The URL can be used to link to this page

Home My WebLink AboutAPA1770I I · t I I I I I I I I I SUSITNA HYDROELECTRIC PROJECT . FEDERAL ENERGY REGULATORY COMMISSION PROJECT No. 7114 Susitna Hydroelectric RECEIVED SEP 21 1984 LG L ALASKA ALASKA POWER AU THOR ITY COMMENTS ON TH E · · FEDERAL ENER GY REGULA TORY COMMISS IO N DRAFT ENVIRONMENTAL IMPACT STATEMENT OF MAY 1984 VOLUME 1 INTRODUCTION • AUGUST 1984 DOCUMENT No. 1770 • L..o---_ALASKA POWER AUTHORITY __ ____. • • • FEDERAL ENERGY REGULATORY COMMISSION SUSITNA HYDROELECTRIC PROJECT PRO JECT NO. 7114 ALASKA POWER AUTHORITY COMMENTS ON THE FEDERAL ENERGY REGULATORY COMMISSION DRAFT ENVIRONMENTAL IMPACT STATEMENT OF MAY 1984 Volume 1 Introduction August 1984 Document No. 1770 Susitna File No. 6.4.6.2 - c-.;...-) ALASKA POWER AUTHORITY ~4 WEST 5th AVENLlE·ANCHORAGE,ALASKA 99501 August 21,1984 Susitna File No.6.4.6.3..... Phone:(907)2n·7641 (907)276·0001 - ..... ..... ..... Mr.Kenneth Plumb Secretary Federal Energy Regulatory Commission 400 First Street,N.W. Washington,D.C.20001 Subject:Susitna Hydroelectric Project Draft Environmental Impact Statement Dear Mr.Plumb: Transmitted herewith are the comments of the Alaska Power Authority (APA)on"your Draft Environmental Impact Statement (DEIS)for the Susitna Hydroelectric Project,No.7114,as noticed in the Federal Register on May 25,1984. The APA's comments consist of this letter,plus the following attachments: ..1.An Executive Summary in which the APA summarizes its principal comments on the DEIS. 2.Section-by-Section Technical Comments,arranged to follow the organization of the DEIS.The technical comments respond to the specific points made in the DEIS;and 3.Technical Appendices,which contain thorough analyses or updated data on fuels pricing and economics,the alternative hydroelectric projects described in the DEIS,the alternative thermal (gas/coal) projects described in the DEIS,and the most recent results of the Susitna StUdy Program. The Executive Summary and the Technical Comments together comprise the APA I S comments which should be incorporated in the Final Environmental Impact Statement (FEIS). By organizing the DEIS comments in this manner,the APA intends to permit the reader to progress from the most general observations to the most specific.In keeping with that organization,the APA's major concerns with ~he DEIS are highlighted below: ..... o o A key factor in assessing the economic feasibility of the Susitna Project is the world oil price forecast.In its analys~s FERC relies on an internally generated and undocumented oil price forecast which lies at the extreme low end of the range of forecasts prepared by established and respected experts • PERC projections of future natural gas prices and availability of supply are also inconsistent.The low gas prices forecasted would discourage rather than encourage exploration for and development· of the additional gas reserves which would be necessary to fuel PERC's proposed thermal alternatives. -o o o o o PERC seriously underestimates the price of coal by dismissing the possible development of an export market and by holding the price of coal steady even though the price of oil is forecasted to increase from 2010 throug~2050. FERC greatly overstates the potential adverse impacts the project will have on fisheries and wildlife.FERC has made several erroneous and unsupported assumptions concerning the degree of utilization by salmon of the Susitna ma.instem for spawning activities,and by moose and black bear of the Susitna impoundment zone habitat. FERC overlooks and fails to give appropriate weight to serious adverse consequences which would result from the re~ommended DElS alternati ve generating scenarios. PERC has failed to,consider adverse socioeconomic impacts of the recommended DElS alternative access route and has given undue weight to £'ish a.nd wildlire impacts of the APA's preferred routing. PERC has used inconsistant project costs and economic analyses to demonstrate S.n economic advantage for the mixed hydro-thermal scenario.When the correct costs and an unbiased analysis are adopted~this advantage will disappear. ...... - .- APA is disappointed with the quality of the DElS and concerned with the pot.ential for delay that it represents.The State of Alaska has invested approximately $100 million to date in its efforts to implement a cost-effective solution to the energy needs of the Alaska Railbelt.The State should be able to rely upon the Federal Government to produce an unbiased and accurate assessment of those efforts. Since the public expects an independent and impartial assessment of the proposed project by PERC,the premature conclusions drawn in FERC's DElS have created concern and confusion over one of the most significant issues facing the people of Alaska. APA expects that PERC will proceed with preparation of the PElS on schedule.Further~APA expects a professional,balanced,and objective document that will address all concerns and result in a FElS upon which the Commission can adequately base its decision with respect to licensing the project. APA is available to provide additional information or lend assistance as the Commission deems necessary.Questions may be addressed to Mr.Jon S.Ferguson at (907)279-6611.-J:;j)~R Larry rf/.Crawford Executive Director JSF/LDC!sm ARLIS L 'b .Alaska Resources 1 Tan"&f 'l':.~...IhOrmatlOn Services dJKb.orage.Alaska ..... PREFACE In May 1984 the Federal Energy Regulatory Commission,Office of Electric Power Regulatioln,published a Draft Environmental Impact Statement (DEIS)in connection with an application filed by the Alaska Power Authority for the proposed Susitn.a Hydroelectric Project.This Comment Document contains the Alaska Power Authority's comments on the DEIS.The Comment Document consists of an Executive Summary,Technical Comments and Appendices. The Power Authority has prepared Technical Comments on specific points made in the DEIS.The Technical Comments are organized into five general areas .... roughly paralle:l to the manner in which the DEIS is organized to facilitate use of both FERC Staff and others reviewing the DEIS.These topic areas are: Topic Area Code 1.Need for Power NFP 2.Alternatives ALT 3.Aquatic Resources AQR 4.Terrestrial Resources TRR 5.Soci,al Science SSC Each Comment by the Power Authority is identified by an alphanumeril;code which comprises the three-letter topic area code followed by a three-digit number.The Comments within each topic area are numbered consecutively from the beginning to the end of the DEIS document.In addition,each Comment - identifies the.location and subject of the DEIS statement referenced.For the reader who would like to read the DEIS and Power Authority Comments in parallel,a Cross-Reference Index is provided which lists the Comments applicable to.each section of the OEI8.- 49661 840820 I - - - [~ - - ,~ .- For those interested only in very specific topic areas,a Subject Index is provided which lists comments applicable to specific subjects by use of key words. Ahead of and supported by the Technical Comments,the Power Authority presents an Executive Summary of the Comment Document.This Summary provides a general discussion of the major conclusions of the DEIS and the Power Authority I s assessment of those conclusions.A Bibliography is also included in this DElS Comment Document. Detailed technical documentation for many of the Comments are contained in Appendices to the Comment Document.Appendix I,Fuels Pricing and Economics,documents the economic feasibility of Susitna based on the latest oil,gas,and coal prices forecasts and revised thermal plant costs and characteristics.Appendix II evaluates Non-Susitna Hydroelectric Alternatives.Appendix III,Thermal Alternatives to Susitna,addresses the environmental assessment of thermal (coal-and gas-fired)alternatives to Susitna.Appendices IV through VII transmit results of environmental studies on the Susitna basin impacts of the Proposed Project. 49661 840820 2 - - - - .~ Volume No. 1 2A 2B 2C 3 4 ALASKA POWER AUTHORITY COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT OF MAY 1984 TABLE OF CONTENTS 'Contents Transmittal Letter Preface Table of Contents Executive Summary Bibl iography Cross Reference Index Subject Index Technical Comments Need for Power Alternatives Technical Comments Aquatic Resources Technical Comments Terrestrial Resources Social Science Appendix I -Fuels Pricing and Economics Appendix LI -Evaluation of Non-Susitna Hydroelectric Alternatives - ..... ..... Volume No. 5 6 7 8 9 TABLE OF CONTENTS (cont.) Contents Appendix III -Thermal Alternatives to Susitna Appendix IV -Temperature Simulation,Susitna River, Watana Dam to Sunshine Gaging Station,Open Water Appendix V -River Ice Simulation,Susitna River, Watana Dam to Confluence of Susitna and Chulitna Rivers Appendix VI -Slough Geohydrology Studies Appendix VII -Temperature Simulation,Watana and Devil Canyon Reservoirs - re i I ~ I I. II. III. IV. V. VI. EXECUTIVE SUMMARY TABLE OF CONTENTS Int rodulc t ion General Comments on DEIS Energy Policy Issues A.Use of Renewable Resources B.Fuel Use Act C.Present Energy Scenario Need for Power A.Load Growth Projections 1.Historical 2.Population Forecasts 3.Load Forecasts B.Fuels Pricing Proposed Project A.Engineering Assessment B.Environmental Assessment 1.Fisheries Impacts of the Proposed Susitna Project 2.Nitrogen Supersaturation 3.DEIS Proposed Alternative Access Plan 4.Terrestrial Wildlife Issues C.Cost Assessment Evaluation of DEIS Proposed Alternatives A.Engineering Assessment B.Environmental Assessment 1.Unavoidable Impacts of Non-Susitna Hydro 2.Johnson Dam and Reservoir 3.Keetna Dam and Reservoir 4.Browne Dam and Reservoir 5.Snow Dam and Reservoir 6.Chakachamna Alternative Site 1 2 6 6 7 8 9 9 9 9 10 11 18 18 18 19 24 25 26 27 27 28 30 31 32 33 35 36 36 5304/163 .- - VII. 7.Thermal Generation 8.Comparison of Impacts of Susitna and. DEIS Preferred Mixed Thermal-Hydro Alternative C.Cost Assessment 1.Hydro Alternatives 2.Thermal Generation 3.Susitna Basin Alternatives Conclusion iii· 37 42 43 44 45 45 46 5304/163 - - ..... -- EXECUTIVE SUMMARY I.Introduction The hydroelectric potential of the Susitna River Basin was first identified by a U.S.Bureau of Reclamation Reconnaissance Study completed in 1948.The Bureau completed a project feasibility study in 1961 which recommended that a five stage river development plan be authorized by the U.S.Congress.In 1975,the U.S.Army Corps of Engineers (COE)completed a comprehensive feasibility study which recommended the current two dam development concept.The COE prepared an environmental impact statement for the project which was issued in final form,after all required reviews, in January 1977.The COE updated its feasibility study in 1979 and reaf- firmed both project economics and the proposed Devil Canyon -Watana com- bination as representing optimum development of the Susitna Basin. In February 1983,the Power Authority submitted to the Federal Energy Regulatory Commission (FERC)an Application for License for the Susitna Hydroelectric Project,as a two-stage project substantially the same as that:proposed by the COE.Submittal of the Application followed three years of additional engineering,economic,and environmental studies by the Power Authority.After requesting additional information from the Power Authority,FERC accepted the Application in July 1983.FERC used the Application "comments on the Application by Resource Agencies,and some additional information submitted by the Power Authority to prepare a Draft Environmental Impact Statement (DEIS).In May 1984 the DEIS was distribut- ed for reviE~w and comment by interested parties. The DEIS Comment Document constitutes the Power Authority's review and comment on the FERC DEIS and prOVides,where appropriate,more recent and/()r improved analyses for FERC's review and use.Based upon comments received from reviewers and its own further analysis,FERC will prepare a Final Environmental Impact Statement (FEIS)on the project. TIbe organization of the DEIS Comment Document is discussed in the 5304/163 1 ,.... F" I Preface.In summary,however,it is composed of three major portions: 1)the Executive Summary which identifies the Power Authority's chief concerns about the DEIS conclusions;2)Technical Comments which deal with specific dat.~,analyses or conclusions in the DEIS;and 3)Appendices which provide additional data and analyses on a number of topics. II.General Comments on DEIS The Power Authority concurs with FERC methodology which is: (1)to estimate future requirements for power in the Railbelt;(2)to develop alternative means of meeting projected power requirements for the Railbelt;(3)to assess the economic,enginee,ring and environmental costs of a range of representative generation scenarios;and (4)to select a preferred alternative.Further,the Power Authority would agree that FERC has examined a variety of reasonable projects that are probably the best alternatives to the Susitna Project. Based upon FERC's consideration of engineering feasibility, economic characteristics and environmental effects,as stated in the DEIS, FERC found that a mixed hydro-thermal scenario totaling 1853 Megawatts would be the most effective solution to meet Railbelt generation require- ments.The Power Authority feels that this conclusion acknowledges the need for power development to meet future Railbelt needs and that it recognizes that hydroelectric projects will prOVide'the greatest long term economic advantage.However,the Power Authority feels that FERC has incorrectly and inadequately analyzed the engineering feasibility,economic characteristics and environmental effects of both its preferred scenario and the Proposed Proj~ct. In:spite of the importance of the forecasted price of oil,FERC relied upon internally generated and undocumented oil price forecasts rather than upon forecasts prepared by established and credible experts. The Power Authority presented a range of established credible forecasts in its License Application.Yet,FERC inexplicably chose to ignore those 5304/163 2 - - - forecasts and instead generated its own projected prices,which fall into the extreme low end of the range of price forecasts from other respected sources. Given the linkage between the world price of oil and gas and coal _prices,FERC's analysis leads to miscalculations of future coal and gas prices as we:ll.In forecasting future coal prices FERC compounde-d its original error by determining that an export market for Alaska coal will not develop.FERC therefore projects coal prices based upon production costs plus transportation costs,rather than upon the higher prices which could be obtained in an export market.These production and transportation costs are themselves understated in the DEIS.More importantly,the determination that an export market for Alaska coal will not develop is based upon assumptions as questionable as the FERC's oil price forecasts. Wllile FERC does not explain the manner in which construction costs for the non-Susitna hydro alternatives were estimated,it is apparent that the 1980 Development Selection Report prepared by Acres American, Inc.,which contained screening level estimates for the alternative hydro projects,was compared with 1982 feasibility estimates for the Susitna Project.As a result,the costs of the non-Susitna hydro alternatives are seriously understated. Blacause of the questionable assumptions about fuels prices and the cost of alternatives to Susitna,the Power Authority believes that the credibility of the economic analysis contained in the DEIS is questionable. The FEIS should incorporate revised economic analyses based upon additional data provided in this document.Such revision will show no economic ad-vantage for the mixed hydro-thermal alternative,but rather,a substantial economic advantage to the Proposed Susitna Project. The DEIS states that there are benefits for the decentralized and diluted impacts of the mixed hydro-therttlal alternative.This is unsupport- 5304/163 3 - - - -, .- - - able in view'of the aggregate impact of the hydro-thermal alternative and the poor showing of the hydro alternatives in terms of environmental impact per Megawatt:of installed capacity. FERC's analysis of the environmental impacts of the Alternatives, including Susitna,is inadequate~Hydropower development in the Susitna Basin has been exhaustively studied since the 1950's.If the proposed alternatives were subjected to the same intense scrutiny,FERC's list of environmentaLl impacts associated with them would undoubtedly grow and become more detailed.For example,FERC quantifies the projected impact on salmon of the Susitna Project as a 50%reduction in annual juvenile growth for salmon,and growth reduction by 60%to 7~%for early emigrating chum and pink salmon.These calculations are themselves too high,and unsup- ported by d~lta furnished to FERC,but for its proposed alternatives at Keetna,Johnson and Lake Chakachamna,all FERC can say is that there is potential loss of salmon population or habitat.Would these "potential" losseS'combined equal or exceed the alleged disturbance to be caused by Susitna?There simply is not the same wealth of data to allow detailed quantificat:ton of the environmental impacts of the alternatives.Moreover, FERC has sel=mingly ignored or downplayed the data that does exist concerning significant adverse consequences of the alternatives.The degree of analysis devoted to each alternative in an EIS should be substan- tially similar to that devoted to the Proposed Project.Where uncertainty exists regarding significant impacts of the alternatives,the EIS must in- clude a reasonable,worst-case analysis.The Power Authority has supplied such analysl5!s for significant impacts of the hydropower and thermal alter- natives. Arrother problem with FERC's environmental analysis is that some impacts associated with Susitna,such as accelerated slope and soil ero- sion,would result from any hydropower development.Yet FERC has not included such generic impacts in its list of impacts of the alternatives. The environmental impacts of alternatives to Susitna are therefore seriously underrated. 5304/163 4 - - ,~ - - - - -I A basic problem with FERC's environmental analysis is that FERC has failed to adequately compare dissimilar impacts.For example,how can the substantial,adverse air quality impacts from virtually every element of the coal cycle (mine-transportation-powerplant-waste piles)be less significant than the mitigated impacts of the Project on aquatic resources? FERC has not documented its judgments in balancing one environmental value against another.Thus,the Power Authority cannot understand how the DEIS can identify anyone environmentally preferable alternative.FERC should at least idemtify two or more environmentally preferable alternatives. A final problem in the environmental analysis is that it is dif- ficult to uIlderstandhow FERC weighted simila:r impacts.For example, Susitna would inundate or disturb 56,000 acres while the FERC's combined hydro-thermal plan would similarly disrupt 124,000 acres,more than twice as much land.FERC states that the Susitna Project would disrupt wilderness-type recreation experiences in the middle Susitna Basin while the Brown hydropower alternative would disrupt a major river touring route along the NE~nana river.With regard to socio-economic impacts,the Johnson site alone ldll completely inundate two communities--Dot Lake and the Living Word---and cause displacement of all residents (approximately 250) from their homes,social settings and sources of livelihood.In contrast, the Susitna Project would neither inundate communities nor displace residents but would cause rapid growth of several small communities.In light of thlase comparative impacts,the Power Authority questions FERC's determination that a combined hydro-thermal scenario is the preferred alternative. The DEIS seriously underrates the environmental impacts of the mixed hydro·-thermal alternative and overrates the impacts of the Susitna Project.With the benefit of improved information on the alternatives,the FEIS should change the characterization of impacts for the thermal components from "minimal"to significant and critical.Furthermore,the characteriz.ation of the environmental impacts of the mixed hydro-thermal alternatives should change from less than the Susitna Project to greater 5304/163 5 .