-
ment cost and present worth of the benefits were then amortized at 6-1/8
percent over the 100-year project life to give annual costs and benefits
which were then compared to give the benefit-cost ratio.
24~
209 The coal alternative was not evaluated at an 8.77 percent discount
rate. The 8.77 percent figure is used to calculate annual fixed charges
and, as such, is used for different purposes than the discount rate
employed in the hydro analysis. Incorporated in this 8.77 percent
is the composite of municipal and REA borrowing costs in the Anchorage
and Fairbanks areas. It is this cost of borrowing that is properly
compared with the 6-l/8-percent discount rate annually estab 1 i shed
by the Treasury Department. The composite financing used by FPC in
analyzing the public, non-Federally financed coal alternative was 6.25
percent interest rate for the Anchorage-Kenai market area, and 5.95
percent interest rate for the Fairbanks market area.
210Most of the recreation benefits attributed to reservoir development
are associated with the Devil Canyon site. Also see response number
81.
211 Comment noted.
212 The paragraph has been reworked to indicate that portions of the
listed rivers are Class VI boating rivers, and that Devil Canyon is
difficult instead of dangerous.. For more information on white water
of Susitna, see response number 257.
2:l3 The Corps of Engineers is aware that 11 The Susitna is indeed proposed
· as a wild river in the conservationists 1 D-:2 bill--11
• Furthermore,
all land and water within the immediate area of project influence,
including the upper Susitna River, are tentatively scheduled for
selection as Native deficiency lands, which are classified as D~l.
Section 3.0 of the EIS is devoted entirely to a discussion of the
relationship of the proposed action to land use plans.
214 The paragraph from which the word 11 Severa 111 is excerpted refers to the
1974 findings of the U.S. Fish and Wildlife Service during a survey
of raptor populations in the canyon area of the upper Susitna River.
During this survey, three nesting pairs of bald eagles and two gyro-
falcon nests were observed near the Devil Canyon area. ·
215The Susitna River dams will require access roads which will be built
at Federal expense. They wi 11 require year-round rna intenance.. The
State may choose to incorporate these roads into the State highway
system. If it does, then maintenance will become a State responsibility
and cost. On the other hand, if the State does not choose to incorporate
the roads into its highway system, maintenance will continue as a
Federal responsibility and cost. Hunting pressure will not increase
as a result of road. access into the damsites since ADF&G has the·
statutory capabilities to control the actual pressures. Thus, only
the potential forhunting pressure will increase.
2.116 The Susitna River has been drawn with a darkened line to more clearly
· · show its 1 ocation on the schematic maps.
250
/-,.
217 The EIS clearly states (in Section 5.0) that increased pressures on existinq
game populations through hunting, tr~pping, and general disturbance and -
harassment will require i ntens ifi ed game management and 1 aw enforcement
practices. As previously stated, ADF&G has the statutory capabilities to
control these pressures--albeit, at ~reater cost and effort on the. part of
Sta~ government.
218 The quoted statement is included in the EIS to emphasize the importance of
Susitna River Basin to wolverines. Encroachment to date has included more
than 11 hunting lodges and trappers' cabins;" it has also included hunting and
sig'nificant impact on wolverines in the Upper Susitna River Basin. We have
expressed concern, however, (in Section 5.0) that any losses to moose and
caribou .occasioned by the project wi 11 11
••• impact upon predator species."
This, of course, includes the wolverine.
219 Of course, the use of ATV's can be controlled. The Alaska Department of Fish
and Game, in commenting on the draft EIS, has stated that it has the statutory
capabilities t~ control the actual pressures of increased hunting potential.
In the discussfon of ad¥.erse environmental effects which cannot be avoided
{Section 5.0), with re{erence to required road construction, it is stated:
"This would have the potential to increase pressure on existing game popu-
lations through hunting, trapping, and general disturbance and harrassment.
This in turn would require intensified game management and law enforcement
practices and preventative measures for the control of wildfire.'' Increased
costs related to intensified management and law enforcement would be borne
by the State.
220There is nothing in the referenced paragraph which implies that the "Super-
lative, huge whitewater of Devil Canyon" is unattractive, much less 'very
unattractive'." However. to be constant with an earlier change in adjectives
suggested by the reviewers, we have substituted the word ''difficult" for
"violent. 11
2~ 1 The Jones and Jones· report was provided to the Alaska District in r1arch 1975,
and has been available in the District office for public review since that
time. All relevant, significant information contained in the report was
utilized in preparation of the draft EIS. With respect to the report's
recommendation concerning the inundation of Devil Canyon, the following is
quoted from page 8 of the report: "In particular, it is suggested that
relocation of the Devil Canyon Dam to a point above Devil Creek be investi-
gated, perhaps at a higher pool level, coupled with relocation of the Vee
damsite somewhat downstream and deletion of the Watana damsite entirely.
Possible benefits include preservation of the esthetic resources of Devil
Canyon and enhanced reservoir fish habitat and recreational opportunities."
In fact, not only was this alternative considered and evaluated, it was but
one of a number of dams and combinations of reservoirs which were evaluated
in selecting the proposed plan. The authority and responsibility for this
final decision rests with the District Engineer--not with a consultant.
251
2 2 2 Comment note'ct.
2 ~ 3The ETS candfdly discusses the inundation of some 82 miles of the Susitna
River, including: 9 miles of the existing ll-mile whitewater section in
Devdl Canyon. The whole section from which the sentence is quoted deals
with energ;y needs. The Susitna River does, in fact, constitute an i nex-
haustible energy source.
2 2 4 The ordinate scale of the load projections on the projected energy
demand graph was. inadvertently not labeled in the draft ElS. The numbers
in this scale represent ki 1 owatt-hours (in mi 11 ions) and have been so
labe:led in the revised draft EIS. The origin and meaning of the curves
on the graph are fully discussed in the EIS. The. mid-range 1 oad projection
curve selected for the Corps• analysis is considered conservative, with
annual rates of increase in power, requirements less than 7 percent
afte:r 1980 as compared to an historical annual growth rate of 14 percent
duri'ng the period 19;60 to 1971.
2 2 5 On the basis of data from reservoir projects on many types of rivers,
the Corps has developed a reliable methodology for calculating sedimentation
rates. On the basis of this methodology, which includes consideration
of g;eologic characteristics of the basin, river gradient, precipitation
patterns, runo·ff characteristics, and topography, the Corps has estimated
that the project will exceed by a large margin the 100-year 1 ife upon
which economic justification is based (it is presently believed that the
use'fful life of the project due to sedimentation may exceed 500 years).
2~ 6 Nitrogen supersaturation is a phenomenon which would only occur when
water is released through the overflow structure. This would occur at
an estimated frequency of once every 2 years with a duration of 14 days.
The overflow structure will be designed to minimize introduction of
nitrogen. The expected impact of this condition is not significant
enough to warrant relocation of the dam.
2270uoted fully, the sentence containing the phrase "future detailed studies"
states: "However, this phenomenon would be the subject of future detailed
studies to determine the distance at which sediment loads would become
reestablished ... There is nothing in the EIS indicating that such studies
11
••• will be necessary to make sure general channel degradation won•t
occll.lr below the dam ... " It is true that the referenced future detailed
studies are recommended as part of preconstruction planning. Detailed
pla~ning of all Corps projects is done following specific Congressional
authorization and funding of such studies. Following the completion of
detailed preconstru.ction planning, Congress again determines whether or
not the project should be funded for construction.
252
2~8 The EIS states only that possibly other fish habitat would be created at
higher elevations on the tributaries to the Watana reservoir. The actual
effects can only be predicted on the basis of detailed field studies. There
is a good possibility that reservoir fluctuation would not significantly
affect spawning habitat, Drawdown will occur during the winter months,
when river inflow is low. The reservoir will be filled during the ~pring
and summer months of higher runoff. Should spawning occur during the
period when the reservoir is full and relatively stable, there may be
little adverse impact on any new spawning habitat created at the higher
elevation.
229 In describing river characteristics under existing conditions in Section
2.0 of the EIS, it is stated: 11 During the winter when low temperatures
retard water flows, streams run relatively silt-free.11 We see no conflict
between this statement and the one on page 49 of the draft EIS which states
that winter investigations by the Alaska Department of Fish and Game indi-
cated that suspended solids ranged from 4 ppm to 228 ppm. Following project
construction it is predicted that suspended sediment in releases at Devil
Canyon Dam would be relatively low (15 to 35 ppm) year-round as a consequence
of heavier sediments being retained in the reservoirs. However, even at
this low figure, it is predicted that the water may not be as clear in the
winter months as it now is due to the nature of the very fine 11 glacial scour 11
which will be introduced into the reservoirs during the summer months and
remain in suspension during the winter. Sediment samples taken by ADF&G
under existing conditions reflect a transport of heavy sediments which
originate from the riverbed itself. Relatively high concentrations of
large, granular material may not significantly affect water clarity,
whereas much smaller amounts of a finely suspended sediment will cause a
turbid or 11 milky 11 appearance. The last two sentences of the reviewer's
comment are noted.
230 All lakes silt up. The rapidity of filling is related to the amount and
characteristics of sediment inflow, outflow, and the size, depth, and
. length of the lake. This is equally true of natural bodies of water and
manmade lakes.
2 31 The ''proposed series of high-head dams 11 refers to the Devi 1 Canyon and Watana
dams. These are the only dams proposed for development in the Upper Susitna
River Basin.· The proposed high-head Watana Dam inundates the Vee damsite
thus making it unavailable for hydroelectric development. There are no
232
other damsites suitable for development of a high-head dam.
The following statement is made in the referenced paragraph of the EIS:
•• ... under adverse ice conditions, the reservoirs could result in increased
problems for some segments of the herd. Also, there could be somepermanent
changes in historical herd movement patterns. n The five-month study by
ADF&G was referenced because it is the only study that has been made of
caribou crossing at the Watana reservoir site. A previous paragraph states
that caribou do use the area.
253
2 3 3There is no implication in the referenced paragraph that the moose count
figures are ''meaningful.11 They are included simply as a matter of recorded
fact. If any conclusion can be drawn from these statistics, it would appear
to be that the upper Susitna River and the low drainage areas of the major
tributaries provide important moose wintering habitat. The statement
11 COoperation from the Corps has been very poor 11 is a misstatement of
facts. The Corps has cooperated and worked very closely with ADF&G.
2ii 4 Impacts resulting from the transmission lines, including secondary effects
resulting from road access, are thoroughly discussed in other paragraphs
in this section of the report. We note with interest that some reviewers
regard transmission lines as a threat to wildfowl because of the possibility
of collision while others believe that wildfowl tend to avoid transmission
1 i ne corridors.
235 The visitation estimate was provided by a private consultant who closely
coordinated his work with the Bureau of Outdoor Recreation and the Alaska
Division of Parks. Benefits attributable to recreation constitute approxi-
. mately 0.2 of 1 percent of the annual project benefits. The Corps has not
predicted that the estimated 77,000 people who will visit the project
annually will also visit Talkeetna, which would be separated from the
De vi 1 Canyon site by over 110 mi 1 es of roads. There is no p 1 an ned direct
project road access between Gold Creek and Talkeetna.
236As required by the 1958 Wildlife Coordination Act, the Corps has requested
from the U.S. Fish and Wildlife Service an evaluation of project impacts
upon fish and wildlife resources, including moose. Upon the conclusions of
their study, a determination will be made through the cooperative efforts
of wildlife agencies to determine mitigation measures necessary for the
unavoidable destruction of moose habitat.
237 The Corps' description is accurate as written. There are many criteria
established for wilderness classification of an area. The description was
put in the EIS to inform the reader of the wilderness quality of the area.
The fact that a portion of this area will be extensively modified, including
complete inundation of some 84 miles of river, is clearly stated and exten-
sively described in the EIS.
238 As stated in response to a previous question, the lands affected by the
project are presently classified as native village deficiency lands, and
the Corps is aware of conservationists' D-2 legislation now pending before
Congress.
239 The Corps is not considering placing the transmission line on the west side
of the highway and railroad between Gold Creek and Cantwell. The quoted
sentence is factual as written. The schematic figure indicating the
location of the transmission line corridor has been clarified.
254
240 The Susitna Fault, although close to the project, does not have the
probability of creating as violent an earthquake at the reservoir sites
as does the more distant Denali Fault. For this reason, an 8.5 Richter
Maximum Credible Earthquake (~1CE) at the Denali Fault (40 miles distant)
was selected for design purposes rather than the 6.0 Richter MCE event
which could result from the Susitna Fault (2.5 miles distant). The
fault system of the entire area would be thoroughly studied prior to
final project design and construction.
241Again the statement concerning the possibility of th~ occurrence of ice-
fog conditions below Devil Canyon Dam during periods of extreme cold
weather is factual as written. As noted in the comment, this is hardly
a critical point given the remote location of the damsite.
242 The EIS already recognizes growth as an inevitable occurrence in the
Southcentral Region, unless an anti-growth policy is established to·
prevent it. The projected energy demand upon which justification for
the project is based is clearly explained in the EIS and illustrated in
Figure 9. A medium growth rate~ as projected by the Alaska Power Adminis-
tration, contains no provision for energy needs which would be required
of large industrial development. The question of industrial development
is more fully addressed in response number 255.
243 The temporary impact of construction workers.-upon small communities is
discussed in the EIS (Section 5.0). The fact that the impact is temporary
is one of the primary reasons that it may be particularly adverse. The
total period of construction is expected to take 10 years. Approximately
4 years will be required for preconstruction planning. Construction
workers will not be present during this period. As stated previously,
Talkeetna is over 110 miles by road from Devil Canyon Dam and nearly 150
miles by road from the Watana damsite.
244 Nitrogen supersaturation in the Columbia River is caused by the depth of
the plunge pools immediately downstream of the various dam projects.
The Corps of Engineers, through extensive research conducted jointly
with State and Federal environmental agencies, has developed a 11 flip
lip 11 that is being incorporated into the Columbia River spillway section
of hydropower projects to prevent flows from plunging into deep pools.
Although nitrogen supersaturation is still present in the Columbia
River, the concerned agenci~s are optimistic that with the installation
of 11 flip lips 11 into the spillway of critical projects, the level of
nitrogen supersaturation in the Columbia River system will be reduced to
noncritical levels. Other factors influencing nitrogen supersaturation
include water depth in the river, stream turbulence, distance, etc.
245 The sentence quoted from the EIS states that, along with energy conservation
and conservation of nonrenewable resources, environmental protection
will be attached increasing importance by the nation. The EIS clearly
indicates the trade-offs between these different values which would be
required by hydroelectric development. The nation, as represented by
the actions of Congress, will in effect determine whether or not the
costs of the trade-off are justified by the benefits. The EIS does not.
state or imply that dams constitute a renewable resource. Only water is
indicated as having this characteristic.
255
246Alternatives related to gas, oil, and coal are sufficiently discussed in
the EIS to explain the justification of their rejection as alternatives to
hydropower.
24? Comment noted.
248 The sentence from which the phase is quoted refers to all tidal flow hydro-
electric eroposals. Tidal power is seldom if ever proposed in areas where
it is not 11 suitable... Cook Inlet may be one of the best areas for such
development; nevertheless, the 11 extreme costs and environmental effects 11
are· the basis for not recommending it for tidal flow hydroelectric develop-
ment.
249 The basis for the rejection of nuclear power, solid waste burnfng, and oil
and gas alternatives are explained in the EIS. Some of the alternatives
were rejected on the basis of providing either excess or insufficient
energy to meet a reasonable amount of the needs of moderately projected
growth.
250 The statement is factual and has not been deleted from the EIS. Scientific
studies of the radiation effects of high voltage power lines indicate that
there are no harmful human effects from lines transmitting less than 500 kv.
The maximum power transmitted on the proposed system would be 345 kv.
Farming practices, furthermore. generally do not expose humans to sustained,
close-range contact with transmission lines. For reference to an authori-
tative study concerning the health hazards of transmission line radiation,
see response number 196. ·
2 51 Comments noted.
252 Prices at the actual time of construction will undoubtedly be higher than
January 1975 prices. Similarly, the price of energy will also be higher,
and since the project produces energy long after the great majority of
project costs are paid, incorporation of a general price level escalator
would have the effect of amplifying benefits to a greater degree than
costs. Assu~ing inflation would, therefore, cause the project to appear
more economically favorable. Inflation is not assumed because assumptions
about future price levels are deemed too speculative. Future values,
cost, and benefits wi 11 be equally affected by i nfl ati on. Long-range
projections are not made based simply on his.torical rates of growth.
They are often included in a discussion for purposes of comparison.
2~3 Comment noted.
2 54 The study revea 1 s that the hydro project wi 11 produce the required energy
at a low economic and environmental cost.
256
2.55 Stimulation of S,j.gnificant heavy industrial development is not expected to
result from the Susitna Project for the following reasons:
1. The projected energy load growth upon which the marketability as-
sumptions are bflsed, does not incorporate significant heavy industrial
development. Rather, the projection assumes a gradual expansion of industry
based only on already planned expansions to existing facilities and on readily
identifiable new industry closely tied to proven resource capabilities and
economic realities; this development is expected with or without the project.
2. The hydro project is designed to provide additional power incrementally
through phased construction. From 1986 to about 1995, the Susitna power will
meet both increased load and displace otherwise produced by more costly stream-
fired plants. The less efficient and obsolete steam-fired plants will be
inactivated or retired.
3. There will be some secondary energy associated with the proposed
plan. Such energy is not designed into the plan, but is a result of defining
the "firm" energy as that which can be produced in the worst water year
(drought). Thus, in most years, there is additional water available to produce
"secondary" energy which, because it cannot be quaranteed to the user, is
usually sold at a discount on a when-available basis.
The secondary capability of the proposed plan is seasonal, occuring during
the summer months .of June through September, and amounts to about 12 percent of
the firm energy output. Of the 25 years of stream flows utilized for the
operational studies, secondary energy would be available during the summer
months of 16 of the years. It is estimated that secondary energy would be
marketed at about 10 mills per KWH or approximately 50 percent of the estimated
cost of firm energy. Neither firm nor secondary energy generated from the
Susitna Basin projects will be what is commonly termed "cheap" power even
though it is attractive when compared to the thermal generated alternatives
available for satisfying future Railbelt energy needs. Marketability analysis
has determined that the required pay-back _usage rate for firm energy ·from
the Susitna Project, is 21.2 mills per KWH. In comparison, present rates for
firm energy marketed by Bonneville Power Administration in the Pacific North-
west during the winter months is 4.1 mills and less in the summer. In general,
energy by the hydro project will be somewhat less expensive than energy provided
from alternative sources. It is for this and environmental reasons, that the
hydro project is the selected plan. The resulting energy cost savings will
accrue to all Railbelt area electricty users. This lower cost energy will
provide a slight locational advantage to the Railbelt area in comparison to
conditions without the plan. Significant stimulation of heavy industry is
not expected to result, however, because as noted above, the project is
designed such that available capacity as closely as possible approximates
the projected demand. Further, the cheaper secondary energy will be available
on too irregular a basis to serve as an important determinant in industrial
locational decision-making.
256 Coment noted.
I""'
CITIZEN COMMENTS AND RESPONSES
W. L. Bl ackadar
Eric 'Boerner
~Mary Evans, Dan Huttunen, and Bob Fox
Sea Airmotive, Inc.
Stephen Kurth
Dan M.awhi nney
Thomas E. Meacham
Philip N. Osborn
Christopher Pearson
R. John Strasenburgh
c. H. Swanson, Jr.
John R. Swanson
Barbara Winkley
258
Comments
257
258..;2'pl
262
263
264~276.
277-280
281-310
311
312
313
314
315
316
SALMON MEDICAL CENTER
EICX 1110
SALMON, IDAHO S34G7
W, 1.. EILACKAOAR, M.D.
71116•31!133
EIOYD IC, SIMMONS M.D.
. 7116•311133
October 16, 1975
Alaska District ·Corps of 'Engin~ers
Anchorage, Alaska
· Dear Sir:
Re: Draft environmental impact statement on
the Upper Susitna Basin -Hydroelectric
power development ·
I have reviewed carefully your 95 page statement and am
alarmed that you dismiss the adverse changes in Devil' s Caeyon in
a two line insert on.page 93. The loss of Devil's Canyon for white
water kayaking deserves much more impact than you have given it.
This section of canyon has on~ been paddled a few times but it is
paddleable and it is destined to become extreme~ well used and
extremely popular. ·
Ten years ago, almost no one had run the Grand Canyon
in kayaks. Now, thousands are traversing this famous gorge. As
these thousands look for new horizons, Devil' s Canyon looms as
the only challenge which is technically feasible to do without
undue risk. I paddled Devil's Canyon in l972 1 ·plan to return with
a large group this next summer and I know of another group that
will go independent~. To lose the Devil's Caeyon section of white
water would be a tragic loss to America and it's future generations
because there is no other place like it in North America, or for that
matter the world.as far as I know.
You dismiss the anadromous fish capacity of the Susitna
by stating that fish do not now traverse. Devil' s Canyon. This to
my knowledge is true and yet it would be a ver.y simple project to
pass fish successfully through Devil's Canyon since the bottleneck,
I believe, is only in two drops. These could easily be alter~d with
short tunnels to permit this passage or some sort ofladder operation
so actually the loss t~ fisheries of Devil's Canyon is thoroughly aa
great as that loss would be at Rampart over a five hundred ye~r period.
259
Alaska District Corps of Engineers
October 16, 1975
·Page Two
While you have listed maqy proposals ror the Susitna
all of them include a dam in Devils Caqyon. Certain.ly some alter-
native thought should be given towards having only the upstream
dams bu:L.lt allowing future gen~rations to make the decision in,
. Devils Canyon. ·
Please enter this statement in the hearing record and
. have it show that there is· strong opposition to the Devil t s Caeyon
dam and that this loss will be irretrievable. ·
WIB:kc
260
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RESPONSE TO COMMENTS BY
W. L. BLACKADAR, M.D.
257Comments contained.in Dr. Blackadar's letter of 16 October 1975
are noted. Drawings and notations made by Dr. Blackadar on
1 October 1972 (not an inclosure with Dr.· Blackadar's letter of
16 October 1975) are also inclosed, since they contain additional
·information related to the navigability of the whitewatersection
of Devil Canyon. Comparing the possible loss to theoretical salmon
introduction into the upper Susitna basin to the huge,,area covered
by the Yukon River drainage above Rampart appears to be,somewhat
exaggerated.
267
259
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1
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1
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'!t j, t~< ~ sd Nflw d ~~ .. ho.,s~ ~
268
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r W 11\Af o{ U-c. W .Lcll.l k of .f..&< re~io~J '? 1..0 h~l~-N; tL hAp~ il 2 6 0
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popvt,;,.ho.v ,.,.., ~< S" f-4-t.. Is if ......,0 .,..#-. ?vshl~j -1-te.s. c. ~,.,, _._." f?.t..,-~-1 2 61
ft,.n:( .fm-f.l.<~ b4df ;,.,fo J/,-< o. ... l,l.J~ J iN fl.~ ,._,,.,c of. d-t"c~p,... ..... f ,.,._,( f...,,;;~
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c.,.-{AtiJ,....,S.!? '}110-'C. r<sf~ 1S ~v(eJ~ fo J~.f,",..;""" /-It-e. ~ f.'{tcl> f~..,f d_,#r> h..,,(d,
'
11
h'*v'l' (JAI Jl,'f... wic..J£lk iiv f/r-c Aflill ..#'d-4-(fD -14<-$OGio-~Co-v,_·,._ A'S~ed,.
c,..)l .... ~.. .. ~ f~c.ff""' .fi-t. ?'op(-c of 14 Cl'tS!flf,
-']h.J~-v/( jD'-' -for-:}"-';" f~<-AIVd (A-f,"t',v,-e_ iN A~~,.,.,.,./ )?11
5~~· .
269
RESPONSE TO COMMENTS BY
ERIC BOH4ER
2 58 The growing populations of the Anchorage and Fairbanks areas wi 11
generate an increased demand for energy. Hydroelectric power is
considered to be the most desirable method of supplying projected
energy needs at this time. ·
259The alternatives are listed and discussed in Section 6.0 of the EIS.
2 6 0 See response number 240.
261 The possible impacts of the impoundments on the Nelchina herd have
been discussed in the EIS. Additional studies concerning the wildlife
within the region will be conducted during the preconstruction planning
phase of the project.
27U
·~.
Box ?002,
Anchor~ge~ Ak., ·99510
~•r Sirs,
October 19, 1975
~26 Skarl.:ad Hall.
U. ot A., College, Ak.
99?01
We've been dhcour•r:•d by p .. t propoul;~~ ml!d• by the Corp•, particularly
the R•mp•rt Dam }·,ropoul. W•'re IIKI:re encour•g•d by the Zullitn• D•m prnjt~ct, which
~ . . . . .
demon11tr•h• mor., thorouch rl'lsl!l•rch •nd mnr8 •tt.:ation to environmenbi impact. th•a
the preceding •tudiea. Rowever, Wit c.'o find •om• wuknellm•• in thll study, Rnd we
. : .
find we can't liecept the proposal tor • number of rer;aona.
This tl'latit'lony coneid~r.s o,nly the Dev;i.l Clin;yon/W•hn• d•m• proponal. Th!!lle
two d-r.ss will haveo eome t~if!li!icant impact•,· which we found were inadequa;tely
con::dd~r~d, or not condderttd a.t all, in yuur study. . .
