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Home My WebLink AboutAPA1293. (I ... I ,· i . I··· I I I I I I I I I :I I •• I ALASKA POv!ER AUTHORITY SUSITNA HYDROELECTRIC PROJECT . REVIEN AND TESTif10NIES ON ACRES FEASIBILITY REPORT APRIL 14-16J 1982 ACRES ANERICAN INCORPORATED 1000 Liberty Bank Building Main at Court Buffalo, New York 14202 Telephone: (716) 853-7525 I· I • ••• I I •• I I I •• I I I I ·I I I I I: CONTENTS 1 • Repor·t to APA Boatd by Extern a 1 Review Pane 1 2. Testimonies by Environmental Agencies 0 (a) State of Alaska Department of Fish & Game (b) U.S. Fish & Wildlife Service (c) U .. S. National ~1arine Fisheries Service " .... ~~ ¥~,:~:1' '-, " :.r 1/ I, I I I I I I I ALASKA POWER AUTHORITY SUS!TNA I . !--FI_L_:E~P~~::~~O::.':~=.,J . ~·v. ,t SSQUENCE NO. ~ c·-:""'/1 I c-.:;;.· .. ~'1 ------.,;;----- April 15 ~ 1982 -------;;.:-c-.. ,.--,·~-~~---.... ,,, .. .,_ " R~~CEIVED #'PR 19 1982 P.EP('RT TO ACn£S itmt.fiithii Ul&UllP.DRAtED BO!l.RO OF D I RECiOR~ALASKfi. PC~lER AUTHORITY · -- .. ~ From EXTERNAL REVIEW PANEL, SUSITNA HYDROELECTRIC PPOJECT After reviewing the comorehensive Feasibility Report prepared by Acr·eSi American Inc. , the Extern a 1 Review Pane 1 offel'·s to the A 1 ask a Pow,e:~· Authority the following unanimous comments on the proposed Susitna Hydroelectric Project~ 1 .. 2. ~ ... 4 . 5. 6. 7. 8. It is recognized that the project wi11 heve environmental impacts on wildlife, fisheries, and botanical resources. However, the extent and severity of these impacts appear to be relatively sma11 end furthemore mariy of these environmental losses can be mitigated in full or in part. The high dams proposed for Watana and Devil Canyon can be designed to safely withstand the maximum anticipated earth- quake forces. The proposed design adeouately responds to the hydrologic environment in terms of spillway capacity and dependabi1ity. If the project is financed at an ooportune time when bond interest rates and oil revenues are favorables the potential lono term benefits of the Sus'itna project will be considerable. Pccordi ng1y we cons; cier that thP overa 1 i impa.ct of -t:he project on the State of Alaska could be attractive. To this end we endorse the plan to epply in September 1982 for a permit from the Federal Energy Regulatory Commission. MoreovPr, wP enrinrse the prnno11,;1 tn prncPed with site inves- tiaations and desio~ of the project, with concurrent work on some of the critical environJ'llental studies, particularly 'those concerning downstream pffects of the dams on the stream and its fish life. 1ne arrival of any opoortune time to proceed with con~·~uction will depend on critical issues of fina~ce ano marketing )f power which cannot now be accurately forecast. Our recommendation is that tendP.r documents with all supporting oeotechnical investioations and desicn stu~ies be d~v~looed. Qe estimate that a t~tal period of tfiree to four years will be required for this phase of work. The pro.i ect will then be readv to be implemented whenever the financial climate for contractin9 becomes favorable. The advanti9-es of proceeding in this manner are: I I I I I I I I .I I I I I I I I I I. I I ./ ( 1) {2) (3) The economic benefits of being ready for financing; the momentum of the ongoing study and an infonned staff; a:nd the ability to avoid a crash design program. The disadvantaoe is the sma11 risk of loss of the desian costs in the event that, for some reason~ the project is nev~r built. 9. We recommend that the Alaska Power Authority develop a de- tailed business plan which incorporates a financing and marketing plan into an overa1·1 business strategy. The olan would describe the critical events that ne~d to be accom- plished, the interre1ationship -of th~se events, the approach to accomp1ishing these 90n1~, the management and control practice that are appropriate, the most economic financirt9 strategy, and powe>r alternatives if the Susitna pro,iect is delayed or the demand forecast changes. 10. This Panel is of the opinion that the economic climate wi 11 eventually indicate that it is advisable to proceed with the construction of the Susitna project and at that time it wi11 be in the best interests of the State ~f Alaska tc develop this important natural resource. a .. dlb , • ro tlQ , . 'i:R~= "'Andrew H. Merr·ftt = ouma H. BOl ton Seed ===: · I I I I I I I I I I I I I I I I I I I 334 WEST 5th ~NENUE .. ANCHORAGE, ALASKA 99501 , Mr. Chaa.rles Conway, Chairman Alaska Power Authority 334 West Fifth Avenue, 2nd Floor Anchor~lge, Alaska 99501 Dear Mr. Conway: April 14, 1982 Phone: (907) 2n·7641 (907) 276-0001 In response to your letter of February 3 to members of the Alaska Power Authority External Review Panel for the Susitna Project and your request for a critical evalua.tion of the Acres AmericcLn Inc. Feasiblity Report and findings and the responses of individual Panel members to specific questions, we Offer the followtng attached comments on the various aspects of the study. It: has been a pleasure working with members of the Alaska Power ~~uthori ty staff and Acres American, Inc. on this important study amd we would like to e.xpress our apprec:iation to you and all concerned for the help and support we have received in preparing our reports and recommendations over the past two years. /.1/1----~~~i.