- -- ..... -. - ...... than the Susitna Project. While in its summary of the DElS,FERC states the mixed hydro- thermal plan is preferable from an engineering standpoint,it does not present any discussion in the DEIS to support this statement.The Power Authority is not aware of any engineering drawback to the Susitna Project and FERC does not identify any such problems in the DEIS.On the other hand,studies of some of the alternatives included in FERC's mixed plan have pointed out engineering problems.The DEIS does not discuss these engineering eoncerns.It is difficult,if not impossible,to understand on what engineering basis FERC found the mixed hydro-thermal plan preferable. In sum,the Power Authority's analysis of the DEIS leads to the" conclusion,that,in assessing the Susitna Project,FERC used a worst-case analysis ~hile it used a partial,best-case analysis on alternatives to the Proposed Project.If Susitna and its alternatives are given a balanced assessment as required by the National Environmental Policy Act,Susitna can be shown to be the preferred plan in terms of economic feasibility, environmental impact and "engineering. Although FERC prefers its mixed hydro-thermal plan,it recommends that if development in the Susitna Basin is authorized,the Proposed Project be licensed and constructed in stages.The first stage would be Watana at a lower height than proposed by the Power Authority.The Power Authority does not believe that such an approach represents the highest and best use of the resource. The FEIS should result in a finding of the merits of the Susitna Project and recommend expeditious implementation of the Susitna Project as proposed by the Alaska Power Authority. III.Energy Policy Issues A.Use of Renewable Resources--- The FElS should recognize that the State of Alaska has chosen to 5304/163 - - -- ..... ..... - invest a portion of its current revenues,which are being realized through the sale of non~renewable resources,in the development of economically and environmenta.lly sound renewable energy sources to serve future generations which may be faced with declining revenues.This decision is manifested through the legislatively created Energy Program for Alaska.Susitna is an authorized project under this program and is proposed to serve the Railbelt Region of the State where the ~ajority of the population resides. The Energy Program for Alaska is completely intrastate and is 100%funded by state equity contributions,loans or revenue-bonds.Three hydroelectric projects within the program are operational and a fourth will soon be completed,none of which are located within the Railbelt.Rural residents not served by the existing projects,nor contemplated to be served by the Susitna Project,are recipients of rate equalization funds through the legislatively established Power Cost Equalization Program. B.Fuel Use Act------ Section 212(f)of the Power Plant and Industrial Fuel Use Act of 1978 acts as a legal constraint on adding gas-fired units for base-load generation ~lS suggested by FERG.An exemption for the development of electric generating facilities in Alaska using natural gas as a fuel during the period December 30,1982 to December 31,1985 is provided by Section 317 of U.S.House Bill 7356.However,Section 317 goes on to say that this exemption shall not apply to any new electric power pl'ant using natural gas produced by the Prudhoe Bay Unit of Alaska. The Fuel Use Act mandates the highest and best use of gas re- sources and prohibits the addition of new base-loaded gas-fired generation in the nation.While Alaska received a three-year exemption from this act, as amended and noted above,the exemption expires in 1985.The Power Authority fl~els that it is imprudent to base long term planning on further exemptions to the Act.If FERC suggests that the Fuel Use Act will be waived permanently,the FEIS should provide justification for this supposition.None of the Railbelt utilities,nor the Power Authority,can 5304/163 7 - - - - - - - - legitimately plan for intermediate and long-t~rm power supply based on gas-fired units. C.Present Energy Scenario The DEIS catalogues existing means of meeting electric require- ments in the Railbelt,and notes that at present,natural gas is the primary fuel in electric generation,particularly in the Anchorage area. This is supplemented by coal generation located primarily in the Fairbanks area.As stated in the DEIS,the Railbelt has benefited from relatively inexpensive electrical energy by virtue of low-cost natural gas-fired gen- eration.HClwever,the DEIS fails to recognize that this resource cannot be depended upon for future electric generation .to the extent it has been in the past.Cook Inlet gas reserves are declining,making uncertain the availabilit)r of gas for long-term generation ·planning.As supply declines, there will be intense competition for the resource among users.This will lead to increasing prices.The majority of homes in the Railbelt,parti- cularly Anchorage,are heated with natural gas.This is a more efficient and higher priority use of the resource than electric generation.The benefit of conserving developed gas reserves for home heating has not been measured in the License Application or DEIS economic analyses,but it is of considerablE!value.FERC acknowledges that new gas reserves will have to be developed in the 1995-2000 time frame if present use patterns persist, and that prices must rise sufficiently to promote that development.The price of future gas delivered,whether new Cook Inlet discoveries or North Slope gas,will most likely be established on the basis of equivalent world energy pricl!or the "net back"value of exported gas.The impact of this price increase,should it occur,will doubly affect the Railbelt consumer through increased electricity and heating costs. The DEIS suggests that wood has potential as a fuel for wide- spread use in the Railbelt.While wood burning can potentially reduce heating cos·ts in areas not served by natural gas,it is difficult to under- stand this suggestion as applying to the metropolitan areas of Anchorage and Fairbanks where serious air quality problems already exist and where 5304/163 8 ..... - - (fJI'i!'O. .- the heating lenergy demand is focused.It should be noted that restrictions on wood burning have become necessary in Juneau,and could be anticipated in the Fairbanks area because of extreme air quality problems.Vehicle inspections for engine emissions are being instituted in Anchorage and Fairbanks in response to EPA air quality requirements.Any further in- crease in wood fuel use would present substantial problems.The FEIS ~hould reevaluate its proposed use of wood as a fuel. IV.Need for Power------- A.Load Growth Projections 1.Historical The DEIS makes reference to the his,tory of "boom and bust"cycles in the economic history of Alaska.The economic history of Alaska has been no more cyclic than that of other western states during their development, before sufficient infrastructure existed to support a diversified,stable economy.Since statehood the economic trend in Alaska has been towards stability coupled with long-term growth.Periods of relatively intense construction activity-are unavoidable in the development of resources necessary to promote long-term stability.The FEIS should assume a rea- sonable sustained growth unless it demonstrates technical analysis support- ing contention of assumed "boom and bust"cycles. Net generation for the Railbelt in 1983 was 3024.5 GWh,as indicated in.Railbelt Area Utility Historic and Forecasted Net Generation, U.S.Department of Energy,Alaska Power Administration,May 1984.The same document reports the mid-range forecast of load growth from 1983 to 2000 to be 4.6%.The DEIS mid-range forecast predicts 2802 GWH in 1983 (7.3%lower than actually experienced)and 2.2%growth for the same period.The FEIS should quali.fy the conservatism of their projections by reference to cur- rently experienced load growth. 2.Population Forecasts Rather than relying on load growth projections from utilities which are ge:nerally short-term projections and have come under criticism 5304/163 9 - - - - from some sources as being optimistic.the Power Authority chose to develop load projections through the use of state-of-the-art econometric modeling. Economic conditions are projected using the Man in the Arctic Program (MAP) model.The 'MAP model was selected because of its independence from the Susitna Project studies and its established reliability.The MAP model has been continuously updated since its development.It has been used by the Bureau of Land Management,the Federal Power Commission.the Department of Agriculture,and numerous state agencies and private interests.FERC also chose to use the MAP model in its analysis.However.the Power Authority finds that the DEIS outputs do not match the Power Authority's load projection outputs.The FEIS should more completely document inputs and outputs and any changes in model structure or:parameters. The DEIS uses the MAP model in developing population projections. The DEIS load projection implies that the population of Alaska in 1985 will be 468,452.The estimated present population of the state as of July 1983 is 510,500.The DEIS population projections are more conservative than the already conversative-projections provided in Appendix 1. The DE IS projections differ significantly from the Power Authority's projections in the long term.The FEIS should acknowledge and explain the basis for the extreme conservatism of FERC's populationprojec- tion or use population projections that are consistent with State experience. 3.Load Forecasts MAP model economic projections were input to the Railbelt Electric Demand (RED)model,operated by Battelle Pacific Northwest Labo- ratory (Battelle),an independent economic consulting institution.Upon completion of its modeling effort.the Power Authority's analysis projected a 2.7%growth in demand over the 1983 -~OOO period.This estimate appears conservative when compared to projections developed by the U.S.DOE,Alaska Power AdminJlstration.based on Railbelt utility dc;l.ta.The DOE forecasts a 4.6%demand growth over the same period.In contrast,FERC,using the same 5304/163 10 - - "..., , - - .... MAP/RED modeling tools as the Power Authority,derived a 2.2%growth over the 1983 -2000 period. It would be useful for FERC to compare the reference case load projections to similar projections nationwide and in the western states. FERC should also acknowledge that economic conditions implied by its assumptions and projected growth represent an extremely pessimistic view for both the state and the nation. The net effect of the DEIS oil price forecasts and other economic assumptions,when input to the MAP/RED simulations,produce a projected electric den~nd of 5234 GWh in 2010 under the DE IS medium scenario,com- pared to thEt License Application Reference Case of 5858 GWh.The effects of the DEIS's low economic assumptions are then given double weight by the DEIS method of extrapolating the load out to 2020.Under the DEIS's extrapolation approach,by 2020 the load is only 6224 GWh,compared to the Power Authority's 7481 GWh. B.Fuels Pricing The Power Authority has gone to considerable effort,as shown in the License Application,to prepare a comprehensive fuels pricing analysis suitable for the 50-year period of project analysis using internationally recognized experts in the field.The Power Authority's analysis has been subject to (~ontinuous refinement and validation.An update of this analy- sis is contained in Appendix I of this document.The FERC fuels analysis, on the other hand,does not.appear to be based upon any comprehensive, consistent ]~eview of the total world energy balance nor is it supported by a reasonablE~number of credible authorities in the field.FERC founds its analysis upon unsupportable assumptions about the direction of world oil prices.Given the linkage between gas and coal prices with the world price of oil,the assumptions in the FERC oil price analysis lead to miscalcula- tions of future coal and gas prices and ultimately the economic feasibility of the project. 5304/163 11 """ The economic framework underlying the FERC analysis determines the prices of competitive fossil fuels and the demand for electricity in the Railbelt area,and thus the economics of the proposed Susitna Project. FERC's economics framework can be described as follows: - - - - o o o o Oil prices will decline principally as a result of fuel switching,conservation,and the growth of non-OPEC oil production (p.1-9 of the DEIS). Natural gas prices will remain low (less than oil prices) principally as a result of the oil price decline (pp.1-30, B-7). The motivation for the substitution of coal for oil and gas has diminished because oil and gas prices have and will continue to decline;therefore,the demand for coal in in- ternational (Pacific Rim)markets will weaken (p.1-33). An export market for Alaskan coal will not develop (i.e. zero value as an export commodity)because international demand for coal will grow less and the competition from alternative coal.suppliers will increase (p.1-33). This framework is illogical because all of its assumptions or "conclusions"hinge on the continuation of a recent short-term decline in the price of oil.Yet the principaL factors which FERC cites as con- ,....tributing to the price decline,are highly unlikely to continue unabated in the wake of that decline,and do not provide adequate support for the as- sumptions in the DEIS which are critical to long-term pricing projections. For example,the lower economic growth that has prevailed in the free world during the last decade is one major factor in the short-term decline in the price of oil.Yet that lower growth was itself largely caused by the huge increase in energy costs during that same period.High I~' 5304/163 12 - - ""'"I energy costs disrupted industrial planning.Industrial production slowed, resulting in less energy consumption.FERC now projects a significant decline in energy prices (oil prices to decline by almost one third between 1983 and 1990,down to the level of oil prices in 1979 before the last high price increase took place)which,based on the experience of the last decade,should stimulate economic growth again,not continue to depress it. Conservation is the other major factor which contributed to the reduction of energy consumption during the last decade.Conservation in- creases as the cost of energy exceeds its utilization value in various applications,or as investments in energy saving processes or devices be- come economical.If the cost of energy dec1i,nes as FERC forecasts,the trade-off between energy price on the one hand,and conservation on the other,will shift back again.While investments once made will likely not be undone by reduced energy costs.,new investments in energy saving pro- cesses or de''lices will occur only at a much reduced level,and some energy conservation that took place in the past because energy prices exceeded its utilization value will be undone.Yet FERC assumes that conservation will continue unabated at the rate experienced by the wor1d'since 1979. Finally,FERC anticipates oil price's to decline due to growth in non-OPEC oil production.While the growth in non-OPEC oil production over the past decade is undeniable,it is precisely the oil price increase that took place during this same period that caused the increase in production. If oil prices were to decline in the future as FERC projects,the major reason for the non-OPEC production increase that took place in the past not only would be removed,it would be reversed.Non-OPEC oil production would not only be arrested,it may actually decline in these circumstances. FERC assumes that fuel switching,conservation and growth of non-OPEC oil production,phenomena that'are attributable to increasing oil prices,will continue in the face of declining oil prices.This is illogical.If these phenomena continue it will be because of increasing oil prices.Increasing oil prices will then lead to increased gas prices, 5304/163 13 - - - ,... increased demand for coal (resulting from fuel switching),increased coal prices,and a significant value for Alaskan coal as an export commodity as predicted by the Power Authority. Moreover,a c+ose analysis of each of FERC's underlying assumptions on fuel switching,conservation and non-OPEC production indi- cates an approach of simply projecting past trends into the future without analysis of whether.these trends reflect long-term developments or short- term phenomena.A close inspection of data underlying past trends in fuel switching,conservation and non-OPEC production does not support the FERC approach of simplistically extrapolating them indefinitely into the future without adjustment. In making long-range pricing projections,FERC has placed an inordinate emphasis upon short-term oil market dips experienced in 1983 and has adopted the most pessimistic position on every variable affecting oil prices,such as world economic growth.This pessimistic view on economic indicators is not shared by most economists and,moreover,actual market experience in 1984 has not borne out the FERC projections. The FERC 1984 price forecast has already proven to be too low,by several dollars per barrel.The posted price remains at $29 per barrel and the most recent meetings of OPEC's official committee has affirmed both the existing production quotas and the posted price.The spot price recently dropped to as much as $2 per barrel below posted;however,this is primarily a seasonal decline caused by decreased summer demand and failure to lower production in anticipation of such a decrease.Production will be adjusted to the market and spot prices will strengthen toward posted prices,most:likely stabilizing to within 50 cents of posted.The spot price for market crude was quite stable from April 1983 through May 1984, generally runriing 25 cents to 50 cents per barrel below posted. In 1984,FERC's projections have already proven to understate economic growth by 2%,oil demand by 2%or 3%,demand for OPEC crude by 10% 5304/163 14 - ..... - to 20%,and the price of crude by 10%to 15%.These incorrect estimates are sound indications that the FERC short-term oil price'projection to 1990 will be too low and therefore is an inaccurate basis for analysis.The Power Authority has examined recent world oil price trends,which have developed since the License Application filing.and has updated certain projections made in the Application.These updated projections are pre- sented in Appendix r of this document.Recent data amply demonstrate that the Power Authority Reference Case presented in the License Application is conservative in estimating future price trends. The FERC projections of gas price and availability are influenced by the defects in its oil price analysis.FERC concludes that natural gas-fired gemeration will in the long-term prove more economic than the proposed Susi tna Proj ect.This J:onclusion is based on several miscon- ceptions of Cook Inlet natural gas availability and is inconsistent with DEIS projected future gas price trends. In FERC's view,natural gas in the.Railbelt is at present "exceptionally inexpensive due to the bountiful supplies associated with petroleum production in the Cook Inlet area,coupled with the lack of an extensive eJ'~port market."FERC should understand that,by the nature of the Cook Inlet and Kenai fields,gas production reflects development of the capacity to produce natural gas and is not a byproduct of oil production. Moreover.to assume that th~present circumstances will hold throughout the economic planning horizon overlooks critical data presented in the License Application.Cook Inlet proven reserves will be exhausted in 1998,and undiscoverecL but economically recoverable reserves will be depleted no later than 2007.Although unexpected reserves may be discovered,they cannot be counted on tQ serve domestic requirements throughout the service life of SusJltna.More recently developed data,presented in Appendix I, show that reserves have been steadily declining for the past three years. and indicatE~that Cook Inlet production will begin declining by the mid-1990's at the latest,with the resource exhausted shortly after the turn of the century.If FERC assumptions about future gas prices are 5304/163 15 - correct,thla exploration needed to find additional supplies would not be encouraged.Low prices would serve only to shorten the projected life of the Cook Inlet reserves because the reserves currently undiscovered may subsequently not prove to be economically recoverable. A further ramification of the FERC gas price assumptions is that "... depleted