•loat imporbnt •r• thtt po11dble imt'•ch .on the Nel<1hin• CPribou herd. This
is th-. moct import•nt h~rd in Alaeka in t11rm• of annual 8port-hunt~r hprvPsts
it c!4'1M:t:-V"I'I 1m1ch conLlid~r:Ption. Colonel O..b.-.lius m"'ntione.t during his pr4usedbtion
•t th .. F11irhl'ni~K h"~trinc on thlt l>r•ft. Jo:rn that th11 hertl conaitltent1y crMitu"l'l
th•· rivl!'r in Jt1ly, •nd th•t t)'" m•Jor imp•et eft th~ ch•m,.. (1ft th"' hl'rd would be •n
the herd b liJ~ely. In middl~ May, tb., hflrd c•l'l'-'1111 •long the eouth b•nk11 or. · ... ~ ~·
the Sudtn• Riw.r, ber.dde thl'! propo~ed ~labn• rttllervoir. Th.-'herd normPlly
cro~s'a to tho summ~r eround~ north or the river in ,.t@ t!Qy •nd e•rly Junfl. . ' . . .
lligrtAtion timu: nuctuDttt more wiiely th~n your r.,port inflic8tea. (MoiJt of thia
271.
information comes 'from all Al••k• Departm&nt or Fish and Cl.imf' report entitfed,
t
"Nelc . ."lilta Caribou :Report", b;r Gregory N •. Boa, publi!h~d in Apr~l 1973 by the
Departm~tnt)
It ia likely:that th11 herd would frequently cross the rourvoir b,ror• the
• ' L
ice h out. C•ribou are f'Xcf!llent awimmer• ~nd low morbli ty woul~ ·be .e.Y.pected . ;
. .
1 •
wve1t tothe:n. br'glt humb&ra of'.vny young cdwtii cro11.!1 •n :lee-free, turbulent t-iver.
~· HowevAr 1 hoofed aJtimalc can't cope with !~lla throuch ice: they aro not •ble to
climb 1out ag•in. At Loako Louin, biologi11h h've obaerved ea.ribou breaking ~hrough
thin ic.:~, •nd ~tll.th" •nim»lll •ubsequently drowned. ..
l,'e woridor about the ahbility of th~t ice on Hahna ~uervoir with ~xpaeted w•ter
level nuctu•'!:iona or' 125 feet.~ Ice de.nloping on fluctuatin~ w~.ter. ~urf•C~l'
·could bet ttxpected ~o be p~rticuJ.arly 'unabblo, We wnuld expeo::t uubble ice Oft'
the reurvoirt~ to: hwve zerioua effecte on c•lf number-3. ·
a.nd •sr.orhd member" of thlt public to the are•1 .further incrttuing m'lrblity.
The a:ro• pr"l'l~ntly act. a11 • recharce aru !or wildlife: • llUmber o! different
game popubtion.i enjoy abbility o!·numbera and aecurity in the dam aru, due mo~tl:r .
to difficult •ccns. If th~t d•m• are built, \Y'e "trongly r~eommond beping th&~~cce ..
road cloaed to the P'lblic, and 'ole' recommen,d Rot pl~nnirig camp'aitu' and recrutioR
are•s:s.round thf'l reaervoira.
w. looked·at the Al•aka Power Commi•aion report Oft which your enerc~ demand
. .
curve h bu.,d. W11 que"tion itn •ccuracy, drt.c• it predict. future .Onor~ need partl;r
oft incre;,:red eMrgy ua<t 'o~~temming from t~e oil pipttlin• ir:tp,.ot: an :impact we don.' t
expect to continue.
hne proJected.
Thll Corp•' Public Brochure .e:ta.to-1<1," A p~rtic!ll,..rly iinp~.rhnt eonsidera~Hon
ot.clrrtdn hydropowltr proj~cts i~ the pot~tntbl to providtt f..~r more pow~r th~n d,emandf!d
at the ti~r• op~r•tif'n begin.s. Plel\::U'ul pow~r at rel•tivllil:y lo'll' CO.IIb c~n •timulato
·growth' •nd developmf!nt .. "(pr-. 11).
w~ dna•t ~~~t tn ~·· 1nnr~·-·d in~u.tri•li~~tion i• the fit•t•--we re~l th•t thi•
ia 8 very rul• d•ngiiT' .from thia hydrofll•rtJ'i~ JII'Ojeat. rr:t.m11d ly fl'll"' tt\tllt I"UfiOI'l,
we would r•th«tr s•e~ '.tor th~t immed~ate :t'nture, utili?.llti('ln of ftlltUN•l £1118 from the
JIOWer.
W• dan't w•nt •ner-gy produet~a above that :nec .. nry tor the iml'lediat,.. future,
dac111 exeefta e7le:rgy could atimulete, 1ot only inclu•trializ•tio,, but 'lria,.te!ul era~~:rgy
uee--• b•d h•bi t for the public to develop. We fed that it is poor planaiag to
decid~ to build ~ d•.ill before kllowblg wh•r~ the gaa pipelbe will go •. i ·
We que-stion Colonel IMbeliua' •htement, made at the Fairb•nl<n hurinc, th•t
the life exp•et-;ney of thl'! d.t.m would be 500 years. Thiu I'JOI'Imn ;l.mprob•ble 1 a bee
we laow or JI.O dll.m with • projected lifetir!"e of over 100 yu.ra. Hoover dam Willa
also predicted to h•ve • low ailtatioa rate, IIJld U becM 11ilting up before conatructioa
Wl".e completed • ~\'h.a t WOU1d tho b•nefi t/coat an.aly~ia look like if tho projected
. lifetime weR 100 yeara or l•a~, rather than 5do yeara? We feel thia would be a more
ru.liatic eatima.te' •
. The Sud ttl• ia oJte of the mo111t import•at river" in the a tate in hrm• of 1 ta
b .. uty and in h~a of the •bunda.Jle~t of wildlife in· ih dr•in•ge area.. We pl•c•
a v•ry high v•lue ~· aa urad•rmned Suaitu. River, :aot oBly for .the abov~ reaaona,
but !or ita v•lue a.a a. wilderaesa.· It energy im r••lly n•c•~••l"Y• ~~ ~pprov• of
hydropower projeota oa am~ll~r •c•l••· ~~. feel that the Cud tn• River i• the wrong
I
Sbcer•i;y,
.'/1~ &w~
_Mary Evans .
2
S 2 wiljTife m•&;./.1\t major,, u •• or A. ~_)d.-;/; J / .{.~
D•n Hutto.n•n
wildlif., m.lJtagement m•jor, U. o! A.
~~c-<.,-;:f ,,..,_
Bob Fox
TVCC inatructor
RESPONSE TO COMMENTS BY
MARY EVANS, DAN HUTTUNEN, AND BOB FOX
2.62 Connnents are noted.
In reference to comments on the Nelchina caribou herd.:· ·The information
on caribou (Sections 2.01.3.1 and 4.03 of the EIS) was taken from
s~veral sources including the Alaska Regional Profiles--Southcentral
Region, July 1974 and the State of Alaska, Department of Fish and
Game 1 s Alaska•s Wildlife and Habitat, January 1973. As stated in
the EIS: 11 Warmer weather and a rapidly filling reservoir should
eliminate any adverse ice conditions during the month of May.11 The.
major calving area for the Nelchina herd is on the upper reaches of
Kasina Creek, Oshetna River, and Little Nelchina River drainages with
calving generally taking place between mid-May and mid-June. Migra-
tion to the surrounding summer ranges usually begins in the latter
part Df June with the major movement taking place in July.
As stated in Section 4.15 of the EIS: Even though the project-life
is computed on a 100-year period fdr economic reasons, with adequate
maintenance, the useful life of the proposed projects due to sedi-
mentation is estimated to be excess of 500 years. The benefit-cost
ratio is based on a project-life of 100.years and is a fixed standard
for all Federal· hydropower project evaluation.
274-
SEA· AmMOTIVE, INC .
. , .J ' .
·~. Chal.X'INlll, Ladies & Gentlemen:
. ' '•
MY·~ is ward I. Gay. ~operate~ ~ve, Inc. at Lake Hood,.
~.~J:F t4xi ~atum. ·~have lived in ~tage for the pa~t 40 years . . ~ ~ve seen a lot of changes here •
.-.>{_ ,. . •• ,
·· ~ have needed the· Devil Canyon Dam on the Upper S\isitna River for
. . . ' .
20 ~!3 ~,in fact, I f~ew personnel on survey trips of this dam site
~e f:h.:p\. 25 years ago, before any gas or Qil was disoovered in Alaska.
+·.·.iU.~ ~ when. the Eklutna hydroelectric plan was fir~t proposed
·,(~fol:'e \<k:irld War .. !I). The original ~t:ima~ ~s slightly over six
mill.ion dollars. When we finally got ~und to doing it, the oost was in
excess of 32 million dollars. The big delay wa.s because~ did not~
th.at much power. Then gas was discovered at Kasilof. The people in
. ~ . '
Ancoorage ~ted gas,· so we voted a 20 year franchise to a oonpany and
built a pipeline fran Kasilof .to Anchorage that we are still paying for,
· even though we have ·natural gas right across the inlet fran u.S that there
is no use for. Chugach Electric has built a power plant at Beluga, that
should have been in Anchorage, but the gas was cheaper at Beluga even with
' '
building 2 ~r lines to tranSinit it to Anchorage. It seems they can
bring the por.Yer in but not the gas. Maybe because of the franchise.
'Anyway 1 the people have to pay fOr it 00 n\:l.tter 00w it iS done S0 instead
of rraK,ing rrore mistakes, · lets build the . Devil Canyon Dam on the Susitna
and furnish pc:Mer to the whole rai.lbelt. This will be utilizing a natural
. resource. that is not ~le. '!hen the natural resources that are
e,xpendable, such as natural gas, oil and (X)a.l can be sold to other states ·
and oountries that are not as fortunate. as we are in having an abundance ·
of water.
275
SEA AIRMOTM:.. INC.
It has been ~ that ~ dam \«)U).d dest.J:oy wild gane habitat and
calving grounds fot: caribou. I took .JI¥ first hunting party to the Fog
Lakes in the fall of 1947 and have hunted there every year' since. I
have seen thousands of caribou go down the bank and •swim the 100_ yard~
of river and go up the other 'side, seldc:m stopping in the small spruce
timber because they Jcni:M they are vulnerable to wolves and bear in the ·
I
timber,· and there is \leey little for ~ to eat there. I have never
seen a Ct::M have her calf down iri the canyon. 'Itley like the hills al:ove·
tint:ler where they can see and run. ·This also applies to noose.' With
the dam built, the caribou \\Ould only haVe ·to swim across a 1/4 mile
lake. 'n)at is nothing for them or lllX)se either, or a grizzly bear for
that matter. ~has never been any fish in the SUsitna drainage
above'. the dam site. Even the ~ canrx>t buck the white water in the
; . -·~ . ··~--> ':' •
canyon. '1be l;ake oould be stocked with fish and~ ~ wonderful,
I
accessable recreation area that the people of the railbelt are already
in need·of. The garre animals are nearly gone in this area OCM, mainly
because we have protected . the wolves for the last 7 years. This can be
······.
changed in a fett years. I .. think the proper people have 1'lCM learned that
man Cannot all~ the other predators to increase, unlimited,· and still .
have ~ w::mderful game paradise that he desires to view.
f sincerel· ·
.· .·1· -~oR~
263 ,_/" wazd I. Gay .u ..
276
2 6 3 Corrments noted.
RESPONSE TO COMMENTS BY
WARD I. GAY
SEA AIRMOTIVE, INC.
ft:""~ ~~·
AA1LA'ouYLa:.A.K-) ~ J'9S07
o~~o) 197:::;-.
278
I 264
265
flU(_( M>;~ M.t ~., d ~. .
. ~;;tu/ ~·-a· A;# c-;s /-'-ftft ~ 7/
. tJ!.~~ ~ ~ ~ 27'~ tJ.A.< /JU!/ ael ~:AJ-~~t(-~-::~7~-
1
o/ };7: t, ~ j,IJ'f, ~/.Tn-._7/2£"'-• .
2 6 ~ /Zrft ~. 1//:Fu.-~/ ~A-a·. 5P ~ci-wk.-
. ~·~2dr ~~~·~
'
280
/~.
281
--------------~---·-------------
270
282
273
283
284
--.
275
276
285
WETLANDS
of the UNITED STATES
THEIR EXTENT AND THEIR VALUE
TO WATERFOWL AND. OTHER WILDLIFE
By Samu.e1 P. Shaw and C. Gordon Fredine
Office of Ri11er BlUlin Studi~
CIRCULAR 39
FISH AND WILDLIFE SERVICE
UNITED STATES DEPARTMENT OF THE INTERIOR
THE PROBLEM OF
SAVING WETLANDS
The great natural wealth that originally made
possible the growth and development of the United
States included a generous endowment of shallow-
water and waterlogged lands. Theoriginal inhab-
itants of the New World had utilized the animals
living among these wet places for food and cloth-
ing, but they permitted the land to remain essen-
tially unchanged.
The advent of European settlers brought great
changes in the land, and aquatic habitats were
particularly vulnerable to the settlers' activities.
Kenney and McAtee wro~e in 1938:
Among the assets of mankind, wildlife receives _its true
appralsafon'fY.. in ad~j!~dsJ!!_gt)S _c>!_~\yiiizatlon, -W~en,
owing to the heedless destruction of earlier times, it has
beenserfousiyifli(;i-Irreparably reduced. Under -plo~eer
coiirutlonstherufe~fortiie-tree:tffierlfOl wildlife are imme-
diate exploitation of the useful and drastic destruction of the
useless, and these rules. tend to remain in effect long after
the original motives are gone. in the earlier stages. of·
se.ttlement no one thinks of allotting any land (or the use of
wildlife; the effort is to .wrest every possible acre from
nature and make it yield an income. There is no vision to
I see, there is no time to learn, t_hat land Uflits _\Y_i~l,l-~heir
! natural occupants, as exemplified by a beaver meadow, a I muskraCmarsh, a duck lake, a deer forest, or an antelope
mesa, -~r.~ pr?ductive entities that under certain circum-
'· stances may be worth far more than anything man can put
'-in their place and that orice destroyed may never be re-.
1 establish~~: -(7)1 . · · _
THE NATURE OF-WETLANDS
The term "wetlands,'' as used in this report and
i_n the wildlife field generally' refers to lowlands
covered with shallow and sometimes temporary
or intermittent waters. · They are referred to by
sueb names as m~ushes, swamps, bogs, wet mead-
ows, potholes, sloughs, and river-overflow lands.
Shallow lakes and ponds, usually with emergent.·
vegetation as a conspicuous feature, arc included
in the definition, b~t the permanent waters of
streams, reservoirs, and deep lakes are not in-
I Italic numbers ln bmckrts refer to item• in the List or Rrferenct•s on
Jiagr 47.
eluded. Neither are water areas that are/so tem-
porary as to have little or no effect on the develop-
ment of moist-soil vegetation. Usually these very
temporary areas are of no appreciable value to the
. species of wildlife considered in this report.
Most wetlands can be drained or filled to create
suitable land for agricultural, industrial, or resi-
dential expansion. Others lie in potential im-
poundment sites where permanent deep-water en-
vironments can be developed. If either type of
project is carried out, however, the food and cover
plants required by 'Y"aterfowl and other wetland
wildlife no longer grow in abundance. These
aquatic plants ne.ed waterlogged or shallow-water
soils in order to thrive.
Apparently, a great many people still think that
until one of these two courses is followed, any wet-
land area is just so much wasteland-an unfortu-
nate occurrence in the land-economist's classifica-
tion of productive land uses. So long as this belief
. prevails, wetlands will continue to be drained,
filled, diked, impounded, or otherwise altered, and
thus will lose their identity as wetlands and their
value as wildlife habttat.
COOPERATIVE PLANNING
State and Federal agencies engag~d in conflicting
programs of wetland destruction and wetland pres-
ervation must work together to develop unified
wetland-use programs. that are both acceptable to
the landowner and ben~ficial to the Nation.
It is one-sided planning. for example, if a flood-
control agency neglects wildlife walues as it plans
for the elimination of river-overflow areas, when
these areas are used by millions of ducks during the
winter season.
In land-use planning, an agency dealing with
drainage projects would be subject to criticism if
its plans to remove water from extensive marsh-
lands or scattered potholes ~ere developed without
regl).rd for the fact that, individually or collec-
tively, they provide essential habitat for thousands
3
. SUMMARY . OF ·CHAPTERS
The problem of saving wetlands is to prevent
marshes, swamps, open shallow waters, and sea-
sonally flooded lands from being drained, flooded,
or filled, hence losing their value as wildlife habitat.
These types of aquatic environments, collectively
identified in this report as wetlands, furnish ~ssen
tial habitat .for all waterfowl, most species of fur
animals, and many species of farm game, forest
game, and warm-water fish. Coordinated advance
planning by all resource interests is the keynote
to solving the problem. As an aid in such plan-
ning, the Fish and Wildlife Service, with the coop-
eration of State game agencies, conducted a wet-
lands inventory with emphitsis on present useful-
ness .of the lands as waterfowl habitat.
A century of wetland· exploitation has taught
many-lessons" ih the use .. and .. inis11se" of. wetlands. Tile-swain i> Lari<r-xcts 0fTs49;' T8·5~--ai1<r 1s6o
paved the way for transferring nearly 65 million
acres of wetlands in 15 States from Federal to
State administration for the purpose of expediting
their drainage. Nearly all these lands are now in
private ownership, and their use by wildlife is usu-
ally only a minor consideration. Although evi-
dences of wetland losses as revealed by previous
inventories are not completely reliable because
they represent different types of coverage, it
appears that at least 45 million of the original 127
million acres of natural wetlands have been drained
or otherwise destroyed. Agricultural. drainage
(102 million acres now in organized enterprises)
and flood control are the forces primarily respon-
sible, but other activities such as canal construc-
tion, drainage for mosquito control, industrial ex-
pansion, and highway building have greatly re-
duced the wildlife values ofsome wetlands, partic-
ularly along the coasts.
44
Wetland soils have physical and chemical prop"'"
erties that are derived from the environment in
which the soils odginate. Climate, landform, and
native vegetation largely govern the nature of this
environment, hence also the nature of the soils
and their potential uses. Most Wl'tlands are
underlain by organic soils known as peat and
muck, or by recently deposited, water-carried .
alluvial soils. In general, alluvial soils have higher
· 'agricultural potentials than peat and muck. ·
Many peat and muck soils,have proved unproduc-
tive for agriculture after drainage; others are in-
herently fertile. In many areas, there appears to
·be a direct relation between potentially good agri-
cultural wetlands and presently good waterfowl
wetlands, suggesting that competition between
agricultural and wildlife interests ,.,.ill become
more intense in the years ahead.
The wetlands inventory re\·eals ·the location,
classification, and evaluation of 74,439,300 acres
of wetlands as waterfowl ha~itat. At least 90
percent of all wetlands of importance to waterfowl
are included. From the standpoint of waterfowl
value, the total acreage covered by the inventory
is distributed as follows (in millions of acres): 8.9,
high; 13.6, moderate; 24.0, low; and 27.9, negli-
gible. Values are based on relati..::e waterfowl use
in the State where the wetlands are located. By
wetland categories, the eight inland fresh types
comprise 63,491,000 acres, the three inland saline
types comprise 1,618,000 acres, the three coastal
fresh types comprise 4,041,000 acres, and the six
coastal saline types comprise 5,290,000 acres.
The 20 wetland types are ecological classifica-
tions designed to help recognize the relative im-
portance to waterfowl of the many different kinds
288
.. ~.
~~-
RESPONSE TO COMMENTS BY
STEPHEN KURTH
2 6 4 Comment noted. Practically no .. wetlands .. for waterfowl are located
within the proposed Devil Canyon and Watana reservoir areas.
265 Comment noted.
266 The 6-1/8 percent interest rate is provided by Water Resource Council,
and is based on the current cost to the Federal Government of borrowing
money.
2C~ Reduction of flooding and erosion could result in subclimax"growth
of vegetation in the braided channel system and would provide browse
for moose.
268 Project power will be marketable by existing power marketing agencies,
at rates to be established by normal rate-setting procedures and
after public hearings have been held. Use of power by industries
can be regulated by means of power rates. Also see response number 255.
269 Growth projections in Alaska are not based primarily on past growth
statistics, but rather on demographic, economic, and other factors
which will control future growth.
270 The no action alternative is covered in Section 6.02.1 of the EIS.
271 Statement regarding nuclear power providing 50 percent of the electrical
power by the year 2000 refers to the nation as a whole. Nuclear
power does not represent the most feasible alternative power source
for Alaska, as stated in Section 6.02.4 of the EIS.
2 7 2 Comments noted.
2 7 3 Comments noted.
274 Comments noted.
2 7 5 Comments noted.
2 7 6 Comments noted.
289
/0-;).~ ·-7 J-
290
291
RESPONSE TO COMMENTS BY
DAN MAWHINNEY
27? The proposed Susitna project would change the areas where project
facilities such as dams, reservoirs, roads, transmi~sion lines, and
recreation areas would be built, but we would d~sign and construct these
facilities using the highest standards to lessen the adverse impacts and
to,maximize the ben~ficial impacts.
278 Alaska is and will continue to be a great state where people can live,
work, play andenjoy the wonderful natural resources that are found
here, but those of us who moved here from other places orwere born here
will have to consider that others will come here in the future for much
the same reasons that motivated the present residents to live here. To
some this might not necessarily mean progress, but it is the 11 real
world.11
With good planning we hope to help provide a good place to live and work
and still retain much of Alaska's great wealth in the natural environment.
True, some people will be more directly affected by our proposals for ·
hydroelectric power than others, but we believe that what we do propose
will adversely affect fewer people than any other viable alternative
which would provide equivalent electrical energy. Also, we believe that
the proposed project is economically and engineeringly feas·ible and less
environmentally damaging than any other alternative which could meet
electrical energy needs of the future. ·
279 In~the Alaska Native Claims Settlement Act more than 80 million acres of
Alaska's 356 million acres are proposed to be retained in the 4 Federal
systems in~luding parks, wildlife refuges, wild and scenic rivers and
natural forests. The State has also proposed millions of acres for park
and recreation lands. It is also reasonable to assume that much of the
over 40 millions of acres of native lands, 106 millions of acres of
State lands and the balance of lands left in other private and Federal
control will be left in its natural state or developed to encourage
recreation but it is obvious that some development will also take place.
280 As noted in Section 9.0 of the Environmental Impact Statement, we have
had three sets of Public Meetings in both Anchorage and Fairbanks where
all the public has been invited to attend and to express their feelings
and concerns on thi~ proposed project. People from the Talkeetna area
and from the areas that would be directly affected by project facilities
attended the meetings; the people listened to the proceedings and some
made comment, both for and against the proposed project.
292
.~.
,.-
' I I
I
THOMAS E. MEACHAM
ATIORNEY AT LAW
' SUIT£ 403
310 '"K"' STREET
ANCHORAGE, ALASKA 981501
(8071278-1322
't807l 278-1443
October 9, 1975
Colonel Charles Debelius
District Engineer
Alaska District
u.s. Army Corps of Engineers
Box 7002
Anchorage, AK 99510
Re: Written Testimony Concerning Draft
Environmental Impact Statement
Dear Colonel Debelius:
I am enclosing with this letter a copy of my comments
concerning your Draft Environmental Impact Statement on hydro-
electric power development on the Upper Susitna River Basin,
Alaska.. I delivered this testimony orally at your public hear-
ing on October 7, 1975, and would request that my written tes-
timony be included in your hearing record.
I would also request that this letter of transmittal
b~ included in your hearing record, since additional facts con-
cerning the production of your Draft Environmental Impact State-
ment became evident during th~ course of the hearing.Tuesday
night. From the testimony given by the Alaska Department of
Fish and Game, it is apparent that your Draft Environmental
Statement was issued prior to completion of studies by the
Alaska Department of Fish and Game, which had been on contract
with the u.s._ Fish and Wildlife Service to conduct wildlife
studies in the affected area, and for the specific purpose of
your environmental analysis of the proposed project. By accel-
erating the completion and issuance of the Draft Impact State-
ment, ·your office has totally excluded a body of knowledge
which, if available to the general public, would have permitted
a much more thoro:ugh analysis of the effects of your proposed
project. In addition, I would assume that availability of the
results of this study would have aided your own planners in
evaluating the proposed project.
Not only is this deliberate omission very detrimental
from the standpoint of an adequate environmental statement, but
Colonel Charles Debelius
Alaska District
Corps of Engineers:
October 9, 1975
Page two.
I learned at the hearing that the Corps of Engineers had also
excluded an additional contracted study which was intended to
explore in depth some aspects of the project, for·purposes of
your Environmental Impact Statement. I believe that the firm
of Jone~ & Jones, Consultants, was engaged to study certain
aspects of the project. I have seen their report, entitled
Uppe~ Susitna River: Inventory and Evaluation of the Environ-
mental, Aesthetic and Recreational Resources. This firm was·
also contracted to analyze spec1f1c aspects of the proposal,
but the last-minute acceleration of the deadline date fpr the
Impact Statement precluded any analysis of the voluminous
results of their study in your Draft Environmental Statement.
I believe that the deliberate exclusion of these two
relevant source nta'terials, and the lack of public knowledge
of their conclusions, bas dealt a very strong blow against your
Draft Environmental Statement. I would expect that, at the
least, full consideration of these documents will be given in
your Final Environmental Impact Statement, and that these doc-
uments will be available for evaluation by the interested
public. ·
Thank you very much for your even-handed treatment of
the hearing itsel:f, and for the efficient manner in which it
was organized and conducted.
2811
TEM/bja
Enclosure
Yours sincerely,
Thomas E. Meacham
RESPONSE TO COMMENTS BY
THOMAS E. MEACHAM
LETTER DATED 9 OCTOBER 1975
281 A concerted, continuing effort has been made throughout the study
process to acquire all data possible from all concerned sources
with special emphasis on fishery and w"ildlife data so vital for a
valid assessment of project effects on major ecosystems and the
total environment. We have worked through the U.S. Fish and Wildlife
Service (FWS), as the lead agency, to coordinate our study with
Alaska Department of Fish and Game (ADF&G). We had, prior to the
Public Meeting, a preliminary report of FWS (containing the ADF&G
contribution). This report, prepared in accordance with the Fish
and Wildlife Coordination Act, was formally published on 10 October
1975. · In addition, we had informal contacts on a nearly daily basis
with FWS personnel to be as sure as possible that no new or important
information relative to their area of responsibility was being omitted
from consideration. The fact that the Jones and Jones inventory and
evaluation {prepared under contract to the Corps of Engineers) is not
contained in toto in either the DEI S or f eas i b i1 ity report does not
mean that it has been excluded, omitted, or ignored in our evaluations.
Quite the contrary, it has been of much va 1 ue to us, and has been
in our hands for over six months prior to completion of the DEIS.