-~n:cpen- ~ P.. . . :-f::.£4~ "~ Dennis M. Rohan Attachment: as stated Sincerely, EXTERNAL REVIEW PANEL -MEMBERS H. Douma Q..P.Ao, JQ}.£,! ,)'#; Andrew H. Merritt H. Bolton seed ' - I I I I I I I I I I I I I I I I I I I ............. . , ~~.~. ,-. ,---;------- ENVIRONMENTAL CONSIDERATIONS Development of the Susi tna Hydroelectric Project will impact the environment of-the Susitna basin in a number of ways. The t-wo reser- voirs will inundate substantial areas which now s11pport forest,s and some kinds of wildlife; the constructio-: camps, roads, and tra:nsmis- sion lines will disturb various upland ecosystems; and the flow of the Susitna River below the dams will be modified as sia.lmon spa·wn.ing and rearing habitat. A number of on-going studies have shed considerable light on existing animal populations and vege.tationa.l types. Although some information is still far from complete, it is. possible now to anticipate some of the impacts that the project will impose on these co:mmuni ties. In the aggregate, the total impact '¥ill be relatively small. Moreover-, by judicious management, it will be possible to mit- igate some of the habitat losses by improving habitats elsewhere. The dis cuss ions which follow summarize th(~ environmental problems as they are now understood. Reservoir Areas The two impoundments, with· c.n aggregate area of about 71 square miles, will obviously be converted from terrestrial to lacustrine hab- itat with a loss of all the plants and wildlife that use these areas now. Among the larger animals whose numbers will be reduced are moose, black bear, and several species of mustelid fur-bearers. A wide variety of small birds and mammals will be evicted. Yet most of these species are common in this part of Alaska; there are no known endangered species of either plants or animals. In the case of the moose, it is proposed to manipulate vegetation along the lowe~ sus i tna,. by burning or mechanical means, to create more winter range and hence to increase moose populations there to compensate for losses of moose in the impoundment areas. A somewhat reduced moose popula- tion in the upper Susi tna basin might mean some reduction in the dependent wolf pop•Jlation. The Wa tana impouncment intersects a migra- tion route used by the Nelchina caribou herd. Although caribou swim well, and easily cross natural water barrie~s, there is a possibility that ice shelving along the shore of the Watana reservoir might inter- fere with caribou movements. If such a problem is detected, the ice shelf could presumably be blasted. Of greater importance, pernaps, is the necessity to clear and remove all the timber from the impoundment areas to preclude the formation of floating log jams that could create a truly dangerous barrier to migrating_caribou. The upper Susitna River· supports several native fish, of which the grayling is the primary game species. Although the rive~ habitats that are inundated will be lost to grayling production, it is possible that the reservoirs themselves may support modest populations of gray- ling and perhaps lake trout. 1 I I I I I I I I I I I I I I I I I I I Downstream Effects Below the Devil Canyon dam, the flow of the river will be substan- tially altered from its natural cycle. High summer flows will be captured in the reservoirs to supply winter discharge. The reduced summer flows in the river might adversely affect salmon spawning and rearing habitat as far downstream on the confluence with the Chulitna River, near Talkeetna. Side sloughs that are used as spawning areas by chum and sockeye and as reari.ng areas by juvenile coho and chinook will be cut off from flushing flows which normally occur at high levels of discharge. Considering the total runs of salmon that spawn in the Susitna drainage and its tributaries, the proportions that uti-· lize the reach between Talkeetna and Devil Canyon are as follows (figures from Schmidt and Trihey): Species Coho Chinook Sockeye Pink (odd yec.rs) Chum Total susitna runs (approx.l 33,000 76,000 340,000 113,000 286,000 Percentage spawning ,above Talkeetna 8% 2% 1% 3% 15% • Ch.um and coho salmon are the two species that might be adversely affec·ted by construction o~f the dams. There a.re good prospects for mitigation of those potential losses. Thirty-two sloughs have been identified along this stretch of the river. Mechanical opening of in- take channels might permit flushing flows at di~scharge levels planned for normal power production. Occasional highelr flows might be re- leased, if needed. Additionally, artificial spawning channels ~ight be constructed. If proper multiple outlet