Cook Inlet supplies could not be augmented by North Slope sup- plies.Neither the ANGTS nor TAGS projects would go forward at gas.prices projected by FERC,because their sponsors could not recover project costs adequately.Therefore,it is not consistent for FERC to assume both low future pricl~s for natural gas and that natural gas would be a viable long-term alternative to the proposed Susitna.Projec.t.Under FERC price assumptions,only Cook Inlet gas would be available,and Cook Inlet reserves arl!being rapidly depleted. TIle Power Authority's Application assumes that an attractive export markl!t would develop to justify construction of either ANGTS or TAGS.Therefore,the Application assumes North Slope gas would become available.The Application showed,however,that while gas supplies would be available,gas would not be an economic means of generating electricity when compared to the Susitna Project over the long-term.Since the Application,the Power Authority has updated its analysis of .natural gas supply and prices.This update is presented in Appendix I of this document.The Power Authority's updated analysis confirms its License Application conclusions that natural gas,even though available,would not be an econo~[ic means of generating power when compared to the proposed Susitna Project. The FERC miscalculations on future oil prices also distort coal price projec:tions and,in some areas of the DElS,the alternate fuel as- sumptions are not consistent with the oil price assumptions.For example, FERC has an increasing price for oil,beginning in 2010 after a short-term decline.B)r 2050,as shown in Table 1-23,the oil price reaches $66 per barrel,mOrE!than double the present price.By FERC's own statement and 5304/163 16 I~ the precedent cited by FERC,this escalation in the price of oil should encourage conversion to coal,strengthen coal demand,and increase the price of coal.Yet,FERC holds the price of coal constant,at $1.55 per MMBtu,through 2050. FERC further implies that there will be no export market for Alaskan coal because of interfuels competition and the diminished di- versification from oil to coal.FERC acknowledges that the export price represents the real cost for local use if an export market develops,but, because it dismisses the possibility of an export market,concludes that the value for local use will in fact be the cost of extraction plus local transportation. Finally,FERC makes no effort to assess the competitive position of Alaskan coal vis-a-vis the other sources of coal mentioned.FERC implies that shipments from all these other sources will increase,but for some unexplained reason Alaska can never be an exporter of coal.There is no basis given for this conclusion. The sole basis for the coal price forecast appears to be vastness of the world's coal resources and Alaska's in particular.Despite the vastness of the world's coal resources,the world price of coal has in- creased during the same period of time that the price of oil increased in real terms. More important in determining coal price than the vastness of the resource is the cost of production.The cost of production is affected by various factors which determine whether a resource is economically recover- able.FERC makes no analysis of any of those factors in projecting coal prices.In particular,FERC gives no consideration to the effect of mine size on cost of production.Market limitations will necessitate the installation of small mine capacity,e.g.,in one million ton increments. The costs for such small increments will be much higher than FERC assumes for its base price of coal. 5304/163 17 ..... Since the License Application was filed,the Power Authority has updated its License Application Study of future Alaskan coal export poten- tial,and its coal prices projections.The updated discussion is presented in Appendix I. ..... ..... v.Propose~Project A.Engineering Assessment The DEIS states that: "Based on considerations of engineering feasibility, economic characteristics,and environmental effects,• ...a mixed thermal-based generation scenario,supplemented with selected non-Susitna bas.in hydropow:er facilities would be thl~most effective approach to meeting the projected generation requirements of the Railbelt area." ~ I However,in the Power Authority's review of the DEIS,no engineering problems associated with the Watana or Devil Canyon sites were identified.As discussed later,some alternative sites may present more significant lmgineering problems .than the Susitna Project.It can only be concluded that FERC selected its preferred alternative based on considera- tions other 1than engineering feasibility.The FEIS should state the engineering problems associated with each alternative,and then identify a preferred alternative if one is identified. B.Environmental Assessment There have been extensive studies on the environmental implications 'of the Susitna Project.The DEIS uses the information provided in the Application,but incorporates little of the data or analysis which has since been accomplished and furnished to FERC. Extensive comments have been prepared (and provided in the Technical COlrnnents volumes of this document)on aquatic and fisheries, wildlife and terrestrial habitat,cultural resource,socioeconomic, recreation,aesthetics and land use analyses in the DEIS.These comments 5304/163 18 .- - - - .- I, will permit updating and refining of these analyses in the FEIS. Appropriately,the conclusions and'recommendations of FERC focused primarily upon hydrological and fisheries analyses of the Proposed Project because of the integral nature of design and operation of the Proposed Project and impacts on fisheries • The principal environmental conclusions ,and recommendations in the DEIS with which the Power Authority takes exception are FERC's treatment of potential water temperature and flow fluctuations and their impac.ts on fisheries,the nitrogen supersaturation potential and the proposed alternative access plan.In addition,"the Power Authority disputes thl!FERC findings with respect to adverse wildlife impacts. L Fisheries Impacts of the Proposed Susitna Project FERC concludes that "Potential growth of juV'enile salmon downstream of Devil Canyon and Watana dams would markedly decrease when both dams .Wl!re in operation •••"due to adverse alteration of the riverine temperature regimes (DEIS Section 4.1.4.2,Page 4-30).This conclusion reflects several unsupported assumptions. FERC argued that the costly multilevel intakes proposed by the Power Authority at both Watana and Devil Canyon Dams to control the temperatures of water released from the dams and minimize environmental impacts would not be effective.The Power Authority disagrees with the". unsupported statements in the DEIS.The Power Authority has extensively studied the performance of the proposed multilevel intakes using the state-of-the-art Dynamic Reservoir Simulation Model -(DYRSEM).The ability of this model to.simulate intake dynamics and temperatures of released water has been demonstrated in applications of the model to Eklutna Lake.Additional results of temperature analyses of the proposed Watana and Devil Canyon Reservoirs for many hydrological and meteorological conditions,for various stages of project development and for several different levels of system energy demands,are included as Appendix IV of this document.The Power Authority believes that the effective operation 5304/163 19 -of the multilevel intakes will minimize downstream temperature impacts. FERC argued that,in the river downstream of the dams,water released from the dams would: o o warm up toward its natural temperature in the summer more slowly than estimated by the Power Authority,and cool down toward its natural temperature in the winter more rapidly than estimated by the Power Authority. - .- - - Based on these conclusions,the DEIS found greater temperature differentials between natural and with-project conditions in the summer and called into question the Power Authority's e~tire effort to predict environmental impacts resulting from altered river temperatures and river ice • In this regard,the analysis provided in the DEIS is seriously flawed.Th.e simplified equations used by FERC in predicting river temperatures contained errors.The Power Authority corrected these errors and refuted the summer warming and winter cooling rates estimated by FERC. In fact,th,e equations in the DEIS,when corrected,indicate that the Power Authority's river temperature modeling is accurate.Additional river temperature and ice simulations usi~g sophisticated state-of-the-art computer models have been undertaken.The results,for various hydrological and meteorological conditions and for various levels of project dev1elopment and system demands,are included in Appendices V and VI of this document. The updated temperature studies that have been conducted by the Power Authority since those furnished in support of the"License Application permit a closer examination of reservoir thermal structure and the effects of dam operation on Susitna River temperature than was possible by FERC in the DEIS evaluation. These studies indicate that the project will introduce a 5304/163 20 - ~ I ..... - temperature lag of approximately three weeks in late September and early October.Temperatures will be about 3 0 C warmer for any given day while the lag persists and the lag dampens out by mid to late November.In the spring,a lag of approximately three weeks will occur in May and June and temperatures will be about 3 0 cooler during the lag.The lag dampens out by late June.The Power Authority's studies indicate that these changes will not significantly affect.spawning. FERC uses its erroneous analysis of altered temperature regime as an input to an analysis of adverse impacts on incubating eggs and rear~ng ..juveniles.This analysis is in error because it fails to note that essen- tially no spawning takes place in the mainst~m under present conditions. Chinook,coho,pinks,and about half of the chum spawn in tributaries upstream of mainstem effects.The remaining chum and sockeye spawn primarily in sloughs in areas of upwelling groundwater.Studies to date indicate that the temperature of upwelling water will remain unchanged by the Proposed Project's operation,and that these spawning/incubation sites will remain unaffected by Project flows.unless overtopped by staging during the formation of an ice cover.Anatyses of ice regimes indicate that sioughs are :not likely to be overtopped more frequently with the Proposed Project than under naturaY conditions. Jrrvenile salmon redistribute throughout the system following their becoming mobile after emergence.The following table shows the rearing habitat of each salmon species.It is apparent from this table that the majority of juvenile rearing habitat does not occur in areas which are di:rectly affected by mainstem temperature. 5304/163 21 - ffJliiIl;l, ..... ~ecies Chinook Sockeye Pink Coho Chum Freshwater Rearing Habitats of Salmon Species in the Portage to Talkeetna Reach of the Susitna River Rearing Habitat side channels,sloughs and tributaries upland slough none --immediately move downstream to saltwater before river warms,no freshwater rearing upland sloughs and clearwater tributaries sloughs (1 to 3 months) before passing downstream to saltwater ..... 'r- I This information indicates that chinook juveniles would be the only juvenil,es likely to rear inmainstem temperatures regimes.They redistribute through the system in early summer and the greatest numbers are found in the side channels in July,August and September.During this period 23 percent of rearing juveniles are found in side channel~.At that time they would experience a relatively small and possibly negligible temperature change due to the Project. In addition to the problems associated with the predicted temperature regimes presented in the DEIS and the assumed distribution of juveniles in potentially affected areas,there are flaws in the analysis of juvenile salmon growth in the Susitna River under natural and with-project conditions.First,the method used to predict growth of juveniles was developed from data collected on juvenile salmon in lake systems of the Pacific Northwest.Presumably,salmon of the Susitna River have adapted to the colder tlemperatures and higher water velocities which occur in Alaskan rivers.Second,since growth of juvenile salmon is not only a function of temperature but also a function of food ration obtained by the juveniles, it is likely that under the slightly reduced temperatures induced by the r ! i 5304/163 22 ..... .- .... Proposed Project,the reduction in growth will not be directly proportional to the reduction in temperature.It is proposed that the juveniles will attain a -larger proportion of their needed food ration and therefore will be able to grow at a more efficient rate. In,light of the data summarized above,FERC's assessment of a potential 50%reduction in annual juvenile salmon growth overall is overly pessimistic.Current analysis of project impacts on salmon is illustrated in the following table,which indicates that a more appropriate conclusion would be that it is unlikely that there would be significant imp~c,ts on salmon if the Proposed Project is pursued with the proposed mitigation program. Salmon Populations in the Portage to Talkeetna Reach of the Susitna River %Reduction,Returning Adults Returning Adults Estimate of Portage Creek Lost,Lost,Portage Total Adults 'to Talkeetna,Portage Creek Creek to Returning t0 6 /W~t~out.to Talkeetna,Talkeetna, SP:cies 1/the River -MJ.tJ.gatJ.on Without Mitigation With Mitigation Chl.nook 2/185,000 6%550 6% Coho 3/45,000 0%0 0% Pinks -150,000 1%even yrs.75 0% 4/odd yrs.6 Sockeye 1/175,000 25%475 0% Chum 2?0,000 11%1000 0% ,ptA )j ~/ 1.1 §./ Assumes loss of 25%of side channel rearing habitat,22%of chinook rearing in side channels,escapement past Curry is 9130 fish,. Assumes no loss of spawning or rearing habitat. As surnes los s 0f 25%0f slough spawning hab i ta t ,to tal even year slough escapment is 300 fish and odd years is 20 fish. Assumes loss of 25%of slough spawning habitat,total slough escapment is 1900 fish. Assumes loss of 25%of slough spawning habitat,total slough escapment is 4000 fish. Portage Creek to Cook Inlet. 5304/163 23 - .- - - - - - This assessment presupposes that the habitats are at their carrying capacities,and that loss of spawning or rearing habitat will lead to an equivalent loss of adult escapement.This final assumption is extremely conservative. In the Power Authority's view,most potentially adverse environ- mental impacts are mitigab1e.Therefore,a negative finding on environmental grounds is not warranted.The FEIS should find that the environmental impacts,with appropriate mitigation,are acceptable. Concerning mitigation measures,the DEIS accepts the Case C flow regime recommended by the Power Authority in ,the License Application.FERC also recommended that spiking flows be implemented during August and September to improve access to certain salmon spawning areas.The DEIS is not clear in its recommendation of spiking flows;variously referring to"••••••f10ws up to ••••••20,000 cfs ••.••••""••••f10ws in excess of 20,000cfs ••••••and Il ••••••spiked releases of 24,000 cfs ••••••"The DEIS does not prmTide comparison of the benefits and costs of various releases. The Power Authority estimates that implementing the spiked flows may result in costs in excess of $200,000,000 over the life time of the project (the reduction in the present worth of net benefits in 1982 dollars),while providing improved access to spawning areas for about 1800 salmon per year. The Power Authority is continuing its mitigation and power planning studies which are a~med at developing optimal use of the resources in both the environmental and economic sectors.Alternate flow regimes are being con- sidered which include spiking releases.However;the Power Authority' believes that flow regimes should be selected after comparing both environ- mental and economic trade-offs,and that the effectiveness of mitigation measures in addition to flow regulation should be included in this anal- ysis. 2.Nitrogen Supersaturation FERC appears to contradict itself on the issue of potential occurrence of nitrogen gas supersaturation.In the DEIS Summary Section, 5304/163 24 - - - - - Vol.1 p.xxv)FERC finds that significant nitrogen supersaturation would occur in neaLrly every year of the Proposed Project's operation.This conclusion is unsupported by any analysis appearing in the main text or appendices of the DElS.Indeed)the treatment of the issue elsewhere in the DEIS document supports the Power Authority's position that there currently e~:ists a natural occurrence of gas supersaturation in the Susitna River which could be reduced by the operation of the project as proposed. This would result in an improvement to present Susitna water quality. Early in the project's planning process,the Power Authority decided to include fixed cone valves in both the Watana and Devil Canyon dams.These valves will be used when power ~eleases are insufficient to meet minimum downstream flow requirements or to release excess water from the reservoir when the reservoir has filled.Fixed cone valves are designed to release water under a substantial head of pressure,and to disperse water by releasing it as a spray.This spray does not plunge to a significant depth when it impacts the tailwater and therefore does not result in gas supersaturation.With the fixed cone valves it is unlikely that nitrogen supersaturation would become a problem under normal operation of the project. 3.DElS Proposed Alternative Access ~ FERC recommends that the·proposed Susitna Project be accessed via a route departing from a Gold Creek railhead and traveling east to Devil Canyon and Watana dam sites.The ~ower Authority proposed a railhead at Cantwell and a project road departing the Denali Highway and traveling south to Watana,west to Devil Canyon and,when Devil Canyon is construc- ted,a rail link from Gold Creek. Selection of an access plan requires decisions on (1)route,and (2)mode (road,rail,or road and rail).Analysis of access plans must be a multi-disciplinary exercise which includes assessments of: o environmental impacts and risks; o socio-economic impacts; 5304/163 25 0 road and rail design criteria; 0 construction difficulty and risk;~ 0 impacts on construction schedule;and 0 life cycle construction and operating costs. - - The Power Authority has undertaken substantial analysis of the access question which has been provided to FERC,and remains confident that its multi-disciplinary analysis and route selection remain valid.FERC recommends a,ccess from Gold Creek based upon its assessment of impacts on fish and wildlife resources.It fails to consider socioeconomic impacts upon the pot1entially affected communities of Gold Creek and Talkeetna. Both communities would experience increased p.opulations,and resulting demand for slervices.The FEIS should include a multi-disciplinary assess- ment which presents all facets of the evaluation.In particular,the FEIS should detennine the socioeconomic impacts of access via Gold Creek on Talkeetna and other small communities along the rail line.In addition, the evaluation should provide a quantitative assessment of impacts on fish and wildlife of the alternative routes,which thus far is not provided in the DEIS analysis.The Power Authority believes that using such an approach would lead to adoption of the Power Authority's access plan. 4.Terrestrial Wildlife Issues The Power Authority review of the terrestrial wildlife and botanical resources sections of the proposed project portion of the DEIS has revealed various errors,inconsistencies,and inaccurate inferences. These have been noted in the Power Authority Comments.In addition, recently available results of current studies have been reported where - - appropriate. o o 5304/163 Some of the most important observations are summarized below: New data on peregrine falcon nesting locations demonstrates that the proposed transmission line route is situated 1.4 miles away from the closest nesting location rather than two locations within 1 mile of the route as previously thought; Incorrect inferences were made regarding moose and brown bear habitat preferences relative to the impoundment zone 26 -.. ..