295
282
COMMENTS REGARDING DRAFT ENVIRONHENTAL IMPACT STATEMENT:
HYDROELECTRIC POWER DEVELOP~NT ON 1H~ UPPER
. , SUSITNA RIVER BASINt" .ALASKA .
October 7, 1975
Gentleman:
My name is Tom Meacham. I am a resid~nt of Anchorage,
Alaska and am conservation chairman of tho fvlountaineering Club
of Alaska. I am testifying as an individual.
I believe that your Draft Environmental Impact Statement
regarding hydroelectric power development on the Upper Susitna
River is subject to criticism both in concept and in detail. I
will deal with the criticisms I have regarding the conce~t first.
Your Draft Impact Statement was issued on September 22,
1975. This hearing comes exactly two weeks after that date, ·
offering no realistic opportunity for public input based on the
assertions of fact and assumptions made in your ImpactStatement.
Instead, this hurried consideration of the Impact Statement seems
designed to nul·lify or elimin'ate any m·eaningful criticistn from
persons or organization~ which may have some doubts about your
project. This certainly is not the "atmosphere of public under-
standing, trust, mutual co,operative, and in a manner resJ;>onsive
to the public interest", as your regulations require.
The Draft Impact Statement itself is much too narrow,
given.· the scope of the pr.pblem. The Draft Statement purports
to analyze the feasibility of hydroelectric power in the Upper
S.usitna Basin, in relation to other alternative power squrces
which may be available. ·l'le are told that more extensive studies
will pe made of the various .factors required under the National .
Environmental Policy Act, if the project is approved. However, ·
I have found nothing in the.Draft Statement which could pe termed
a feasibility report., ·in relation to other alternative power
sources and the projected needs of the rail belt area in future
years. Because the question o'f feasibility and of future need
will receive'only the present enviroJ1rilental·analysis, that anal-
ysis must be'as complete as any required under NEP.l\.. for any spe-
cif~c ~speQt of actual hydroelectric'plant construction. The
I
296
Comments to Draft EIS
October 7, 1975'
Page two.
. • I
writers of this. Impact Statement have, wi.th no s~atutory authority I
and very little actual authority, determined that hydroelectric
power is the "most feasible" means to meet the area's presumed ·
future needs, and have, without further analysis, proceeded to . 2 8 3
present the details of the proposed dam construction. Questions
which they have left unanswered are the following:
1.'
2.
:r.
' . . .
What is the source 6£ any assumptions regarding I
population grpwth and growth in electrical de-·
mand in the rail belt area? Are there variations . 284. ·
among sources in these projections; and if so,
which projections did the Corps examine and adopt?
Mas· any comP,rehensive economic, social or environ-me~tal.analtsis been done of other alternatives to
the hydroelectric project, including purchase of
power from Canada, coal gasification, coal'burning, 285
use of natural gas, geothermal resources, or any .
other available ·o·r projected source· in Alaska? If . 1
studies have been examined regarding these factors,
what is tne source of these studies?
Will hydroelectric development in t,he rail belt
area discourage. use and development of alternative I
sources? · Will other sources develop despite con-2 8 6
struction o·f hydroelectric projects?
These questions, and others which I am sure other persons will raise,·
go to the very premise upon which your Environmental Impact Statement
was based: : the "feasibility" of hydroelectric power development in
the rail belt region. Until these issues are addressed, there is no
point in discussing specific construction proposals for various dams.
However, the tone of your Impact Statement indicates quite clearly
that 11 feasibility" to your agency is merely a question of receiving
the requisite amount of dollars from Congress, and that once that
grant is assured, the Corps of Engineers will very quickly demonst·rate
that hydroelecttic power in· the rail belt region is physically feasible.
The real question of the propriety .of hydroelectric power, in the con-
text of this region's needs and in contrast with other available
sources, will never. be answered.
Because the majority. of your'Draft Impact .Statem~nt deals
with t.he reality of a two-dam constr.uction proposal, ! have some
297
Comments to Draft EIS
October 7, 1975
Page three.
287
'
!
questions to iaise·concerning that proposal. I feel that there
are several v.ery ser. ious in. consistencies or unwarranted ·as·. sumptions
made in tha't Impact Statement, and I feel confident that satisfac-
. tory answers will be provided at the time the final impact statement
ia written. Among my ques.tions are the following:
1.
288
2.
290 .
1
3.
4.
291
s.
• 292
Is the capacity of the Devil Canyon~watan~
project excessive? The p~ojected electrical
output is approximately six times the present
need for the entire state, yet it is only one•
fourth of your projection of the rail belt
area's needs in 1985.
What entity will manage the proposed project?
Will it be a TVA-type authority,·which has dem-
onstrated little responsiveness to the public
interest? Will the authority operating the
project be subject to jurisdiction of the Alaska
Public Utilities Commission?·
What will be the policy on sale of "secondary
energy"? What is the purpose for providing a
capacity to produce secondary energy? Will sale
of secondary energy be subject to regulation by
the Alaska Public Utilities Commission? ·
Will rate structu~es favor sale of large blocks
of power, at low unit cost, to major industrial
users? If so, will the availability of cheap
power induce basic industries to .locate. in the
rail belt region? Would this location for basic
industries be desirable,' from the social, econ-
omic and environmental standpoint of the existing
rail"belt community?
!'·
You have stated that the project area contains
some discontinuous permafrost. Is any permafrost
located beneath the impoundment areas of the two
dams? If so, will the extreme yearly drawdown be-
hind Watana Dam lead to continuous melting of
permafrost and erosion of resevoir banks?: ·
What will be the effects upon fish, wildlife and
human activities downstream from the dam sites
298
Comments to Draft EIS
October 7, 1975
Page four.
during the twelve years of construction? Will
the SusH:.na River be entirely impounded. ,by
Watana.Dam while Devil Canyon Dam is being
constructed?
7. What effect will the loss of low, clear flows of
.the Susitna River in wintertime have upon the
fish which migrate from the tributaries to .the
main stem during wintertime to avoid freezing?
8. What effect will the increased wintertime volume,
more than eight'times the· existing uncontrolled
winter flow, have upon fish and wildlife iri the
Lower Susitna? What effect will this increased
winter flow qave upon erosion potential?
9. Will multi-level releases of water from behind
the dams lead.to increased siltation during re-
leases·, when:j· water and silt from the bottom por-
tions of the resevoir are released? .
10. What will be the peak monthly flows antici~ated
on the river after construction? The Impact
Statement lists only average monthly flows, not
peak flows.
11.
. 12.
' 1'3.
14.
What measures will be taken to.control the problem
of "frazzle i..ce" ·under cold winter conditions?
What is the present cons.umption of the rail belt
area, in terms of barrels of oil?
Has the total energy cost of twelve years of dam
construction been debited against the eventual
production of the project, in terms of barrels
o:f oil~ . ·
How much oil would the total first costs of the
project buy at today's prices?
1293
I 294
l 295
I 296
I· 2 9 .,
I 9n 8 ,J:;. '1' ·.
I 29~
1 soo
I ao1
15. What will.be the actual amount of delivered power I
to Fair. ba .. nks. , Anchorage, and o.the·r· rail.· belt points?
The Impact Statement lists only the projected·power
produc·tion at the dam site, and does not calculate
• 1
302
299
------------------~·~· --.
Comments to Draft EI$
October ·7, 1975
Page five.
16.
.303
304r 7
•
. . '118. t '
305 .
I
power losses.
What factors w~re used to calculate a benefit-
cost ratio of 1.4? Why was an artificially low
~nterest rate pf six and one-eighth per cent
used? Does the nature of this project, on· a
·glacial river with no presently known technique
for dredging resevoirs f~lled by .sediment, jus-
tify a 100-year life projection?
Upon what factors was the 100-year project life
calculated? Does 'the Corps of Engineers have
any available data from other hydroelectric pro-
jects constructed 6n glacial rivers with stream
flows comparable to the Susitna River? ·
·Whai will be the effect Qf increased energy,
velocity and .abrasion of the released water below
Devil Canyon Dam upon the Lower Susitna River,
and upon the. turbidity of the river?
3
.. ~:;
6
. '119 ·. ·Is "flood control" a planned benefit of the
'resevoirs, as mentioned on page 71 of your dr~ft?
·'What is the historical incidence o{ Susitna River
floods?
20.
307
Why has the proposed project been stressed for a
:"maximum credible earth~uake" with an epicenter
forty miles distant, since t~e Susitna fault is
.only 2.5 miles from the site of the dams? Upon
'what assumptions is the ·turbidity rate during
winter flows of 15 to 35 parts per million calcu-
:lated? This assumption seems excessively low,
• when measured against the, river's incre.ased abra-.
·Sion potential, the multi-level releases, and the
significantly increased winter volumes.
' . . '· '
Your Draft Impact Statement has seriously neglected to place Devil
Canyon in the context of present and future recreation potential
in Alaska and in North America. You state that it is one of three
major white water rivers in Alaska. However, you neglected to point
·out that, among white water experts, it is considered the premier
stretch of white water in North America, if not in the world. Of
300
,.,-i
I Comments to Draft EIS
October 7~ 1975
Page ·six.
the three Alaskan rivers mentioned, the Alsek and the Bremner are
inaccessible by boaters at either their origin or their termin\ls.
By contrast, Devil Canyon can be reached on the Denali Highway
for departure, and its tepninus lies on !'the Parks Highway. Recre-
iltional white water boating is one of the fastest-growing sports ·
in the nation, and particularly in Alaska, yet we have no analysis
of this increase in popularity in your Impact Statement. On the
contrary, your only statements concerning outdoor recreationists,
or to white water boaters in particular, are repeated references
to "a few hardy souls" with veiled implications that anyone who '
tries to kyak any portion of Devil Canyon has a death wish. Your
impact statement fails to analyze the tremendous growth of self-
propelled sports, such as mountain~ering, hiking, backpacking,
and white water boating. Instead, it assumes without basis in
fact that the Devil Canyon ar~a has no present or future poten-
tial·for these sports, and can only be made available for recrea-
tion users by creating some sort of artificial access, such as·
resevoirs and roads. The Draft Impact Statement does not discuss
the proposed Talkeetna Mountains State Park and the effect such a
resevoir might have on that proposal •. Nor does it disc~ss the ·
federal lands· surrounding the resevoir proposal which may be se-
lected by Cook Inlet Native Regional Corporation, or may be traded
to the State of Alaska as an addition to the Talkeetna Mountains
State Park proposal. With increased mechanized access being one
of the prime features·of the project, it will almost certainly h~ve·
some type of impact upon a State Park proposal. What value was
added to your bene~it-cost: ratio for the recreation opportunities
which you foresee as a r~sult of construction of the project, and
upon what factors were these values based? •
I
Simply stated, I feel that the value of Devil Canyon of
the ~usitna River, as the freest, wildest, most violent and most
impressive free-flowing river 'on the continent, 'has been entirely
overlooked. The river, to my knowledge, is still eligible for
wild river status under federal law, and any deGision by the Interior
Department not to recommend t~e river iri 1973 was based on the fabt
that a hydroelectric project was proposed, and not on any inherent
characteristic of the river itself. ·aase·d upon the con-t;:ent of your··
Draft Environmental Statement, I have found no compelling reason why
Devil Canyon should not remain free and uncontrolled, a monument to
nature and· no't ·to man·, or particularly to the Corps of Engineers or
our Congressional delegation.
Please include my statement in your recor~ of oral testimony
301
108
·,
309
310
Comments to Draft EIS
October 7, 1975
Page seven.
concerning .this proposed project;:. I am also submitting a written
statement which I would like included in your hearing record. I
will e~pect to receive copies of any further public correspondence
which you may issue as consideration· of the feasibility of this
proposed project continues. In addition, I would expect to re-
ceive your Final Environmental Impact Statement' concerning hydro-
electric project feasibility in Southcentral Alaska.
Thank you very much.
Lt~
Thomas E. Meacham
1410 "H" Street
Anchorage, Alaska 99501
302
·~.
RESPONSE TO COMMENTS
OF
THOMAS E. MEACHAM
DATED 7 OCTOBER 1975
282 The timing of the issuance of the DEIS (22 September) and the scheduling
of the Public Meeting(s) (7 and 8 October in Anchorage and Fairbanks)
were responsive to CEQ guidelines. Guidelines for agency compliance
with NEPA are promulgated by the President's Council on Environmental
Quality. These guidelines stipulate a 45-day review period for the DEIS
following the announcement of its availability in the Federal Register.
Such announcement was made in the Federal Register printed on 3 October
1975. Thus, the period for public review and comment on the document
does not expire until 17 November 1975. With regard to public hearings,
CEQ guidelines stipulate that a DEIS be made available at least 15 days
prior to the time of such hearings. This requirement was met in scheduling
the Public Meeting in Anchorage on 7 October 1975. Opportunity for
public input into the DEIS in this instance is 57 days--from 22 September
to 17 November 1975. Actually, comments received by 3 December 1975 are
included in the EIS.
Public Meetings (hearings) are designed to involve public participation
in a continuous two-way communication process which fnvolves keeping the
public fully informed on the status and progress of studies and findings
of plan formulation and evaluation activities. It is a means of actively
soliciting from agencies, groups, and individuals their opinions and
perceptions of objectives and needs. And, finally, it is one tool for
determining public preferences regarding resource use and alternatives
thereto. Two previous sets of meetings had been conducted prior to the
October meetings. The first informed the public that the study was
underway and solicited their views as to the direction it should take
and as to what specific concerns, wishes, or inputs they had relative to
the study subject matter, the study area, and any other allied fields
they cared to address. The second set of meetings reported to them the
study progress, especially a number of possible alternative means of
accomplishing (and even the option of foregoing accomplishing) the basic
study purpose of providing electrical energy to supply projected area
needs. Once again the comments, desires, and inputs (both factual and
intangible) of the public were solicited. The latest meetings continued
the previous progress from general to specific by presenting the end
tesults of the preceeding studies, expressed public opinions and wishes,
and weighing of the many technical, environmental, and economic aspects
of the alternatives.
303
283 Related to the above misunderstanding of the public review period
of the DEIS, there appears to be some confusion as to the purpose
and scope of this document. Simply stated, under NEPA (Public Law
91-190), a summary document (EIS) must be prepared outlining for
public scrutiny (and review by Federal, State, and local agencies)
the significant impacts (both adverse and favorable) which can be
reasonably foreseen to result from a specific course of action
proposed by a Federal agency. The content of the document is out-
lined to include five major areas of discussion. They are: the
environmental impact of the proposed action; and adverse environmental
effectswhich cannot be avoided should the proposal be implemented;
alternatives to the proposed action; the relationship between local
short-term uses of man's environment and the maintenance and ·
enhancement of long-term productivity; and any irreversible and
irretrievable commitments of resources which would be involved in
the proposed action should it be implemented. A great body of
interpretations, regulations, legal decisions, and policies have
subsequently evolved to more specifically define the procedures,
fo~mats, detailed contents, and processing of the various and
sundry versions of EIS's. The feasibility report is a separate
and distinct document which examines in detail many of the questions
you raise. This document, as well as the DEIS, contains data
whlch were summarized at the Public Meeting. Because the report
cou1dnot be finalized until the public views on its general
content, especially on the conclusion and recommendations to
be contained therein, it could not, of course, be published
prior to the meet·ings set to obtain those views. It is now being
·given final revisions as a result of the meetings and of review
by higher authority.
2 8 4.The growth rate. projections for energy demand are by the Alaska.·
Power AdministNtion (APA). They reflect a 1975 revision of the
figures from the 1974 Alaska Power Survey. The major competitive
projections are those published by OBERS (Office of Bus·iness ·
Economics-..:now renamed Bureau of Economic Analysis--and Economic
Research Service). These projections are based almost solely
on population trends and have to date consistently badly under-
estimated all varieties of growth in Alaska.
285 The alternatives mentioned have been considered as a part of the
feasibility study. Data from all available sources have been
utilized. Coal is found to be the major alternative to hydropower.
286 Hydrodevelopment may or may not supplant development of alterna-
tive power sources. The proposed project will supply the area
power deficit only to about the mid-1990's when either additional hydropower
or other alternative sources will have to be developed.
304
.~.
2 8 7 Comment noted.
288 The capacity of the two-dam project is not excessive. The electrical
output is less than three times the present Railbelt need (not six times
the present State need, as you state). As such, in conjunction with,
present systems (and any others developed to meet the demand growth
prior to hydropower availability), the proposed system will satisfy the
mid-range demand curve until the 1990's when additional power will be
needed.
289 Alaska Power Administration (APA), a Department of Interior agency, will
manage the project much in the way Bonneville Power Administration
manages the Federal hydro system in the Pacific Northwest. They are not
subject to APUC regulation, but work closely with them.
2 9 0 Yes. However, there is very 1 ittle secondary energy associated with the
proposed plan. Such energy is not designed into a plan, but is a
result of defining the 11 firm 11 energy as that which can be produced in
the worst water year (drought). Thus, in most years, there is additional
water available to produce 11 Secondary 11 energy which. because it cannot
be guaranteed to the user, is usually sold at a discount on a when-
available basis. The secondary capability of the proposed plan is only
about 12 percent of the firm energy output. Again, APA is not subject
to APUC regulation, per se, but cooperates closely with them.
291 The proposed project is not intended to be developmental, but to meet a
projected, conservative growth projection. If the projection is correct,
there should be little in the way of large blocks of power available to
induce extraordinary industrialization. For further response to this
comment, see response number 255.
292 Yes, some permafrost is located beneath the Watana reservoir and may be
also within a portion of the Devil Canyon reservoir. We foresee both
melting of this permafrost and some erosion as a result. However, the
overburden subject to erosion is shallow over a majority of the steep,
rocky canyons, and the net effects on either storage capacity or the
shoreline should be minor.
293 The downstream effects during construction should be minimal inas~uch as
. the entire natura 1 river flows wi 11 be passed by diversion tunne 1 s unti 1
completion of the Watana Dam about 1986. At that time, a regulated flow
consistent with the needs of downstream fishery management will be passed
until completion of Devil Canyon about 1990. Again the river flows will
be diverted through a tunnel around the Devil Canyon damsite during the
construction period at that site. After that, full regulated flow, as
305
described at the Meeting, will be released. It is now standard procedure
to minimize construction inputs of turbidity-pollutants to the river
during construction to the extent that all construction waters will be
cycled through settling basins, etc., if such need is found.
294 The low level (less than 35 ppm) of glacial 11 flour 11 which we expect to
be passed downstream year-round (in lieu of highly turbid summer flows
and very clear winter flows) is similar to the natural conditions at
Kasilof River-Tustumena Lake where fish thrive very well. We foresee no
noticeable adverse impact from this source. However, a final determi.:..
nation of these effects will not be made until detailed studies, some of
which are currently underway, are completed.
295 The wintertime flow volume, even though substantially greater than that
of minimum natural flows, is sti 11 quite moderate and should have 1 ittle
adverse impact on downstream fish and/or wildlife. The equalization of
the summer and winter flows and the elimination of most of the sediment
load will tend to change the dimensions at the river and will increase
its erosive potential, but not necessarily actual erosion. The rocky
nature of much of the canyon below the damsite will resist any regime
change for centuries. Only in areas of alluvial depo~its would the
tendencies for concentrated flow in a narrower, deeper, possibly meandering
channel manifest themselves. Furthermore, they would only be noticeable
in that portion of the Susitna River upstream of the Chulitna River
confluence. In the past, estimates of erosion downstream of damsites
have been too great. In these estimates, the phenomenon of channel
armoring (i.e., the small size material is swept away and not replaced,
leaving a uniformly large stone bottom highly resistant to further
erosion) was not considered. With the present state of the art, most of
the above-mentioned morphological processes are calculable, and any
potentially adverse effects can be minimized.
296 The purpose of the multilevel intake structures is to allow selection of
the water released to preclude just such downstream quality problems.
297
No releases will be made from the reservoir bottom, but only from the
active power pool--say about the upper one-third to one-half the reser-
voir depth.
The peak monthly flow would occur during a major flood and would be much
less than the natural peak flow since the reservoirs offer storage to
allow a spreading of the total flood volume over a period of days rather
than a few hours under unregulated conditions. During non-flood periods
the combined Devil Canyon and Watana system would be operated so that
Devil Canyon would reregulate the Watana reservoir discharge to provide
306
·-
nearly constant hourly streamflow below Devil Canyon. Devil Canyon, in
effect, wi 11 be serving a component of the base load of the system and
Watana waul d be util fzed to.serve peaking requirements. The composite
effect of this oper~tion would provid~ a nearly const~nt hourly hydro-
graph for the river reach below Devil Canyon.
298 Frazil ice is a short-term early winter phenomenon involving a specific
~et of meteorological conditions in association with shallow, clear
rapidly flowing water, and the absence of ice cover. The very deep,
milky, relatively placid waters of the reservoirs are totally opposite
to the conditions favorable to frazil ice formation. Be that as jt may,
if such ice did form, the capability of selective withdrawal of deeper-
lying, warmer waters provided by the multilevel intake system would
offer a simple, immediate, built-in solution to the problem.
29~The estimated Railbelt energy demand for 1975 is 2.4 billion kilowatt-
hours, the equivalent to consumption of 5.2 million barrels of oil.
300 In terms of construction costs, yes; in terms of energy consumed, no.
3 () 1 The answer depends on what value is assigned to today's oil. At a price
pf $13 per barrel for oil from OPEC nations, the project's first cost is
equivalent to approximately 115 million barrels of crude oil. It should
be noted that the energy provided by the project over its 100-year
economic life will result in non-use of over 1.5 billion barrels of oil
or its energy equivalent of over 11 trillion cubic feet of natural g~s.
It is also likely that future oil prices could increase substantially.
302The quoted 6.1 billion kilowatt-hours reflect the net annual power
delivered to the two distribution centers, Pt. Mackenzie for Anchorage
and Ester-Gold Hill for Fairbanks, after deduction of transmission
losses estimated at 0.7 percent of prime energy. The approximate split
of delivered energy is 25 percent to Fairbanks and 75 percent to Anchorage.
303 The basic benefits are shown on page 106 of the EIS. The interest rate
is that set by regulation of the Water Resource Council for use in
economic evaluation of Federal projects, and reflects the government's
cost in borrowing money. Sedimentation is calculated to reduce the
system storage capacity by 4.2 percent in 100 years. Most of the lost
storage is in the ''dead storage" zone, not available for power production
in any case. The system power output reflects the storage lost to
sedimentation over the 100-year project life. Also see response number
121.
. 307
304 The 100-year life is a Corps of Engineers standard for this type of
project, used in computation of project economics. This policy is
accepted by the Water Resources Council and by Congress. The actual
useful life of the structures should exceed the 100 years by a large
margin. The Corps has data from projects located on many types of
rivers. It is from this data that a standard methodology of calculating
sedimentation rates has been developed. To attempt correlation of
sedimentation of the upper Susitna River with other rivers only on the
basis of flow or storage of water is meaningless. Many factors, including
but not limited to geology of the basins, river gradients, precipitation
patterns, runoff characteristics, and topography, influence sedimentation
and must be considered to determine any valid correlation.
3 0 5 Increased kinetic energy in the form of high water velocities due to the
large head of water behind the dam is dissipated at the dam. Most of
the fi!nergy is absorbed by the power station turbines. Spillway and
outlet works releases spend their energy in the discharge pool below the
dam. Thus, the discharge velocity ratios in the canyon downstream of
the dam are the same after project completion as under natural conditions ..
306 Flood control is a project benefit. The present adverse effect of
floods on humanity is limited to damages to the Alaska Railroad. Pre-
vention of these damages is the sole claimed flood control benefit. As
the downstream area develops, there will be a growth in population and
property which could be adversely affected by unregulated flows; however,
no estimate of this future benefit is claimed. Flood control benefits
are about 0.03 of 1 percent of average annual project benefits.
307The Susitna Fault, although close to the project, does not have the
probability of creating as violet (high magnitude) an earthquake as the
more distant Denali Fault. It is for this reason that an 8.5 Richter
Maximum Credible Earthquake (MCE) at the Denali Fault (40 miles distant)
was selected for design purposes over the 6.0 Richter MCE event at
Susitna Fault (2.5 miles distant).
The turbidity level is predicted on the basis of all settleable solids
be·ing trapped by the two reservoirs with only the suspended solids
(glacial flour). 15-35 ppm being released at Devil Canyon Dam. The
present summer sediment load of the river is attributable to easily
erodable soils in the upper basin and is not an indication that signi-
ficant material is being picked up downstream of the canyons. In fact,
the lower riverbed is relatively stable under all but extremely high
flows because of the gravel-cobble nature of the bed materials.
305
/......,..
~~ B The DEIS and feasibility study do not slight the recreational potential
~. of the whitewater river. Factually, the area is isolated, has little
access, no supply-subsistence facilities, and the Devil Canyon portion
of the river is so violent as to discourage.all but the most skillful
kayakers. As best as we have been able to determine, less than a dozen
attempts have been made to run portions of the rapids in the last 50
years. Its classification as a Class 6 river, a threat to the 1 ife of .
even the most skillful boatsman, and the awe of its violence exhibited
in written accounts of some who have challenged the rapids guarantee
that its recreational use would be limited to a very few people. The
reservoirs could and would, however, provide recreational opportunity to
broader sections of the public, while about three miles of the rapids
would remain to challenge the whitewater enthusiasts. As to ignoring
the area potential for 11 self-propelled sports, .. our view is that these
are the most likely recreational uses for the lands surrounding the
reservoirs. As such, we have estimated only a limited recreational
development based on camping-hiking-boating, rather than a heavy day-use
type of development.
The DEIS does not discuss the conceptual Talkeetna Mountains State Park
inasmuch as the State Division of Parks has not indicated any plan that
the project area should be a part thereof when or if the park becomes a
reality. Rather, they have discouraged a·ssociation of the project too
closely with the existing Denali State Park, preferring that the area be
considered a separate State Recreation Area if the State becomes the
project recreationa 1 sponsor. The fact that the 1 ands for many miles to
the south of reservoir sites are presently set aside for native selection
under the Alaska Native Claims Settlement Act would appear to argue
heavily against the probability that the proposed park and project would
be in any way closely associated, at least for the foreseeable future.
J~;;;J Comment noted.