- .i\lMlAt- o o and moose impact estimates,which imply that the impoundment zone is more important habitat than it really is,and which overestimates the number of moose impacted by the project; Additional data on black bear denning in the project area indicates that denning sites are not a limiting resource and that the DEIS overestimates impact on black bears; Updated information on the Jay Creek mineral lick indicates a lower potential for impact than previously thought. - - - - C.Cost Assessment When the License Application was f~led,the projected project construction cost for the Watana and Devil Canyon hydro developments was $5,150 million (1982 dollars)0..The construction cost utilized in the DEIS analysis is $5,565 million.Since the filing of the License Application, the Power Authority has conducted additional geotechnical and engineering investigations,on which a report has been provided to FERC.These studies have shown that by refining certain design concepts the design could be improved.The estimated construction cost of the Proposed Project,taking into account these design refinements,actual and estimated pre-design ex- penses,and refined estimating procedures,could be reduced to $4,830 million.This represents a difference of $320 million from the License Application,and a reduction of $735 million from the cost estimate used by FERC in its analysis of project economics.The FEIS should adopt the re- vised construction costs of $4,830 million as this number reflects the additional investigations conducted since the Application filing. VI.Evaluation of ~Proposed Alternatives The DEIS r.ecommends as a preferred alternative to Susitna,based upon engineering,environmental and economic considerations,a mixed thermal-based generation scenario,with selected non-Susitna hydro projects added as needed.FERC specifically suggested use of 5 non-Susitna hydro projects:Johnson,Browne,Keetna,Snow and Chakachamna.The alternative 5304/163 27 - - - - plan also includes one 200 MW coal-fired plant at Nenana~three 200 MW combined-cycle gas-fired plants and three 70 MW combustion turbines. Alternatively,FERC suggests that if Susitna Basin development were authorized~it should only be licensed in stages,with the first to be a Watana I development at 2100 feet elevation,rather than the proposed Watana development at·2205 feet design crest elevation.The DElS further concludes that based solely on environmental considerations,an exclusively thermal based arrangement would be preferable.FERC studied a range of thermal plans and also considered an all gas and four mixed coal-gas scenarios.These plans involve three to five 200 MW coal-fired units. Under an all coal scenario~FERC proposed locating three of these units at Nenana and two at Willow. The Power Authority disputes the FERC conclusions and recommenda- tions with respect to the engineering~environmental and economic feasibility of the proposed alternatives.FERC has not considered a number of engineering~environmental and economic factors about the alternatives which~if properly evaluated~would diminish their attractiveness as alter- natives to Susitna and~indeed,call into question the very feasibility of certain of th,e alternatives.These data on the alternatives are presented in the Power Authority's Appendices II and III of this document entitled Evaluation of Non-Susitna Hydroelectric Alternatives and Thermal Alternati- ves to Susitna.The following is a summary of the main conclusions reached by the Power Authority in its review of FERC's suggested alternatives concerning thle engineering~environmental and economic difficulties associated with each alternative. A.Engineering Assessment In the DEIS~FERC does not identify any engineering difficulties involved with the Susitna Project as currently planned.Moreover~the alternatives,particularly the non-Susitna hydro alternatives have varying degrees of associated engineering problems~as discussed below~which were not noted or given any weight in the DElS.Therefore it is difficult for the Power Authority to determine how engineering considerations influenced 5304/163 28 - .- - - FERC to favor the alternatives • Johnson.Being remotely located with respect to the Anchorage- Fairbanks Transmission Intertie,this site would require a long transmission line.U.S.Bureau of Reclamation studies of this site raise significant questions about foundation·suitability;surface geology suggests a deep valley filled with permeable,unconsolidated sediments. Potential difficulties exist with readily obtaining sufficient borrow materials.The Johnson site would probably require incorporation of fish passage facilities. Browne.Relocations of the existi~g major highway route between Fairbanks and Anchorage,the Alaska Railroad,the Golden Valley Electric Association Transmission line,and several homes would be required.The site would potentially require substantial foundation excavations and would probably require incorporation of fish passage facilities. Keetna.There would be potential difficulties with readily obtaining sufficient impervious borrow materials.The site would require incorporation of fish passage facilities. Snow.This site would require upgrading a long transmission line from 115 KVA to 230KVA.The site is subjected to glacial outburst flooding at approximately three year intervals.This would require special design treatment in the way of increased project freeboard,increased spillway capacity,or a reduced pool operating level. Chakachamna.The proximity of the Barrier,Blockade,and McArthur glaciers,Mt.Spurr volcano (located seven miles from the lake outlet),and the high seismic risk would all require special engineering considerations.The glaciers could cause outburst floods and would require special design treatment of project features.An eruption of Mt.Spurr volcano could inundate the proposed power intake site with volcanic ash or trigger a landslide or mudflow which could bury numerous project features. 5304/163 29 - - The ten mile long-power tunnel will require detailed geologic investiga- tions because of its greater susceptibility to problems created by changes in geology along its length.High in-situ rock stresses may occur near the underground powerhouse due to the nearby presence of the Lake Clark-Castle Mountain fault.This site would also require incorporation of fish passage facilities,of uncertain effectiveness. Thermal.Additional transmission capacity would be required from Nenana and Willow to connect proposed coal-fired units under the all-coal scenario,and from Nenana under the mixed hydro-thermal.Additional trans- mission also be required from the gas generating stations. As a result of the above noted engineering considerations,the FEIS should indicate that not only were engineering considerations not used to discriminate among alternatives,but also that the Susitna alternative is the preferred engineering solution. The FERC conclusion that,from an environmental standpoint alone, a thermal-based generating scenario would be preferable to Susitna seriously understates the significance of adverse environmental impacts which would occur in the all coal-based scenario and mixed coal-gas scenario both at the plant sites and as a result of increased mining activity required to obtain the additional coal.It also assumes away environmental difficulties with the all-gas scenario.Supplementing thermal generating plants with non-Susitna hydropower as needed would create additional adverse environmental impacts which the FERC analysis has failed to consider.Had FERC fully recognized the combined cumulative adverse consequences of either the thermal or the mixed thermal and non-Susitna hydropower generation that would have to be developed in lieu of Susitna,it would have concluded that the adverse impacts of its suggested alternatives far outweigh any environmental disruption associated with Susitna. - .~ ..- B. 5304/163 Environmental Assessment 30 - - The following is a summary of the key environmental difficulties of each alternative which the Power Authority believes have not been properly weighed in the DEIS analysis.and which should be considered in the FEIS analysis. 1.Unavoidable Impacts of Non-Susitna Hydro The unavoidable adverse impacts associated with the alternative hydro sites are significantly greater than the unavoidable adverse impacts associated with the proposed Susitna Project.Adverse impacts associated with the proposed SusitnaProject would occur relatively close in time and would be constrained to one relatively small area of the state.In con- trast.the adverse impacts associated with the hydro portion of the combined hydro-thermal alternative would occur over a longer period as additional units are constructed.and will severely impact at least ..five discrete areas within the state.The extent,magnitude and severity of each discrete impact for each alternative hydro site alone in some cases is greater than the extent.magnitude and severity of that same impact for the Susitna Project in some cases.The cumulative and sequential unavoidable adverse impacts associated with the five alternative hydro sites combined exceeds the comparable impacts associated with development of the Susitna Project. o o with The most significant unavoidable adverse impacts associated development or the five hydropower alternatives are as follows:. o Permanent dedication of approximately 125.000 acres of vegetated land.including high quality palustrine wetlands. to project features.with resulting permanent loss of wildlife habitat. Inundation of the Native village of Dot "Lake.and the community of the Living Word. Permanent inundation of a portion of the Nenana coal fields. as well as portions of the Alaska and George Parks Highway. the Alaska Railroad.portions of a Golden Valley Electric Association transmission line.a natural gas pipeline.a 5304/163 31 ,'fI{i!!i#t. - - o o o o o o o o power substation and the Alaska-Fairbanks Intertie. Alteration of the temperatures,flow regimes,ice regimes and turbidity of six rivers and one lake.These direct impacts necessarily lead to impacts on aquatic communities, including valuable and important anadromous fisheries,and terrestrial wildlife. Elimination of spawning and rearing habitats for all five Pacific salmon species in the Chakachatna and Talkeetna Rivers. Reduction in brown bear populations due to loss of salmon as a seasonal food. Loss of portions of white-water rafting and kayaking areas and river touring opportunities in the Nenana River and Talkeetna Rivers.< Permanent adverse impacts on subsistence hunting and fishing in the region of each site,and permanent loss of sport fishing opportunities. Severe adverse impacts on small communities near the five alternative hydrop9wer locations,including housing shortages,shortages in community services and revenues,and increased disruption of Native lifestyles. Permanent and severe impacts on visual aesthetics in widely dispersed areas of the state,due to construction of four dams and reservoirs (mud flats,beach erosion),transmission corridors,access roads,and relocation of highways, railroads and communities. Direct,possibly significant impacts on four nesting locations of the endangered peregrine falcon. 2.Johnson Dam and Reservoir---- Construction of the Johnson Dam and Reservoir would have extreme- ly adverse impacts on land resources in the project area.The reservoir itself would inundate approximately 94,500 acres of land.Beach erosion associated with the reservoir could be very extensive. 5304/163 32 i~ Relocation of 23 miles of the highway and the pipeline from the river flood plain to the foothills of the Alaska Range will result in significant impacts along the relocation route of those facilities, including slope stability problems. Two communities,the Native community of Dot Lake and The Living Word (at Dry Creek)would be inundated by the Johnson Reservoir,necessita- ting their relocation. Three species of salmon,the chinook,coho and chum,migrate upstream of the Johnson Dam site.It will be necessary to incorporate fish passage facilities into the Johnson Dam in order to facilitate both upstream and downstream passage of these fish.It is expected that the fish passage facility would be only partly successful in maintaining these runs given the size of the Johnson Reservoir and its water quality.It is questionable whether fish will be able to successfully navigate through the reservoir.The extensive habitat loss associated with this project would result in significant impacts to many wildlife species,especially big game.Habitat loss associated with ehe Johnson project is on the order of twice the loss associated with Susitna. 3.Keetna Dam and Reservoir---------'---- FERC's proposed Keetna project would be constructed on the Talkeetna River,a main tributary of the Susitna.Construction activities associated with obtaining impervious borrow materials from higher eleva- tions will significantly increase the occurrence of slope failure. Construction of the 25 mile long access road along the south bank of the river will have similar effects.Permafrost deposits in the area will increase the probability of permafrost thaw impacts,thus necessitating the incorporation of special engineering designs into the construction of the dam and all access facilities.Since glacial deposits will form the shoreline of the Keetna Reservoir,a worst-case analysis would indicate that slumping and slope failure could result from construction of the Keetna alternative. 5304/163 33 - - FERC underestimates the importance of the Talkeetna River as a spawning ground for the five species of Pacific salmon.Less than 25%of the migrating salmon continue up the Susitna above its confluences with the Chulitna,and Talkeetna Rivers.The majority,approximately 75%,migrate up the Talkeetna to spawn.Altered flow regimes could preclude downstream access into important sloughs,creeks and tributaries for spawning.The Alaska Department of Fish and Game (ADF&G)has specifically commented on the fishery impacts associated with the Keetna Site as follows: liThe potential fpr fisheries impacts with the development of the Keetna alternative hydro site appears to exceed any individual site discussed in t~e DElS.The Talkeetna River is a major" producer of salmon with rapidly increasing levels of recreational use.The DElS implies that little is known about the size and composition of fish migration up the Talkeetna River.The ADF&G regularly monitors chinook and sockeye salmon escapement on several major clearwater tributaries of the Talkeetna River. Prairie Creek,above the Keetna site,has the highest density of spawning chinook salmon per stream mile of any stream within the Matanuska-Susitna borough.Chinook salmon escapement in Prairie Creek generally range between 3,000 to 5,000 fish,but in 1976 it was as high as 6,513 fish.Equally important is the fact that these salmon support the highest concentration of brown bears during July and August of any known location within the Susitna basin.'Nearly 40 brown bears are attracted,to Prairie Creek to feed on chinook salmon.The ADF&G has recommended that this stream and its adjoining upland be protected from incompatible land uses.Prairie Creek also contains sockeye and coho salmon, but numbers are not well quantified. Disappointment Creek,located at the Keetna site has a chinook salmon escapement of 200-300 fish,and is also popular for rainbow trout and Dolly Vard~n fishing which occurs at its confluence with the Talkeetna River. Chunilna Creek,downstream of the Keetna site,is a major salmon producer and a major sport fishery occurs at its confluence with the Talkeetna River.On even years,pink salmon escapement often exceeds 250,000 fish.Chinook salmon escapements have been as high as 2,000 fish.Sockeye escapement into Fish Creek (a tributary to Chunilna Creek)range from 5,000 to 10,000 fish.Up to 2,500 coho salmon and 7,500 chum salmon have been estimated in this creek:Sport fishing onChunilna Creek averaged 4,260 user-days annually of fishing effort between 1977 and 1981. The potential impact of the Keetna dam on salmon resources is greater than what would occur with the Susitna development becaus~the Talkeetna River salmon populations greatly exceed those in the Susitna River above its confluence with the Chulitna 5304/163 34 }J .- - - ,~r River.The size,composition and behavior of fish runs above and below the Brown~and Johnson site are less well known and the magnitude of impacts are difficult to compare with the Susitna."!/ 4.Browne Dam and Reservoir The Browne Dam would be loc~ted on the Nenana River approximately-, 65 air miles southwest of Fairbanks.The proposed reservoir will inundate· rail,highway and electric utility corridprs.As with the Johnson alterna- tive,the Browne alternative would require extensive and expensive relocations.It would be necessary to relocate approximately 16 miles of railroad and nine miles of highway.Each could be relocated o~to steeper slopes than exist at current location thus resulting in more highly exposed excavations,and increased slope stability problems.The existing Golden Valley Electric Association transmission facility and a portion of the Anchorage-Fairbanks Intertie would have to be relocated. Land use in the Brown site area consists mainly of low intensity dispersed recreational use.Coal d~posits and some mining occur in the area east of Healy.The Browne Reservoir would inundate a portion of the Nenana coal fields,but not where mining is now occurring.The DEIS does I not discuss the effect of such.inundation'on the feasibility of its coal- fired alternative. In contrast to the DEIS finding that no anadromous fish occur at the potential Browne site,chinook,chum and coho salmon occurrence have been reported by the ADF&G to occur upstream of the Browne site.Fish passage facilities would be needed.Again,a reasonable worst-case analy- sis would indicate that such facilities would be only minimally successful. Chum salmon could virtually be lost above the site. Yanagawa,C.M.-ADF&G Regional Supervisor,Habitat Division 1984 Memorandum to Jack Heesch OMB Project Coordinator on Susitna Hydroelectric Project DEIS. 5304/163 35 ..... ...... "'" .... - 5.Snow Dam and Reservoir The Snow Dam would be located in a bedrock gorge in the Snow River near the southern end of Kenai Lake.Although the small size of the Snow Reservoir and its location in a bedrock gorge will minimize the length of shoreline subject to erosion and the potential for slope failures.the probability that erosion and slope failures will occur is still high.For example.excavation of impervious borrow would significantly increase the possibility of slope failures in the area.Glacial outburst floods on the Snow River have been observed on the average of every three years.Special operating instructions.and incorporation of costly engineering designs to facilitate control or passage of such flooding.would be necessary. Development of the Snow site will result in the inundation of Lower Paradise Lake and a significant resident species recreational fishery of grayling and rainbow trout at that location.In contrast to the state- ment in the DEIS that no anadromous fish are known to occur in the Snow River.coho and sockeye salmon spawning areas exist in the Snow River down- stream of its confluence with the south fork.The coho and sockeye salmon contribute to the highly important Kenai River sport and commercial fisheries.These could be adversely affected by development of the project. 6.Chakachamna Alternative Site This alternative would affect the Chakachatna River,Noaukta Slough.the MacArthur River and Chakachamna Lake.It entails diverting Chakachamna Lake water to the MacArthur River.Chakachamna Lake and its upstream tributaries provide major rearing habitat for some 40.000 sockeye. Decreasing flows in the Chakachatna River will adversely impact anadromous fish in the lower river including the important rearing areas on Noaukta Slough.Access to important spawning areas and tributaries and sloughs will be eliminated.The diversion of Chakachamna Lake water to the MacArthur River would result in miscuing.straying and delay of anadromous fish that normally spawn above Lake Chakachamna.Increased flows in the 5304/163 36 .- .... r, .... MacArthur River are also expected to inhibit upstream migration of salmon. Lake tapping could affect the lake's nutrient balance,and will increase temperatures.Operation of the project is expected to create significant changes in the hydraulic regime of the McArthur and Chakachamna Rivers,with potential adverse consequences for fish habitat. 7.Thermal Generation a.Natural Gas Fired Generation FERC has proposed alternate generating scenarios which vary in the extent to which gas is used.FERC proposals range from 10 combustion turbines of 70 MW under its coal scenario,tq 8 combined-cycle 200 MW plants with two 70 MW combustion turbines under its all-gas scenario,to only three combustion turbine 70 MW plants with three 200 MW combined-cycle plants under the mixed thermal/hydro scenario.All of these'scenarios have been found environmentally preferable to Susitna;however,the DEIS seriously understates the impacts of even the all-gas scenario,its "cleanest"alternative.'FERC seems to has assumed a ~impact without data or supporting analysis.The National Environmental Policy Act (NEPA) requires a reasonable,worst-case analysis when such data gaps exist. "Available data indicate several significant impacts of gas generation which should be included in the FEIS.The severity of these impacts will vary, depending upon the extent to which gas is a component of any alternate , generation scenario. The cumulative effects of carbon monoxide (CO)emissions from the Anchorage combustion-cycle plants,which will result under all of the DEIS thermal and mixed thermal-hydro scenarios,could significantly increase ground-level CO concentrations.Since Anchorage is a nonattainment area now,further public health degradation would occur. Total NO ,TSP and secondary aerosols from the combined-cyclex plants can create regional haze in the Cook Inlet area under reasonable, worst-case conditions.Visibility would be degraded for the substantial 5304/163 37 - proportion of the citizens of Alaska who live around the Cook Inlet. Gas-fired power plants generate considerable noise.Effects on Wildlife and humans within areas of significant audibility could occur. The DETS lists potential sources of water pollution and states that adequate protection will be provided.There is no methodology included in the DEIS to determine the potential impacts of each of the pollution sources upon surface water quality or quantity.Further,there is no background data on.existing surface and ground water quality and quantity.Therefore,this.assertion is unsupported. The DEIS does not identify the locations of the combined-cycle units or combustion-turbine units for purposes of analyzing specif~c impacts.FERCmust either make its siting choice for gas plants.or utilize assumptions regarding reasonable,worst-case siting. FERC has failed to estimate properly the amount of wetlands to be affected by plant construction and operation.If the exact acreage of. wetlands affected by construction and operation cannot be calculated,the DEIS must include a worst-case analysis. Using reasonable,worst-case assumptions,visual effects could also be significant due to the highly scenic character of the potential areas subject to industrial development. b.Coal-Fired Generation Scenario' As with gas generation FERC has assumed varying levels of coal usage in its proposed generating alternatives,which range from one 200 MW plant with the mixed thermalnon-Susitna hydro plans to five 200 MW coal plants in the all coal scenario,and has fqund them all environmentally superior to Susitna. FERC underestimates the impacts of coal fired development.Below 5304/163 38 ~, is an inventory of potential effects of increased coal usage. Land.The DEIS admits that increased levels of potentially hazardous materials in soil might occur without identifying the materials or their degree of hazard. When considering worst-case estimate of the amount of land required for mining coal,the potential for acid leachate into soil from mining,leachate of hazardous materials from flyash and spent limestone slurries,the level of wind erosion of soils,modification of surface drainage and topography,and slope failures due to excavation and permafrost that result from vegetation stripping,it should be concluded that significant adverse effects can result. Climate,Air Quality,Noise.Significant air impacts of both the Nenana mine and coal transport,have been ignored in the DEIS.The effects can be significant.The air quality impacts of the three 200 MW coal-fired plIilIB,plants at Nenana and the two 200 MW plants at Willow were studied by the Power Authority.Hypothetical power plant sites near both cities were assumed,to show the impacts that would be caused by power plants in the area.The impacts of the Lignite Creek coal mine expansion and the impacts of the required coal unit trains have also been investigated.The results of the analyses are as follows: 5304/163 o o o The coal mine expansion would create long-term fugitive dust impacts in the Lignite Creek valley and would also impact Denali National Park. "Fugitive dust from the coal-fired power plants would create long-term impacts near the power plants.The fugitive dust might cause exceedances of the PSD Class II increments near the power plants. Stack emissions from the power plants would cause long-term impacts in a large area around each plant.S02 emissions would create the most significant impact.The calculated worst case S02 concentrations near both the Nenana and 39 .... ..... ..... o o Willow power plants are approximately 41 percent of the allowable PSD Class II increment.Stack emissions from the Nenana power plant would cause increases in the pollutant concentrations in Denali National Park. The degradation of visibility caused by the power plant plumes would be long term and would affect many key vistas that are considered a valuable cultural resource in Alaska. Ice fog and steam plume formation from the gas-fired power plants could be a significant siting constraint.The gas-fired power plants near Anchorage could have a significant impact on carbon monoxide,nitrogen dioxide,and ozone concentrat~ons in the urban area. The noise impacts of the coal mine blasting,continuous mining operations,coal unit trains,and the power plants were estimated,using realistically worst case assumptions.The results of the analyses are as follows: /'- I o o o o Blasting noise from the mine would probably be audible in .some parts of Denali National Park.The blasting noise would occur daily. The continuous mining noises would affect a large area in the Lignite Creek valley. The coal unit trains would create long-term noise impacts along the'entire railway between Nenana and Willow.The coal trains would add significantly to the existing rail traffic along the Alaska Railroad. The power plants would create long-term noise impacts, affecting a large area around each facility.Noise impacts on residential areas would be a major si·ting constraint for the gas-fired power plants in the Anchorage area. Aesthetics.The potential aesthetic impacts of the coal mine, unit trains,and the power plants were considered.The results of the 5304/163 40 o o .... .... .... I .... .... .... aesthetic impacts evaluations are as follows: o The unit trains would create very significant,long-term aesthetic impacts.The unit trains would add significantly to the existing rail traffic along the Alaska Railroad. The power plants would create long-term,significant impacts for ground travelers and air travelers along the Railbelt. The large industrial facilities would probably be constructed in otherwise pristine areas.The disruption of the environment would be especially noticeable to air travelers • Water Quantity/Quality.The water ,quality impacts of the coal mining operations and the power plants would be long term.The estimated impacts are as follows: o The coal mining operations would cause long-term and possibly irreversible groundwater impacts in the Lignite Creek area.Surface runoff from the mining operations would cause changes in streamflows and increases in stlspended sediments in surface waters. The power plants would require long-term water supply sources.The power plarits would continuously discharge treated wastewater to the receiving streams,causing long-term changes in water quality . Terrestrial Ecology.The combined five coal-fired power plants would create long-term disruption of approximately 3,000 acres.Additional long-term terrestrial disruption wotlld be caused by the access roads, railroad spurs,and gas pipelines • Aquatic Ecology.The potential impacts of the gas pipelines, access roads,coal mine,and the power plants would be a major constraint on the thermal power alternatives.The facilities would have to be designed to avoid potential significant impacts on anadromous fish spawning grounds. ~ I 5304/163 41 8. ..... I I Socioeconomic Impacts.Construction and operation of the power plants could cause significant socioeconomic impacts in the small communities near the power plant sites.The communities could be faced with the need for more educational facilities,medical services,and social services due to the influx of temporary workers during the power plant construction. Comparison of Impacts of Susitna and DEIS Preferred Mixed Thermal-Hydro Alternative The following table highlights for comparison purposes the environmental consequences of Susitna versus the combined hydro-thermal alternative recommended in the DEIS as the FERC preferred.alternative.The table illustrates that the aggregate effects of the combined hydro-thermal alternative are far more disruptive to the environment than Susitna would· be. ENVIRONMENTAL EFFECTS OF SUSITNA AND DEIS HYDRO-THERMAL ALTERNATIVE - Impact a.noise and fugitive dust during 1.constructioh 2.operation Proposed Project present none Hydro-Thermal Alternative present significant for coal mining and transport .-b.population significant increase in small adjacent communities c.permanent loss of lands significant;plus loss of Dot Lake and The Living Word communities 1.facilities / road/transmission 2.impoundments 3.mines 15,000 45,000 ° ac. (hydro + 8,000 ac.+ 115,000 ac.+ o + thermal) 625 ac.°ac. 450 ac. Total 60,000 ac.123,000 ac.+1075 ac. -5304/163 Grand Total = 42 124,000 ac. .- d.permanent loss of marsh and pond type wetlands none significant;more than 30,000 acres lost .... e.impacts to wildlife loss of moose habitat habitat and wetlands significant loss of moose habitat f.permanent impacts on subsistence use ,~ g.permanent impacts ~,on recreational hunting -h.permanent impacts on aquatic habitat and fish .- i.loss of recrea- tional fishing minor subsistence use of wildlife in project area redistribute access opportunities among hunters escapement of 2000-4000 salmon at risk if no mitigation.With mitigation,no net loss . minor loss associated with impoundments,redistri- bution of fishing opportunities Johnson impoundment critical to Dot Lake Native Community Redistribute access opportunities among hunters· escapement of 50,000 to .100,000 salmon at risk if no mitigation.Permanent loss of several thousands chum for Johnson site. loss associated with impoundments - j. k. 1. m. permanent loss of recreational white water permanent loss of river navigation visual impacts degradation of air quality loss of several miles of class VI waters minor impact on Portage to Talkeetna Reach.Opens navigation through Vee Canyon. present.Project in remote area,transmission enters developed corridors none loss of several miles of class IV waters major impact on Lower Tanana River present,some projects remote,some in developed areas.Plumes and haze impact widespread in substantial population areas significant in major population areas. - - C.Cost Assessment FERC seriously understates the costs of both the mixed non-Susitna hydro-thermal alternative and the all thermal alternatives.In so doing,the DEIS analysis is skewed to make alternatives appear more attractive than Susitna.Inclusion of all costs of alternatives in the 5304/163 43 •I en .... .... comparison would have reduced the alleged economic benefits of the alternatives.Below are summarized cost data on alternatives which should be factored into the FEIS analysis.These data are developed in more detail in the supporting Appendices II and III,Evaluation of Non-Susitna Hydroelectric Alternatives,and Thermal Alternatives to Susitna. 1.Hydro Alternatives While FERC does not explain the manner in which construction costs for the non-Susitna hydro alternatives were estimated,it is apparent that the 1980 Development Selection Report (DSR)prepared by Acres American,Inc.,which contained screening level estimates for the alternative hydro projects,was compared with 1982 feasibility estimates for the Susitna Proj ect.The result is i11us,trated in the following table. DSR Cost DElS Cost 3/Apparent(1980 Level,(1982 Level, x 10 6 )x 106) Escalation, $$DSR to DEIS 624 681 9%increase 896 1.1 319 2)64%decrease 476 519 9%increase 254 305 20%increase 1,480 905 39%decrease Project I""'>Alternatives Browne Johnson Keetna Snow Chakachamna Alternative Total r-" 3,733 2,729 27%decrease Proposed Project 2,860 5,565 1::./95%increase ......... Jj 5304/163 A cost for Johnson was not included in the DSR.The cost shown was computed using DSR quantity estimate~ and unit costs for Browne,Keetna,Snow . Basis for cost presented in DElS unknown. DEIS costs used by FERC; $5,565 million cost for the Proposed Project is a check estimate presented in the July 11,1983 supplement to the License App1ica- 'tion filing for comparison purposes.A more current estimate (by the Power Authority)of $5150 million was presented in License Application. 44 "... - When the costs of the hydro alternatives are brought to a level appropriate for comparison with the Susitna Project,the analysis shows that the costs of the alternatives are significantly greater than those stated in the DElS.FERC should incorporate in its FElS the revised cost parameters for the hydro alternatives. In addition,studies of the power and energy production of alternatives,which are presented in the Appendix II of this document, suggest that when energy generation is matched to load growth,the avail- able annual energy of the alternatives cannot be absorbed by the system until 2025.Also,the studies show that the December 2010 total dependable capacity of the alternatives would only be 34%of the total installed capacity of the alternatives. 2.Thermal Generation As mentioned earlier,the costs of coal-fired powerplants have received closer examination since the filing of the License Application. Recent actions by the Alaska Department of Environmental Conservation indicate that they would employ best available containment technology cri- teria on new coal plants,and would seek containment in the high range of 95 to 98%.Achieving these objectives would prove technically difficult in the subarctic conditions of the interior and would substantially increase capital and operating costs of these facilities.Recent Power Authority studies have demonstrated that the operating and maintenance costs,capital costs,and other cost components of coal plants are greater than earlier believed.Fixed costs have increased by more than a factor of three,while variable costs have increased by more than a factor of six.Moreover,the coal quality is less than previously calculated.Both of these factors further reduce the economic attractiveness of coal-fired units in any generation plan.Revisions to cost estimates of other thermal plants are also indicated by the Power Authority's studies.These revisions are pre- sented in Appendix I of this document. 3.Susitna Basin Alternatives Although FERC finds that the mixed thermal-based,with non- 5304/163 45 ,~ - - - Susitna hydro,scenario would be the most reasonable alternative,the DEIS states that should any hydroelectric development be authorized in the Susitna Basin,the first stage of this development would be the Watana I alternative.This development would be identical to the Proposed Project, except that Watana dam would be scaled down to have a crest elevation of 2125 feet (648m)and a normal reservoir level of 2100 feet (640m). FERC estimates the total construction cost of the proposed Watana Development to be $4,062 million (1982 $).The Watana I alternative is estimated by FERC to be $3,494 million (1982 $).Studies conducted by the Power Authority since the filing of the Application indicate that the cost estimate for the proposed Watana Project is ~onsiderably less than the estimate presented in the DEIS.(The revised cost estimate for both Watana and Devil Canyon is $4,830 million in 1982 $). The future opportunity to develop fully the Susitna River should not be precluded by a Watana I project.Therefore,cost estimates for Watana I should include those steps necessary to permit subsequent raising of the dam height to the full License Application elevation.Although the Watana I alternative has an obvious lower cost resulting from the lower dam height,the Power Authority analyses indicate that the Proposed Project is the optimum development for the Susitna Basin. As presented in Figure B-19 of the License Application,the Watana Project as proposed results in a net benefit when compared to Watana I.In addition,Watana at reservoir elevation 2185 develops the full hydroelectric potential of the site. VII.Conclusion In the DEIS,FERC states that it favors a mixed hydro-thermal generation scenar~o based on considerations of economic feasibility, environmental impact and engineering.As shown in this Executive Summary and in greater detail in the Technical Comments and the Appendices.the proposed Susitna Project is preferable on all grounds,when it,and 5304/163 46 "n 1 - alternatives to it,are given a balanced assessment.At a minimum,the FEIS should incorporate the most current data available,particularly that within this Comment Document,which has been supplied to FERC on a continuous basis since the License Application filing.FERC should use such data to conclude that the Proposed Project represents the preferred means of meeting the future electrical needs of Alaska's Railbelt. 5304/163 47 - -- BIBLIOGRAPHY For Alaska Power Authority Comments on the Federal Energy Regulatory Commission Draft Environmental Impact Statement of May 1984 This Bibliography is organized according to the five categories of the Technical Comments.Within each category,the references are listed alphabetically by author.For brevity,the following acronyms are used ~n the citations. - ..... .... .- Acronym Acres ADF&G ADNR AEIDC AlEE AK. ALUC APA ASL Battelle BLM BP CaE DCED DOE EBASCO EPA FERC 28052 840820 Affiliation Acres American,Inc. Alaska Department of Fish apd Game Alaska Department of Natural Resources Arctic Environmental Information and Data Center American Institute of Electrical Engineers State of Alaska (General) Alaska Land Use Council Alaska Power Authority Alaska State Legislature Battelle Pacific Northwest Laboratories Bureau of Land Management British Petroleum Corps of Engineers Alaska Department of Commerce and Economic Development u.S.Department of Energy Ebasco Services,Inc. U.s.Environmental Protection Agency Federal Energy Regulatory Commission 1 - - .- - Acronym FNSB FDA HE lEA IEEE ISER NOAA NPS O&GCC PND R&M SHeA SHP TES UAM USBR USDASCS USGS 28052 840820 Affiliation Fairbanks -North Star Borough Frank Drth and Associates Harza-Ebasco Susitna Joint Venture International Energy Agency Institute of Electrical and Electronics Engineers,Inc. Institute of Social and Economic Research National Oceanic and Atmospheric Administration National Park Service Oil and Gas Conservation Commission Peratrovich,Nottingham &Dr~ge,Inc. R&M Ass~"~iates Sherman H.Clark Associates Susitna Hydroelectric Project Terrestrial Environmental Specialists University of Alaska -Museum U.S.Bureau of Reclamation u.s.Department of Agriculture,Soil Conservation Service U.S.Geological Survey 2 ..... ..... '"'" ..... - -..... ..... NEED FOR POWER Citation Acres 1983.SHP -Feasibility Report,Chapter 18.1983. AlEE 1960.AlEE Committee Report,Application of Probability Methods to Generating Capacity Problems, Paper 60 1185 presented at the AlEE Fall General Meeting,Chicago IL,Oct.1960. AK DCED 1983.Alaska Department of Commerce and Economic Development (DCED).1983.State of Alaska Long Term Energy Plan 1983. AK O&GCC 1983.State of Alaska Oil Gas Conservation Commission,Statistical Report,1983. Battelle 1982~l.Existing Generating Facilities and Planned Additions for the Railbel t Region of Alaska. Volume VI.September,1982. Battelle 1982b.Candidate Electric Energy Technology for Future Application in the "Railbel t Region of Alaska. Richland WA.Volume IV.October,1982. BP 1984.Statistical Review of World Energy 1984. British Petroleum,London.June 1984. DOE 1980.Demonstrated Reserve Base of Coal 1n the Uni ted States as of January 1 •.1980. EBASCO 1983.Use of North Slope Gas for Heat and Electricity in the Railbelt.1983 • EKONO 1980.Peat Resource Estimation in Alaska.Final Report.Vol.1.Bellevue,WA.August 1980. Technical Comment Numbers NFP042 NFP035 NFP020 NFP038 NFP098 NFP032 NFP044 NFP046 NFP105 NFP106 NFP107 NFP092 NFP018 NFP092 NFP015 NFP044 NFP105 28052 .QLdl.Q .,n 3 NEED FOR POWER (cont.) Cit1!l.tion--- Energy Resources Co.1980.Low Rank Coal Study:National Needs for Resource Development.Walnut Creek,CA. Vol.2.