J.iUJ.Comment noted.
philip n. osborn • geologic consultant
21·12NO AVE, N.E. • BELU:VUE, WA 98004 • (206) 45,·3588
· 17 October 1975
Col. Charles A. Debelius, District Engineer
Department of the Army
Alaska District, Corps of Engineers
P •. o. Box 7002
Anchorage, Alaska 99510
SUBJECT: Draft Environmental Impact Statement: HYdroelectric Power Develop-
ment, Upper Susi tna River Basin, Southcentral Railbelt Area, Alaska .
Gentlemen:
'rhe following material is submitted for inclusion in the records of the public
meeting of 7 October 1975, RE: Southcentral Railbel t Area, Hydroelectric
Power l::itudy, and as specific comment in reply to the Draft Environmental
lmpact Statement recently issued by the Corps in relation to this study.
Within my capacity as a geologic consultant I have had previous imput to this
study; specifically, in preparing a reconnaissance geologic study of the
Upper Susitna River watershed for the report to the Corps by Jones and Jones;
Upper Susitna ~. Alaska: _!u Inventory~ Evaluation of~ Environmental,
Aesthetic, ~.Recreational Resources. My comments are ref)tricted to the
geolo.g:ic aspects of the proposed project and within this discipline to the
inherent seismic dangers of the site and the geomorphological adjustments
which may ensue construction of the project. I have thoroughly reviewed the
Draft EIS and have personally communicated with Mr. Yould and Mr. Chandle~.
RespectfUlly submitted, ... N; ({k~
Eno.
310
pacific northwest and alaska
geology • ground water resources
The Dratt Environmental Impact Stateme."tt for hydroelectric power develqpment
in the Upper Susi tna River baain contains insufficient data within the geologic
discipline. This data is essential to a complete and adaquate evaluation'or
the proposed project--its merits, benefits, and costs• Specifically;
1) 'fhe geologic map on page 16 is incomplete; :raul ts which transect the
Susitna ~in are not shown. Major faults intersect the Susitna River down-
stream from Tsusena Creek (Susi tna Fault), at· Vee Canyon, upstream from the
confluence of the Susitna and Maclaren Rivers, and near Denali. Severa,l
smaller faults are located in the Valdez Creek area and at other areas . . .
within. the site. Undoubtably, other faults exist within the study regionr·
they may be presently inferred :or unmapped due to the immense area and the
lack or detailed geologic surveillance.
2) The geologic map shows no indication of structural features, partiou~
larly in Devil Canyon. A larger scale map should be included showing faults,
joints, shear zones, and lithology of the Upper Susitna Basin at the proposed
dam sites. Specifically, at Devil Canyon, a. master joint set striking
N. 25° w. and dipping 80° east,. a minor joint set striking east -·west and
dipping north, a shear zone with strike and dip similar to the master joint
set, and the massive phyllite lithology striking east -west and dipping
0 . • approximately 50 -60 · south are not shown lKachadoorian, 1974; Osborn, 1974;
Jones and Jones, 1975).
') There is no mention of actual movement along the major faults within the
study area and those outside but which could ha.ve significant effect on a
dam and reservoir system; in particular, but not limited to, these faults
and offsets should be mentioned: Denali Fault ~~-post-Pleistocene
displ~cement of 120m measured and 200m from aerial photograph interpretation;
Totchunda F$ul t --post-Wisconsan displacement of 270m (Page, 1972) ;
Susi tna Fault -... 11 km or displacement inferred from morphological expression
(Osborn, 1974)
311
4) The pos·sibili ty of an. increase in seismic activ:i ty as a: result of reservoir
impoundment and fluctua.~iori is not mentioned. Noting the immeqiat.e proxiiility
of the Watana. reservoi~ to the Susitna Fault, this possiplli ty shoulti be . ··
considered. This phenomenon has been widely recognized and is well documented,
e.g., inerea.se in. earthquake aetivity following the impoundmant of Lnke Mead
behind Hoover Dam (Richter, 1958).
5) There is no mention of the recurrence periodic! ty of great earthquakes
(greater than 8.0). within Southcentral Alaska. A great earthquake may be
expected.a.pproximately once evei:y 30 years (Sykes, 1971) or 16.7 times
during the reasonable lifespan of the dam structure.
' '
6) Large portions of the Upper Copper River basin subsided during the March,
1964 earthquake (Plafker, 1965). The implications of further· subsidence
during future earthquakes and the possibility, however remote,.of a. change in
drainage patterns whereby the Watana reservoir might invade the Upper Copper
River basin should be analyzed.· It should be noted there is only162 feet
of elevation gain from the Vfatana full pool level to Lake Louise. There is ·
' .
a high probability that the Copper River system has been the outlet for the
Upper Susi tna iirainage at least once and possibly ·several times during the
geologic history of the Upper Susitna River (Osborn, 1974).
7) lt is absolutely imparative that the possibility of a seiche generated
by seismic activity or landslide within either reservoir be considered.
These standing waves can have devastating effects, as evic;lenced at Lituya r . . .
Bay (Miller, 1960), and have been responsible for several overtoppings and·.
dam failures in historic times.
In addition, the following geomorphological problems and questions. should
be addressed.
8) How will the accumulation of sediment at the bedload "dumping.ground"
at the upper end of the Watana reservoir effect the river morphology?
312
~
,. I
9) What changes will occur in delta building at the mouth of the Susitna
River and what are the effects on sedimentation in Turnagain Arm as a result
of lower sediment loads in the Susitna? (The principal source area of
. sediment in Turnaga.i.n .;Arm is the Suai tna. drainage.)
10) All existing [iediment load study samples are instantaneous; there are no
continuou~ samples. Due to the tremendous sediment load in the 30 day period
following breakup l perhaps 60 -80% of total) when discharges may exceed
90,000 cfs, the existing data.~.s inadaquate to allow volumetric extrapolation
for· a tOO year period.
1 t) Wha. t ·effects. will fluctuations of the Wa tana. reservoir have on solifluction
mass wasting and will there be a substantial increase in shorelin~ erosion?
12) What effects will the transmission corridor have on permafrost in the
area of traverse? How will the transmission towers be anchored to prevent
dislbcation by heavin~.of the disturbed surface?
These· and many other questions, problems, and ina.da.que.cies suggest that the
document should be returned to the Southcentral Ra.ilbelt Task Team for
additional studies and voluminous additions to the Draft Environmental
lmpact Statement.
~LAA;J. ~~I · &:v;:;t Osborn,
Geologic Consultant
311
313
REFJ.ill.ENCES ~
Jones and Jones, 1975, Upper Susitna River, Alaska: ~ Inventory~ F.valuation
£f Jh! Environmental, Aesthetic, and Recreational Resources. Prepared for
Alaska District, Corps of r~gineers.
Kachadoorbn, R.,· 1974, Geology of the Devil Canyon Dam Site, Alaska, !!.• .§_.
Geological Survey Open _Elli Report 1A:.4Q..
Miller, D. J ., 1960, Giant Waves in Li tuya Bay, Alaska, .!!· .§.. Geological
Survey Professional Paper ~·
Osborn, Philip N.,. 1974, Geologic Reconnaissance 21. ~Upper S'U.sitna ~
Watershed. Prepared for Jones and Jones.
Page, Robert A., 1972, Crustal Deformation on the Denali Fault, Alaska, 1942 -
1970, Journal 2.£ Geophysical Research, v. 77, p. 1528.
Plafker, George, 1965, Tectonic Deformation Associated with the 1964 Alaska
EarthqUAke, Science, v. 148, p. 1675.
Richter, Charles F., 1958, Elementary Seismology, San Francisco: w. H.
Freeman and ·Co.
' Sykes, Lynn R., 1971, Aftershock Zones of Great Earthquakes, Seismicity Gaps,
and Earthquake Prediction for Alaska and the Aleutians, Journal £f Geophysical
Research, v. 76, p. 8021.
314
RESPONSE TO COMMENTS BY
PHILIP N. OSBORN
311 The EIS recognizes the most important and major geologic aspects .
Jf the project area. The Corps of Engineers will study all of the
areas of geologic concern expressed in Mr. Osborn•s letter and
many more geologic conditions as the Southcentral Rai"lbelt study
continues. To this end, the Corps has already retained two con-
sultants specialized in the field of tectonics and seismi'ctty;,o'f
the area. The United States Geological Survey has been asked to
do the geological mapping of the river and reservoirs. This would
include tectonics of the area, land slides into the reservoir,
seiches in the reservoir, as well as the required geologic data as
outlined in Corps of Engineers• regulations and manuals.
315
Det~r \ a'r.
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~~up h y \ rt.c..l Insh
(u(l eqt> A-k
t~"nh t h ""'" tht
CAV\V 'Y\ e eJ FC/'r
t htt" S ~.ll'u" \"' hn
Phlf 0:J two f\ <Am~ CTh
i-hc vpper Su~·h'"' nn,. Wt~viJ
proclvt~. I. th,nh t h~1 -f-'n.<.
pro1 ~(,h~ of ener'1 y
Jv -nut j(A tH 1 h h>
(.A p nJ bu \,\ ~ Jow"' turn·
t-h..c. . r Gt t ~ of
tht f:CA. u-· b u "-h.J a ru.. c.t f~ ·
p I p t h h.~ ,-l F I h"' h.~.
t h \'Y\ ~ t " "'-\ o. }) t \ Q 't\1 t .)., 'l. . . .
"\-'k · Dev' h C:..antur-. . ~ 11-.. · 0 ·C. H'" h J evm.t) ·
m a \-\. r-e f.v.) c:r,.. 't \, ~ ;l· t ht. y .
h u v«.. t h~ fA d cJ eJ a J v c.,-n l-o..ctJ.
of f\ot~J "~~ \~5 lo.nJ l +hu1
wov\c\
316
I "h\ p u.t.t ' I Ja th ,~\.\ thuv~"
thc-.t ,F-fA •JQYY\ I ) fo. b-t
bu,\t \"n A \ "~ },"~ . tht. s u s-tt"" . . ~( p '(A.CA F0r }t\ tlVtt 1S
312
312 Comments noted.
RESPONSE TO COMMENTS BY
CHRISTOPHER PEARSON
31.8
~~
!
!
Col. Charles A. Debclius
District Engineer
Al:l.::;ka District, Corps of Engineers
P.o. Box 7002
An~hora~e,: AK 99.510
Dear Col. Debeliust
.. P.o. Box 171
' Anchorage, AK 99510
Octo oor 11,· 197.5
. 1 am writing in general reference to tho Upper Su.sitna River Project.
Althoue:h I am al:jain:;t tho project for environmental and social impact
reasons, !' would like to focus my comments on a speciftc part of the
study. The folloHlng comment::;, therefore, have to do with the trans-
mission corridor, called alternative "Susitna-1" in the Septembnr 1975
draft of the Environmental Assessm(lnt of the Susi tna Transr.~i::mion System,
l'rhich pa.ralJ eln the .'\lanka Railroad between Talkeetna and Gold Creek.
As a p.'lrt-.ycar resident of Lane Creek, located near mile 241.7 of the
Alns~a Railroad, I am deeply concerned about this part. of the project.
I am not. alone; thore are hundred:; of people who o 'lin or hmze land .and
~rho have recreation or residence ca.bins in tho area affcctcil by "Susitna-1"
between Talkeetna and Gold Creek. Access road!; wl1l ruln this area,
bringing in large numbers of people and all tho attendant problemG 1 which
ls precisely what most people who bull t in this a.roa ~ranted to get away from.
In addition to tho roads, the transmission towers, lines, and cleared areas
will be unsightly and an impairment of the wilderness environment•
In reading the above mentioned draft, I was surprised and dintressed at
the incomplete artd misleading information which it contnined. I arn refering
he~ to the rnatrlccs and ~upportlng text for the Environmental Assessment ·
and Environmental Impact sections." Although tho draft seems to have been
intended as .a superficial study, the errors I will note arc so glaring that
they requ.irP. comment and correction before the draft in used as a basis
for any deciolona,
The matrix for this segment· of "Susitna-1" 'under t!xisting Developments
indicate several rail:coad stops, of uhich. L.'l.nc' i~ on1!, Lann is not even
a flae stop, nnd hit:m 't been for many years. The current. flag stops are mile
232, 233,5, 2J6, 2)8.h, 239.5, 241.?, 2ll1t-.6, and othern north to Gold Creek.
Each of thcr-:c ~b11J::1 rcpresnnt small communi ties of a ccat to red three to
ton ca.binn Hhlch pe·ople usc for recreation or residence, moctly the latter.
The locatlons o~ thn c~binn rnn~e up to three mlloz, and occais16nally
further, ffola the rnJ lrond tracks, The nat.rix· for Im1mctn under Jo.!xisting
Developeme!ltn indtcat.n::; no impact in this area, althouch lower down on the
pae;c thrJ Stephan Lnke cnbin5 arc mentioned, Th~ text 1 c equally incomplete.
Infact, the '"Impa.cts of Preferred Corridor Susi{na-1 .. (pg. J8) scarcely
mentions the Talkeetna-Gold Creek.seg:ncrrt at all.
--...,----·-------~------------,--,.-----
. -2-
The rather significant oversignt of ignoring ·.this large block of people
and the impact the "Su::;itnn.-1 11 corridor will have on them, indicates a
very su'J)erficial and n.lmost irresponsible analysis. I note that the
ma.tiees can be cazily updated. In light of the imforma.tion contained
herein, I hope that the draft, tla.trices and text, will be corrected
before being submitted tc decision makers.
A wilderneos lire ;for myself and a large number of peoJPle will be destroyed
if the transmission lines arc built in this corridor. ··I. would therefore
like to ccc the "SusH.nn.-1" alternativ"J between Talkeetna and Gold Creek
abandoned, If this cannot be dorte, t.her. at l~"last study it carefully to
minimize the impa.c·t, . Therefore, I certainly hope you will consider helicopter
cons·truction in this area and chooce a route which wlll avoid prl vately
leaned or ownod land.
cc., Zcnators Gravel and Stevens
Reprc~cntatlvr:-Yeung
Bob r.r,.,sr;, ,>\lz::;/::1. ?ower Adciinistratl6n
Sinccr~Jly,
/ii •:,( )t;. ·' /./1.~ ..
. I '
R. John Strasenburgh
·~ .
/--,
' I
313
RESPONSE TO COMMENTS BY
R. John Strasenburgh
The study is currently in the feasibility stage, thus detailed
design and routing of the transmission line has not yet been
accomplished. For this reason, the present routing of the line is
designated as a relatively broad strip of land constituting a
11 corridor.11 As stated in the Environmental As~essment for Trans-
mission Systems (APA): 11 TO avoid presumption of private lands, the
final route will be flexible enough to circumvent small blocks of
private land.11 The assessment goes on at some length describing
the actions which will be taken to lessen the obtrusiveness of the
transmission line with care given to proper design and locations.
The section of the assessment dealing with impacts on scenic quality
and recreation ends with the following statement: 11 Whenever possible,
existing rights-of-way should be shared or paralleled to .avoid the
problems associated with pioneering a corridor in inaccessible areas.
Trails in these 11 inaccessible 11 areas should, however, be avoided;
preserving wilderness quality entails sharing or paralleling an
rights-of-way exc~pt trails, and from these, lines should be shielded
as much as possible.11 Thus, preservation of the wilderness setting
will be a major consideration in transmission line location and
construction.
321
-----,----------------------------------~---------------~----------------------
STILLWATER CLINIC
BOX B
COLUMBUS, MONTANA
October 21, 1975
Alaska District Corp of Engineers
Ariehortige, Alaska
99500
Re: Upper Susitna &sin Hydro-Electric Power· Development.
Dear Sir~;;:
It comes to my attention that a power·development
including a dam or several dams in the upper Susi tna
and Devil 1 s Canyon is still being proposed. It is my
feeling that very little thought has been given to the
environmental impact that such a project would have, and
the permanent loss of some tremendous river floating and
boating in the future years. This particular stretch of
river is as magnificent, as far as rivers go, as McKinley
is when one considers its relationship to other mountains.
I feel that any measure to change or deface this river
should be as carefully considered as would a proposal to
change or def"ace Mount Me Kinley.
I wish you would enter this statement in the hearing
record as evidence that there is strong opposition to the
Devil's Canyon Dam that will permanently destroy the marvels
of this canyon.
·314
CHS/ch
---------------------------------·';
.~·
314 Comments noted.
RESPONSE TO COMMENTS BY
C. H. SWANSON, JR. M.D.
323
[)'~~~ .
t9j.~~"\4f:·~
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~.;~ ... '4-,. ~ ~f"4' \
1). W\ A,;;.. ·,
JOHN R. SWANSON
p, 0. B.ox 9Z2
Berkeley, California 94701
'\'~~m~~c~~ltA.;t; ~v-Nvv~.~ R~t~~~..w.t~~;x ·
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:k ~. ~ru.~~Mi.,/1./~ /~A4~~~~\1~.:.Jtl.stitGid\fu ~ ~ 1--~ ~ ~ r;t.b k1$f\.\t\..~ ~\ ~YJ/WJ\.A .vv.k~&~j,~
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324
i :
(~~1.5 Comments noted.
RESPONSE TO COMMENTS BY
JOHN R. SWANSON
Alaska· District
Corps of £ncineers
P.O. J3ox 7002
Anchorace, Alaska 99510
Dear nir:
'
410 Skarland Hall
University of Alaska
Fairbanks, Alaska•99701
Oct 7, 1975
I attended your hcarincs held here in Fairban~s.in October, with
great interest and concE!rn for the ·future development of the proposed ·
oams on the DiG Susitna River. . · · ·
I was somewhat sur!'rised when Colonel Dobclius mentioned tha~ there.
micht still he a ponsibility of· additional dam construction such
as the Rarn}1art. ','/hen the Corps tries to resurrect such sl-:cletons
of this rnacni tude of tbiolocical blunder, it maltes onp wonder about
some of thr rcasonin~ behind present studies.
Althou:::h I \'toul<1 be the first to admit that the ·Dcvil's Canyon arfla
\';ould be~~ probabl~ the best location for a d.am site in the State, I
·reel that 1.t is neccsEary to evaluate all of Alas~m's resources, ·
anrJ. \':ise land usc planninG~ \'tith the best and wisest use of resources
instead of dovelopinc in a piece meal style. · ·
I fr.cl that the quf1stion should be raiscd·as.to the necessity of
a riam for hydro-electric power/at this timf1. 'l'herc nrc presently
Many cn~rr.:y resources being .,.,c{stcd in Alaska. FlarinG of natural
[~as has been ca.rricd out for over a decade in Cook Inlet. As a
sturlent· on cnr.1!JUS at the University of Alaslta at Collecc, I '.'titness
entire floors urinccccsarily burnin~ clcctrici ty 211 hourr; a day, and
consumption is at a maximum.
Th(! rnct that 'thr. Corpn of Ent~ineers is planninr, this project at
this tir.1c, prior to tmowledr,e of the route the eas p;Lpclino will
.take, indicates D.n attltudo of "development for development's sake"
to pcrhapn quo t.c a well lmo\'m Alaslwn inversely. . •
If, tnfact thp-North Slope ::as nipcline docn. r;o throu::·h Alasl~a, it
would appear to'me to be extremely short sichtod at this .time to
co ahead \'Tl th construction plans, as well as encouracinc more waste
of Alaska's renewable and non rene\'rablc resources. ·.
······.
. cc: Governor Hammond
Yours· ~inccrc~y'·J;
rf.. ~ .I ~ . ' ~~l.l..j r~ !
Barbara Winkley .
/~.
31 6 Co11111ents noted.
RESPONSE TO COMMENTS BY
BARBARA WINKLEY
327
LETTERS RECEIVED BY THE CHIEF OF ENGINEERS
AS A RESULT OF COORDINATION
OF THE
REVISED DRAFT ENVIRONMENTAL STATEMENT
AND RESPONSES THERETO
329
UNITED STATES DEPKRTMENT OF COMMERCE
The Assistant Secretary for Science and Technology
Washington, D.C. 20230
October 4, 1976
Lieutenant Genera 1 J. W. Morris
Office of the Chief of Engineers
De?a~t=ent of the Army
Washington, D. C. 20314
Dca. r G~'ncr.::tl. Horris:
This i~·. in reference to your revised draft environmental
impact statement entitled "Upper'Susitna River Basin,
Southccntral Railbelt Area, Alaska." The enclosed comments
from the National Oceanic and Atmospheric Administration
are forwarded for your consideraticn ..
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you. We
would appreciate'receiving eight copies of the final
statement.
Sincerely, n.4 .~ (R_ (X~ Sid~ller 0
Deputy Assistant Secretary
for Environmental Affairs
Enclosure: •
Memo from Mr. Harry L. Rietze
Director, Alaska Region·
331
U.S. DEPARTMEN. OF COMr .. 1ERCE
National Ocoanic and Atmonphoric Adminlatrctlon ·
NationaZ Marine Fisheries Se~ice ~
P. 0. Box 1668~ Juneau~ Ataska 99802
DATE: September 15, 1976 FAK21/JB
TO: EE, Offir.e of Ecology and Environm~ntal Conservation
r. ~·f··t.......:;t (. S\f~t_SEP 2 9 1976
THRU: ~~ F3, Associate Director for Resource Management
~[~ a :cf(~ -~LH.L/~/l--.
S£p 2 9 1976
FROM: j i)' · Harry L. Rietze ~e 1 Director, Alaska.Region
·SUBJECT: Review of Revised DEIS #7607.37, Hydroelectric Power Development,
Upper Susitna River Basin, Southcentral Railbelt Area,
Alaska Corps of Engineers ·
The revised draft environmental impact statement for Hydroelectric
Power Development, Upper Susitna River Basin, Southcentral Railbelt\
Area, Alaska, that accompanied your memorandum of July 21, 1976, has
been rece~ved by the National Marine Fisheries Service and we offe~.
the follpwing comments.
Comments
4.U Environmental Impacts of the Proposed Action
t~~s section made several references to changes in various
parameters of water quality and fish habitat. How~ver, the
problem of streambed erosion and channel change and its effect
on fish spawning and rearing habitat in the Susitna River
system should be discussed in greater detail.
317 We believe that if the channel pattern changes from a braided
stream pattern to a single, dTep or incised watercourse during
winter months, as indicated, there-.could".be a significant
reduction of groundwater head with resultant dewatering of
sloughs used as spawning and rearing area~. Of twenty-eight
sloughs identified in 1974. and 1975, at least 22 were utilized
by salmon for spawning and/or rearing areas.2 ·Reduction of
intra-gravel flows could seriously affect mortality of eggs
and alevins.
'
5.0 Environmental Effects Which Cannot Be Avoided
P-agei67, paragraph 3
Elevated water temperatures during the first few weeks of
development of salmon eggs can creat-e....a.bnormalities and
332
increased mortality. 3 . Higher than nonnal temperature regimes
·can also affect the degree-day requirements of developing eggs
and fry so that earlier emergence from the substrate can occur. 318
This could take place at a time when food sources are not
available or during a period of adverse environmental conditions.
Both could affc.-t survival of fry. We believe that the DEIS should
address these effects.
1 llyuroelectric Power Development, Upper Susi tna River Basin,
Southccntral Railbelt Area, Alaska Corps of Engineers,
Interim Feasibility Report, page 67, paragraph 5.
2 Prcauthorization Assessment of Anadromous Fish Population
of Upper Susitna River Watershed in the Vicinity of the
Proposed Devil Canyon Hydroelectric Project. Alaska Department
of Fish anJ Game, 197 5.
3 TI1e Low-Temperature Threshold for Pink Salmon Eggs in
Relation to a Proposed Hydroelectric Installation. Bailey,·
Jaclc E., and Evans, Dale R., Fishery Bulletin: Vol. 69,
No. 3, 1971.
333
317
318
RESPONSE TO COMMENTS BY
U. S. DEPARTMENT OF COMMERCE
NATIONAL OCEANIC AND ATMOSPHORIC ADMINISTRATION
NATIONAL MARINE FISHERIES SERVICE
Further environmental studies are required to adequately address
the problem of streambed erosion and channel change and resulting
effects on fish spawning and rearing habitat. The preliminary data
presented in the DEIS are a basis for identifying areas that need
further analysis. Detailed biological and hydrological studies will
be made to obtain data necessary to assess the impact of altered
stream flow on the relationship between the main stream channel and
existing sloughs and tributaries downstream from the project.
As stated in the DEIS, temperatures of the water released from Devil
Canyon Dam would be adjusted to approach the natural river water
temperatures. This would be made possible by the proposed incorpo-
ration of selective withdra~l outlets into the dam structures. The
design necessary to provide optimum temperatures, as well as dis-
solved oxygen and nitrogen levels and other critical water quality
control. will be determined by detailed modeling studies.
334
REPLY TO
ATTN OF:
u.s. ENVIRONMENTAl PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE
SEATTlE, WASHINGTON 98101
lOFA -M/S 623
ocr 1 5 1976
Colonel George R. Robertson
District Engineer
Alaska District, Corps of Engineers
Department of the Army
P. o. Box 7002
Anchorage, Alaska 99510
Dear Colonel Robertson:
We have completed reviewing the Revised Draft Environ-
mental Impact Statement issued by your office on "Hydro-
electric Power Development, Upper Susitna River Basin."
We believe that this version of the DEIS is, like its
predecessor, premature in that the Corps has not yet
collected enough current water quality data to adequately · 319
describe that portion of the existing environment and to
allow a thorough review. We feel there should also be an
attempt to model the reservoirs and their discharges in
an effort to estimate their effects on downstream water
quality and aquatic biota.
In particular, for our review the environmental statement
should contain data which shows the current values for
turbidity (as well as suspended and dissolved sediments),
dissolved oxygen, dissolved nitrogen and temperature for
points in the river upstream of the proposed reservoir '320
sites, at these reservoir sites and downstream of the
proposed project. We do not believe that water quality
data which is largely twenty years old can always be ·used
to represent current conditiorein the river.
This additional data should be used to model the reservoirs
and the effects of project discharges on downstream water
quality so that a supportable assessment can be made, in
the statement, of the project's effects on downstream
turbidity, dissolved oxygen concentrations and water
temperatures. We believe that such an effort is essential
335
Page Two
I in order to ensure that the proposed mitigating measure 321 (multi-level reservoir outlets} is adequate to ensure
compliance with Alaska's Water Quality Standards.