(For U.S.DOE,Contract DE-AC-108-79FC1006). FERC 1979.Hydroelectric Power Evaluation.DOE/FERC- 0031.Washington,D.C.August 1979. lEA 1984.Oil Market Report -Monthly Oil Market and Stocks Assesslnent.July 1984. Technical Comment Numbers NFP018 NFP032 NFP050 NFP092 IEEE 1977.Symposium Dynamic Performance. pp.32-42. On Reliability Criteria for System 77CH122l-l-PWR.New York,NY. NFP035 ..- - IEEE 1982.Power System Reliability Evaluation.Tutorial Course,Publication 82EHO 195-8-PWR.pp.54, 56. Kresge,D.T.,T.A.Morehouse,and G.W.Rogers 1977. Issues in Alaska Development.ISER,Univ.of AK.Univ. of WaEhington Press,Seattle 1977. Mabuce,E.M.,R.L.Wilks,S.B.Boxerman 1975. Generating Reserve Requirements -Sensitivity to Variations in System Parameters.IEEE Paper PG-75-65l-0 presented at the 1975 Joint IEEE/ASME/ASCE Power Generation Technical Conference.Portland,Oregon. Sep.28-0ct.1,1975 SHCA 1984.1984 GNP Forecasts compiled from the literature '(i\lall Street Journal,Fortune,and Business Week). Van Der Tak,H.G.1966.The Economic Choice Between Hydroelectric:and Thermal Power Developments.World Bank Staff Oc:casional Papers Number 'One,John Hopkins Press Baltimore.1966. Woodward-Clyde Consultants,Inc.1980.ForecastingPeak Electrical Demand for Alaska'sRailbelt.December 1980. NFP035 NFP009 NFP035 NFP089 NFP050 NFP051 28052 RLdlR?O 4 ~ i I - ...., - - ,- - ALTERNATIVES Citation Acres 1981.SEP-Task 6,Design Development.Development Selection Report.December 1981 • Acres 1983.SHP-Feasibility Report Supplement,Vol.1, Engineering and Economics.April 1983. ADF&G 1983i.Anadromous Waters Catalogue.Division of Habitat protection,Juneau,AK. ADF&G 1983j.A.nnual Management Report,1983,Yukon Area. Division of Commer-cial Fisheries. ADNR 1984.Letter from R.Merritt of ADNR to J.Wilder of Harza-Ebasco.June 22,1984. APA 1984.Letter from J.Ferguson to Mr.R.Martin of Alaska Dept.of Environmental Conservation. February 24,1984. Battelle Memorial Institute 1966.Talkeetna Joint Frequency Data Summarized from Tape-Deck TD1440 (NOAA) by Pacific Northwest Laboratory.Richland.WA.1966. Bechtel Civil and,Minerals,Inc.1983.Chakachamna Hydroelectric Project Interim Feasibility Assessment Report.Vol.II.Appendix to Section 6.0 and Environmental Appendix Al.A.5 Alaska Power Authority, Anchorage,Alaska. Technical Comment Numbers ALT004 ALT068 ALT019 ALT030 ALT031 ALT032 ALT033 ALT049 ALT054 ALT029 ALT049 ALT079 ALT036 ALT037 ALT038 ALT075 ALT078 ALTOI0 ALT019 28052 RLL0820 5 - - ALTERNATIVES (Cont'd) Citation Bentz,R.1983.Inventory and Cata-10ging of Sport Fish and Sport Fish Waters in Upper Cook Inlet,Vol.24. ADF&G.Federal Aid in Fish Restoration and Anadromous Studies. Bilello,M.A.1966.Survey of Arctic and Subarctic Temperature Inversions.U.s.Army Material Command, Cold Regions Research and Engineering Laboratory. October 1966. EPA 1977.Guidelines for Air Quality Maintenance, Planning and Analysis.Volume 10.EPA 450/4-77-001. October 1977. EPA 1980.Workbook for Estimating Visibility Impairment. EPA 450/4-80-031.November 1980. Gilbert CommorMea1th 1983.The Anchorage-Fairbanks Transmission Intertie. Latimer,D.A.,H.Rogo,and T.C.Daniel 1981.The Effects of AtllllOspheric Optical Conditions on Perceived Scenic Beauty.Atmos.Environment 15(10/11),1865-1874. MacC1arence,~1.1984.Personal Communication.Alaska Dept.of Environmental Conservation.June 28,1984. MaIm,W.C.1980.Human Perception of Air Quality.J.Air Pollution Control Association 30(2),122-131. February 1980. MaIm,W.C.1981.Ruman Perception of Visual Air Quality (Uniform Raze).Atmos.Environment 15(10/11),1875- 1890. MaIm,W.C.1984.Personal Communication.National Park Service,Ft.Collins.June 1984. Technical Comment Numbers ALT031 ALT078 ALT038 ALT075 ALT045 ALT052 ALT045 ALT045 ALT008 ALT015 ALT045 ALT045 ALT045 628052______,.l,I8i.':.t4~Qi.l.l8:.=2o.l\OQ:....__-__..:.._ ..... - ALTERNATIVES (cont.) CitaLtion McHenry,T.1984.Personal Communication.ADF&G. Seward,AK. Middleton,P.,Stewart T.R.,Dennis R.L.,and Ely D. 1983.Implications of N,CAR I S Urban Visual Air Quality Assessment Method for Pristine Areas;Managing Air Quality and Scenic Resources at National Parks and Recreation Are!as,edited by R.D.Rowe and L.G.Chestnut. Westview Press.1983. Miller,S.~983.Phase II Progress Report,Big Game Studies,Vol.VI -Black Bear and Brown Bear.Alaska Power Authority. Mills,M.1983.ADF&G Statewide Harvest Study.Sport Fish Division 1983. NOAA 1979a.Climatography of the United States,No.90. 1965-1974.Airport Climatological Summary for FairbanksInternational and AnchorageAirports.National Climatic.Cente!r,Asheville,N.C.1979. Petrich,D.H.1979.Aesthetic Impact of a Proposed Power Plant on an Historic Wilderness Landscape.Proceedings of Our National Landscape:A Conference on Applied Techniques for Analysis and Management of the Visual Resource.USDA Forest Service General Technical Report PSW-35.1979. R&M 1982j.SliP-Processed Climatic Data,Vol.5,Watana Station.March 1982 R&M 1982k.SliP-Processed Climatic Data,Vol.6,Devil Canyon Station.March 1982 R&M 19821.Sm?-Processed Climatic Data,October'19B1 thru September 1982 Vol.5,0650 Watana Station, December 1982 R&M 1982m.Sm?-Processed Climatic Data,October 1981 thru September 1982 Vol.6,0660 Devil Canyon Station, December 1982 Technical Comment Numbers ALT019 ALT045 ALT031 ALT049 ALTO 78 ALT045 ALT022 ALT072 ALT022 ALT072 ALT022 ALT072 ALT022 ALT072 28052 840820 7 r I -i ..... - ALTERNATIVES (cont.) Citation U.S.Air Force 1983.Revised Uniform Summary of Surface Weather Observations.Environmental Technical Applications Center,National Weather Service,Scott Air Force Base,Illinois,1983. Watsjold,D.1984.Personal Communication,ADF&G. Anchorage,AK. Technical Comment Numbers ALTO 78 ALT031 28052 840820 8 .... AQUATIC RESOURCES Citation Acres 1983.SHP-Draft Slough Hydro geology Report. March 1983. ADF&G 1981.SHP-Subtask 7.10,Phase 1 Final Draft Report,Adult Anadromous Fisheries Project • Technical Comment Numbers AQ4098 AQRl19 ADF&G 1983a.SI~-Aquatic Studies,Phase II Report. Synopsis of thE~1982 Aquatic Studies and Analysis of Fish &Habitat Relationships.1983. .... .... ADF&G 1982.SHP-Susitna Final Data Report,Vol. Studies,1982,Part B: Hydro Aquatic Studies Phase 2,Adult Anadromous Fish Ap·pendices A-H II,AQR072 AQR072 AQR073 AQR039 .... .... ADF&G 1983b.First Draft.1983 Phase 1I,Adult Anadromous Investigation.Susitna River Hydro Aquatic Studies 1983. ADF&G 1983c.Susitna Hydro Aquatic Studies Phase II. Basic Data Report,Vol.3.Resident and Juvenile Anadromous Fish Studies on the Susitna River Below Devil Canyon,1983. ADF&G 1983d.Susitna Hydro Aquatic Studies Phase II Basic Data Report,Vol.3.Resident and Juvenile Anadromous Fish Studies on Susitna Below D~vil Canyon, 1982,Appendices . ADF&G 1983e.Susitna Hydro Aquatic Studies Phase II, Basic Data Report,Vol.4.Aquatic Habitat &Instream Flow Studies,982.Parts I and II.1983. ADF&G 1983f.Susitna Hydro Aquatic Studies Phase II, Data Report,Yirinter Aquatic Studies.October 1982-May 1983. ADF&G 1983g.Susitna Hydro Aquatic Studies Phase II, Basic Data Report,Vol.4,Aquatic Habitat &Instream Flow Studies,1982,Appendix A through C. AQR119 AQR087 AQR097 AQR123 AQR068 AQR108 AQR072 AQR073 AQR119 AQR108. 28052 84°6 2 0 9 'i .... .... AQUATIC RESOURCES (cont.) Cit.ation ADF&G 1983h.Susitna Hydro Aquatic Studies Phase II, Final Data Report,Vol.2,Adult Anadromous Fish Studies,1982 ADF&G 1984b.Susitna Hydro Aquatic Studies.Report No. 1.Adult Anadromous Fish Investigations,May-October 1983. ADF&G 1984c.Susitna Hydro Aquatic Studies, (Provisional),Report No.3,Part I,Chapter 1 (Appendix).Aquatic Habitat and Instream Flow Investigations (May-October 1983). ADF&G 1984d.Susitna Hydro Aquatic Studies Report 2, Resident and Juvenile Anadromous Fish Investigation (May-October 1983)July 1984. AEIDC 1983a.SHP-Aquatic Impact Assessment Effects of Project-Related Changes in Temp.,Turbidity,&Stream Discharge on Upper Susitna Salmon Resources. Technical Comment Numbers AQR043 AQR085 AQR068 AQR072 AQR079 AQR083 AQR087 AQR090 AQR115 AQR130 AQR131 AQR141 AQR013 AQR024 AQR081 AQR043 AQR092 AQR091 AQR089 AQR1l9 AQR080 AQR059 AQR123 AQR036 AQR081 AQR100 28052 840820 10 AQUATIC RESOURCES (cont.) Cito!ltion Technical Comment-----Numbers AEIDC 1983b.Stream Flow and Temperature Modeling In the AQR033 Susitna Basin,Alaska. ,.... I I Bell,M.C.1980.Fisheries Handbook of Engineering Requirements and Biological Criteria.Prepared for U.s. Army COE,Portland District.February 1973 (Revised 1980). Brett,J.r.,V.E.Shelbrown,and C.T.Shoop.1969. Growth Rate and Body Composition of Fingerling Sockeye Salmon Oncorhynchus nerka,in Relation to Temperature· and Ration Size.J.Fish Res.Bd.Can.26:2363~2394. Brett,J.R.1974.Tank Experiments on the Culture of Pan-sized Sockeye (Oncorphyncus nerka)and Pink Salmon (0.gorbuscha)using Environmental Control. Aquaculture,4:341-352. Brett,J.R.,W.C.Clarke,and J.E.Shelborn 1982. Experiments 011 Thermal Requirements for Growth and Food Con version Efficiency of Juvenile Chinook salmon. Oncorynchus tshawytscha.Canadian Technical Report of Fisheries and Aquatics Sciences No.1127. I,- Chow,Ven Te (ed.)1964.Handbook of Applied Hydrology. McGraw-Hill.New York. Crisp,D.T.1981.A Desk Study of the Relationship Between Temperature and Hatching Time for Eggs of Fish Species of Salmonid Fishes.Freshwater Biology·il:361- 368. Davis,S.M.and·R.J.H.DeWeist 1966.Hydrogeology.John Wiley and Sons.New York. AQR123 AQR123 AQRl06 AQR123 AQR082 AQR057 AQR123 AQR008 AQR028 AQR1l9 AQR036 - Elliott,J.M.1975.The (Salmo trutta L.)Fed on Ecol.44:823-842 28052 840820 Growth Rate of Brown Trout Reduced Rations.J.Anim. 11 AQR123 .- - .!,""",. ..- - r- I I I AQUATIC RESOURCES (cont.) Citation Forster,R.E.1968.The Sockeye Salmon Oncorynchus nerka.Fisheries Research Board of Canada,Ottawa, Canada.422 pp. Grau,E.G.,W.W.Dickhoff,R.S.Nishioka,H.A.Bern, L.C.Folmar,1981.Lunar Phasing of the Thyroxide Surge Preparatory to Seaward Migration of Salmonid Fish. Science 211:607-609. Gulland,J.1974.The Management of Marine Fishes. University of Washington Press.Seattle,Washington. HE 1984a.SHP-Slough Geohydrology Studies. HE 1984b.Water Surface Profiles and Discharge Rating Curves for Middle and Lower Susitna River.Draft Report. January 1984.Volumes 1 and 2. HE 1984c.SHP-Reservoir and River Sedimentation.Final RepOrt.April 1984. HE 1984d.SHP-Instream Ice,Calibration of Computer Model.Final Report.April 1984. HE 1984e.SHP'-Eklutna Lake Temperature and Ice Study. Final Report."April 1984. Imberger,J.,and J.C.Patterson,1981.A Dynamic Reservoir Simulation Model:DYRESM 5,"Transport Models for Inland and Coastal Waters.Chapter 9,Academic Press,1981. Johnson,R.L.1975.Prediction of Dissolved Gas at Hydraulic Structures.U.S.Bureau of Reclamation: GR-8-75. Technical Comment Numbers AQR078 AQR083 AQR087 AQR088 AQR088 AQR141 AQR035 AQR067 AQR071 AQR074 AQR036 AQR006 AQR008 AQR025 AQR028 AQR098 AQR071 .AQR037 AQR030 AQR032 AQR032 AQR031 28052 840820 12 - - ..... - AQUATIC RESOURCES (cont.) Citation Lagler,K.F.,J.E.Bardach,R.R.Miller 1962. Ichthyology.John Wiley and Sons,,Inc.N.Y.545 pp. McPhail,J.D.and C.C.Lindsey,1970.Freshwater Fishes of Northwestern Canada and Alaska.Bulletin 173 Fisheries Research Board of Canada.Ottawa,Canada. Morrow,J.E.1980.The Freshwater Fishes of Alaska. Alaska NorthwE~st Publishing Co.Anchorage 1980. Patterson,J.G.,P.F.Hamblin~and J.Imberger.1984. "Classification and Dynamic Simulation of the Vertical Density Structure of Lakes,"Limnology and Oceanography. Vol.29,No.4.,1984. PND 1982.SHP-·Susitna Reservoir Sedimentation &Water Clari ty Study" Quane,T.1984.Personal Communication,ADF&G, Anchorage,Alaska July 1984. R&M 19810.SHP-Task 3,Hydrology,Ice Observations 1980-1981.August 1981. R&M 1981c.SHP-Task 2,Surveys &Site Facilities, Hydrographic Surveys.October 1981. R&M 1981d.SliP-Task 2,Survey &Site Facilities.Subtask 2.16 -Closeout Report,Hydrographic Surveys.October 1981. R&M 1982a.SHP-Task 3,Hydrology,River Morphology. January 1982. R&M 1982b.SHP-Task 3,Hydrology,Hydraulic and Ice Studies.Marctl 1982. Technical Comment Numbers AQR088 AQR078 AQR095 AQR144 AQR032 AQR023 AQR076 AQR043 AQR071 AQR009 AQR098 AQR098 AQR098 AQR098 AQR0,74 AQR098 AQR028 AQR067 -.,28052 840820 13 - - - AQUATIC RESOURCES (cant.) Citation R&M 1982c.SHP-Task 3,Hydrology,Processed Climatic Data,Vol.6,Devil Canyon Station.March 1982. R&M 1982d.SHP'-Processed Climatic Data May 1982 Through September 1982,Vol.7,0665-Sherman Station December 1982. R&M 1982e.SHP'-Task 2,Surveys and Site Facilities,1982 Hydrographic Surveys Report.December 1982. R&M 1982f.SHP-Task 3,Hydrology,Winter 1981-82,Ice Observations Report.December 1982. R&M 1982h.SHP-Task 3,Hydrology,Tributary Stability Analysis.December 1982. R&M 1982i.SHP-Task 3,Hydrology,Slough Hydrology, Interm Report.December 1982. R&M 1982j.SHP-Hydraulic and Ice Studies.Chapter 5&6, Attachment A.March 1982. R&M 1983.SHP-Susitna River Ice Study,1982-1983.Task 4,Environmental.Final Draft. R&M 1984a.SHP-1982-l983 Susitna River Ice Study.Final Report.January 1984. R&M 1984b.Processed Climatic Data,October 1982 - September 1983,Volume V,Devil Canyon Station."(No. 0660).Final Report,June 1984. R&M 1984c.Processed Climatic Data,October 1982 - September 1983,Volume VI,Sherman Station (No.0665). Final Report,June 1984. Ricker,W.E.1975.Computation and Interpretation of Biological Statistics of Fish Populations.Bulletin 191. Fisheries Research Board of Canada.Ottawa,Canada. Technical Comment Numbers AQR074 AQR074 AQR098 AQR071 AQR098 AQR025 AQR026 AQR098 AQR098 AQR07l AQR098 AQR071 AQR009 AQR098 AQR07l AQR074 AQR074 AQR141 "28052 840820 14 ,.... ,.... - - ,.... - ..... ,.... AQUATIC RESOURCES (cont.) Citation Sigler,J.W.,Bjorn and Everest 1984.Effects of Chronic Turbidity on Density and Growth of Steelheads and Coho Salmon. Trihey 1982.SHP-Preliminary Assessment of Access by Spawning Salmon to Side Slough Habitat Above Talkeetna. Trihey 1983.SHP Preliminary Assessment Of Access by Spawning Salmon Into Portage Creek and Indian River. Trihey 1984.SHP-Response of Aquatic Habitat Surface Areas to Main13tem Discharge in the Talkeetna to Devil Canyon Reach of the Susitna River,Alaska.Final Report.June 1984. u.S.Army COE,Portland District,1979.5th Progress Report on Fisheries Engineering Research Program 1973- 1978~Spillway Deflectors to Reduce Buildup of Nitrogen Saturation. USBR 1977.Design of Small Dams.U.S.Govt.Printing Office,Washington D.C 1977 USFWS 1983.Effects of Various Water Temperature Regimes on the Egg and Alevin Incubation of Susitna River Chum and Sockeye S;almon.August 1983 • USGS 1974-198.3.Water Resources Data for Alaska,Water Years,1974 thru 1983. USGS 1983.Sediment Discharge Data for Selected Sites in the Susitna River Basin,Alaska.1981-1982. Wurtsbaugh,W.A.and G.E.Davis.1977.Effects of Temperature and Ration Level on the Growth and Food Conversion Efficiency of Salmo gairdneri,Richardson. J.Fish BioI.,11:87-89 ,Technical Comment Numbers AQR126 AQR072 AQR036 AQR098 AQR131 AQR073 AQR03l AQR008 AQRl19 AQR043 AQR006 AQR098 AQR123 28052 840820 15 - TERRESTRIAL RESOURCES Citation ADNR 1984.Tanana Basin Area Plan.Fish and Wildlife Element and Wildlife Resources Narratives (Background Report).ADNR and USDASCS. ADNR and USDASCS 1984.Susitna Area Plan.Summary of the Public Review Draft.June 1984. APA 1983.SHP-Application for Major Project to the· Federal Energy Regulatory Commission.Filed February 1983,Revised July 1983. APA 1984a.Responses to Department of the Interior Comments on License Application.Volumes 1 and 2. February 15,1984. APA 1984b.Letter from J.Ferguson to D.LeFebvre,ADNR. May 30,1984. Ballard,W.B.,.J.S.Whitman,N.G.Tankersley,L.D. Aumiller,and P.Hessing 1983.SHP-Phase II Progress Report,Big G~ime Studies,Vol.III,Moose-Upstream. ADF&G. Ballard,W.B."C.L.Gardner,J.H.Westlund,and J.R. Dau 1982.SHP--Phase I Final Report ,Big Game Studies, Vol.III,MoosE~-Upstream.ADF&G.119 pp. Bechtel Civil and Minerals,Inc.1983.Chakachamna Hydroelectric Project.Interim Feasibility Assessment Report. Claget,G.1984.Personal Communications,Snow Supervisor,Soil Conservation Service.Anchorage,AK. Cook Inlet Region,Inc.,and Placer Amax Inc.1981.Coal to Methanol FE~as ibili ty Study.Beluga Methanol Project. Final Report.Vol.IV.Environmental. Technicpl Comment Numbers TRR002 TRR016 TRR048 TRROOS TRROI0 TRR027 TRR04l TRR049 TRR067 TRR098 TRROSI TRR048 TRR003 TRR02l TRR022 TRR003 TRRQ22 TRROlS TRR019 TRR076 TRR034 28052 840820 16 - - .... - - ...... TERRESTRIAL RESOURCES (cont.) Citation Elliott,C.L.1984.Wildlife Food Habits and Habitat Use on Revegetated Strip Mine Land in Alaska.PhD Dissertation,Univ.of Alaska,Fairbanks.174 pp. Kessel,B.,S.O.MacDonald,D.A.Gibson,B.A.Cooper, and B.A.Anderson.1982.SHP-Phase I Final Report, Birds and Non·-Game Mammals.Univ.Alaska Museum. Fairbanks,AK. Miller,S.D.,and D.C.McAllister 1982.SHP-Phase I Final Report,Big Game Studies,Vol.VI.,Black Bear and Brown Bear.ADF&G. Miller,S.D.1983.SHP-~hase II Progress Report t Big Game Studies,Vol.VI,Black Bear and Brown Bear.ADF&G Miller,S.D.1984.SHP-Annual Report,Big Game Studies, Vol.VI t Black Bear and Brown Bear.ADF&G,April 1984. Modafferi t R.D.1983.SHP-Phase II Progress Report,Big Game Studies,Vol.II,Moose-Downstream.ADF&G,April 1983. Money,D.1984.Personal Communication t Endangered Species Biologist,U.S.Fish and Wildlife Service. Anchorage t AK. Municipality of .Anchorage 1980.Anchorage Coastal Resource Atlas:.Vol.1.The Anchorage Bowl.Planning Dept.Physical Planning Div.December 1980 • Technical Comment Numbers TRR035 TRROlO TRR054 TRR054 TRR005 TRR007 TRR027 TRR053 TRR054 TRR079 TRR023 TRR024 TRR002 TRR013 -28052 840820 17 ..... ...... - TERRESTRIAL RESOURCES (cont.) Citation Pitcher,K.W.1982.SHP-Phase I Final Report,Big Game Studies,Vol.IV,Caribou.ADF&G,March 1982. Pitcher,K.W.1983 -SHP-Phase II Progress Report,Big Game Studies,Vol.IV,Caribou.ADF&G,April 1983. Pitcher,K.W.1984.SHP-1983 Annual Report,Big Game Studies,Vol.IV-Caribou.ADF&G,April 1984. R&M 1981.SHP'-Task 3,Hydrology,Ice Observations 1980- 81.August 1981. R&M 1982.SHP'-Task 3 -Hydrology,Processed Climatic Data.Volumes 1 through 8,December 1982. Robus,M.•1981~.Personal Communication,Habitat Biologist,ADF&G.Fairbanks,AK. Roseneau,D.G.,C.E.Tull,and R.W.Nelson 1981- Protection Strategies for Peregrine Falcons and Other Raptors Along the Planned Northwest Alaskan Gas Pipe- line Route.Final Report,Volumes I and II.LGL Alaska Ecological Research Associates,Inc.June 1981 • Tankersley,N"G.1984.SHP-Final Report,Big Game Studies,Vol.VIII,Dall Sheep.ADF&G,April 1984. White,C.M.1974.Survey of the Peregrine Falcon and Other Raptors in the Proposed Susitna River Reservoir Impoundment Areas.Unpub.Interim Report,U.S.Fish and Wildlife Service.Anchorage,July 1974. Technical Comment Numbers TRR068 TRR068 TRR004 TRR068 TRR019 TRR016 TRROIO TRR026 TRROIO 28052 840820 18 - I'""", - ,.- TERRESTRIAL RESOURCES (cont.) Citation Windler,G.1984.Personal Communication with Geophysical Institute,University of Alaska,Fairbanks, AK. Wise,J.1984,.Personal Communication,State Climatologist,AEIDC,university of Alaska,Anchorage. Wolff,J.D.~ld J.C.Zasada 1979.Moose Habitat and River Floodplain and Yukon-Tanana Upland.Proc.North American Moose ConL Workshop 15:213-244. Technical Comment Numbers TRR019 TRR019 TRR020 TRR024 28052 840820 19 - SOCIAL SCIENCE Citl!ltion Alaska Nation.:J.1 Interest Lands Conservation Act (ANILCA).December 2,1980. ALue 1983.Thl~Denali National Scenic Highway Study. ADNR 1981.Susitna Basin Planning Background Report. Scenic Resourl:es Along the Parks Highway.1981. ADNR and USDASCS 1982.Tanana Basin Area Plan Land Use Atlas.1982. ADNR and USDASCS 1983a.Tanana Basin Area Plan. Recreation Ell~ment.October 1983. ADNR and USDASCS 1983b.Tanana Basin Area Plan Mineral Element.August 1983. ADNR and USDASCS 1983c.Tanana Basin Area Plan Agriculture Element.August 1983. ADNR and USDASCS 1983d.Tanana Basin Area Plan Forestry Element.August 1983. ADNR and USDASCS 1983e.Tanana Basin Area Plan Settlement Ell~ment.August 1983. ADNR and USDASCS 1983f.Tanana Basin Area Plan Fish & Wildlife Eleml~nt.August 1983. ADNR and USDASeS 1984.Susitna Area Plan.Summary or the Public Review Draft.June 1984. Technical Comment Numbers SSC082 SSC082 SSC018 SSC019 SSC018 SSC072 SSC018 SSC072 SSC019 SSC072 SSC072 SSC072 SSC072 SSC072 SSC072 28052 840820 20 - ..... ..... ..- SOCIAL SCIENCE (cont.) Citation ADNR et a1.1984.Susitna Area Plan,Agency Review Draft,February 1984. BLM 1980.BLM Land Use Plan for Southcentra1 Alaska. Summary Report.U.S.Dept.of Interior.Anchorage,AK. Sept.1980. FNSB 1984.Fairbanks North Star Borough Draft Comprehensive Plan -Side 1 and 2;Maps.January 1984 • FDA 1984a.Socioeconomic Impact Projections -Car Transportation Scenario,1984. FOA 1984b.SHP-Trapper Creek Household Survey Report, 1984. FDA 1984c.SHP-Ta1keetna Househ9Jd Survey Report,1984. FOA 1984d.SHE'-Cantwell Household Survey Report,1984. ISER 1983a.MAP Model Regional Base Case Projections, 1980-2010.For Use In DCS Lease Sale 87 (Diapir Field) Impact Anaiysis.Prepared for Minerals Management Service,Alaska DCS Office.Anchorage.February 1983. ISER 1983b.SHP -Man-In-The-Arctic Program (MAP) Tecnnica1 Documentation Report,July 1983. Technical Comment Numbers SSC006 SSC018 SSC074 SSC075 SSC082 SSC074 SSC082 SSC072 SSC029 SSC071 SSC107 SSC1l3 SSC105 SSC105 SSC105 SSC008 SSC008 28052 840820 21 SOCIAL SCIENCE (cont.) Ci t.3.tion Technical Comment----- Numbers Justus and Simonetta 1983.Social Pollution:Impact SSCl08 Mitigation and Compensation Schemes and the Indian Interest,in:Alaska Symposium on the Social,Economic and Cultural Impacts of Natural Resources Development. pp.216-226.Anchorage,AK.August 25-27,1983. Mountain West Research,Inc.1981.Electric Transmission SSC032 Line Effects on Land Values.A Critical Review of the Literature.Prepared for Bonneville Power Administration.Billings ,Montana.December 1981. - I~ NPS 1982.Ho,g to apply the National Register Criteria for Evaluation.Washington,D.C.,June 1982. Talmadge,V.and o.Chesler 1977.The Importance of Small,Surface,and Dis turbed Sites as .Sources of Significant Archeological Data.Interagency Archeo logical Services,Office of Archeology and Historical Preservation,NPS Washington,D.C.1977. UAM 1982.SHP - A Preliminary Cultural Resources Survey in the Upper Susitna River Valley,Final Report. UAM 1983.SHP-·1982 Cultural Resources Survey.Final Report.March 1983. UAM 1984.SHP -1983 Field Season,Cultural Resources Investigation.Vol.1.,Final Report.January 1984. SSC133 SSC125 SSC121 SSC012 SSCOV SSC1l6 SSC127 SSC130 SSC144 SSC163 28052 840820 22 J j .J J J j 1 1 1 1 ]J I 1 CROSS-REFERENCE INDEX This Index organizes the Technical Comments by the Section in the DEIS to which they refer.Each Technical Comment .is listed by its alphanumeric code opposite a Section of the DEIS.If a Technical Comment deals with more than one Section,it is listed opposite each Section with which it deals. DEIS SECTION SUMMARY 1.PURPOSE OF AND NEED FOR ACTION 1.1 PURPOSE OF ACTION 1.2 NEED FOR POWER 1.2.1 Historical Energy Requirements 1.2.1.1 Perspective o~Geography and Economy of the Region 1.2.1.2 Energy Use in the Region 1.2.2 Present Energy Scenario 1.2.3 Future Energy Resources 1.2.4 Load Growth Forecast 1.2.4.1 Alaska Power Authority Forecasts 1.2.4.2 FERC Staff Projections 1.2.5 Generation-Load Relationships of Existing and Planned Railbelt System 1.3 ALTERNATIVE ACTIONS 1.3.1 Alternative Project Designs 1.3.1.1 Previous.Studies 1.3.1.2 Applicant's Studies 1.3.1.3 Staff Studies 49702 840820 1 SEE COMMENT NOS. NFPOOl,NFP002,NFP003, NFP004,NFP005,NFP006?NFP007 ALTOOI AQROOl,AQR002 NFP008,NFP009,NFP010,NFPOll NFP012,NFP013,NFP014 NFP015,NFP016,NFP017,NFP018,NFP019,NFP020,NFP021 NFP022 NFP023,NFP024 ,NFP025 NFP026,NFP027,NFP028, NFP029,NFP030,NFP03l NFP032,NFP033,NFP034 ,NFP035 NFP036,NFP037 -1 -1 J 1 ._, J .]I )1 1 1 j 1 DEIS SECTION 1.3.2 Other Hydroelectric Alternatives 1.3.3 Non-Hydroelectric Alternatives 1.3.3.1 Petroleum Fuels 1.3.3.2 Natural Gas 1.3.3.3 Coal 1.3.3.4 Peat 1.3.3.5 Geothermal Energy 1.3.3.6 Tidal Power 1.3.3.7 Solar Energy 1.3.4 Non-Structural Alternatives 1.3.4.1 Effects of Conservation on Demand 1.3.4.2 Effects of Rate Revision on Demand 1.4 SCENARIO DEVELOPMENT 1.4.1 Susitna Basin Development 1.4.2 Non-Susitna River Hydroelectric Development Plans 1.4.3 Natural-Gas-Fired Generation Scenario 1.4.3.1 Scenario Evaluation 1.4.3.2 Data Assumptions for Gas Scenario 1.4.4 Coal-Fired Generation Scenario 1.4.4.1 Scenario Evaluation 1.4.4.2 Data Assumptions for Coal Scenario 1.4.5 Scenario Comparison and Combined Scenarios 1.4.5.1 Hydroelectric Scenarios 1.4.5.2 Thermal Scenarios 1.4.5.3 Combined Scenarios REFERENCES 49702 840820 2 SEE COMMENT NOS. ALT002,ALT003,ALT004 NFP038 ,NFP039 NFP040,NFP04l,NFP042,NFP043 NFP044 NFP045 NFP046 NFP047 NFP048 NFP049 NFPOSO,NFPOSl,NFPOS2,NFPOS3 NFP050,NFP053 NFPOS4,NFPOSS NFPOS6,NFP058,NFPOS9 NFP057 ,NFPOS9 NFP060,NFP06l NFP063 NFP063 NFP062,NFP063 J 1 -1 DEIS SECTION 1 I )J ) SEE COMMENT NOS. l ]-1 1 J 2.PROPOSED ACTION AND ALTERNATIVES 2.1 PROPOSED PROJECT 2.1.1 Locat ion 2.1.2 Facilities 2.1.2.1 Watana Development 2.1.2.2 Devil Canyon Development 2.1.2.3 Constru'ction and Permanent Site Facilities 2.1.3 Construction Schedule 2•1.3•1 Wa t ana 2.1.3.2 Devil Canyon 2.1.4 Construction Workforce Requirements 2.1.5 Operation and Maintenance 2.1.5.1 Operation 2.1.5.2 Maintenance 2.1.6 Safety Inspections 2.1.7 Access Plan 2.1.8 Transmission Line Electrical Effects 2.1.9 Compliance with Applicable Laws 2.1.10 Future Plans 2.1.11 Recreation Plan 2.1.11.1 Inventory and Evaluation of Potential Recreation Development Areas 2.1.11.2 Implementation and Description of the Proposed Recreation Plan 2.1.11.3 Recreation Monitoring Program 2.1.12 Mitigative Measures Proposed by the Applicant 2.1.12.1 Land Resources 2.1.12.2 Water Quantity and Quality 2.1.12.3 Fisheries 2.1.12.4 Terrestrial Communities NFP064 NFP066 NFP065 ALT005 AQR003 AQR004' 49702 840820 3 j ]j 1 1 ---1 .-1 j J 1 J J )i J I DEIS SECTION 2.1.12.5 Threatened and Endangered Species 2.1.12.6 Recreation Resources 2.1.12.7 Socioeconomic Factors 2.1.12.8 Visual Reaources 2.1.12.9 Cultural Resources 2.2 SUSITNA DEVELOPMENT ALTERNATIVES 2.2.1 Alternative Facility Designs 2.2.1.1 Applicant's Studies I 2.2.1.2 Alternative Watana Facilities 2.2.1.3 Alternative Devil Canyon Facilities 2.2.2 Alternative Access Corridors 2.2.2.1 Applicant Studies 2.2.2.2 Corridors Studied 2.2.2.3 Development of Plans 2.2.2.4 Description of Most Responsive Access Plans 2.2.3 Alternative Transmission Line Corridors 2.2.4 Alternative Susitna Development Schemes 2.2.4.1 General 2.2.4.2 Watana I-Devil Canyon Development 2.2.4.3 Watana I-Modified High Devil Canyon Development 2.2.4.4 Watana I-Reregulating Dam Development 2.3 NATURAL-GAS-FIRED GENERATION SCENARIO 2.3.1 Alternative Facilities 2.3.2 Location 2.3.3 Construction Requirements 2.3.4 Operation and Maintenance 2.4 COAL-FIRED GENERATION SCENARIO 2.4.1 Alternative Facilities 2.4.2 Location 49702 840820 4 SEE COMMENT NOS. TRROOl SSCOOl,SSC002.SSC003 NFP067 NFP068 NFP068 NFP068 NFP068 NFP069 .ALT006.ALT007,ALT008 NFP069 J J I 1 1 }1 1 -1 --,J J -I DEIS SECTION 2.4.3 Construction Requirements 2.4.4 Operation and Maintenance 2.5 COMBINED HYDRO-THERMAL GENERATION SCENARIO 2.5.1 'Hydro Units 2.5.1.1 Browne 2.5.1.2 Chakachamna 2 ..5.1.3 Johnson 2.5.1.4 Keetna 2.5.1.5 Snow 2.5.2 Thermal Units 2.5.2.1 Facilities 2.5.2.2 Location 2.5.2.3 Construction Requirements 2.5.2.4 Operation and Maintenance 2.5.3 Transmission 2.6 NO-ACTION ALTERNATIVE 2.7 MITIGATIVE MEASURES FOR ALTERNATIVE SCENARIOS 2.7.1 Land Resources 2.7.1.1 Geology and Soils 2.7.1.2 Land Use and Ownership 2.7.2 Climate,Air Quality,Noise 2.7.3 Water Quantity and Quality 2.7.4 Fisheries 2.7.5 Terrestrial Communities 2.7.5.1 Plant Communities 2.7.5.2 wildlife 2.7.6 Threatened and Endangered Species 2.7.7 Socioeconomic Factors 2.7.8 Visual Resources 2.7.9 Cultural Resources REFERENCES 49702 840820 5 SEE COMMENT NOS. NFP069 NFP069 ALT009,ALTOlO NFP070 ALTOll,ALT012,ALT013,ALT014 ALT015,ALT016 ALT017,ALT018 ALT019 TRR002 ALT020 SSC004,SSC005 }1 -)J I I )I 1 1 1 1 1 j j J J nElS SECTION 3.AFFECTED ENVIRONMENT 3.1 PROPOSED PROJECT 3.1.1 Land Resources 3.1.1.1 Geology and Soils 3.1.1.2 Land Uses and Ownership 3.1.2 Climate J Air QualitYJ Noise 3.1.2.1 Climate 3.1.2.2 Air Qvality and Noise 3.1.3 Water Quality and Quantity 3.1.3.1 Surface Water Resources 3.1.3.2 Surface Water Quality 3.1.3.3 Groundwater 3.1.4 Fish Communities 3.1.4.1 Watershed Above Devil Canyon 3.1.4.2,Devi 1 Canyon to Talkeetna 3.1.4.3 Below Talkeetna 3.1.4.4 Access Roads and Transmission Line Corridors 3.1.4.5 Fishery Resources 3.1.5 Terrestrial Communities 3.1.5.1 plant Communities 3.1.5.2 Animal Communities 3.1.6 Threatened and Endangered Species 3.1.7 Recreation Resources 3.1.8 Socioeconomic Factors 3.1.8.1 Population 3.1.8.2 Institutional Issues and Quality of Life 3.1.8.3 Economy and Employment 49702 840820 6 SEE COMMENT NOS. SSC006 ALT02l AQR005,AQR006 J AQR007 J AQR008,AQR009,AQR013 AQR010,AQROll J AQR014 AQR012 TRR003 J TRR004, TRR005, TRR006,TRR007 J TRR008 J TRR009 TRRO 10 J TRRO 11 SSC007 SSC008 SSC009 )J 1 1 1 1 1 1 -1 j 1 J I J ]J 3.1.8.4 3.1.8.5 3.1.8.6 3.1.8.7 DEIS SECTION Housing Community Services and Fiscal Status Transportation Human Use and Management of Wildlife Resources 3.1.9 Visual Rsources 3.1.9.1 Landscape Character Types 3.1.9.2 Prominent Natural Features 3.1.9.3 Significant Viewsheds,Vista Points,and Travel Routes 3.1.10 Cultural Resources 3.2 SUSITNA DEVELOPMENT ALTERNATIVES 3.2.1 Land Resources 3.2.2 Climate,Air Quality,Noise 3.2.3 Water Quantity and Quality 3.2.4 Aquatic Communities 3.2.5 Terrestrial Communities 3.2.5.1 plant Communities 3.2.5.2 Animal Communities 3.2.6 Threatened and Endangered Species 3.2.7 Recreation Resources 3.2.8 Socioeconomic Factors 3.2.9 Visual Resources 3.2.10 Cultural Resources 3.3 NATURAL-GAS~FIRED GENERATION SCENARIO 3.3.1 Land Resources 3.3.1.1 Geology and Soils 3.3.1.2 Land Use and Ownership 3.3.2 Climate,Air Quality,Noise 3.3.2.1 Climate 49702 840820 7 SEE COMMENT NOS. SSCOlO SSCOll SSCOl2,SSCOl3 ALTO 22 SSCOl4,SSCOl5 1 J J 1 I J ]1 1 i J J J )1 ] DEIS SECTION 3.3.2.2 Air Quality and Noise 3.3.3 Water Quantity and Quality 3.3.4 Aquatic Communities 3.3.5 Terrestrial Communities 3.3.5.1 Plant Communities 3.3.5.2 Animal Communities 3.3.6 Threatened and Endangered Species 3.3.7 Recreation Resources 3.3.8 Socioeconomic Factors 3.3.9 Visual Resources 3.3.10 Cultural Resources 3.4 COAL-FIRED GENERATION SCENARIO 3.4.1 Land Resources 3.4.1.1 Geology and Soils 3.4.1.2 Land Use and Ownership 3.4.2 Climate,Air Quality,Noise 3.4.2.1 Climate 3.4.2.2 Air Quality and Noise 3.4.3 Water Quantity and Quality ,, 3.4.4 Aquatic Communities 3.4.5 Terrestrial Communities 3.4.5.1 Plant Communities 3.4.5.2 Animal Communities I 3.4.6 Threatened and Endangered Species 3.4.7 Recreation Resources 3.4.8 Socioeconomic Factors 3.4.9 Visual Resources 3.4.10 Cultural Resources 3.5 COMBINED HYDRO-THERMAL GENERATION SCENARIO 3.5.1 Land Resources 49702 840820 8 SEE COMMENT NOS. ALT023 TRRO 12,TRRO 13 SSC016 .SSC017 ALTO 24 SSC018 SSC019 ·1 1 J J -1 -J I J J -J J 1 J J DEIS SECTION 3.5.1.1 Geology and Soils 3.5.1.2 Land Use and Ownership 3.5.2 Climate,Air Quality,Noise 3.5.3 Water Quantity and Quality 3.5.4 Aquatic Communities 3.5.5 Terrestrial Communities 3.5.5.1 Plant Communities 3.5.5.2 Animal Communities 3.5.6 rhreatened and Endangered Species 3.5.7 Recreation Resources 3.5.8 Socioeconomic Factors 3.5.9 Visual Resources 3.5.10 Cultural Resources REFERENCES SEE COMMENT NOS. ALT025 SSC020 ALT026 ALT027,ALT028 ALT029,ALT030,ALT03l,ALT032,ALT033 TRROl4 TRROl5,TRROl6,TRR017 TRROl8 SSC02l SSC022 SSC023 ALT034,AL:035 AQROl9 ALT036,ALT037,ALT038 4.ENVIRONMENTAL IMPACT 4.1 PROPOSED PROJECT 4.1.1 Land Resources 4.1.1.1 Geology and Soils 4.1.1.2 Land Use and Ownership 4.1.2'Climate,Air Quality,Noise 4.1.3 Water Quantity and Quality 4.1.3.1 Surface Water Resources 4.1.3.2 Water Quality 4.1.3.3 Temperature 4.1.3.4 Ice Processes 4.1.3.5 Groundwater 4.1.4 Aqu~tic Communities 4.1.4.1 Plant and Invertebrate Communities 49702 840820 9 NFP071, AQROl6, AQR024 , ALT039 AQR032, NFP072, NFP073, AQR017,AQROI8, AQR025, AQR026, AQR030,AQR031, AQR033, AQR034, NFP074,NP075,NP076 AQROI5, AQR020,ACR021,ACR022,AQR023, AQR027,AQR028, AQR029, AQR035,AQR036 ,AQR037,AQR038 1 I 1 1 J 1 J j -I 1 J )J )i ) DEIS SECTION 4.1.4.2 Fish Communities 4.1.5 Terrestrial Communities 4.1.5.1 Plant Communities 4.1.5.2 Animal Communities 4.1.6 Threatened and Endangered Species 4.1.7 Recreation Resources .- 4 .1.8Soeioeconomi c Impacts 4.1.9 Visual Resources 4.1.10 Cultural Resources 4.2 SUSITNA DEVELOPMENT ALTERNATIVES 4.2.1 Land Resources 4.2.1.1 Geology and Soils 4.2.1.2 Land Use and Ownership 4.2.2 Climate,Air Quality,Noise 4.2.3 Water Quantity and Quality 4.2.4 Aquatic Communitres 4.2.5 Terrestrial Communities 4.2.5.1 Plant Communities 4.2.5.2 Animal Communities 4.2.6 Threatened and Endangered Species 4.2.7 Recreation Resources 4.2.8 Socioeconomic Factors 4.2.9 Visual Resources 4.2.10 Cultural Resources 4.3 NATURAL-GAS-FIRED GENERATION SCENARIO 4.3.1 Land Resources 4.3.1.1 Geology and Soils 4.3.1.2 Land Use and Ownership 49702 840820 SEE COMMENT NOS. AQR039,AQR040,AQR04l,AQR042, AQR043,AQR044,AQR045, AQR046,AQR047,AQR048,AQR049,AQROSO,AQR05l,AQR052 , AQR053, AQR054,AQR055 TRROl9,TRR020 TRR02l,TRR022, TRR023, TRR024,TRR02S,TRR026,TRR032, TRR029,TRR027, TRR028,TRR030,TRR03l .....". SSC024,SSC025, SSC026,SSC027,SSC039 SSC028, SSC029,SSC030,SSC03l,SSC032,SSC033 SSC034,SSC03S,SSC036 SSC037,SSC038 ALT040 TRR033 SSC039 SSC040,SSC04l,SSC042,SSC043 10 J )J 1 }»-,).J I J ]]1 )J ; DEIS SECTION 4.3.2 Climate,Air Quality,Noise 4.3.3 Water Quantity and Quality 4.3.4 Aquatic Communities 4.3.5 Terrestrial Co~munities 4.3.5.1 Plant Communities 4.3.5.2 Animal Communities 4.3.6 Threatened and Endangered Species 4.3.7 Recreation Resources 4.3.8 Socioeconomic Factors 4.3.9 Visual Resources 4.3.10 Cultural Resources 4.4 COAL-FIRED GENERATION SCENARIO 4.4.1 Land Resources 4.4.1.1 Geology and Soils 4.4.1.2 Land Use and Ownership 4.4.2 Climate,Air Quality,Noise 4.4.3 Water Quantity and Quality 4.4.4 Aquatic Communities 4.4.5 Terrestrial Communities 4.4.5.1 plant Communities 4.4.5.2 Animal Communities 4.4.6 Threatened and Endangered Species 4.4.7 Recreation Resources. 4.4.8 Socioeconomic Factors 4.4.9 Visual Resources 4.4.10 Cultural Resources 4.5 COMBINED HYDRO-THERMAL GENERATION SCENARIO 4.5.1 Land Resources 4.5.1.1 Geology and Soils 4.5.1.2 Land Use and Ownership 49702 840820 11 SEE COMMENT NOS. ALT04l,ALT042 AQR071 TRR034 SSC044,SSC045 SSC046 ALT043,ALT044,ALT045 TRR035 SSC047,SSC048 SSC049 SSC050 ALT046 SSC051 )»1 1 )J 1 ]1 )])] DEIS SECTION 4.5.2 Climate,Air Quality,Noise 4.5.3 Water Quantity and Quality 4.5.4 A,quatic Communities 4.5.5 Terrestrial Communities 4.5.5.1 Plant Communities 4.5.5.2 Animal Communities 4.5.6 Threatened and Endangered Species 4.5.7 Recreation Resources 4.5.8 Socioeconomic Factors 4.5.9 Visual Resources 4.5.10 Cultural Resources 4.6 NO-ACTION ALTERNATIVE 4.7 COMPARISON OF ALTERNATIVES 4.7.1 Land Resources 4.7.1.1 Geology and Soils 4.7.1.2 Land Use and Ownership 4.7.2 Climate,Air Quality,Noise 4.7.3 Water Quantity and Quality 4.7.4 Aquatic Communities 4.7.5 Terrestrial Communities 4.7.5.1 Plant Communities 4.7.5.2 Animal Communities 4.7.6 Threatened and Endangered Species 4.7.7 Recreation Resources 4.7.8 Socioeconomic Factors 4.7.9 Visual Resources 4.7.10 Cultural Resources 4.8 RELATIONSHIP TO RESOURCE PLANS AND UTILIZATION 4.9 UNAVOIDABLE ADVERSE IMPACTS 4.9.1 Proposed Project 49702 840820 12 SEE COMMENT NOS. ALT047,ALT048 ALT049 TRR036,TRR037 TRR038 SSC052 SSC053,SSC054 SSC055 ALT050 ALT05l,ALT052 ALT053 ALT054 TRR039 TRR040 SSC056 SSC057 SSC058,SSC059, SSC060,SSC06l,SSC062,SSC063 ALT055,ALT056 J })-'}1 1 --1 1 'I 1 1 1 j J ]I DEIS SECTION 4.9.2 Alternatives 4.10 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES 4.10.1 Proposed Project 4.10.2 Alternatives 4.11 SHORT-TERM USES AND LONG TERM-PRODUCTIVITY 4.11.1 Proposed Project 4.11.2 Alternatives REFERENCES 5.STAFF CONCLUSIONS 5.1 SIGNIFICANT ENVIRONMENTAL IMPACTS 5.1.1 Proposed Project 5.1.1.1 Land"Resources 5.1.1.2 Climate,Air Quality,Noise 5.1.1.3 Water Quantity and Quality 5.1.1.4 Aquatic Communities 5.1.1.5 Terrestrial Communities 5.1.1.6 Recreation Resources 5.1.1.7 Socioeconomic Factors 5.1.1.8 Visual Resources 5.1.2 Alternatives 5.1.2.1 Land Resources 5.1.2.2 Climate,Air Quality,Noise 5.1.2~3 Water Quantity and Quality 5.1.2.4 Aquatic Communities 5.1.2.5 .Terrestrial Communities 5.1.2.6 Recreation Resources 5.1.2.7 Socioeconomic Factors 5.1.2.8 Visual Resources 49702 840820 13 SEE COMMENT NOS. ALT056 .TRR04l SSC064 ALT057 ALT058 ALT058,ALT059 ALT060 AQR056 ,AQR057 TRR042, TRR043, TRR044,TRR045 ALT06l,ALT062 NFP077 ALT063,'ALT064 ALT065 TRR046 SSC065 )J 1 j J J 1 J J I J )j DEI S SEC,TION 5.1.3 No-Action Alternative 5.2 RECOMMENDATIONS 5.2.1 Power Generation 5.2.2 'Flow Regul~tion 5~2.3 Access Plan 5.3 MITIGATIVE MEASURES 5.3.1 Land Resources 5.3.1.1 Geology and Soils 5.3.1.~Land Use and Ownership 5.3.2 Climate,Air Quality.Noise 5.3.3 Water Quantity and Quality 5.3.4 Aquatic Communities 5.3.5 Terrestrial Communities 5.3.6 Recreation Resources 5.3.7 Socioeconomic Factors 5.3.8 Visual Resources 5.3.9 Cultural Resources 5.4 RECOMMENDED AND ONGOING STUDIES 5.4.1 Land Resources 5.4.1.1 Geology and Soils 5.4.1.2 Land Use and Ownership 5.4.2 Aquatic Communities 5.4.3 Terrestrial Communities 5.4.4 Recreation Resources 5:4.5 Socioeconomic Factors 5.4.6 Visual Resources REFERENCES :-i~,. SEE COMMENT NOS. NFP078 ALT066,ALT067 TRR047 NFP079,NFP080 AQR058,AQR059 ALT068 SSC066 ALT069 NFP081,NFP082 AQR060.AQR061,AQR062 AQR063,AQR064 ,AQR065,AQR066 TRR048 SSC067.SSC068,SSC069,SSC070 SSC071 APPENDIX A.LOAD GROWTH FORECAST:THE ALASKA POWER AUTHORITY FORECASTS A.1 METHODOLO (;'{ A.2 LOAD PROJECTION 49702 840820 14 NFP083,NFP084,NFP085 NFP086 ~.]j 1 j j ]J ]]J )-~-1 1 J DEIS SECTION A.3 WORLD OIL PRICE A.3.1 Some Current Views A.3.2 Masking Effect of Inventory Changes A.3.3 Some Recent Trends and Their Meaning A.3.4 APA Oil Price and Load Projection A.3.5 FERC Projections REFERENCES APPENDIX B.FUTURE ENERGY RESOURCES B.I INTRODUCTION B.2 PETROLEUM FUELS B.3 NATURAL GAS B.3.1 Reserves/Resources B.3.2 Pricing of Natural Gas B.3.3 Future Price of Natural Gas B.3.3.1 Completion of the ANGTS B.3.3.2 Completion of Gas'Pipeline to Alaskan Gulf and Construction of LNG Export Facilities B.3.3.3 Construction of Facilities to Export •Additional Volumes of Cook Inlet Gas B.3.3.4 No Additional Facilities for Export of Cook Inlet Gas B.3.3.5 Future Gas Prices B.4 COAL B.5 PEAT B.6 GEOTHERMAL ENERGY B.7 TIDAL POWER B.8 SOLAR ENERGY REFERENCES 49702 840820 15 SEE COMMENT NOS. NFP087 J NFP088,NFP089,NFP090 NFP092 NFP09l,NFP094 J NFP095 NFP096 NFP097 NFP098 NFP099 ,NFPlOl NFPlOO NFPl02,NFPl03,NFPl04 NFP105 NFP106 NFP107 J J J j )J ]]D J I i -1 ] DEIS SECTION APPENDIX C.ENERGY CONSERVATION C.l ENERGY CONSERVATION AND THE NATIONAL ENERGY ACT OF 1978 C.2 CONSERVATION OF OIL AND NATURAL GAS--THE POWERPLANT AND INDUSTRIAL FUEL USE ACT OF 1978 C.3 THE PUBLIC UTILITY REGULATORY POLICIES ACT OF 1978--RATE,DESIGN,LOAD MANAGEMENT,AND REDUCTION OF THE GROWTH RATES IN THE DEMAND FOR ELECTRIC POWER C.4 RATE DESIGN AND LOAD MANAGEMENT--THE NARUC RESOLUTION NO.9 STUDY APPENDIX D.345-kV TRANSMISSION LINE ELECTRICAL ENVIRONMENTAL EFFECTS D.l INTRODUCTION D.2 OZONE PRODUCTION D.3 AUDIBLE NOISE D.4 RADIO NOISE D.5 ELECTRIC AND MAGNETIC FIELDS D.5.!Electric Fields D.5.2 Magnetic Fields D.6.ELECTRICAL SAFETY REFERENCES APPENDIX E.GEOLOGY AND SOILS E.l AFFECTED ENVIRONMENT E.l.l Proposed Project E.l.l.l Upper and Middle Susitna River Basin E.l.l.2 Lower Susitna River Basin 49702 840820 16 SEE COMMENT NOS. NFP108 J 1 J -]J J J ]"I 1 1 1 J 1 )) DEIS SECTION SEE COMMENT NOS. 17 E.l.l.3 Power Tra~smission Line Corridors E.l.2 Susitna Development Alternatives E.l.2.1 Alternative Dam Locations and Designs E.l.2.2 Alternative Access Routes E.l.2.3 Alternative Power Transmission Routes E.l.2.4 Alternative Borrow Sites E.l.3 Non-Susitna Generation Alternatives E.I.3.1 Natural-Gas-Fired Generation Scenario E.l.3.2 Coal-Fired Generation Scenario E.I.3.3 Combined Hydro-Thennal Generation.Scenario E.2 ENVIRONMENTAL IMPACT E.2.1 Proposed Project E.2.1.1 Watana Development E.2.1.2 Devil Canyon Development E.2.1.3 Access Routes E.2.1.4 Power Transmission Facilities E.2.2 Susitna Development Alternatives E.2.2.1 Alternative Dam Locations and Designs E.2.2.2 Alternative Access Routes E.2.2.3 Alternative Power Transmission Routes E.2.2.4 Alternative Borrow Sites E.2.3 Non-Susitna Generation Alternatives E.2.3.1 Natural-Gas-Fired Generation Scenario E.2.3.2 Coal-Fired Generation Scenario