Because of this information gap we must continue to rate
the proposed action and the environmental statement ER-2
(environmental reservations, inadequate information).
322 This rating and the date of our comments will be published
in the Federal Register in accordance with our responsibility
to inform the public of our views on proposed Federal actions
under Section 309 of the Clean Air Act, as amended.
We appreciate this opportunity to review your Revised
Draft Environmental Impact Statement and would be glad
to discuss our concerns with you at your convenience.
For additional information contact Dan Creventsen in our
Anchorage office (907) 265-4881 and/or Dan Stetnborn in
the Seattle Regional Office-(206) 442-1595.
Sincerely,
tl (! '-(' '--~ ,,''
f0.;:..'/..£1..t.LCU..it ~
' I
Alexandra B. Smith
Director
Office of Federal Affairs
336
RESPONSE TO COMMENTS BY
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
319 We agree that further water quality studies, both for line data
and impact analysis, are required to thoroughly describe the existing
environment and to assess project impacts. During the preconstruction
phase, detailed biological and hydrological studies, including
reservoir modeling. will be made to obtain this information.
320 Detailed water quality studies to determine present baseline levels
of a variety of parameters, including those listed above, will be made.
As preconstruction studies proceed, or supplements to this
statement will be prepared and coordinated as appropriate.
321 During preconstruction stages, reservoir modeling will be
accomplished to allow simulation of reservoir and downstream changes
of a number of parameters which affect the ecological cycle. This
will require an extensive base line data acquisition program to properly
calibrate the model. This analytical model will then be used to
adequately determine environmental impact and to ensure that proper
mitigating measures are incorporated in the design of the project.
322 Corrments noted.
337
323
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 2D21JI
1~--Septe_mber_l976
Lieutenant General J. W. Morris
Chief of Engineers
Department of the Army
Washington, D. C. 20314
Dear General Morris:
This Department has reviewed the draft environmental
impact statement concerning the Upper Susitna River
Basin, Southcentral Railbelt Area, Alaska.
While the proposed project does not appear to signifi-
cantly impact on the remote Alaskan area in which it
is located, the DEIS does not address plans for pro-
viding health services to construction workers, many
of whom may well be Alaskan natives. This matter
should be addressed in the final EIS.
Thank you for the opportunity to review the document.
Sincerely,
Charles Custard
Director
Office of Environmental Affairs
338
·~.
RESPONSE TO COMMENTS BY
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
323 Because of the remoteness of the site, complete health services
will.be provided throughout the construction phase of the project.
Thank you for the comment recognizing the need for plans for pro-
visions of these services.
339
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C .. 2{1240
PEP ER-76/692 29 October 1976
Dear General Morris:
Your letter of July 9, 1976, transmitted your proposed report
and revised draft environmental impact statement on Hydro-
electric Power Development in the Upper Susitna River Basin,
Alaska. Your letter requested the comments and recommenda-
tions of this Department on the report and comments on the
draft environmental impact statement. We are pleased to
respond with the views and comments as set forth in the body
of this letter.
Chief of Engineers' Report
We have no objection to your recommendation for authorization
of the phase I design memorandum stage of advanced engineering
and design for the project. We agree that additional detailed
studies will be required to determine the potential impacts
of a project of this magnitude and complexity on the Alaskan
environment and economy. The wilderness characteristics of
this remote area with its fish, wildlife, and recreational
resources will have to be fully investigated prior to con-
sideration of authorization for project construction.
Many of the necessary studies will involve this Department by
tradition, expertise, and legal responsibility. We would
expect to work closely with you in determining the scope of
project studies to be undertaken and in developing a schedule
and budget to support this work.
Areas of specific concern include evaluation of impacts on
fish, wildlife, and recreational resources, including impacts
on whitewater boating; land management; mineral resources; and
the Department's responsibilities with respect to transmitting
and marketing power from Corps of Engineers' projects.
The report of the Fish and Wildlife Service makes several
specific recommendations which we believe should be adopted
f.t-~CNo .... UT'O"' ¢-(l
~ ~ ~ -1 -m ~ ~
"'2.. ~
'j, ~
'?'6-191~ 8
340
2
as part·of the phase I planning effort. Among·other things,
the Fish and Wildlife Service recommends that the preserva-
tion, propagation, and management of fish and wildlife '
resources be among the purposes for which. the project.will
be authorized for construction. We believe that·phase. I
work should include detailed studies of the fish and wildlife
resources of the project area and potential project effects
on these resources. We direct your attentiorr to coordinated
studies recommended in November 20 and Decemberl5; 1975,
letters from the Area Director, Fish and Wildlife Service,
to the District Engineer and to a November 18, 1975, .t>eport
entitled,. ''Biological Study Proposals Relating to Hydroelectric
Development of the Upper Susitna River Basin" prepared by the
Alaska Department of Fish and Game.
The Fish and Wildlife Service provided funding estimates in
those letters for the detailed fish and wildlife studies
covering a £ive-year study period. We understand th~t the
phase I study period may cover only three years;·. consequently,
the fish and wildlife studies would have to be condensed into
the three-year period. This would not affect budget require-
ments. The recommended studies reflect concerns that the
baseline hydrology and fishery data are inadequate to predict
even primary project impacts.
Range and effects of turbidity and temperature changes are
speculative, as is the extent of dewatering of sloughs. The
proposed fish and wildlife studies would be aimed at a de-
tailed understanding of these project impacts and the formu-
lation of measures to mitigate or compensate for fish and
wildlife losses. It is not apparent from your proposed
report or from the Conference Report on 8.3823, the Water
Resources Development Act of 1976, whether the recommended
fish and wildlife studies are to be included in the phase I
funding. We strongly recommend that the proposed fish and
wildlife studies be recommended in your final report for
funding and implementation.
We recorrunend that the detailed location studies of facilities
and power transmission lines include clarification of land
status and consultations with land managing entities. We
urge close coordination with the St~te Director, Bureau of
Land Management, 555 Cordova Street, Anchorage, Alaska 99501.
This office can assist you in such complex areas as right-of-
way permits and compliance with the Alaska Native Claims
Settlement Act.
341
______________________ " ___ __,'1"".---r~-=---·-----·
3
Essentially all project costs would be allocated to power
purposes to be repaid, with interest, from revenues from
power and energy sales. The criteria for repayment are
somewhat different than the criteria for economic evaluation
with respect to period for analysis and interest rates. This
is reflected in the marketability analysis furnished by the
Alaska Power Administration (letterof DecemberlO, 1975) •.
From the viewpoint of the Interior Department responsibilities
for transmitting and marketing power under Section S.of the
1944 Flood Control Act, the project as proposed in the Dis-
trict Engineer's report. appears to be a feasible undertaking.
However,· this finding must be qualified to the extent that
any substantial changes in the plan may adversely affect
project feasibility ..
In some study areas we cannot fully agree that the available
data and studies are not adequate for the purpose of seeking .
an authorization to construct. We believe the finding ignores
a lqrge portion of the data in the studies relevant to Susitna
Basin that have been compiled over a period of more than
20 years since the project was first given serious considera-
tion. To the extent that these data are applicable and sound,
they should :be utili:z;.ed. ·
We r.ecognize that the project would involve a very large in-
vestment. However, the indicated costs do not appear out of
li.ne with other power alternatives available to the State and
the Nation. The indicated costs appear quite favorable in
comparison with current experience with large coal-fired or
.nuclear power plants and substantially.lower than expected
costs for more exotic future alternatives.
We obtained from the District Engineer, Alaska, an indication
that :the phase I studies would probably require approximately
three years and would cover the full range of data and studies
concerning environmental, socio-economic, and engineering ·
studies. The District Engineer also advised that the phase I
studi:es would not include constructing a road to the Watana
damsite, but that a pioneer road to Watana would likely·be
included in the advanced engineering and design studies (Section
l(b) provisions). This point concerns us since Section l(b)
specifically excludes construction and land acquisition. It
appears that this should be resolved in your final report even
thou~h the Conference Report on S.3823 pid not adopt the
Sect~on l(b) reconunendation.
342
/~.
We believe the data from the marketability analysis should
be included in your report to Congress since that analysis
is directly relevant to impact of the proposed project on
power syptem rates, revenue requirements, and costs to the
consumer.
Your report notes that the power is to be marketedby the
Alaska Power Administration of the Interior Department and
the District Engineer's report makes the recorrunendation that
the marketing agency also operate and maintain the project.
These provisions are consistent with the March 14, 1962,
Memorandum of Agreement, between ourtwo departments con-
cerning waterdevelopment in Alaska, the Columbia River Basin,
and the Missouri River Basin.
Technical Appendixes
There are two changes in the technical appendixes furnished
by the Alaska Power Administration. Appendix I, Part 2,
Page G-90, revise the last sentence to read: "They indicated
that on the basis of normal utility requirements, an intertie
to Glennallen could probably not be justified until after 1990,
thus a line to Glennallen is not included in the plans and
costs for the initial development proposal."
Appendix I, Part 2, Page H-39, last paragraph, delete sentence:
"Thermalconstraints necessitate larger conductors with larger
kV systems." The conductor size needed to meet current
c~rrying capacity is generally smaller than the conductor
size needed to reduce interference (TVI, RI, audible noise) to
acceptable levels. This interference is a result of corona
which is a function of voltage level and conductor diameter.
Page.H-44, Table 8. A total figure for losses for each plan
should be given.
We have some questions on Appendix I, Part 1, principally
concerning the Corps' modification of the Bureau of Reclamation's
feasibility design for the Devil Canyon Dam. The questions are
of a technical nature and are being discussed with the District
Engineer. We will furnish supplementary comments after these
discussions are completed.
343
------------------~-~~---------r--
324
5
Revised Draft Environmental Impact Statement
General Comments
We.suggest the statement be revised to show that the proposed
federal action is authorization and implementation of the
phase I design memorandum work. A brief description of the
work contemplated under this action should be included. ·
The revised draft statement appears to include essentially.
all items that would actually be impacted by the hydroe.lectric
project and the transmission lines. Thus it appears adequate
for the purposes of phase I studies even though data is
lacking to make detailed analyses of impacts.
We note that previous comments by several Interior-Department
bureaus are acknowledged in the Revised Draft-Statement, and
that the indication of Corps commitments made in response to
the comments should somewhat mitigate potential .adverse impacts.
Detailed Comments
325 lsummary pc;ge, paragraph 3 (a). The para~raph should ·refer to
the capaclty and number of powerplants lnvolved.
326
327
328
Page 7, Section 1.03. _ Descri~tion of Action .. Along with
statements about ongoing studles and studies that will be
conducted during the preconstruction planning stage~ a state~
ment should be included to the effect that minerals assess-
ment surveys will also be conducted during preconstruction
planning stage. This same statement should be included in
the final Chief of Engineers' report before transmittal to
Congress £or funding of the necessary studies. Mineral re-
sources should be given the same treatment as otherresources
present in the proposed project area.
1
Page43, 3.01. Since title to Native corporations or the
State of Alaska has not been issued to land at this date along
the p-roposed_ transmission corridor, the status remains un-
settled. The final statement should indicate coordination
with the BLM State office in this matter.
Page 43, 3.02. The land status here remains unclear since
the proposed exchanges have not been fully implemented or
concurred by all parties. Development impacts on adjacent
lands cannot be assessed until ownership is finally deter-
ined. The State and Native corporations could have different
development philosophies.
344
6
Page 50, paragraph 2. There is an important apparent con-
tradiction between the feasibility report and the draft
statement concerning winter flows. Page 67, paragraph 5 of
the report states that the river will channelize into a _
single deep watercourse between Devil Canyon dam and Talk~~tna
in winter; page 50, paragraph 2 of the draft states that ··-
higher winter flows may increase egg survival in the·· sloughs.
We believe there is a good chance that if the ttive!' does form
a single deep channel in winter, the sloughs may d~ain into
it and markedly reduce egg survival. This possibility should
be treated at length in the final statement.
The regulated flows will have the additional adverse effect
of limiting natural streambank and bar erosion and deposition
downstream from the dam. These natural processes presently
create large areas of floodplain willow and alder and support
sizeable numbers of moose. Regulated flows will reduce the
extent of disturbed area and consequently the amount of flood-
plain habitat and the number of moose supported by it. -
In vie.w of these serious problems. '·the release regime .for the 1·
dam will have to maintain the integrity of present aquatic
and floodplain habitat. Regulation of flow as proposed in
the draft statement may therefore not be possible.
329
330
331
Pages 67-70, Section 5.0. The section does not describe any I
impacts from powerplants and switchyards. The statement should 332
discuss these impacts or lack of impacts as applicable.
,Summary
The Department of the Interior concurs in the Army recommenda-
tion and recent Congressional action calling for authorization
of the phase I design memorandum stage of advanced engineering
and design including necessary detailed environmental studies, 333
subject to the comments stated above. With above noted excep-
tions, we further believe the revised draft environmental
impact statement is generally adequate for its purpose.
~puty ~s~1stan~
Lt. General J. W. Morris
Chief of Engineers
Department of the Army
Washington, D. C. 20314
345
·-----------------------------------.. -·~---·---~-.,·-~~~--"~-.. -----
the Interior
32l~
325
327
RESPONSE TO COMMENTS BY
UNITED STATES DEPARTMENT OF THE INTERIOR
Based on current guidelines established by Executive Order 11514,
the Council on Environmental Quality and Corps of Engineers Regulations,
we interpret the proposed Federa·l action to consist of the ultimate
project proposal. This is necessary to insure that decision makers
have sufficient information concerning a given proposal to determine
its justification in light of environmental consequences. Studies
made during phase I design memorandum work are necessary to determine
the impacts of the recommended proposal, and the EIS will subsequently
be supplemented as appropriate to reflect impacts in detail. Some
impacts related to phase I studies are inevitable due to the remoteness
and inaccessibility of the proposed project area. These will be
related primarily to physical explorations in the vicinity of the dam
sites and along an access route which would be developed if the project
is authorized for construction. This will require use of heavy equipment
which is proposed to be hauled to the work site by all~terrain vehicles
during the winter to avoid damage to tundra and other vegetation and
delicate soils. Thus physical disturbance will be limited to t•elatively
small areas and will, in so far as practicable, be contained within
proposed impoundment areas, or along the access trail developed by the
Department of Interior when it made geological studies of the area in
years past. Should the project not be authorized for construction,
some rehabilitation measures may be necessary. Overall, the physical
impacts related to phase I field investigations are expected to be.
relatively insignificant. A major objective of phase I studies is to
identify avoidable adverse impacts associated with the project should
it be implemented, and to incorporate mitigative measures where necessary.
The summary page has been held to a very brief, general description
of the proposed action and the major impacts associated with it. A
discussion of specific features would be so lengthy as to negate
the usefulness of the summary. The capacity and number of power
plants involved are described in section 1.03.
DLi'ring phase I studies the mineral resource of the proposed impoundment
areas will be assessed. The need for such a study has been acknowledged
in the final EIS.
The referenced paragraph clearly states that the status of land
occupied by alternative transmission corridors is presently-un-
settled and that existing jurisdictions are subject to change as
determinations are made for ultimate disposal. The State BLM
346
office has been kept informed of potential real estate requirements
throughout the initial study phase. These efforts will be intensified
during the detailed study phase not only with BLM, but with all
other concerned agencies, organizations and individuals.
328 Comments noted.
329 As stated on page 47, paragraph 2,and page 49, paragraph 41 of the
DEIS, there is expected to be a period of channel stabilization of
the Susitna River with some changes in the relationship between the
regulated river and existing salmon rearing and spawning sloughs
and tributaries. The extent of channel degradation and the effects
of this phenomenon on important fisheries habitat will be the focus
of extensive biological and hydrological studies throughout the
preconstruction planning stage.
330 The expected short-term result of regulated flow downstream of the
project is the enlargement of areas supporting pioneering species)
such as willow and alder, as this vegetation overtakes the areas
previously dominated by flood disturbances. But as the vegetation
of these areas matures, climatic species may take over and result
in reduced moose habitat. The significance of this phenomenon will
be the subject of detailed baseline data accumulation and analysis
during the detailed study phase.
331 Although detailed baseline hydrologic data are presently not avail-
able on which to base conclusions, preliminary findings indicate
that the release regime of the project may cause an unavoidablg
change in the present aquatic and floodplain habitat of the
Susitna River. It is possible that the river, through flood stage
reduction and flow regulation, may become a·single meandering·channel,
with increased flow and turbidity expected downstream from the project
during the winter and decreased flows and turbidity during the summer.
Therefore floodplain and aquatic habitat may be modified. The magnitude
and extent of this change is speculative until further studies are
conducted during the detailed study phase.
332 Upon completion of installations there should be no appreciable
impacts resulting from the location and operation of the power-
p 1 ants s i nee they wi 11 be 1 oca ted underground and will not release
gaseous or solid pollutants. Switchyards will occupy open space
which must be altered for this purpose. However, this will be
infinitesimal compared to lands inundated by reservoirs. Impacts
of these facilities will be addressed in a supplement to the EIS upon
completion of detailed studies required to determine their design and
specific location.
333 Comments noted.
347
,,.It.
FEDERAL POWER COMMISSION
WASHINGTON. D.C. 20426
Lieutenant General J. W. Morris
Chief of Engineers
Department of the Army.
Washington, D.C. 20314
Reference: DAEN-CWP-A
Dear General Morris:
2 Decernber-1976
This is in reply to your letter of July 9, 1976, inviting comments
by the Commission relative to your proposed report, and to the reports
of the Board of Engineers for Rivers and Harbors and of the District and
Division Engineers, on the Southcentral Railbelt Area, Alaska (Hydroelectric
Power) Upper Susitna River Basin. A revised draft environmental impact
statement accompanied the reports.
The cited reports cover studies of the feasibility of providing
electric power for the Anchorage-Fairbanks Railbelt area through hydro-
electric development in the Upper Susitna River Basin. After consideration
of ,alternative plans, the plan selected would consist of developments at
the Watana and Devil Canyon sites. Because of the magnitude and complexity
of the projects, a phased approach to the final decision on construction
was recommended. Initiation of the phase I design memorandum stage was
authorized in Public Law 94-587, app~oved October 22, 1976.
As proposed, the development would consist of the 810-foot high
Watana Dam with an installed capacity of 708,000 kilowatts and the 635-foot
high Devil Canyon Dam with an installed capacity of 684,000 kilowatts. The
total estimated cost of construction, based on January 1975 price levels,
is $1,531,800,000.
The proposed hydroelectric development is designed to supply most of
the increased power demands between 1985 and 2000 of the Anchorage and
Fairbanks areas, as well as other small communities in the Railbelt region.
The Alaska Power Administration has made several projections of the combined
348
Lieutenant General J ~ W. Morris -2-
loads of these areas. The various projections are generally consistent
with information supplied to the Federal Power Commission by the advisory
committees involved in the Commission's forthcoming Alaska Power Survey.
The mid-range projection, which was selected by your Department for use
in its evaluations, assumes a utility load growth rate of 12.4 percent
·annually between 1974 and 1980, 7 percent between 1980 and 1990, and 6
percent between i990 and 2000. Total peak demands would increase from
451 megawatts in 1974, to 870 megawatts in 1980, to 1,670 megawatts in
1990, and to 3,170 megawatts in 2000. The mid-range projection appears
to be a reasonable estimate of power loads that can be anticipated to
occur within the Railbelt area.
Power values deve~oped by the Commission staff were based on the
estimated costs, using January 1975 price levels, of coal-fired stea~
electric plants constructed in the Fairbanks and the Anchorage-Kenai areas.
A combination of REA and municipal financing was assumed. On the basis of
Commission staff assumptions as to the utilization of the hydro system
power between the two areas, composite power values of $89.93 per kilowatt-
year for dependable capacity and 5.98 mills per kilowatt-hour for energy
were derived.
Using these values, and applying appropriate discounts to reflect a
time-lag before the power installation would be fully usable to meet the
area loads, the total annual power benefits as computed by your Department
are $128,153,000, including a nominal economic value for the interconnection
between Fairbanks and Anchorage. Independent calculations by the Commission
staff agree very closely with that amount. The staff also notes that, in
addition to the economic benefits, the proposed interconnection between
Anchorage and Fairbanks power systems should have a definite beneficial
effect on the reliability of both systems. Including your Department's
estimated benefits for recreation, flood control, and area redevelopment,
the total annual benefits would be about $138,000,000, compared to your
Department's estimates of annual costs of about $104,000,000. Consequently,
the proposed development appears to be economically justified.
The staff suggests that f~rther studies be made during the phase I
design memorandum stage to determine the optimum development of the Upper'
Susitna Basin. Although the basic Watana-Devil Canyon development appears
to be well justified, variations in power load growth could warrant con-334
sideration of additional projects in the basin or deferral of construction
of the Devil Canyon project. Further studies could also lead to different
conclusions concerning such factors as height of dams, size and number of
units, or provisions for future units.
Based on its cons~deration of the reports of your Department, the
revised draft environmental impact statement, and the studies of its own
staff, the Commission concludes that the proposed Watana and Devil Canyon
349
Lieutenant General J. W. Morris -3-
hydroelectric developments appear to be economically effective means of
meeting projected power loads of the Anchorage and Fairbanks Railbelt area.
The Commission recommends that further studies be made to determine the
optimum scale and scheduling of the developments needed to meet the load
growth of the area. The Commission staff will be available to work with
your Department in resolving some of these issues.
Sincerely yours,
350
334
RESPONSE TO COMMENTS BY
FEDERAL POWER COMMISSION
The Corps of Engineers acknowledges and concurs in the views
expressed by the Federal Power Commission. Detailed studies
will be made during the phase I design memorandum stage to
determine the best combination of features for optiumum develop-
ment of the Upper Susitna Basin.
351
. .JAY 5. HII.MMCNO
GO'IIERNOR
335
STAT,E OF' ALASKA
CFFIC:E OF" THE GOVERNOR
JUNEAU
Lt. General J. W. Morris
Chief of Engineers
Department of the Army
Washington, D.C. 20314
Dear tt. General Morris:
November 17, 1976
Reference is made to your letter of July 9, 1976, informing me that a
copy of your proposed Southcentral Railbelt Area, Alaska, Upper Susitna
River Basin, Interim Hydroelectric Power Feasibility Report had been
submitted to the Director, Division of Water and Harbors, for review and
comment prior to transmission of the report to Congress. Subsequent to
this action, coordination has been maintained with the Alaska District
Engineer who has provided additional information defining the range and
type of studies endorsed in your report.
I concur in the recommendation by the Board of Engineers report that
further study effort is needed for a project of this magnitude. I agree
that additional detailed studies, including those addressed by my task
force, will be required to determine the significant impacts associated
with the magnitude and complexity of the project. Our task force
recommendations will be supplied to the District Engineer.
The information obtained from the District Engineer concerning studies
proposed in the next stage coincides well with the environmental, socio-
economic and technical studies identified by the State Task Force during,
review of the Draft Environmental Impact Statement. As these detailed
studies are addressed, coordination should be maintained with the State's
designee to assure that assessments are answering those points raised in
the task force report and to insure that the information developed will
be adequate on which to base future State recommendations.
Thank you
comments.
these
RESPONSE TO COMMENTS BY
STATE OF ALASKA
OFFICE OF THE GOVERNOR
335 The Corps of Engineers acknowledges and concurs in the comments
expressed by the Governor of the State of Alaska. Detailed
environmental, socioeconomic and technical studies wtll be made
during the phase I design memorandum stage to determine the impacts
of the project. These studies will incorporate recommendations
by the State Task Force, and coordination will be maintained
with the State's designee.
353
t:hie;f' of ;>n~ineers
Un~ted Jt1.tes Army Corps of 3ngineers
',/aShin:,~on, D. c. 20314
Thomas Taggart
Box 1195
Se;rard, .Uaska 99664
19 December, 1976
Certified ilail
?.e: DAE!·l-C:'i'P-C: R'~1IS:ID DR:'c?T ;;;.nilOm~~·lTAL IHFACT STJ.T3t!SiiT, IfiDliDSL3CTRIC ro;'GR
0?/ZLOFi·I;;:;'l', UP?SR SU3I~TA :l.I'nH 2 UFI, AL..\SKA.
Do .3.1" Sir:
I,!: :rou can at all comprehend the pure hatred :·rhich I attempt to convey in this letter,
:rau '·rill have oe:ru11 to 8ra5P the magnitude of your crimes. I hold in utter contempt ever-;
'ore.ath of :ti.r u}';ich enters your atrophied lungs, everoJ perverse offspring Hr.ich 1ti.ll follcw
in your 3hadowed corridors • I hereby dedicate the last drop of blood ~lithin me to the ne-
:;.atian of :rour will.
Befor rroing furt!l.er here, and ever mindful of I!I"J mm lack of eloquence, I rededicate the
follo•dng e:r.cerpts of a poem to ;rou and your fello•r conspirators againest life.
11.<\STEHS £! ;vAR 'b'J Bob D',rlan
CoC~e you ma!;te!'3 of • .. rar, :rou that build the big guns
T)•J ti;~t (mild the dc<i.t.h 'pla.'les, you that build all the bombs
·::-ou that :1ide behind walls, ;rou that hide behind desks
I ju:-;t ~rant :.'o'-1 to :mmr that I can see through your masks
Y•.>u thil.t n•cvor done nothin' but build to destroy
You play ·.dth my •,rorld like it's your little toy •••
rcu •ve thro:m the 1-rorst rear that can ev=r be hurled
?c'lr to br"..nrr chlld~n int:l the uorld •••
Ro~i much flo I kno~·r to t ~, k out of turn
You mi~ht cray that I'm :r<Jung, you might sa,y I'm unlearned
:Jut there 1 s one thing I lmcr.-r, though I'm :rounger t:1an you
Tlnt .wen Jesus ~·TO'Jld nevqr forgive ~Ihat you do
Let l'll3 ask you one <1Uestion, is :·our money that good
:o/111 it bu~r ~"011 for':lnmess, do you think that it could
I ti1ink ~·ou ·.:ill 5.nd ·-;hen ~rour death takes its toll
All the money :rou made •rl.ll never buy back ~·our soul
And I hop"! that you die and your death•ll come soon
I :·i:l.ll follo:r your casket in the pale afternoon
And I'll Hatch ~·rhile 7our lo:-rered ::kwn to ;<tour deathbed
,\nd I'll Jta.."ld o 1 er :rour -rrave •til !'111 sure that :;rou 1re dead
Concerning the M.atter at hand, I •,-ras infomed on December 6th, 1976 by }!r. Steve \Vilson,
rrulk 'Unknol-rn, A.rrrr:r Corps of S1o,-ineers, Alaska District that comments on the above-mentioned
::ubject could still be <>'Ubr.ti.tted ror includon in the Final Environmental I:'lpact 3tatement.