E.2.3.3 Combined Hydro-Thennal Genera.tion Scenario ALT070,ALTOn E.2.4 Comparison of Alternatives E.2.4.1 Susitna Development Alternatives E.2.4.2 Non-Susitna Generation Alternatives E.3 MITIGATION REFERENCES 49702 840820 I 1 J ~l J J I 1 J J J )I DEIS SECTION APPENDIX F.LAND USE F.l AFFECTED ENVIRONMENT F.l.l Introduction F.l.2 Proposed Project F.l.2.1 Upper and Middle Susitna River Basin F.l.2.2 Power Transmission Line Corridor F.l.3 Susitna Development Alternatives F.l.3.1 Alternative Dam Locations and Design F.l.3.2 Alternative Access Routes F.l.3.3 Alternative Power Transmission Routes F.l.3.4 Alternative Borrow Sites F.l.4 Non-Susitna Generation Alternatives F.l.4.1 Natural-Gas-Fired Generation Scenario F.l.4.2 Coal-Fired Generation Scenario F.l.4.3 Combined ,Hydro-Thermal Generation Scenario F.2 ENVIRONMENTAL IMPACTS F.2.1 Proposed Project F.2.1.1 Watana Development F.2.1.2 Devil Canyon Development F.2.1.3 Access Routes F.2.1.4 Power Transmission Facilities F.2.2 Susitna Development Alternatives F.2.2.1 Alternative Dam Locations and Designs F.2.2.2 Alternative Access Routes F.2.2.3 Alternative Power Transmission Routes F.2.2.4 Alternative Borrow Sites F.2.3 Non-Susitna Generation Alternatives F.2.3.1 Natural-Gas-Fired Generation Scenario F.2.3.2 Coal-Fired Generation Scenario 49702 840820 18 SEE COMMENT NOS. SSC072,SSC073 SSC074,SSC075 SSC076 -1 J J J j J J J )1 ]]l j j DEIS SECTION F.2.3.3 Combined Hydro-Thermal Generation Scenario F.2.4 Comparison of Alternatives F.2.4.1 Susitna Development Alternatives F.2.4.2 Power Generation Scenarios F.3 MITIGATION F.3.1 Mitigative Measures Proposed by the Applicant F.3.1.1 Dams and Impoundment Areas F.3.1.2 Construction Camps and Villages F.3.1.3 Recreational Use F.3.1.4 Access Route Corridors F.3.l.5 Transmission Line Corridors F.3.2 Additional Mitigative Measures Recommended by the Staff REFERENCES APPENDIX G.CLIMATE,AIR QUALITY,NOISE G.l AFFECTED ENVIRONMENT G.l.l Proposed Project G.l.l.I Climate G.l.l.2 Air Quality G.l.l.3 Noise G.l.2 Susitna Development Alternatives G.l.3 Natural-Gas-Fired Generation Scenario G.l.3.l Climate G.l.3.2 Air Quality,Noise G.l.4 Coal-Fired Generation Scenario G.l.4.1 Climate G.l.4.2 Air Quality G.l.4.3 Noise G.l.5 Combined Hydro-Thermal Generation Scenario G.2 ENVIRONMENTAL IMPACTS SEE COMMENT NOS. SSC077 SSC078 ALT072 ALT073 49702 840820 19 I J J -]1 J J 1 J 1 I DEIS SECTION G.2.1 Proposed Project G.2.!.1 Climate G.2.1.2 Air Quality G.2.1.3 Noise G.2.2 Susitna Development Alternatives G.2.3 Natural-Gas-Fired Generation Scenario G.2.4 Coal-Fired Generation Scenario G.2.5 Combined Hydro-Thermal Generation Scenario REFERENCES APPENDIX H.WATER RESOURCES H.l BASIN CHARACTERISTICS H.I.l River Morphology H.l.2 Habitat Types H.2 FLOW REGIMES H.2.1 Pre-Project H.2.2 Post-Project H.3 HABITAT ALTERATION H.4 WATER TEMPERATURE H.5 WATER QUALITY H.5.1 Salinity H.5.2 Suspended Solids H.5.3 Nitrogen Gas Supersaturation H.5.4 Nutrients REFF:RENCES APPENDIX I.FISHERIES AND AQUATIC RESOURCES 1.1 AFFECTED ENVIRONMENT 1.1.1 Plant and Invertebrate Communities 1.1.2 Biology and Habitat Suitability Requirements of Fish Species 49702 840820 20 SEE .COMMENT NOS •. ALT074.ALT075 ALT076.ALT077 ALT078. ALT079.ALT080 AQR067.AQR068 AQR069 AQR070.AQR072.AQR073 AQR074 AQR075 AQR076 1 J J -1 1 1 J ]I J J ) ----I }1 J 1 J J J J ]i )J DEIS SECTION 1.2.3.1 Plant Communities 1.2.3.2 Invertebrate Communities 1.2.3.3 Fish Communities 1.2.4 Power Transmission Facilities 1.2.4.1 Plant Communities 1.2.4.2 Invertebrate Communities 1.2.4.3 Fish Communities REFERENCES APPENDIX J.TERRESTRIAL BOTANICAL RESOURCES J.1 AFFECTED ENVIRONMENT J.1.1 Introduction J.1.2 Proposed Project J.1.2.1 Upper and Middle Susitna River Basin J.1.2.2 Lower Susitna River Floodplain J.1.2.3 Power Transmission Corridor J.1.2.4 Threatened and Endangered Species J.1.3 Susitna Developm~nt Alternatives J.l.3.1 Alternative Dam Locations and Designs J.l.3.2 Alternative Access Routes J.l.3.3 Alternative Power Transmission Routes J.l.3.4 Alternative Borrow Sites J.l.3.5 Threatened and Endangered Species J.l.4 Non-Susitna Generation Alternatives J.l.4.1 Natural-Gas-Fired Generation Scenario J.l.4.2 Coal-Fired Generation Scenario J.l.4.3 Combined Hydro-Thermal Generation Scenario J.1.4.4 Threatened and Endangered Species J.2 ENVIRONMENTAL IMPACTS J.2.1 Proposed Project 49702 840820 22 SEE COMMENT NOS. TRR049 TRR049 J 1 --1 J ]J 1 J ]]1 } DEIS SECTION J.2.l.l Watana Development J.2.l.2 Devil Canyon Development J.2.l.3 Access Routes J.2.l.4 Power Transmission Facilities J.2.1.S Threatened and Endangered Species J.2.2 Susitna Development Alternatives J.2.2.l·Alternative Dam Locations and Designs J.2.2.2 Alternative Access Routes J.2.2.3 Alternative Power Transmission Routes J.2.2.4 Alternative Berrow Sites J.2.2.S Threatened and Endangered Species . J.2.3 Non-Susitna Generation Alternatives J.2.3.l Natural-Gas-Fired Generation Scenario J.2.3.2 Coal-Fired Generation Scenario J.2.3.3 Combined Hydro-Thermal Generation Scenario J.2.3.4 Threatened and Endangered Species J.2.4 Comparison of Alternatives J.2.4.l Susitna Development Alternatives J.2.4.2 Power Generation Scenarios J.2.S Conclusions J.2.S.l Proposed Project J.2.S.2 Alternatives J.3 MITIGATION J.3.l Measures Proposed by the Applicant J.3.1.l Avoidance J.3.l.2 Minimization J.3.l.3 Rectification J.3.l.4 Reduction J.3.l.S Compensation 49702 840820 23 SEE COMMENT NOS. TRROSO TRROSl J J 1 1 'I J .,1 1 1 1 i )1 DEIS SECTION J.3.2 Evaluation of Proposed Measures J.3.3 Recommended and Ongoing Studies REFERENCES APPENDIX K.TERRESTRIAL WILDLIFE RESOURCES K.1 BACKGROUND K.2 AFFECTED ENVIRONMENT K.2.1 Proposed Project K,2.1.1 Upper and Middle Susitna River Basin K.2.1.2 Lower Susitna River Basin K.2.1.3 Power Transmission Line Corridor K.2.2 Susitna Development Alternatives K.2.2.1 Alternative Dam Locations and Designs K.2.2.2 Alternative Access Routes,Power Transmission Line Routes,and Borrow Sites K.2.3 Non-Susitna Generation Scenarios K.2.3.1 Natural-Gas-Fired Generation Scenario K.2.3.2 Coal-Fired Generation Scenario K.2.3.3 Combined Hydro-Thermal Generation Scenario K.3 ENVIRONMENTAL IMPACT K.3.1'Proposed Project K.3.1.1 Watana Project K.3.1.2 Devil Canyon Development K.3.1.3 Access Routes K.3.1.4 Power,Tra,nsmission "Facilities K.3.2 Susitna Development Alternatives K.3.3 Non-Susitna Generating Alternatives K.3.3.1 Natural-Gas-Fired Generation Scenario K.3.3.2 Coal-Fired Generation Scenario SEE COMMENT NOS. TRR052,TRR053,TRR054 ,TRR055,TRR056,TRR057,TRR058 l'RR059,TRR060,TRR062 TRR06l,TRR063 TRR064 ,TRR065, TRR066, TRR067, TRR068,TRR069 TRRO 70,TRRO 71,TRRO 7 2,TRRO 73 TRR074,TRR075 TRR076,TRR077 49702 840820 24 )1 J J I J 1 1 J ]J 1 .1 J 1 J I j DEIS SECTION K.3.3.3 Combined Hydro-Thermal Generation Scenario K.3.4 Comparison of Alternatives K.4 MITIGATIVE ACTIONS K.4.1 Proposed Mitigation K.4.2 Recommended Mitigation K.s .SIGNIFICANT ENVIRONMENTAL IMPACTS K.s.I Proposed Project K.s.2 Alternatives to the Proposed Project REFERENCES APPENDIX L.RECREATION RESOURCES L.I AFFECTED ENVIRONMENT L.I.I Introduction L.I.I.I Historical Perspective L.I.I.2 Statewide Overview L.I.2 Proposed Project L.I,2.1 Regional Setting L.I.2.2 Upper and Middle Susitna River Basin L.I.2.3 Lower Susitna Basin and Cook Inlet Area L.I.2.4 Transmission Line Corridors L.I.3 Susitna Development Alternatives L.I.3.1 Alternative Dam Locations and Designs L.I.3.2 Alternative Access Routes L.I.3.3 Alternative Power Transmission Routes L.I.3.4 Alternative Borrow Sites L.I.4 Non-Susitna Generation Alternatives L.I.4.1 Natural-Gas-Fired Generation Scenario L.I.4.2 Coal-Fired Generation Scenario 49702 840820 25 SEE COMMENT NOS. TRR078 TRR079,TRR080,TRR081 ssc079 ]-»1 ]]J )1 ]J )1 J ]]1 1 DEIS SECTION L.1.4.3 Combined Hydro-Thermal Generation Scenario L.2 ENVIRONMENTAL IMPACTS L.2.1 Proposed Project L.2.1.1 Watana Development L.2.1.2 Devil Canyon Development L.2.1.3 Access Routes L.2.1.4 Power Transmission Facilities L.2.1.5 Proposed Recreati~n Plan L.2.2 Susitna Development Alternatives L.2.2.1 Alternative Dam Locations and Designs L.2.2.2 Alternative Access Routes L.2.2.3 Alternative Power Transmission Routes L.2.2.4 Alternative Borrow Sites L.2.3 N9n-Susitna Generation Alternatives L.2.3.~Natural-Gas-Fired Generation Scenario L.2.3.2 Coal-Fired Generation Scenario L.2.3.3 Combined Hydro-Thermal Generation Scenario L.2.4 Comparison of AI~ernatives L.2.4.1 Susitna Development Alternatives L.2.4.2 Non-Susitna Generation Alternatives L.3 MITIGATION REFERENCES APPENDIX M.VISUALRESOURCES M.1 VISUAL RESOURCE ANALYSIS CRITERIA M.2 AFFECTED ENVIRONMENT M.2.1 Proposed Project M.2.1.1 Upper and Middle Susitna River Basin M.2.1.2 Power Transmission Line Corridor SEE COMMENT NOS. SSC080 SSC081,SSC082 SSC083 SSC084,SSC085,SSC086 SSC087 SSC088,SSC089 SSC090 SSC091 SSC092 SSC093,SSC094,SSC095 49702 840820 26 -;1 )-1 I J ')))J --.]] DEIS SECTION M.2.2 Susitna Development Alternatives M.2.2.l Alternative Dam Locations and Design M.2.2.2 Alternative Access Routes M.2.2.3 Altern~tive Power Transmission Line,Routes M.2.2.4 Alternative Borrow Sites M.2.3 Non-Susitna Generation-Alternatives M.2.3.1 Natural-Gas-Fired Generation Scenario M.2.3.2 Coal-Fired Generation Scenario M.2.3.3 Combined Hydro-Thermal Generation Scenario M.3 ENVIRONMENTAL IMPACTS M.3.l Proposed Project M.3.1.l Watana Development M.3.l.2 Devil Canyon Development M.3.1.3 Access Routes' M.3.1.4 Power Transmission Facilities M.3.2 Susitna Development Alternatives M.3.2.1 Alternative Dam Locations and Designs M.3.2.2 Alternative Access Routes M.3.2.3 Alternativ.e Power Transmission Line Routes M.3.2.4 Alternative Borrow Sites M.3.3 Non-Susitna Generation Alternatives M.3.3.l Natural-Gas-Fired Generation Scenario M.3.3.2 Coal-Fired Generation Scenario M.3.3.3 Combined Hydro-Thermal Generation Scenario M.3.4 Comparison of Alternatives M.3.4.1 Susitna Development Alternatives M.3.4.2 Power Generation Scenario M.4 MITIGATION M.4.l Mitigative Measures Proposed by the Applicant M.4.1.1 Additional Study 49702 840820 27 SEE COMMENT NOS. SSC096 SSC097 ALT08l SSC098 SSC099 SSClOO SSClOl ))j ))]]).1 ]i DEIS SECTION M.4.l.2 Best Development Practices M.4.l.3 Creative Engineering Design M.4.l.4 Use of Form,Line,Color,or Textures M.4.2 Additional Mitigative Measures Recommended by the Staff REFERENCES APPENDIX N.SOCIOECONOMICS N.l AFFECTED ENVIRONMENT N.l.l Proposed Project N.l.l.l Introduction N.l.l.2 Population N.l.l.3 Institutional Issues N.l.l.4 Quality of Life N.l.l.5 Economy and Employment N.l.l.6 Housing N.l.l.7 Community Services and Fiscal Status N.l.l.8 Transportation N.l.2 Susitna DeveloJxnent ,Alternatives N.l.2.l Alternative Dam Locations and Designs N.l.2.2 Alternative Access Routes N.l.2.3 Alternative Power Transmission Routes N.l.2.4 Alternative Borrow Sites I N.l.3 Non-Susitna Generation Alternatives N.l.3.l Natural-Gas-Fired Generation Scenario N.l.3.2 Coal-Fired Generation Scenario N.l.3.3 Combined Hydro-Thermal Generation Scenario N.2 ENVIRONMENTAL IMPACTS N.2.l Proposed Project N.2.l.lWatana Development N.2.l.2 Devil Canyon SEE COMMENT NOS. SSC102 SSC103,SSC105 SSC104 SSCI06,SSCI07,SSCI08,SSCI09,SSCIIO,SSCIII 49702 840820 28 J J J ]1 DEIS SECTION SEE COMMENT NOS. N.2.1.3 Access Routes N.2.1.4 Power Transmission Facilities N.2.1.5 Alternative Borrow Sites N.2.2 Susitna Development Alternatives N.2.2.1 Alternative Dam Locations and Designs N.2.2.2 Alternative Access Routes N.2.i.3 ·AI ternati ve Power Transmission Routes N.2.2.4 Alternatjve Borrow Sites N.2.3 Non-Susitna Generation Alternatives N.2.3.1 Natural-Gas-Fired Generation Scenarios N.2.3.2 Coal-Fired Generation Scenario N.2.3.3 Combined Hydro-Thermal Generation Scenario SScl12 N.2.4 Comparison of Alternatives N.3 MITIGATION N.4 RECOMMENDED AND ONGOING STUDIES SSCl13 REFERENCES SSCI14, SSCI15,SSCl16 SSCl17 SSCI18,SSCI19, SSCI20, SSCI21,SSCI22,SSCI23, SSCI24, SSCI25,SSCl26 SSCI27,SSCI28, SSCI29,SSCI30,SSCl31 SSCI32, SSCI33,SSCl34 SSCI35,SSCI36,SSCl37 29 0.1.1.5 Transmission Corridors 0.1.2 Susitna Development Alternatives 0.1.2.1 Alternative Dam Locations and Designs 0.1.2.2 Alternative Access Routes APPENDIX o.CULTURAL RESOURCES 0.1 AFFECTED ENVIRONMENT 0.1:1 Proposed Project 0.1.1.1 Introduction 0.1.1.2 Geoarcheology 0.1.1.3 Regional History and Prehistory 0.1.1.4 Middle and Upper Susitna Basin 49702 840820 1 1 J -I 1 ]J )J 1 1 I J 1 SSC142,SSC143, SSC144, SSC145, SSC146,SSC147,SSC148, SSC149,SSC150,SSC15l SSC152 SSC153,SSC154,SSC155,SSC156,SSC157 SSC158,SSC159,SSC160,SSC16l,SSC162 Designs SSG163,SSC164 SSC165,SSC166,SSC167,SSC168 Routes SSC169 SSC170,SSC171 DEIS SECTION 0.1.2.3 Alternative Power Transmission Routes 0.1.2.4 Alternative Borrow Sites 0.1.3 Non-Susitna Power Generation Alternatives 0:1.3.1 Natural Gas-Fired Generation Scenario 0.1.3.2 Coal-Fired Generation Scenario 0.1.3.3 Combined Hydro-thermal Generation Scenario 0.2 ENVIRONMENTAL IMPACT L_ 0.2.1 Proposed Project 0.2.1.1 Watana Development 0.2.1.2 Devil Canyon Development 0.2.1.3 Access Routes 0.2.1.4 Power Transmission Facilities 0.2.2 Susitna Development Alternatives 0.2.2.1 Alternative Dam,Locations and 0.2.2.2 Alternative Access Routes 0.2.2.3 Alternative Power Transmission 0.2.2.4 Alternative Borrow Sites REFERENCES 49702 840820 30 SEE COMMENT NOS. SSC138,SSC139 SSC140,SSC14l - ,.... i SUBJECT INDEX This Index classifies the Technical Comments by subject matter.Each Technical Comment is listed by its alphanumeric code opposite a subject discussed in the DEIS and its accompanying Technical Comment.If a Technical Comment deals with more than one subject,it is listed opposite each subje.ct with which it deals. TECHNICAL COMMENT SUBJECT REFERENCE NUMBERS Access Roads ALT068 TRROO5,TRR024,TRR027, ·TRROS8,TRR073,TRR074 SSC060,SSC066,SSC085, SSC092 ,SSC135,SSCI36, SSCl37,SSC153,SSC165, SSCI66,SSCI67,SSC168-Aesthetic Resources (See Visual Resources) Aesthetic Impacts (See Visual Impac ts) Air Quality ALT005,ALTOO6,ALT007, ALTOO8,ALTOIS,ALT016, ALT020,ALT02I,ALT022, ALT023,ALT024 ,ALT026, ALT036 ,ALT037 ,ALT038 , ALT040,ALT04I,ALT042 , ALT043 ,ALT044 ,ALT045 , ALT051,ALT052 ,ALTOS3, !"""ALT054,ALTOS5,ALT060, ALT069 ,ALT072 ,ALT073 , ALT074,ALT075,ALT076,-ALTOn,ALT078 ,ALT079 , ALT080 SSC094 Al ternatives NFPOOI,NFPOO2,NFP003, NFPOO4,NFP005,NFP007, NFP047,NFPOSO,NFP05I, NFP053 ,NFPOS4,NFPOS5, ~NFP056,NFP057,NFP060, NFP067,NFP068 ,NFP069 , NFP070,NFPon,NFP078 , ~ALTOOI,ALTOO2,ALT003, ALT004,ALT009,ALTOIO, ALTOIl,ALTOI2,ALTOl3 , .....ALTOI4, ALTOI7,ALTOIS, ALTOI9,ALT020,ALT025 , ALT027,ALT028,ALT029 , 49712 840820 1 - TECHNICAL COMMENT SUBJECT REFERENCE NUMBERS f""" Alternatives ALT030, ALT031,ALT032 , ALT033,ALT046,ALT047 , r--.ALT048,ALT049,ALT050, ALTO 53 ,ALTO 54 ,ALT055, ALT.Q56 ,ALT059,ALT061, ALT062 ,ALT064 ,ALT065, ALT066, ALT067,ALT070, ALTO 71 TRR014 ,TRROI5,TRRO 16, f"""TRR017,TRROIS,TRR033, TRR036 ,TRR037,TRR038, TRR039,TRR040,TRR046, TRR047,TRR061,TRR062, TRR063,TRR078 SSC016,SSC020,SSC021 SSC022,SSC023,SSC039, SSC041,SSC042,SSC049, ~SC051,SSC052, SSC053, SSC054,SSC055,SSC056, SSC063,SSC064,SSC065, SSC076,SSC077,SSC079, SSC09l,SSC092, SSC093, ~.SSC095,SSC096,SSC099, SSCIOO,SSCI01 Bear TRR005,TRR006,TRR007, TRROI5,TRR027,TRR028, TRR029,TRR044,TRR053, TRR054 ,TRR055,TRR056, TRR062,TRR066,TRR071,-TRR073,TRR075,TRR079I I Bering Cisco AQR094,I AQR095 Caribou TRR004,TRR025, TRR052, "....TRR068 _. ....., 49712 840820 2 - SUBJECT Discount Rate Eagles Employment Endangered Species Energy Consumption Energy Production Escapement Existing Systems Expansion Plans Export Market Filling Flow Regime Forecasting Fuel Switching Fuel Use Act Furbearers 49712 840820 4 TECHNICAL COMMENT REFERENCE NUMBERS NFP052 TRR008,TRR030,TRR031, TRR045,TRR057 ,TRR067 , TRR072 ,TRR076,TRR08I NFPOll SSCI05 TRR002,TRROIO,TRROII, TRROI8,TRR032, TRR038, TRR040,TRR058 -NFPOI2,NFP013,NFPOI4, NFPOI5,NFP020 NFP036,NFP037,NFP074 , NFP075 ,NFP076,ALT004, AQROI2,AQR080,AQR085, AQR089, AQR091,AQR092 'AQRI06 NFPOI9,NFP02I,NFP022, NFP032 NFPOOl,NFP002,NFP003, NFP005,NFP007,NFP050, NFP051,NFP053,NFP054, NFP055, NFP056,NFP057, NFP060,NFP063,NFP068, NFP069,NFP070,NFP078 NFP040 ALT07I AQROI5,AQR042,AQR054 AQR055,AQR063 ,AQR099 AQRIOO,AQRI03,AQRI04 AQRI05, AQRI08,AQRIIO AQRIII,AQRI31,AQRI42 AQRI44 TRR008.,TRR028, TRR057, TRR072 NFP066, NFP071,NFPon, NFP073,NFP074 ,NFP075, NFP076,NFP079,NFP080, NFP081,NFP082,ALTOI7, ALTOI8 AQR005,AQR007,AQR008 AQROI5,AQROI7,AQROI8 AQROI9,AQR021,AQR027 AQR028, AQR029,AQR039 AQR053,AQR058,AQR059 AQR060, AQR062,AQRI4I AQR062 NFP093,NFP094 NFP047 TRR016,TRR063 TECHNICAL COMMENT ,.-.SUBJECT REFERENCE NUMBERS i Gas Price NFP039,NFP056 Gas Price Resources NFPIOO r Geographic NFPOO8 Geothermal NFP045 ,NFPI06 Gold Creek Station AQROO8,AQROI7,AQR069 Groundwater AQROII,AQROI4,AQR035 AQR036 ,AQR066 ,AQRI05 AQRllB,AQRI34 Habitat AQR019,AQR027,AQR050 AQR053,AQR068,AQR081 AQR084 ,AQR087,AQR090 AQR097,AQRI04,AQRI13 AQRU5,AQR134,AQRI40 AQRI4I TRROO3, TRROO6,TRROO9, TRR013,TRROI7,TRR033, 'TRR035,TRR039,TRR048 , TRR059 ,TRR061 ,TRR078 HEC-2 Model AQR067 HEC-5Model NFP036 Housing SSCIIO Hydraulics AQROO7,AQR020,AQR022 AQR028, AQR040,AQR044 AQR070,AQR071,AQR073,...AQRI04,AQR1l3,AQR136 Hydroelectric NFP053,NFP067,NFPOn, ALTOO2,ALTOO3,ALTOO4,-ALTOO9,ALTOIO,ALTO 11 , ALTOI2,ALT013,ALTOI7, ALTOI8, ALTOI9,ALT025, -.ALT029 ,ALT030,ALT031, ALT032,ALT033 ,ALT046, ALT047 ,ALT048 ,ALT049, ALT050,ALT061 ,ALT062 , ALT064 ,ALT065 ,ALT070, ALT07l SSC021,SSC022, SSC053,-SSC054,SSC055,SSC076, sscon,SSC091,SSCIOO Ice Cover AQR038,AQR1l6,AQR12I TRR068 Ice Model AQR029 Ice Processes AQROO9,AQR037,AQR05I AQR071,AQR098,AQRI20 ~ Impacts ALTOOI,ALT022 ,ALT035 , ALT047,ALTOS2,ALT053, ALT054 ,ALT055,ALT056 , ALT057,ALT058 ,ALT059 , 49712 840820 5 - TECHNICAL COMMENT SUBJECT REFERENCE NUMBERS Impacts ALT064 ,ALT065 ,ALT068 , AQR143 TRROO8,TRR021,TRR023, TRR025, TRR026, TRR030, TRR031,TRR033,TRR034, TRR035 ,TRR036,TRR037 , TRR039 ,TRR040,TRR041, TRR042 ,TRR043,TRR044 , TRR045,TRR046 ,TRR051, TRR057 ,TRR064 ,TRR065 , TRR067,TRR069,TRR070, TRR072,TRR076,TRR077, TRR078,TRR079,TRR080, TRR081 SSCOO3,SSCOO7,SSC015, SSC017, SSC023,SSC024, SSC025,SSC026,SSC028, SSC030, SSC031,SSC037, ..-SSC039,SSC041, SSC042, I SSC043,SSC044,SSC045, SSC046,SSC047,SSC048, SSC050, SSC051,SSC052,-SSC053, SSC054,SSC056, SSC058, SSC059, SSC060, SSC061,SSC062,SSC063,-SSC064, SSC067,SSC069, SSC076,SSG.077 ,SSC081, SSC082.SSC083,SSC084, SSC085,SSC086, SSC087, SSC088,SSC089,SSC090, SSC091,SSC093,SSC094, SSC095,SSC106,SSC108,-SSC109, SSC142,SSC144, SSC146,SSC149, SSC150, SSC153, SSC155,SSC156,-SSC157,SSC159, SSC160, SSC161,SSC162,SSC163, SSC166,SSC168,SSC169,-SSC170 Incubation AQR045,AQR047,AQR048 AQR056,AQR077,AQR116 AQRl17,AQR1l9,AQR120 i"""AQR121,AQR137 Instream Flow AQR059 ,AQR062 ,AQR067 Land Management SSCOO6,SSC072 ,SSC078-Land Use ALT046,ALT050,ALT062 SSC020,SSC032,SSC051, SSC053,SSC054,SSC073, ~SSC074, SSC075, SSC076, SSC077 ..- 49712 6 84082.Q - 49712 840820 8 - TECHNICAL COMMENT SUBJECT REFERENCE NUMBERS Recreation Resources SSc083,SSC084, SSC085, SSC086.SSC087.SSC088, SSC089,SSC090.SSC09l, SSC092 ,SSC093,SSC094. SSC095 r RED Model NFP084.NFP085 Re liabi Ii ty NFP034.NFP035 Reservoir NFP065 ,NFP07l,NFP073 , NFP074.NFP075 ,NFP076 AQROO2,AQR032,AQR038 AQR052,AQR061,AQR062 AQR064.AQR065,AQR076 AQRI09.AQR13l,AQR132 AQR133,AQR143 TRR019,TRR058,TRR068 Reservoir Temperature Model AQR030.AQR038 Retirement Schedule NFP032 Rime Ice 'TRR020,TRR050 River Temperature Model AQR033,AQR046 ,AQR066 AQR074 ,AQR098,AQRl09 AQR122,AQR124 Salmon ALT019, ALT030,ALT031. ~..ALT032 ,ALT033 ,ALT049 AQR012,AQR013 ,AQR053 AQR054 ,AQR056,AQR063 AQR078 ,AQR080,AQR096 AQRlOO,AQRl06,AQRl15 AQR1l9,AQR126,AQR127 ~AQR129,AQR137,AQR141 AQR142 Salmon Access AQR025 ,AQR058 ,AQR060 AQR072 ,AQRI03,AQRI07-AQR1l2, AQR1l4,AQR135 Salmon Growth AQR042,AQR043 ,AQR046 AQR049 ,AQR050,AQR057-AQR082,AQR086 ,AQRIOI AQRI02,AQRllO,AQRlll AQR123,AQR125,AQR138 -.AQR139 Salmon Outmigration AQR051,AQR088 ,AQR128 Sediment AQROO6,AQROlO,AQR023 AQR025.AQR026 ,AQR028 AQR121 Side Channel AQR041 Side Slough AQROO7,AQR023,AQR068 .....Slough AQROll ,AQR014,AQR020 AQR022,AQR029,AQR035 AQR036 ,AQR047,AQR058 49712 840820 9 49712 840820 10 ,.... I TECHNICAL COMMENT SUBJECT REFERENCE NUMBERS Wetlands TRR043 Wildlife Resources TRR012,TRR013,TRR017, TRR020,TRR033 ,TRR035, TRR036,TRR037,TRR039, TRR041,TRR047 ,TRR050, TRR059,TRR060,TRR061, TRR078 Wood NFP020 Work Force SSC112 World Economy NFP089 World Oil Price NFP023,NFP024,NFP026, ""'"NFP027,NFP042,NFP087,I i NFP088 ,NFP089,NFP090, NFP091,NFP092,NFP093 , ""'"NFP094,NFP095,NFP096, NFPI02 World Oil Production 'NFP087,NFP095 World Oil Resources NFP092 - - - 49712 840820 12