I herewith submit 'frr3' eom:n,mts, sane of 1-rhich are in the attached letter of Ha..."'Ch 9th,
1?76 to the Cb.'lir::~a.'"l of the Soard of F.ngineers for livers and Haabors. I a.sk for that l·~tter
rertai!'l:!.ng to. the Int."!rim "ea3ibili ty Report to be included 1d th this one in the YSIS, since
it rel:.1tes to b:.l'licall;r the same i;;sues and 'dll :;ave me the necessi~,y of duplication o!"
e!Tort.
354
~ ...
/~
::'2) ):;,r:. 2.01olt • .), par, 4, sen. 1: This is a va?,ue statc.,~nt. Just hO>f many mining claims
ar0 up there r.r:;r;a:;_r? And in hou large an area of acres/hectares? a as7
23) Sec. -=2.01.1~.5, pa.r. 4, sen, 2: Ii' 11nany11 of thc::;e claims are above the proposed ::"eservoir1 '
can ·.,e •af'el~r a:mur:1e t!1at like·,;ise "many" are •,dthin the area of the propo,sed. reservoir? . 358
24) 3cct.' 2.02h.1,1,
1
p
1
ar. 2, senh. 3: b:·lith a little hebl~ :'rom humans salmon ;auld probably be. 1·
t>:>J.'e>d .1roug Dcv Can:ron, t us t e statement "una. -e to ascend" should oe follm·red by the
·r.:rJ,J 11 'lt 'iresent'', in the F-ii3. 359
25) 3,.~c. '2.03.1, par. 1: Despite all the pipeline rel:J.ted :'iEures cited here, the po;JU:!.ation
?f .\laska ~ 1/5 the la.-1d area of the remainin<? 49 states combined) remains JM..\LLEa THAN the
-opubtian of an:r one of A'1~;rica 1 sJU largest.£!.!:!:.!!! . .. . , ,
26) 3ec. <.OJ .2, par J, sen. 4: To 3a.y that Alaska 1 s current groHth ra~e can cartl~r be at-
trih,ltc':i to the trans-.\Jaska i)ipeli::le is a ver<J misl 'ading statm:::'nt, unlesc.. fiTJ=es are
;;,ben to substantiate .it. I ~rould rrue~s that perhaps 90-95% of' the current :;ro,·rth r:1te is d.it":!etl~· attributabl+o T.\PS• a.:1:.i •. Uaska Hill :cubsequently have a h.rge decEne in ,>opulation
~hen the pipeline is completed.
27) ~Pc. 2.03.2, pa~. 12: This is a truly incredible statem2nt. · ~Yhy not consider reducing
c::m.,·umption '1:; one !lleans or solvinrr the energy problem1 Our grouth has become mllJ.irrnant,
.:;.:1d l:IU.>t be treated as a malignancy.
28) 3ec. 2.03.3.2, par. 1: The spur mentioned here is in actuality the ')e-.rard Highway, .the
r·d.in raad o: the K~na.:i. ?enin::;ula. The seg:nent r'"fer!'ed to is 38 miles lent;, not 27.
2?) 3oc. 2.03,4.2, par. 1, Sen 5: This sentence should be entirel:i deleted from :te ;;-:::::c.
It has no relovJ.l'lce, but r:r:.n~;r is intended to show the majesty of mac!1ines ov,;;r nature,
··;\:ich is a!: inacurate ::m:l ilrtmature ;JO:Ji.tion, and t:r;:>ical of' the insensitive thin~:.:.ng of the
C•)!'9S of C::t;in~ers whict. is p.rcbabl:r made up of people •·rho are totally estra11ged from their
n~tural -::onvir..,-m,mt.
30) .)eo, 4.01, p.-3. r. h: T:1e anticipated suspended sedi;1ent lavels (1 5-35P'Jm) at the :)roposed
O:eYil Can3•on Jam ·nuld :10t con:.'orm to ~PA regulations. This fact alone !:l.;s caused the 2?A
to clasd.ry t.hl.:J .-roject a:J ZR-2 (SnvironCJ:mtal ~servations). T:1is is a aerioos considera-
ti•m, and should be :;reatl/ e:xpand2d upon in the FSI:i.
31) )ec. u.01 J ;:;ar. 14: It it; stated that "3ome :.fLnter moose ranc;e in the riV·1r bottom" I<Ould
''le flo-;ded. I refer here to :\C,-;endix 2 of the IFR, pa.ge 13 oi' the US~\'c',•TS :::-e9ort, the chart
·::Oich i•1d:!.cn.t~:J thn.t 33~920 acres of preferred or critical moose babitat ·,rill be lost to the
;at.1!'ll. :ledorvoir. ':ionl the corps-care to corrnn;nt?
32) 3ec. 11.02, para 18 &19: Here it is concluded that fish '·rould have a di!'c'icult (ii' not
.L·~po:>,·iblo) time of cst:l.blisl1ing thP.:'lsclves in either of the. ::rop·Jsed reservoirs• So what
recr..:at.ional poto;ntial '·:auld be available :·li thout · fi:shing? Pi:merboating? S1d.:nming?
33) Sac. 4.03, par •. 2: this paragra"h tells us th;:;.t Devil Canyon has fe<r areas of big-ga.''le
:;~bi.':.:J.+ • '!':..e u3F:':':iS tn the chart .ouoted in item }31 above tells us that Devil Canyon has
5, 760 acrr>s of tlre::'c::Ted or critica:l i1abitat ~·or :noose. ---34) Sec. 4.03, par. 10: \1h:;r -:.'la:J this paragraph deleted :'rom the Re:rlsed Interim Feasi'.ii.lit:J
!1eport (RI!"!t)?
3S) 'lee. L.13, par. 4: "The proposed tranSlidssion line corridor ;rould cross no existing or
p .. esently pro~o.~ed ::~cenic, ~dld, or recreation.J.l r:i.v~rs, nor uould it cross an;• existing or
prescnti:r pr~jposed ~.1.lderness areas ... " The Susi tna River itself ia proposed as a wild t\
sc·'nic ri-;e>r, and all of the la."ld in the Up·:·er 3usitna !liver -in "would probabl.Jr qualify
f'or ~rl.lderness cla::"iif'ica.<:ion. under most definitions of the term" ( 3ec. 4.13, par. 1) •
357
1360
1361
1362
' 363
1364
1365
1 366
1367
1368
~· 369
1370
371'
3721
3731
374
375
376
377
378
3 7.···.·i;·~ .... · ..
3801
381~
382
J6) 3ec. 4.0?, par. 2, sen 2: It is stated that temporar"J reads 1-rould need to be con-
st!'IJcted in "other ar-e'!.s" to implement clear cutti::1g for the reservoirs. How tem:;orary
is a temporary road and ho!r is it to be "removed"?
31} sec. 4.'-'7, .par 3: 'R'hat is the coMI!lercial potential of the timber to be clear cut
Hithin the reservoir areas and transmission corridors?
38) Jec. 5.0, :nr. 2: On t>-ro occasions in thi.s paragraph the 3usitna !liver is referred·
to as a stre'i."'. That i.s. tantamount to referring to the Himala.•ras as "hills" 1 and b~r
usinfr such phraseology it is apparent th~.t tl!e Corps is attempting to inplem·=nt in our
minds the i::oage of the Susitna being some,·rhat insi~ificant in the re~ional context.
?ur-th(C!'l!IOI"es the last sente:-1ce in this p?ra::raph should be deleted, since it does not
ref·'?!' to an 11 :J.dver3e effect". ·
39) :ec. 5,0, par. 4: "Apr;roximately 9 miles of the existing 11 ·mile '<lh!.':.e:~ater reach
+ht"OUgh Devil Da::yon ~10uld be lost through inundation." Does the Corns in'vend to dis-
M!.ss the sit;nifica.'1ce of this adv<?rse effect ·,ri th one brief' :~entence? 1 refer the Corp!!
here to the Jones & Jones Rec:-ea.tional il.eport :·lhich in no less than five separate instances
cites the importance of the recreational and aesthetic value of Devil Can;,r.,n jJ). lJ:§ t;ri.r.t~
lt~"le ~· On pa~es 6 & 210 of that report, ,Jor.es ,',:Jones recommend r'!oving the lo'•e:r.
·:!:1111 enti:-e:w out of tlevil Ca.'1yon. rh.:.s in fact U, a ·fild o!t scenic river, md :·rill aurely
be de sir;n~~ted'""iS suc'Fi'1i,Y""tl1S"'1J':"'".;. Congress.
l:O) 3oc. 5.0, par. 6: Th~ ~1some 11 moose habitat referred to here is in actuality 39.r680
~ ~ critic.:U. or preferred habitat as per the US7&'35, ,uthough the US?u;is did_ enter
')lla error on page U of the{r report in ap,leJldiX 2 of the feasibilit:f report, this does
i.n no 1o1a_;r i:1dicate that all their figures are inaccurate. Conversel7 1 rathar than ques..;
ti'ming the credibilit:; of the U~?&:·i'l, the Corps whould accept the professionialisn o~
th<·lr •,;ork, ~:!!_documented~ photoFrraphs.
41) 3ec. 5.0, Par. 9, sen. 1: To say that the resident fish por:ulati.on could oe advt'>r::;ely
e.""~cted is an incredible under3tatement. Crc:ss reference here to section 4.02 1 par. 19
··htch, in the. Corps Clim ;;o·:do, states that conditions ~·rill "generally be detrimental" .to
r'!;)iuent rish. Another i::lstance of the unbounded h;:r?OCrisy inherent in the Corps !"'0Sition
M it attempts to "sell" this prooosal to the AJnrydcan peCll)le.
42) 3.,c. 5.0, !)ar. 15, SP-nt~nce 5 should be deleted f:ra1!'the F3IS since it has no· relevanc;e
to thi.s section (adverse emiro:r~"ntal imp.:J.cts).
hJ) ::ec. 6.01, Par. 6, Could the C·:Jrps def:ne ~;ha.t is me1.11t b~· "poll tical !'easibili.ty"7
44) '":ec. 6.02.1: ~'oting that this alternati'.'e• action has :Dt .been d.is:n.i3sed as lae:<ing
feanibility, it should be r;r·catly elabaratod upon in the :<':TI3.
1.5') ;ec. 6.02.2, par.2: :'he first s~ntence here has absolutely no releva."lce to Al,aska•s
ooal r·esoUree and .:;hould bo deleted in t;1.e ?~I3.
46) Sec. 6.02.2, par, 5. nen. 2 thru 4: The qtl3.lity and ·"tl:-,_-!ty of the la.'1d Temo':lrar..J.y
.Ute::-ed b;r. strip ;"lining for coal w<nld not begin to approach the irrepa:-able and oerr.ta."l.nnt
d!IJ'Iage to be done to 39,680 acres of critica2./preferred moose habitat by the hydro propusaJ..
The final E13 should r'.:'lect that fact. -!r7) :>ec. 6.02.2, par 7: Thi:;; par:3.graph d2picts the inane ::u1d h:'!locritical position of the
C.Jzt'" to the extreme. The Corps ~.ttel'!pts to offset the econo1'lic superiority of the coal
altm'tlative (Many· mora jobs ~ greater kilo;-ratt output) by :;;aying th~ the coal alternative
•;ou::l not provide !:"ecreati.:nal. or flood control benei'i t s. Yet on page 96 of the RIFR, the
Cor.::; ~tates that the significance of recro:ational & flood co:1trol to"et:hor equal ~than
J/10t'w 2! 2!:\!. ~~of t:1e total project cost. !io·.·r badly the Corps ·.ra."lts to justif~·
its presence!
358
/~.
I do have additio:'lal co1!111lants hat·tever. To the north of the Upper Susitna River Basin
llc3 Prudhoe ~ay Nith oe!'haps 10 billion or more barrels of oil, and tri:i.lions of cubic feet
-,_: naturJ.l ,:;as. ·ro the Hast are the Beluga and Healy coal.:'ieds (lo•::-sulphur) which are es-
ti.Matad to contain the c1uivalent of 24 billion barrels of oil. To the :;outh is Cook Inl;et
otl :and p::, probable e-xtensive 0. C. 3, reservoirs, ai1d the potential of harnessing Cook
Inl-~t 1 : 30 foot tides • At all times in Alaska the!'e are tremendous ;linds 11'ai ting. to generate
el-,ctl·l.cHy, in :rumm.er months ue have up to 21~ hours per day of unrestricted solar energy,
t:>.nd ceot:lem.al potential such as exists in Sonoma County, California is abundant here.
;Je:>~;ite this ~-;ealth of reso'Jrces, in yoor blundering incompetence and maze of bureauc::-atic
::-e•:•1lations you can .lind no other :-:zy to ;crovide oouer for .Uaska's miniscule population than
to con:;truct clams on the Susi tna :C.ver. Instead o:: a.llo~ring North S'lo::;c oil to go to Japan
a.':; !.s proposed (less oil com;::an:r taxes to U, 3, Treasury), •..thy donit you ener::retically •·fOrk
to 39'3 th;J.t .Uaska g<Jt just the small t!"iekle of oil Ofhich she needs? It '1ould hardly be
·~~:;::.cd 'oy the ~:luttonous consumers. o£ the 11 lo~.rer 46" in their headlonG: rush into oblivion.
ConV.!r,ely, it ~rould ~ave billions of tax dollars by preventing the Susitna Dam ':Joondoogle.
Plea0e re:r~~n from quoting to ~e Public Law 93-577 ?ertaining to con3Grvation of nonre-
ncNahle ::-eso•Jrccs. I understand it perfectly, and I al:>o understand ho~-r ludicrous the appli-
cation of the letter ot t:1at law is to this Gi tuation. ',iE AilE SURR.::;m;nzo :!Z::E El .\LASKA 3Y
.\ ·~::::UTAJLE ·.;::;,".J,T!i CF :IATU?~\.1 :'..'r:JGU:l.CES CF UNLn!IT:!:D P?.Ol·liSE. ile in .Uas!"a could not use
the ;e rflr.o;.~rces in 2000 ;rears. ALLOW US TH3:: IlrSI'J:fr?IC ANT ?1? • .'\.CTIOil OF T!!iS3 lBSOURCES NEEDED
TO 3l:''':,UH cu;r:nr.·/"35 and still maintain the integrity of our natural environment. Most
.Uas!m."ls ~ Alaskans precisely bec"!.use of the lack of dams, freet·ra;;·s ar:d other insidic:ilUS 1 .
der.tcaning encroachments of your ro ciety.
Th'3 follo~ting slcetchy comments :Jertain to the revised m:rs or revised IFR, as note.-:',
1) I iJe"!.iS"te that the :'SIS should include metric convFlrsions foll01-ling all nun'lral<' •rhere
ap!')licahl-:!. The .fact t.h1t this ·ra.sn't done in the draft statement indicates that the Corps
itc;r,lf is unrtl:J!)cnsive to the cha."!.V.ng values of our .:;ociety.
'2) It \fould be a?propriate for· the ?SIS to be expediently brought to the public's attention
via the rJUblic libr:~.ries of the follo1ving com."!!llnities: All Southcentral Alaskan communities,
Juneau (the :; ate~ capitol), the public li";Jraries of the capitol cities or each state and
t:::·rltor:-r, a:1d the District or Colu'lbia. Furthermore, there should be no dollar value placed
;r. such documents ·,rhich ·,ould in:cibit the public's ability to obtain such. Please note rv
~on."l~!'l~-s in the attached letter ~ertaining to the Cot"?s duuious methods of disseminating
-:.n ·o:T'lation on the ·lraft ?roposals fa:-this pro,j;oc t •
.3) Section 2.01.4.5, paragraph 1, page 17 states that ''lt,ost of the Susitna basin above Devil
Can:"ron is considered to '!;le highly favor:l.ble for de':'losits of copper or mol;;"bdenum •• 11
3eo. 4.08, p. 60 of the same document lRDZIS) states that ".,the area has never been mapped
~eologicalJ.y,n Des,ite t!1ese t;m sta.-:e'l1ents, the Corps is apparently not soliciting comments
r!'"am the U. :;, ~ur':'au of :,:ines, and this fact ca3ts a pall. on the integrity of the Corps.
3ince the area has not been exten<Jivel:f checked ~·or ninerals, let us assume for the moment
th-3.t va.at deposits or ura.11ium, gold, plutonium, etc. exi.::t there.
4) Throu~hout the RDZIS and the RIFR the Corp:; ::-ef·?rs simply to moose habitat or good moose
h1bi tat. Ho•t~ever in A.p-endix 2 of the I?R1 the US?&'.-IS r:;fers to the sa.-:1.e areas as preferred
or crit,ical moose h.1.bitat. The Ccl!;IS is again caught being l:ss than candid about i!nportant
fact3 which are Of concern 'to all Alaskans~
5) On the Su1"1M"l~.r page, sec. )b 1 the Corps refers to "increased turbidity dotmstreaiii from
·:>~vil Slll1:;ron" a:; an adverso env! . .ronrr..ental impact. The sa.'!le phenonemon(increased turb::.dity)
is citacl on p. 63 of t.he :.U~R as a I"~a.son for not opting for the alternative of a coal fired
:lO'.ll'C~ n~ e:1cr:::r. Doc-1 the Cons ::'OSsibly consider the pot::>ntial da."ll<:ge to t!:le S11si:hna (a
-a,jcr ri'J :r) to be of: le:;s :;irr::i.fica.~ce thar:,..,d<J.:".a:e to streams around Bebga or Healy where
355
b37
1338
' I
339
340
3411
3421
3431
3441
3451
3461
3471
348,
349-
3·50'
351'
6) 1:: thn ;rune f<J;;:-~::'l"'aph :J.s cited abwe, the Corps refers to the 11 po3sible" il'l.lrlbition o:f
c;\:--l:J~'l :1n·,•e::tcnt.s. ·,;c.·r not "probable'' or 11 hig'lly probable" considering that ;rou ~ropose
to l•,cate the 'iahna. ::tese!"'loir directl:r on tie path of the Nelchina herd? Another c~se of
t:;f'l Cor;Js inclinatiOJ: to :dve us 'licbus half-truths perhaps?
7) '}ec. 1.01, s<Jntenee 2 is a highly acc'..lrate appraisal. of the situation, a;1d as a solution,
~;11f: ·:·T ~UC:i: CO?JSUliPI'IOli?
8) 3cc. 1.01, sen. 3 !Tientions 11 ... at the request of local interests ... " As a concerned cit-
i:~cn, r :1ereby dmnand that the Corps elaborate on that statemrmt in the '5'::;13.
9) Sec. 1.01 ••• T~s ;te::~oiution mandates that the Corps revie•..r "any competi ti·1e alternatives"
to the 3u:Jitna :t·dro ?-:-opooals, and it i,s apt;arent from the P.DEIS J!ld the RI~'R that the Corps
has failed to ej:tensivel:! review the alternatives. · ·
10) 3ec. 1.02., par'l. 1, sen. 3:
t.l:c 3ou.thcentral Ra.ilb~lt ;\rea.
¥4 to be ~inor resources?
It is implied that Alaska's major po~Ier resources exist in
Does the Cor:>S consider ?rllc:!liOe'"'tiay ~d Petroleum }eS·:!l"'/e
11) Sec. 1,03, par. 3, sen. 1: In light of the recent Idaho disaster, is it :rbe to con-
:trJ;c-t an en!"thfill '1:1.-n of t.hiil magnitude? If tho ~{atana Dam bursts, :·rhat of:'ect ;rould it
::a'/0 on the J"'lil Can::·m DJtn? If they both go, <That Hould be the effect on \iillo~r (the new
3~aL<!! capitol) .and l;.><;<Jer villages oi' the Low~r Jusitna RiV?r?
12) ·;ec. 1,03, rar 6: The fi~ures here do not correspond with those ~ben on page 92 of the
;:rr::;o:~. How can the Corps publi::Jh a hlunder o: this magnitude and expect to naint.ain its
C:'e<.iibility?
tJ) ?ig. 2,3.5.,.8,11 1 12:' The maps are in error by projecting the Copper R:L-Jer ni~hl,·a.y to
ooe,•;ct at Cln. tina., ro.t!1er t'lan at Thompson Pass n-orth of Valdez.
ih) .)cc. 1 ~OJ, par. 11; These ficn·es 8hould be updated in the ;;''TI3 to 1977 estimates.
1~) ~'!C. 1.03, par 12: The benefit to cost ratio given here (1.4) is in conflict >lith the
rmc 'ii ·:ron in the R!FR ( 1.)). ',iho are , .. re to believe? Hm• does Senator Gr'lvel• s bond pro-
'os;ll ~fe<'t the 6.J/S;~ intorcst rate?
16) :;ec. 1 ,OJ, par. 15, s:cn. u: To ~mat Congressional C=i':tee does the Cor:cs submt its
r.~ ..... ~d t~ :.~~~?
3 521·17) ~ec, 1,0.3, par. 15, ::;en. 5: 1fould.'1 1 t these a:iditional studies refen·ed to here be 'l
~r.a.:;te of t.·:P: mone;r if Congre:>s should decide to shoot do~m the proposal?
3 118) :'3ec, 1.0.~, par. 15 • .;en 7:. This sentence is ·,rorded as though it is a .f'orel!one conclusion 53 ~hat Concre:!3 ··rill autinri:z.e advvar'c"mc:nt t·:J f:.nal pro.~01ct design and construction, en ;mat
does the C<>r:cs ba3e s·~ch a pres·.1mption?
3 5 .4 .. 119) Sec. ~.111,1, :/'l!', 2, sen • .3: The adjectives us'ld here (cold, swift, s:!.lt-laden, unin-
:1abited) ma:r iJe accu1·ate, but are obviousl:J intended to project an illlage of a harsh, unrelenti.ng
river and Lmd which po;;sibl;r "dec,.,rves" to be t'3l'ned, :rrw not describe the river as "wild
and ::c,nic", the land as •unin.i.abited, but not uninhabitable". ·';ihy not indeed.
3 55 • 20) Fig, 4: ·rhis ma.p is untitled.
I. 21) 1ec, 2,01.2, par. 2 &3: .<ltho·1;;h the Susitna '.·ras not reCOl:l"lended as a 1dld <'.: scr,nic river
3 56 by the >~eretary of Interior, it :1as inde<?d been redornm0nded as such by <Jthcr legislation
(32918 ~ HR1356u), and that ±"act deserves mention in the ?:':IS, as does the river•s nickname:
11 ~ ~ ·;-r:·:=t1"~'!' ::! KA::~~J(J •. ':Q!r.
356
h8) 'Oce. 7.0: I!o~· ma.~ 5'00 :rear old da.'l!s are tile:-:-e in e:-..i::;';ance at ·:his ;:oint in time?
ll:n r:an;,.: 100 ;·c.ar old da':ls?
117) 3r,;c. 9.02, par. 5: 11 ;\.ll in.:'ormal t=oll of people att·"nding the late stage public meet-
tnc" indlcated sur:port for the project •••• " This is· a highly unprofessional. statement by
t:1~ c~rps :md should be deleted ::.n the ?ZI3. Doe:" the Corps bel::.e";e t:-.t ~be public is
c;ullthle enou~h to lend cr~edence to an in~or:nal poll conducted oy t;-.e Corps itself?
50) S-;c. 5.0: This sccti<'l'~ should list the huge mudflats to be cre:J.ted b:r the ';J'atana
:-e.1~rvoir dro.t~d01m as an adverse environmental ef:'ec~.
The follm·ling stat~f!nts pertain to the Interim l"eaGibility n!:!port and t::e revised IFR.
Pare '23: :/lvr ·.•as t:'le :;ource Alaska Re~ional Population and :Tt!:>lo: ment ~J G. 'j. :'lagers
>ietbd ~tOM the RI?R.?
Pa:!<') 35 thru 38: Concerning the methodlogy used by the Alaska Po~·rer ;\cl.nrl.ni::;tr8'!:'..on ;:or
~rojo:Jcting po"r.;r requir'lm!'!nts, is it ·,rise to pr:Jject that ~Uasi-:a•s r!rmtth rat<o in the next
~5-20 :.·ears "'rill be similiar to the national aVel"a.ge ot the 1960's a.'ld earl:/ 1970's?
l.
This can iJe a cold :l."ld inhospitable land at ~imes, ?nd ;Jeople are not going to :-nigr!l.te here
'!S readil;r as the:r 1-1oulj in the "lotmr 48 11 • Thi:o -,uestionable nethod of estL":lating .\laska• 3
r;rn·.;th ro.te casts doubt on the justi::'ication i'or this hydroelect:i::i:c ;;reject.
Page 40: In this table the hi~her r~'lge esti~ate given :or the decade 1990~208C is actually
lo;,·er th<m the lo1~er ral''.'!e 1 Another indication that ':he Cor?s thre1• this report toget:1·~r
·i. 1.1 1.ittle thou;;ht. Footnote 1/on this pa;re indicates that the !'iJUres in the "table ·..rere
arnv"d at ·o:; a hi.:;hl:r speculac:ive :-1a:r of r.,a.soning1 and indicates '!:hat the <·'hole series of
f'i -:ures i:; little more tlun a fabrication.
Paee L5, last para~ra;;h: ·,iho is t!'le Carps of Engineers to assay that ;-re here in Alaska
do not have "!'enerall:'/ acce!Jted growth goals"? \iHO A:1E YOU PECFLE "dHC ~.;oULD XI'TZHPf TO
CI!A}nlELCUh LIVai TO APP:lC':TIUTE YCUR O":JJ:i HORBID,' ?E:W~RSE A:ID Rlil}I!·l'Sli'I'!ID ~::rsTEcJCES?
Fare 59: !T:J.tianal 3conomic Dgvelo·:n~mt Cri t"ria: "Tangible ·bene:'i ts must exceed economic
cu·::t.s.11 !-J.o not belia.v~ t!;.~t ~:-his crit8ria ':·rill b~ mc--~t. Gonsid·::r the :ollo":·:ing items ••
A) B:r nec:<:ting .the coal ultern:J.tive in f'avor of hydrol)Ower, a vast lllT!ount of jobs .. n.n be
lo~t to Has::ans. The 'J'EI3 should spell out hon many jobs :-;ill be lost because of this.
B) This is the const:ruction af a first-tirne-eV8r dam system under Alas:,an conditi.ons.
Cost override~ due ~o the 1oarsh ei'iVi'Mn·:ent could r:ake a sha."'bles of the D/C ratio. Look
I 383
1384
'385
-::.t ':.:.e curr-;nt nricetag on i.he Trms \.las•<a Pi,:eline System :'or an indicator ••• $8,ooo,ooo,ooo.
Up 1000% .f'rom the .original estb.at;,s, largely due to i.n:'lation, but liketdse largely due to
'he unprerlicto.ble elE>.I'lent:>.
It is t;oc;sible that the 'Jevil Can;nn Dam ~·rould not meet the requl!re:nent scceci.:.'ied under
item 2 of t!le i13D 6ri':~ria on this ;:ng"• Item 3 of the 1rzn guidCllines may not be met if
the 9otential lo.3!l ._, the ec::morn-r o~ the coal rel::.ted jobs is figured in, as it should be.
Par;e 61, par. 2: T:1e i'irst half of sentence five is deleted from the RIFR. :,'ithout this
explmator:;• phrasn, the s::cond half of '.::e sent,mce te-::~ds to be mislea~iing.
~'a::e 62, Jjar. 1: iialf o? this ::-aras:raph was deleted f::-om the revised IFR. Those sentAnces
contai.ne.d thG :acts, od thout ~•:U.ch ~he remainder of the ~aragr~ph appears to be conjecture.
T':1e:: sh.:uld be reinstat<:Jd.
Paije 63, pn.r. 2: Here ue hove~ classic example of hou the Corps of: Engineers is attempt-
ing to nega.tivaly in~lu·~nce our thinking ccncernin,. the merits of the coal alternative.
The IFii states: "~en ~rl-th pollution control. devices .. to restrict and/or renove harmrul sub-
.:;t·,nces1 the:M ~-rauld be some de~rad:ition of air q-~::UJ.ty f'rom combuotion products."
In the revised !FR, the Cor~ deletes the tenn "combustion products" in favor of. this i
u-.;ate::-vapor, carbon pa::-ticlc,s, sulfur compounds, and unburned gases ••• " ·,ffiAT 'dE A."'E HOST
CC~·.7CZ:U~ZD ::iiTH HZ:'..Z 15 :" 'JU'?!T~3 AT-:':l·!PT AT ER..;U}f}A.3:1TND, TH~ rll1ERICAN ?ZQPLE.
359
:'a:e 64,., I'~l·, 3: It. is s7_;:tted here th:at the co:Jl altemati·:e 1·Icu1.d :crovi::ie pouer equiv""
'll;mt .to ar.·· ot.;~.:r alternative. This state:nr>nt is false. The coal alte::'l1ati·re would in
f·~ct p-rovide 110,000,000 Kilo~1att Hocars l·f02.E fim •:mergy than the h·:dror.o;:er propeeal.
·1 r~f··r here· ':o .pa.'7e 8,9 of the revised Iil'r,""~:here it is also stated that i:he coal alt2r..
n'Jr,ive ~:ould :,ave a dep:-nda!libe capacit;r <Jf 106,-:::co :~no·•atts t·:ORE than ":.he hydro p:•oject.
It .i:.J also ::Iislsadin;:, on this p:1ge to say tlut tile coal alternatJ.ve meet::; the pro,jected
dem.:md until th"! 1990'3• It i::; in fact a virtuall:r unli:nited resource in compatison to
:,:~~ka•s nce1s, and cou:d keep·us .; ing f.~r 'rell over 1500 ~·
Parre 65: Concari.ng the figures .:·Mm the !"'R and the rev:i ~ed PR., it is infomative to
no·e that the .benefit to cost ratio ar.d net ;mnual benefits or the h;';dropover proj~ct
h:tve b~o:1n revised do~m;rard b:' about 25% in the six mont:1s th:J.t elaps~d bet·-:een these :
ro•o:·ts. Ej the ti~e the cost. of coping ··ri.th Alaska's adverse envi~ent is added to the
co:,:t:l, the i'i~res may Hell !'eflect a negative B/C ratio and no bene!i~s ;-rh8.tever.
F~e 78: Ho ··rhere here is mentioned the lo:;s of habitat to trmscission cu~·::5..dors.
::-urtln·nno. e, it i>l ,inane to .'>~:r that thes'3 reservoirs ;lill provide a contrib,Jtion to
·ra':.eri'ol·tl a:: a "resting area.". I sUf.>'~ose you 1dsh to imryly that ':he l)resent ;-raterfm:l
ore noH suff'.!ring •.rl.thout a maJ'imade ·•~resting B::-ea 11 ! 1'!1E LOSS OF 39,680 :~c:c::3 0? ClUTlCAL
C:l P?.::?:':"lc3J r~OC'>il: H a:o;:o ,T TO t:E-oz :r:;:::;:_;wcns IS F:\R.~::omiT.
Ur:der !'eC!'cstion, the te:nn "adverse effect" refer:-ing to the Devil Can:ron ;rh1 te;,ater ·shoc;ld
be revbl!d to l:'ead "total destruction".
?a~e fl9: ::ndcr NED benefits for t:1e coal alternative, it should be considered that :;hi;;
'1•1Uld ;,e a p::'ivate ··enterp"ise endeavor ,.1hich would contribute much to the rerp<O,tuation of·
om· free cnt"r::rs ::;:rstem. Th·3 figures could be arrived at, if on7one car~d to ::;ursue
'h.:.t Er.e or thi.nkinr!. The fi.~res .riven here 11:1der the Enviromnsntal (ualit;i 2'Uidiolines
::ti"'! iMccu~·at.(~, The:~ rtre in fact outright lies by the Corps ~f Zngim;ers. As ::;tated pre-
vi.T.:,J.:;r, tc1'3 r,ropo~ed d:r;s ~rould. destro:r foTever nearly 40,006 acres of cri t·'_cal or pre-
fer::-11d :1100'30 ;l3bit.:J.t. To CO!'I.pare the ~ deyc'":lCtion o+." 82 mile3 of a major n:ver lil.o;e
-!le 3•.Jsi':::'l'l to the l'ltpor de~r~.rbtion of 110-120 miles ef le::ser rivc;rs is a di.Jtortion
Hhi.ch is injics.ti 'lr:i of Crimi:1al i!' lent by its ferpetrator, the U o ':;, .'crm;:i ::i'Jgi.n.,.ers o
In closing, I a."!! compelled·to say that it becomes extremely difficult to maintain rc-
~c:ect !or one• ~.~ · ;:rovernmr>nt 1-1hen againest all reason and CO!!I!llon sensA that goverr.rnent
attertpts to burden its peoFle ;rith an unneeded and un'-~anted colossus· such as th'.s h:rdro•
P.leetric project,
..\.''ld ~·,hen, <:r.s in this caae, that government at~empts to influence opininn by putting
forth ll\i!1lealiing and distorted facts, it is time f'or those people to revalu~.te their
priorites and redirect the course of their lives, A redress is in order, and shall be
forthcoming.
CC: District Engineer, Anchorage
Di•rision All,'!':i.]J,.eer, ?ortla"ld, Crf'gon i:'residt'm~~ftey-Carter, ,.,..., · _* P.Lro. ... s, C.~o.G ,A.
Gov'omor Jay Haml!lond, Juneau
"'(mater Ted s+:cv~ns, rTashir:.g+,on
~.en;.tor Eike Gr~vel, ·.-Iashington
P.eprc•sent1.t:i. ve Don ·,·ounr.;, >i'azhington
CHA•I'""'IO) Rll'\8-.uo, f~Etuscuy~ Cli.<ih ~"~~.,. .. ~
$~~&.'1.. bi:SI&N«te C'-~t&.. IWb.ot\0~> US'l>t, WA$1\III)e,"I"G~
360
336
337
338
339
RESPONSE TO COMMENTS BY
THOMAS TAGGART
The responses which follow are directed to the numbered comments
beginning on page 2 of Mr. Taggart's letter of 19 December 1976.
Comments previous to these reflect Mr. Taggart Is persona 1 views
of the Corps of Engineers and do not specifically address the EIS;
therefore, no response is deemed necessary or appropriate ..
(1) At the present time metric figures are not well understood by
most of the reviewers. The intent of this EIS is to present infor-
mation concisely and in nontechnical terms so that it can be easily
read and understood by the reviewing public.
(2) The FEIS will be brought to the public's attention in accord-
ance with official directives and guidelines, including those'.of
the Council on Environmental Quality. There has never been any
monetary charge for an EIS prepared by the Alaska District, nor
will there be in the future. Nevertheless, reproduction costs for
these documents are high and are included as part of finite funding
appropriated by the Congress for report preparation and dissem-
ination. It does not appear reasonable to furnish copies to librar-
ies in all other states when it is not known whether or not they
are desired or whether they will even be utilized. EIS copies are
furnished to everyone who has expressed a prior wish to receive
them. Extra copies are printed to fill anticipated additional
requests. No one has been denied access to an EIS who has expressed
an interest to review one.
(3) In coordinating an EIS, the Corps provides the Department of
Interior with sufficient copies for distribution to all of the
interna 1 agencies or bureaus within the department. The Bureau
of Mines is one of these agencies. As a result of the department's
internal distribution, a total of seven agencies responded with com-
ments on the EIS (see pages 124-165, FEIS). As no comments were
received from the Bureau of Mines, it is assumed they had no com-
ments on the EIS. However, the U. S. Geological Survey did provide
comments (see pages 137-140, FEIS). Mineral resources, as well as
all other applicable physical, biological, economic, social, and
technical aspects of the project will be thoroughly investigated,
inventoried, and evaluated prior to any recommendation for con-
struction of the project.
(4) The "facts" concerning moose habitat remain to be determined.
Studies currently underway and which are proposed to be continued
for several more years by the U. S. Fish & Wildlife Service will
361
----------------------,-------------~---------------r------~------------~
determine the amounts, locations, and criticality of moose habitat.
Such adjectives as "good" or "critical" have little meaning during
the feas·ibility stage of a study prior to the completion of the
intensive studies required to determine the precise value of a known
res,ource.
340 (5) Increased turbidity, which is expected to occur downstream
from the project during the winter months, is discussed in the
RDEIS as an unavoidable adverse impact, the significance of which
is not wholly known at this time. At present, there is a very
high summer sediment load due to glacial outwash and a very low
winter sediment load. With construction of the reservoirs, there
is expected to be a low year-round sediment load consisting only
of the very fine 11 glacial flour" which will remain in suspension.
The post-project, downstream sediment load is estimated to approximate
concentrations found below glacier-fed natural lakes in Alaska.
Future hydro 1 og i ca 1 and bi o 1 og i ca 1 studies wi 11 further refine
these estimates and evaluate the· environmental impacts.
In the Interim Feasibility Report, the probability of increased
turbidity due to the introduction of sediments into the streams
and rivers in the vicinity of coal mining activities is discussed
as an adverse environmental impact which must be addressed in the
consideration of the coal alternatives. Environmental impacts were
not the sole basis for the rejection of the coal alternative. Eco-
nomic factors played a large role in this determination.
341 (6) As stated in section 4.03 of the RDEIS, Watana Reservoir would
lie across one of the intermittent seasonal caribou migration routes
between the main calving area and some summer range of the Nelchina
caribou herd~ It is not known what barrier the reservoir will pre-
sent in place of the turbulent river. Also the migration patterns
for this herd are continually changing. Therefore, we think the
choice of the phrase 11 possible inhibition of movement of caribou"
is appropriate--at least until detailed studies of caribou move-
ments are completed during the preconstruction planning phase.
342 (7) This is a rhetorical question the answer to which is beyond
the scope of this EIS. See response number 362 for further comment.
343 (8) The referenced phrase has been deleted from the FEIS. In
studies mandated by congressional resolutions, it is assumed that
the resolutions were initiated at the request of local constitu-
ents. Since the Senate Public Works Committee Resolution. which
is quoted in its entirety in section 1.01, does not identify the
basis for this resolution, further speculation will be omitted from
this EIS.
358 (23) See above response.
~59 ( ) ..., 24 Accardi ng to the October 1975 fish & Wildlife Service report
on the Upp~r Susitna River Basin, the most prob~ble reason that
salmon are unable to ascend Devil Canyon is .11 a hydraulic block
resulting from high water velocities for several rtver mileswithin
Devi 1 Danyon." . The only way that man caul d assist the salmon past
this block is to provide alternate transportation means~ such as
capturing and trucking spawning adults around the canyon or con-
structing a fish passage facility similar to that found on the
Frazer River in British Columbia. Since no such plans exist for the
foreseeable future~ we think that the statement 11 unable to ascend 11
is an accurate description of conditions for salmon in relation
to Devil Canyon.
360 (25) Comment noted.
361 (26) The growth of Anchorage and Fairbanks since 1973 has been
· 1 argely due to activity associated with TAPS. The Anchorage Busi-
ness Index, tabulated below~ indicates the general level of eco-
nomic activity in Anchorage since 1970.
YEAR INDEX RATE OF INCREASE
1970 100
1971 104.3 4.3%
1972 108.1 3.6
1973 114.9 6.3
1974 139.8 21 .7
1975 169.9 21.5
1976 172.7 1.7
Source: Mr. Bob Richards, Alaska Pacific Bank
There was about a five-fold increase in the rate of economic growth
during the pipeline years over the underlying growth rate. of about
4 percent. Postpipeline uncertainties and out-migration of workers
resulted in a less than normal expansion in 1976.
Alaska population and ~conomic growth in the future depends primarily
on development of the State's petroleum reserves, State fiscal policy,
and the growth of other basic industries. Growth will not stop with
the completion of the pipeline. Rather, completion of the pipeline
allows the State to begin collecting large oil revenues that will be
a key determinant in continued economic expansi~n, but at a lesser
rate than experienced at the peak of the pipeline construction
activity.
365
362 (27) Reduced comsumption is one of the various approaches to the
country's energy problem as demonstrated by president Carter's
energy proposal. However, it is not anticipated that reduced con-
sumption will be the complete solution. Therefore, the development
and utilization of renewable resources will become increasingly
important in the future. Implementation of an energy consumption
reduction program is beyond the authority of this agency. Also
an' indepth analysts of this matter is beyond the scope of this
EfS and would be speculative in nature at this time. .
363 (2'8) The referenced paragraph has been corrected to reflect the
true length of the Seward Highway.
36!4 (09) Contrary to the expressed opinion that the referenced sentence
is 11 not relevant and should be deleted from the FEIS,11 the present
use of all-terrain vehicles and the potential for their increased
use resulting from the project is an area of major concern to the
Alaska Department of Fish and Game. They have requested that sec-
ondary impacts related to increased accessibility resulting from
the project be the subject of intensive study and .evaluation during
the preconstruction study phase. Furthermore, the referenced sen-
tence discusses all-terrain vehicles with the intention of point,..
ing out their potential adverse impact on game herds.
365 (30) As discussed in response number 340, the estimates of sus-
pended sediment are based on concentrations found in rivers below
glacier-fed natural lakes in Alaska. Additional hydrological studies
are required to adequately address the question of postproject sus-
p;ended sediment levels. Studies to be made during phase I of the
General Design Memorandum will assess this problem and possible
effects on the biota of the river. The EIS will subsequently be
s,upplemented as appropriate to discuss any impact in detail.
366 (Jl) See Response Number 339.
' 367 (3Z) Any project-related recreational development program would
involve cooperation between the appropriate Federal, State, and
local interests for sponsorship, cost sharing and maintenance of
r~creational facilities. Proposed recreational facilities for the
project area include visitor centers, campgrounds, picnic areas,
trail systems, and boat launches. Therefore, recreational potential
would exist for day-use activities, camping, hiking, and boat·ing
besides hunting and fishing in the area.
36 9. (" ) .... ,33 See Response Number 339.
369 (:34) Paragraph 10 of section .4.03 of the REIS is not deleted in
the Revised Interim Feasi·bi.lity Report (l June 1976). The same
paragraph appears as the second paragraph of page 72 of the RIFR.
366
370
371
372
373
374
(35) See Response Number 356.
(36) The 11 roads" in question will be the minimum nec:essa,ry to allow
men (to cut the plants) and vehicles (to h~ul'the cut material to a
burning or other disposal site). They will, to the greatest extent
possible, be within the impoundment area of the res'ervoirs. Where
this is possible, they will be in existence only until covered by
the reservoir and, thus, wi'll requtre no remov~l. Where this is. not
possible, the roads will be temporary in the sense that they will
not be maintained once cleari'ng is accomplished. At a minimum, unflooded
sections of the roads will be rendered unusable and allowed to revege-
tate naturally. Complete "removal'' of such roacls would require regrad-
ing, plowing and planting to promote revegeta.ti'on. Many areas ofthe
reservoir walls would not be cleared by use of roads; they are too
precipitous and helicopter access, both for personnel and debris
removal, would be the only practi'ca1 a~proach,
(37) The commercial potential has not been quantified, but, from
observation of the types and sizes of trees founo in the reservoir
area (as differentiated from those on more nearly level surrounding
lands), the value 1s considered mini'mal. A more explicit inventory
will be achieved during pre-constructi'on investigations, both from
the viewpoint of commercial value and from their value as wildlife
habitat.
(38) According to the American Heritage Dictionary, 1976 New College
Edition, the definition of a stream is "a body of nmning water,
especially, such as a brook, rivulet, or river." Thus, the Susitna
River may correctly be termed a stream in the broad sense of the
word and the use of this word is not an attempt to play down the
significance of a mighty river. Whether the reduction of the heavy
sediment loads of the summer is an adverse effect or not is still
open to question: Future detailed environmental studies will decide
what effects this reduction will have on such processes as nutrient
transport.
(39) The Corps recognizes the value of Devil Canyon in its present
state. The recreational and/or esthetical value is discussed. in
more detail in the sections of the RDEIS titled "River Character:-
istics," "Recreation," and "Esthetics." The sentence referred to
on page 67 simply lists the inundation of the rtver as an adverse
environmental effect of the project whjch cannot be avoided with
construction of the project.
375 (40) See Comment Number 339.
367
376 (41) The referenced sentence has been modified to indicate that
some adverse effects would result to resident fi~h populations,
particularly in Watana Reservoir.
377 (42) · We concur .. The parqgraph has been modified to delete refer-
ences to beneficial effects.
378 (43) Yes. "Political'' feasibility is that which can reasonably be
achieved within the social (political] framework of the time anc!
place in question. It is usually narr'ower in scope than "economic"
feasibility which depends (in our social system) on the net profit-
loss parameter and is in turn narrower than "technical" feasibility
which is that which can (or could) Qe accomplished with present
technology without regard to ei'ther economic or political restraints.
Thus! political feasibility usually represents a compromise among
the many and varied views and goalS o( the public. .
379 (44) The alternative of no action wtll be one of several alterna-
ives that will be examined in more detail. during the preconstruc-
tion studies. As these investigations proceed, supplements to this
FEIS will be prepared and coordinated as appropriate.
380 (45) We concur. The sentence has been deleted.
331 (46) The economic life of the proposed hydropower project is 100
years. In actuality, the project may function effectively for as long
as 500 years. Dependingon the depth of coal veins which would be
strip-mined as an alternative source of energy, the damage to sur-
face areas could be in excess of that of the reservoir impoundment
areas. There are also enormous costs and technical problems associ-
ated with restoration of mtned areas and the preventton of erosion ·
and po1lution, especially in the fragi'le environment of Interior and
Southcentral Alaska. At present, there has been no large-scale attempt
at revegetation of highly disturbed soils under the severe climatic
conditions found here, and the feasibtl ity of such an undertaking
is not completely known at this time. During detailed stl.ldies which
wfl 1 be conducted prior to a decision by Congress as to whether or
not to authorize project construction, the comparison of these two
alternatives will be more thoroughly assessed and evaluated as to
what the trade-offs actually would be.
382 (47) Although the recreational and flood control elements of the
project constitute a minor portion of the total project costs and
benefits, these are benefits that would not be obtained with the
coal alternative.
383 (48) We have no statistics on the number of existing 500 and/or
100 year-old dams. Since technology has changed vastly in 500
368
(or even 100) years, the existence of such structures would have
little bearing on the life of the proposed structures, except to
stress that if such outmoded techniques and materials could survive
such a time, modern methods and materials could·be expected to do
even better. There are, however quite a few historic buildings
using portland cement concrete (usually as a mortar but sometimes
as slabs or mass elements) that date well in excess of TOO years
and even 500 years.
384 (49) The statement is factual as written. The poll has not been
nor wil1 it be used to justify any future action. It merely repre-
sents the expressed views of people attending the meeting.
335 (50) We agree that the creation of mudflats in Watana Reservoir
during periods of low river flows should be discussed in this sec-
tion. This omission has been corrected in section 5.0 of the FEIS.
Further comments beginning on page 6 of Mr. Taggart's letter of
19 December 1976 pertain only to the Interim FeasibilitY Report.
Thus~ no response is considered appropriate in the FEIS. Mr. Taggart's
letter of 9 March 1976, which also refers to the Interim Feasibility
Report, was inclosed with his comments on the RDEIS and has been
included here. Also included is the letter of response from the
Corps to his letter.
369
C l~.J.!. :-::1.an .
·Eo:?:C. o.f ::n::!n>~!'S for .?.i•··;rs and Ha::-.Jors
K:!.n~'l :,'uib.:.:::;
Fort :.ldvoir, '/.!.r::.nia 22:'~'0
1'hop'las T:l.~(:a:-t it-. . .:U iJo:.: 1 1 ;;
s~~rd, Alask~ 99664
9 Hareh~ 1976
RZ: :~;: .:::rr:; :: .::.t.;:::?I.LITl ;t~i'O :n' Oil 'l'!i:.:: U:?? .~R. Si;SI'l'::A. !UV.i:~t BASI:-!, !tL.U;'-:\
A COP:i of t..'<tis stud7 in four vol·..::.es ancl including the Jones i'.: Jones accr~ational J.e;>ort
~:.3.:; !':;!C.;.!::cd bj· :Oh~ .3e~:ard ?,folic Librar:.r on ?ricia.y, 5 Harch, 19763 .rlrich gave the people of
s0·;;c-::1 app:-o:d.~!!t':!l:r th:-ee (3) da;:rs to :-evie1·1 it and Sllbr.'lit coments by the de.ad!ir:.e of 10 i-!a.rch.
4i'lo !"epo:."T. hi-d ooen x'eqt:ested appro):::L-;atelJ one nonth ago, ::hi.cil. ·.lould have ~o:-red a fairly
~.a;;.;>:'.a:~1e '.:.':.::.e fo:· tne :r.-..:'olic to ravie·.r it had it b:::cn delivered e:>.."PedientJ.:r. I 1wuld like
to ".~:c: t:li.:J oppo!"";.u;:.! ty -..o conrrra~ulate the Army Corps of Engineers on its excell·~nt ti:.":'.ing
ir. :~':.tinfi t:~:Ls ::-cpo:-t int.v ~:,e hnn-Js or.~ t:1e people ~rho Hl.ll be directly affected by the ;;.::-oposed
~rojcct. It i3 ~· estimation that the Corps '11;estionablo methods of disseminating i..n..for:':!.atio.."1
t l ~i'le public ::Juld best 'be d~i'ined as Bo::-dering On Criminality And l~ot Servin§." ?ie i:;zt.icn:U
Ir:. .. e;:-~ast. i-iay I ask tho.t s~ch future pertinent ini'orma.tion be given freely, cpen.l7 ar.C. Jo:.·o;;sly
t.;, t:1~ puo!ic lior!ries of t':ose coo.;'lu::U.ties ..rhera the proposal(s) >-::!.11 have g:-eat e!'!ect upon·
'ci'lJ p.J;:n;ls.c.:. r i"urt!ler:~o~·e ask that :;,is 1-Jtte::-in its entirety be incorporated into a.."!T .Cuture
.:;t•.1c:~ o:• in)::..c·~ statement re<;2.:'ding ti".is project.
I ;'l.a'lf hi-d t~.:-c9 to c::-:.3.:'1;,-re·.rie~-r the five vo1u:1es, a.nrl I ~·r::>uld at t:U.s ti::;e like to co:-::;:cnt
'Jr:.:'!"' tl':·Jr.~. ::: <!..., ·oas~cal:'.~-in opposition to the proposed pro,ject because of three reasons •,;hich
I ~::..ll h~rc el.~.:.:~te u·:_:,on:
( 1) TC.c p.::-o2 set ~·1ill i:-:-eV·3rsibly alter a relatively pristine area of Alas:;:a.
( <:) There is at least one na.ble alternative to the project \-rhich seems to have more rne:i::i.t. ••
(3) Tho c'~·t~s of Engim~crs has bet!n less tho.n candid and perhaps overtly deceitful in pra-
sn.ntinc its cas~, 1·thich leads one to believe that the project itsall may not. be !'casible or de-
siraole fron \•orio:::; standp:lints.
::'irstl;: I ~r:.l~ touch upon ~·lhat I perceive as the rnajor environ.,ncntal i.Rpacts. On the is~uc
of: r:oo:;;c ha'oh;.t, I h.:!ro ~uote !'rom the ::1ain report, page 71: 11 ••• it is e~tir.".ri.":.ed that 2000 to
.)-.:·::j :1c:-es, nr:~t.l.;" in ~-Tatan:t Cr3e!<, c'"~1:d be favorable moose habitat .. •'' T.h:.s st::.te.:'\;Jnt by-the
:;~):-:-.:: is quite :-.U1id in c::':l?a!"ison :n tn tnc follo•,rin;;; ~tatcncnt i':-om t!lc letter of the L"3?a\•IS
r;u:-~!.::;h~d in Ap:H::iix 2, ;:a.~e 22: '' ... :lss~rvoirs 1·ri.ll inundo.te rnoo:Je habitat ccn.:;isting of •••
2i,120 acres of habitat·.:~:::::-: receives mod:1ra.te u~e, and 18,560 acres or habitat ~-;'nich receives
hc&·rJ llSe. 'O'he ~od.ero.tc c:r.ci hcav:r use a:-cas arc considered preferred or critic~ •·'inter ~<r..bitat."
Ccr.:.d the Cor:;s :~'!·Ia pos::;ible l<J~·t t~~!le facts out of the main report by ove::-sight? It doG::. not
r.·~:.": l.i.::eq f:-v~ ~;;'l.:!rc I .:;it. Anyone living in .U:J.:;!<a :1t this t:lr.;.e could .:1ot :1ol'> but be a·,ra:-c
~:::.~ t!'.r.l r.l.OOSC '.'0;:-.:l:t.:.o;·, .!..;; ·.m tho ~13.!'10 1 ond by flooding .39 1 ~80 acres or critical M.d./or 9!'C-
:v~·:.-cd rnoo:;a h-:bi -:.:..t. t:lc Co:;::s :·till in tact be contributing to \:h:::Lt cvuld be the pr:rr.me!nt dc;:rl.:c
o;' 't::e .U~s::a."l ~oose as -..:e n':·r ~::no;r it, Does th'il Gor?S care?
. r::e propoJ'!d da.-::s ~dll ha'IO an adverse effect upon caribou, ~. a."ld tr.e endangered
Fc::-~-"::"ir.'J ~alc.:>:1, to ~:it: :'he ni;::::o:;"t.'..on route of ths g:::ocn.tl:V Cli."'ir.ished (90;~) :ielchina Caribou
:!•1:".::_ :-;.!.:.:.. ue :'r-.;ot,rateci l:T the :)rOpoJcd W:~.tana ae:HlJ:-voir. Cn pa<jCS 206-207 of the-SU?ple.r.lental.,
~f='r,.;:; ·, J'J:'.')S ~:'.lc::-c1.tional 'l.eport it :.: J:oavil;r e~'1!);1a;;ized that the iv"atana Rcs~rvoir could have
11 1:"::::.-a ·:!.·J.to -'·"·.:. S'.l'l'~ro" i:-:;:;act on th.i.:; i1c::-d. ( 2) '!'he ondanzarcd peregrine f.Jl.con !l:ls at least.
tf~: .. C'3 ~J."·.·::J.ti~::. :-~~.:t· .. 'J t~u .. ~·Y.: ·<'1 tli.O .'J~L;: .. :na. t-i'.:L.,," 1r 1la,·;.ley. l~:t.zo 72 oi thO main ~cport. :itat.·cs that.
n;::.-':"·c~il~: ':lil•::i::. ~;:r;lci. !JO;z:.'.:l:r su·:·J.··::!" ::o:-,e rto1•tali":.y :~·om collision::; ~rith to~-:~:::-.5 or T~.r~:;s_ ••• "
t;o:; :-..:...,:.· lo:,.:;•:'J c .. ::. this :J:<:l.J.l'l":':)reci s:;e('"...}:::; :.;u:;tain? {3) Concarn'.ag t.h.o S:.;sitna PJ.v~r s",l.-:ton
;,;:-.:;, h.;:·o :J :~:.:. :;'Jc":.e t:Hl :;,j?~:·r• l"'t':.'3!' in .:'-!'/':lciix 2: "The potential loss to th~ ecor.o -:-.• o?
.1e·c:-::.c ·nt:::-3.1 .• :.'l.=':a thr::•J-"?: c:.:1::tr-Jction a: ~h::.s :)r ·:-Jet cou!l1be nor..-.-t.~me::; ~:-aat'drt.~:~ .. "l th-; -
0::::::l:'r)-:Ji.'r~~·3lll.Ct<J-::. 0:1 ;,,:'-~S 10 O.."l01T:'i' TIV·• e i'i~ are~9l.l. :ail.d _.._3.~2 r..il!IOnS.
.t :~.~un ~lu "v: _,.:; t.he Corps c~ra?u-- -
371
. 'a.ze 2
•::ld ·P'tcl~Oi.lOd i»''il C:l:O~··on c )! llil:L ,·n:nanently ..::!.:i.ninate 9/"'""''.los or the 11 r..iles oi' ~::uto;~
~ra~cr ·.1!-~,ch r:::;::i.St-s th .. ,~. It, ~:~Ould be nd~·-Jd. tnat th:! .. a ~articular stretch oi 1-:hl.te"":~"ater i:i t!'"~t
~~~:...:::1 :!r.S7lir~d incluJlon oi t=-:e S'1si t::.a ?'.!. ver in 82910 and i~11J564 as a :·lild liV3!" under tne
.Uas!<~ :;ativa Cl:o..L-w 3ettla::J~nt Ac:.. ii!:J.,;d.l·::lSS to sDy, ti1.!.G is one of the mo.:;t unique stretches
o::: wat·~r ;,;i~ich Go.:! has 7rnnted us on t=-:is e.J::-th. In no less than five (5) insta.'"':.ces' (pages (3, ··
139, 130-,1.'11, 1;1'1, 2W) t::e Jones C. Jo::es :tecr!'lational ?.eport cites the bporta:tce of the recre-
ational and aest:.etic value of Devil Ca."lyon in its primitive state. The river :!.tseli" is cicscribeci
.:1.:: "T!1s Ho\:nt i!:v~'!'est of lca~,-a..\"ing" on ~age 181. On pa~es 8 !:210 tha :;-cport suG'sests r.aving the
lo::'3r dam. C:'!ti:-ely out of' Devil Can~·on to prcse!"Ved the high qualit;r or the a:-~as "aesthetic and
rec:-eat1on3l vahe and Its uniq~enesS"""in the rogional. context ... n Is the Corps capable or list.-
enin; to .it.s m:n contra.::ted ad'lisors?
There does se81!1 to be other valid reasons to abort this project. Altho,lgil the Co~s esti-
:".at .. oll the proje!C::'~> cc:at to be a"?:'Oxilr.a.tely C1.5 billion, there are quite a feo;~ peo!Jle in high
places t·lho disa;p."!!i#. Among tilm:~ is U .3. Senator Ted Stevens o£ Alaska who concludes that the .
cost ~dll be .ll:t; l,jast $2.5' to :~3.0 billions. It those latter figures aro more nearly :u:curate,
·,:.!\en ~l:e pr':lj'3ct is not ccono;-.icall.T .feasible.
The I.a.hr-r\a.chadoorian •·e~ort (.~P?• i, exhibit D-2) s::~:rs that. 11 it is p:-efarnble to place tl:e
.:::zns a-.rq ir<..""lt f':rulteci and joi:lted areas." Ueve:rt.hcless, the tvat.ana. Dam as proposed Will be onl;J
·~niles Aast of the Susitna Fault. Has the Corps considered that the1.-e ::..re i:l t..'>a neighborhcc;.
c;: t~~eJ.:;e ( 12) co::r::-.Jr.ites d.:r.mst::."eam fro;;1. Devil Canyon Hhich could be imperiled by a precipit()us
'5~s:::ic rald3d disaster? The-nEf!·r state capital is lil~e1nse projected to be built near tne banks
cf ~t.e. lo:-;er 3us!. "t:'la ;:c. ver.
It is concluded on p~e 49 o:' tne ~n report that coal is na technically feasible a:ld eco-
n·:.:-::..call.,'( 'liJ.~l.:: >l.ltel"':lati::a ••• u to the l'wdropo·.rer p::-oposal. There are mtm:r facts andfig-.;:::-es
~·;a'.ch suppo::-t the i'easioility o:' utiliz.in~ coal at this time for ..Uaska1 s needs.. It is consena-
~iveJ.:r esti:'1ated that a m:inL=n of 9.3 oillion tons of coal exist in the c:or.:bined Nenana-Beluga
tields. Yt:tJr rcr.ort states tiiat this coal is of low-sulphur content .which is environmentaJ.l;r
aceopt.able. The repo:-t estimates that 5.63-5.85 million tons l-rould be consumed annua.lly-c:;r .
. U.a:~ka. D;,-d i.vicling 9 • .3 billion tons by the c::;ti•n~ted annual consumption ~;e come up td th enough
c~31 to r~up;JJ..I ;J.aska 1 s nec,ds for appro:d.mttely 1600 years o.t the current rate or con:ru:nption.
EVen if 95;~ of this coal ·,;.:;.:;; shipped outside o;: tile ::;tate, there 1-rould still be enouch left to
_ta.<e ca.rs of' Al.aska's needs for 80 years. F'Jrthormore, the tl>To fields are relatively close to·
tha =".ajO:t ~o;:-.:l:l.tion centers Hh:ich \-toJ4j.ci need th~m, t!:ms eliminating the need for gangling tra.ns-
:::.igsion l:!.ns:: · e::.."tending all over the interior. '£il;'lse coal fields t-rould. ere;; ·~ r.JiJiiT;I more-pe.rr.lanen't
jobs for Ala.;kans than would t:·:e proposed hydropower project ~thich could onzy employ 45 ;.;orkers.
It seems that tile strategic location of ~hese coal fields and their nagnitude indicate. that coal.
is indeed .th:e :ncre sensible tiay of gene:::-a.ting po;;er for .Uasl:a during the next t:eu decades, or-
until tecr.noL;iiCal adva."l.ces allow us to utilize Solar, G3other;:tal, Hind and Tidal resources.
Concerr.ing the environ.-:-:ental impact of coal, it is stated on page 62 of' the Milt re;:ort tl-.at
~p:.-ro:d.r'ra.tel:r 18 1 300 acres of land would be st:ip !llined over nthe 100 year life11 o:t the Healy
project. Hot-tever, on page 89 the retJort contradicts itself by Ga.ying that the Heal:r project is.
estimated at 35 ;-,•oars, 1-hlch, ii' true, wo;.Jld rt:!d'JCe the iinpacted acrea;;e b;r 65%. It should be
emphasized tha·t these 6400 acre:> t-thich •rould be stripped a::-e far less tha."l the 6o,OOO acres t.:hich
~dll be in"n:iatad a."ld/Or clea.::-c:,~t for t~e proposed :-ese:rvoirs and tro.nsr:lission corridors. Fur-
th·Jmcre, ,the Heal7 area is not eor.sidered as critical habitat :for al1,Y >dldli.f'e species as is
the vast maj,~tj" of .acreage 'lrh.'..ch 1;ill be inundated by the :;rat::ma. ~eservoir. .
In su>-:-.~r.r, :!.t i.J a?:;arent t:"la.t t::-,e 1-!~aJ.::; and Beluga coali'ields s~culd be utili.zed. to the
.Jxten t ttat t;1'3J are r.·~,~::.;;::t to -:'ul.til.:. A2.as:Ca' s on!'.!::"@'"J requirenents. It Hould :U.so be ;.rise to
conduct th~ tn;Jch r.eedeci rcse:J.rch :.nto h3:usss1ng 'the )0 foot tides of Cook Inlet. £or Gervi..>tg the
needs of ,\fl.:::;o:ra.::;e -and t.i~e ne:·r capital.
e-••••• Dj.,striet ~;ineer, .. illcho:-a.s:e
Divi~i:m E:'lgineer, Portland, Ore.
!i?nor.liJle Ja:~ s. Hill':'t'>ond, Juneau
iio.1orz;.;,le !·11.~e Gravel, ;·:ashin;:;ton, J.C.
Hono::-:l.cle 7ed Steven:::, :·la::o:tin~on, D.:::.
:::rJ.1J;:o;Jle ;:Jon ald. ::. !oung, '<lashi::;;ton, D.C.
372
NPAEN-PR-R
Mr. Thomas Taggart
General Delivery
Seward, Alaska 99664
Dear Mr. Taggart:
20 April 1976
I am writing in response to your 9 March 1976 letter to the Board of
Engineers for Rivers and Harbors concerning the Upper Susitna River
Basin report which was prepared by this office.
First, let me apologize for the lateness of the report reaching the
Seward Library. This was not intentional nor was there any desire to
deny the public full opportunity to review and comment on the matter.
Rather, it \'/as a result of our underestimation of the public desire to
be informed which caused us to print and assemble fewer of the rather
massive reports than proved to be necessary to meet the public demand.
About 200 copies of the report have been distributed when normally, a
demand of half that would put a report on our 11 best seller 11 list. In
general, we have made a concerted effort throughout the past two years
to foster widespread public participation in all phases of the study and
not just in the review of the end result. This is both a Corps policy
and plain common sense, inasmuch as our studies are designed to meet
public needs and desires by the possible expenditure of public funds to
accomplish actions which the public will have to live with for many
years to c orne .
As to your specific comments on the report and related documents, I
provide the following replies:
We are aware of the descrepancy between the acres of moose habitat which
will be lost as estimated by the Corps and by the U. S. Fish and Wildlife
Service (USF&WS). The acreages estimated by USF&WS reflect some obvious
errors. On page 13 of their report you will find a tabulation showing
that within the 7,550-acre Devil Canyon reservoir, USF&WS classifies
373
NPAEN-PR-R 20 Apri 1 1976
Mr. Thomas Taggart
7,040 acres as being 1 ightly used by moose and an .additional 5, 760 acres
as being moderately used. Unfortunately, we thus find the moose habitat
inundated by the reservoir is some 5,250 acres (69.5 percent) in excess
of the total acreage covered by the reservoir. Further, examination of
the topography and visual observation show that extremely steep canyon
sides. where it would be difficult for a moose to stand or walk and
where vegetation appears to be of a type not generally favorable as
moose forage, make up about one-half to two-thirds of all terrain which
would be inundated by the proposed pool. Again, this conflicts with the
cited moose habitat acreages. The figures for the Watana reservoir,
al thotJgh not summing to more than the total reservoir acres, are sim-
i 1 arly questionable when compared with the observable terrain ( spe-
cifically very steep canyon walls) and vegetation over much of. the
reservoir.
Regarding the effects of the proposed dams on caribou, salmon and the
peregrine falcon, I offer the general comment that we foresee the
possibility of adverse effects on the first two life forms but little
chance of ill effect on the falcon. The magnitude of the adverse impacts
on caribou and salmon cannot at this time be measured. However, the
information and data we were able to acquire indicates that the magni-
tude of adverse impacts to both caribou and salmon would most probably
be moderate and, in the case of salmon, subject to correction through
management and mitigation efforts. The Jones and Jones statement raises
valid questions which will be addressed in future studies. We cannot
prove that adverse effects mentioned in the report could not result from
the profect, but find little evidence that, in fact, they would. The
statement concerning migrating birds and their possible collisions with
the towers and lines was based on the large masses of waterfowl which
migrate through the Susitna-Nenana valleys. The falcon, one of the most
keen-sighted of all creatures, should have no trouble avoiding a struc-
ture which occupies a 200-foot wide strip through a valley a mile or
more in width. As to the USF&WS statement on the value of possible
salmon losses, again there is presently no supportive data to indicate
that salrnon, in the numbers implied by the dollar values, inhabit the
affected waters. Quite the contrary, based on the data produced to date
by Alaska Department of Fish and Game and USF&WS, it would be difficult
to assign a dollar value loss in the thousands of dollars, much less in
the·millions. The multmillion dollar figures, by the way, appear to be
based on total destruction of all salmon thought to originate anywhere
in the total Susitna River drainage, in no way consistent with any
foreseeable impacts of the proposed project.
The third major area which you addressed concerns the destruction of the
esthetic and recreational value of 9 miles of the Devil Canyon rapids.
374
NPAEN-PR-R 20 April 1976
Mr. Thomas Taggart
This is a matter which cannot be adequately analyzed from a purely
logical or numerical viewpoint in that it deals with the emotional
reactions of people to such matters as beauty and awesomeness, the
perceptions of which vary from person to person. We recognize the
unusual violence of these rapids and can understand how canoers and
kayakers who identify strongly with such creations of nature would
regard them as unique or "the Mount Everest of Kayaking." We also
realize that, of all the thousands of kayakers in the nation, only a
handful have, or will ever develop, the skill to actually run these
whitewaters. Thus, as a.recreational asset, Devil Canyon rapids is of
littl~ value to the general public or even to the vast majorityof
kayakers. From the standpoint of esthetics, few people have the means
to view the canyon since there is, without disturbing the land and
damagir)g other esthetic values by construction of many miles of roads,
no convahient way for the general public to come within miles of the
area. This is not to say that we regard the destruction of this white-
water resource as meaningless or inconsequential. The question of the
trade--off value between the rapids and electrical energy was one of the
greatest concerns throughout the study. We wish it were possible to
have both of them; however. our investigations have led us to conclude
that we can have only one and to further conclude that the best interest
of the majority of the public lies in producing the electrical energy at
the expense of sacrificing the esthetic value of the stretch of river.
If the project costs of $2.5 to $3.0 billion which you attribute to
Senator Stevens were in fact accurate, you would be correct in conclud-
ing that the project was not viable. The figure of $1.5 billion, and
awesome amount in itself, is our best professional estimate of the
present project cost. I stress "present" because continued inflation
and thus lessened purchasing value per dollar would in time lead to a
higher prbject cost just as deflation would tend to redu~e the cost.
Please recognize that whatever the general economic trend, the value of
the project output, electrical energy, would follow the same trend with
the probable result of little change in the benefit-to-cost ratio of the
project whatever the dollar cost of construction. This, of course, is a
very simplified economic projection which would be subject to many other
variables whH:h could affect project viability in either direction
We concur with the Lahr-Kachadoorian view that it is best not to build
dams on or near faults. It is unfortunately true, however, that most of
the better hydropower sites throughout the world are found in mountainous
areas which are in all probability the result of the same geologic
processes which also produce earthquakes and faulting. Thus, it is
rarely possible to have the 11 best,11 in which case the engineer is left
with the second choice which is to design his dams to withstand the
375
NPAEN-PR-R
Mr. Thomas
20 April 1976
unavoidable earthquake forces. Such is the case for this project. We
have indeed considered the threat to downstream communities and, as have
most of the numerous dam projects along the western coast of North
America, are designing to preclude a disastrous dam failure. The cnmment
on the location of the new State capitol is difficult to address inasmuch
as no firm siting has been made. However, it-does point up one thing
which should be carefully considered in the choice and development of
the capitol site, that is, 1 ocating the city outside of known or projected
flood hazard zones. We concur that coal powered generation is technically
and economically feasible and that much future use of this resource can
and probably will be made. The numerica 1 analysis you have performed is
oversimplified but probably reflects an adequate genera 1 picture as
relates to many centuries of supply (at present use rates) being avail-
able. Please recognize that the cost of mining this coal will vary
greatly s i nee it 1 ies at depths up to 3000 feet bel ow the surface.
Also, please note that even with the most economical mining technique at
relatively shallow depths (not to exceed 200 feet) that electrical
energy would cost about one and one-half times as much to produce from a
coal..,.fired plant as form the proposed hydroelectric dams. This is why
we consider the hydro plant as economically superior in this case.
Coal, to us, is a very sensible way of generating much of the future
Alaskan demand. The proposed project, at this time and for the project-
ed near future. demands, is even more sensible.
The 11 project life 11 is 100 years for both coal and hycropower to make
economic comparison of the two quite different systems valid. The
actual physical life of the coal plant would be more nearly 35 years
which means in effect that the coal plant would have to be rebuilt twice
before the initial hydropower plant wore out. Because 100 years is the
comparison period, the full 18,000 acres {at a minimum) would have to be
mined. Furthernore, the Healy area, as stated, is heavily utilized by
both moose and caribou, much of it for winter range which means that in
all probability there would be more critical habitat contained in the
50,000 (not 60,000) acres of the reservoirs. I concur that future use of
Healy and Beluga coals should be utilized as practible to meet a sub-
stantial portion of the Alaskan energy demands; but not to the exclu-
sion of better alternatives where such exist. I also concur that re-
search might eventually allow beneficial harnessing of the Cook Inlet
tides but must honestly state that I do not foresee this occurring
in what remains of this century.
It is clearly stated in the Draft Envi ronmenta 1 Impact Statement, which
was prepared for this project in September 1975, that since the current
study is in the feasibility stage, impacts are not exhaustively evaluated.
376
NPAEN-PR-R 20 April 1976
Mr. Thomas Taggart
It is made clear that if the project is authorized and funded for
detailed studies, environmental~ social, economic and engineering
aspects of the project will be studied at length prior to a recom-
mendation to Congress for advancement to final project design and
construction. Indeed, the State of Alaska has conditioned its endorse-
ment of the project with the stipulation that these types of studies
be made. Fish and wildlife studies alone are estimated by the State
to require 5 years for canpletion at an estimated cost in excess of
$4 million. The Corps is in general agreement with these study
proposals inthe event the project is authorized.
For addtional information which was not included in the 4-volume
Interim Feasib.il ity Report, I am inclosing a· copy of the Draft
Environmental Impact Statement. We have added your name to our
mailing list, and will furnish you a copy of the final Environmental '·
Impact Statement when it becomes available.
l Incl
As stated.
Sincerely yours,
S/ JOSEPH W. HURST
LT Colonel. Corps of Engineers
Acting, District Engineer
377
DAEN.:.BR
Mr. Thomas Taggart
Postal Box 1195
Seward, Alaska 99664
Dear Mr. Taggart:
18 March 1976
This is in response to your 9 March 1976 letter of comment on the .
Interim Feasibility Report on Upper Susitna River Basin, Alaska, whi.ch
arrived just after I had sent you IT\Y 15 March letter.
I can certainly. understand your frustration in trying to review a report
which was not easily available. However, I wish to assure you that it
is th·e policy of the Corps of Engineers to provide adequate, timely
information to facilitate public comment on planning reports. I think
the actions described in my letter of 15 March may have already convinced
you of this. I realize that you have not had sufficient time to tho-
roughly review the report, therefore, I am further extending the time
withinwhich the Board will receive comments to 15 April 1976 ..
The comments you have already provided, and any additional corrnnents
which you may provide within the extended time period wi 11 be carefully
considered by the Board before formulating its recommendation to the
Chief of Engineers.
Your interest in this matter is appreciated.
Sincerely yours,
s/ROBERT L. BANGERT
378
Colonel, Corps of Engineers
Resident Member
.~.
DAEN-BR
Mr. Thomas Taggart
General Delivery
Seward, Alaska 99664
Dear Mr. Taggart~
15 MAR 1976
This is in response to your ietter of 5 March 1976, concerning the
Interim Feasibility Report on Upper Susitna River Basin, Alaska.
I am very sorry that there has been a delay in making the Feasibility
Report available for your review. My staff has informed me that
copies of the report were mailed to public libraries in cities of
the Railbelt Area on 1 March 1976, and s~ould have been received at
Seward by 5 March 1976. Although the report is most certainly at
the Seward Public Library now, the Alaska District Engineer mailed
a complete set of the report directly to you on 12 March 1976.
The time for interested parties to provide comments to the Board
has been extended to 25 March 1976.
Despite the unfortunate circumstances which resulted in delaying
the availability of this report for your review, please be assured
that the Corps of Engineers and the Board are very interested in
receiving your comments, and those of other concerned persons.
Your interest in this matter is appreciated.
Sincerely yours,
s/ROBERT L. BANGERT
Colonel, Corps of Engineers
Resident Member
379
,~-.....----------"'1"""------
·rho"-~ 3 Taggart
Gen~ral Deli~:er:r ~-
3e~-lard, ~u~s1=a 99664
5 Harch, 1 ?76
Depart:-12nt of tile :\rr.t;t
Bo::trd of En:Gi:uers i'or 2i'!Cr3 ~nd tial.;bo!"s
r~ Lngma.n BullcLn:-:
Fort 3elvoi.r, ~/ir:;inia 22GSO
Il3: Interim :i<~3asibility iteport On The S:.:sitna River Basin, Alaska.
Dc:ar Si.rs:
J .. :; per tiw ::tttached letter I was assured by Colonel Robert L. Bangert
~cntionad re,:ort :ro"Jld be m:.d~ 2.vail<J.b:.8 to the people of all Southcentral
via the puhlic 'i orari·C)S of said com.:-:uni ties.
that the above
R:!.iloelt communi t
As of this ciate the librar-.:r in the Com::unity of Se';·rard (Southern terminus of the Alaska
P..:;..ilroad) h2.s hot :tet recei.v,;d :--c.;p:r of the report i'ron the Alaska District Sngir~9er. I pe
:jonally '.-trotc to tne Alaska District E:ngineer in rr.id-Feb!"'J~r:T ci tin~ Colonel Bangert 1 s lette
to me, and I c~lso as:<ed that they include a CO:JY of tne supplemental recr::a.tional report to
the .Sei·Ta.rd L~br~ry ·so that corrrr::cmts could be made before the Harch 1Oth de:::dlL11e.
In:'ol';"'l3.ticn c-:-nc .. :nn:Lng 2.. pro,j-::ct of this ma:;nit·Jde shotlld be o~Y;)nly su':~lied to the pub
•·~i1o :rill be (::. :~,:t.l...-3.f::'-'"ct::;d i):r tr1e pro,j~ct. If the Col~ps of Engin::ers is not conscientiou
•mough to frr;el:: su:_~?l~r tbo.t sector of t;1e pub.U .. c ·:nth t.he pertb:ent :i..n.:·onr.ation, t~an the
Corps of lmgin·3er:; is not serll'ing the national intGrest. · ...
In ::;hort, I cannot corrL~··mt on you~ repor·i:. uec<r;se I hJ.Ilen•t s:;en it, as I wppo..;e is th
case of multi ",.:.-Jcios of otner interested pars ens.
cop;r to •••• Div~:.>i.on :2;nginoer, Portl:md, Oregon ••• •••••• •• "':r/o encl.
, Dist:~tct Engineer, .\nehorage u
Secr;;ta.r7 of the A~:-, ·~·lash::.ngton, D. C. u
Hono.:aolc J:J.y ':3. IIa::.:nond, June:m n
Hono~a'ole Hl-ce G:..""1v2l, ~;Jashington, D. G. n
t..tono:2.'olc Ted St2'mns, 'da.~:;~·~:',_::t-on, D. C., u
Hon'?:.:-aole Dom.ld 2. Yonn::r, :.-;ash:.n:~ton, D. r.. u
380