structures are instal~ed in the dams, water temperature can be regulated as well as flows. Much of the silt in the upper river will settle in the reservoirs, result- ing in clearer w.ater flowing from Devil· Canyon dam, which m:ay be ·highly advantageous for rearing of young salmon.. All of these mitiga- tion mea'Jures could preserve the salmon runs at nearly pre-project levels, or potentially at even higher levels, Below Talkeetna, no significant changes in the salmon habitat are anticipated. Elimination of peak floods may res ,·, t in stabilization of bars, islands, and river banks in t.he river bc,ttoms below Devil Canyon Dam, with the result that riparian forest may develop in areas now in wil- low brush. Such· advance in plant succession will be unfavorable to moose, since willow is a prime \'linter food. This trend can be reversed· by a program of logging of the bottomland forest or by judi- cious controlled burning. I I I I I I I I I I I I I I I I I Summary Considering the environmental impacts as a whole, and the possi- bilities for partial mitigation, it does not appear that env-ironmental considerations should preclude the development of the Susitna Project. GEOTECHNICAL CONSIDERATIONS General The External Review Panel, as a group and individually, has visited the proposed dam sites, inspected the rock formations, reviewed the results of the exploration program, and read the interpretations and conclusions presented by Acres in their Feasibility Report. We recognize that the site exploration has been done in various stages over the past years and note that the Feasibility Report has included the pertinent portions of these e~rlier studies. We . conclude that the amount of site geol9gic investigations completed for the Feasibility Report is adequate to effectively preclude unknown geotechnical conditions which would have a major adverse impact on project design and costs. Geology and Project Layout The geologic conditions revealed in outcrops and borings a:t'"e generally very favorable for the structures required for the project. Where local shear zones or other areas of poorer quality rock have been identified, the proposed project features have been pt;>sitioned to avoid them to the degree possible. For example, the di\rersion tunnel inlet structure ·at Watana-bas been moved downstream to avoid the "Fins" feature, the major underground chambers at Watana have been moved to the right abutment to a'\Toid the "Fingerbuster" shear zone, and the orientation of the open cuts and underground chambers have been located where possible to obtain the most favorable orientation with respect to the, joints a:nd shear zones and thereby avoid major rock stability problems. The very good rock conditions revealed in the borings are favorable for the major underground openings proposed and we foresee that the excavation and support of the· chambers will proceed using well established construction methods. We expect that. subsequent exploration will provide the in·formation required to establish the most favorable final position for the chambers as well as providing more detailed information ,on the most appropriate excavation and support .methods for the large diameter tunnels and high slopes. \ 3 I I I I I I I I I I I I I I .I ,-I -· I I ., Special Geologic COnditions The results of the exploration program .at both sites have· revealed no g eo logic structures that can not be handled by · conventional methods. Moreover, the fi.eld work bas been sufficiently widespread to embrace the general geologic conditions so that no major advers~ feature is likely to have been overlooked. One of the most important geologic aspects that will receive careful attention during future field wo1~k is the buried or relict channels on both abutments at Watana.. To date the sttJdies have identified a deep channel on the rigl'lt side that passes between Deadman'· s and Tsusena Creeks that has been filled with varied glacial deposits. The geometry of the channel and general nature of the deposits have been defined by geophysical surveys and borings. More recent studies on the left side in t,he Fog Lakes areas indicate that a similar channel exists here also. The importance of this channel and its deposits for the Watana site are threefold: 1) magnitude of seep~ge, 2) piping of materials towards Tsusena Creek, ana 3) seismic instability of the soils under strong earthquake shaking. These items have been fully addressed in our meetings with Alaska Power Authority and Acres and among. other items, modifications have been made in the level of the reservoir to decrease the height of water ~gainst the saddle dike on the right side. It is clear that furthe~~ field studies are required (and are planned) to assess the import:ance c>f the above mentioned three factors.. However, as has b(!en clearly pointed-out in previous reports., we believe th,'at there are techn.ically and economically viable solutions to these pc.1tential problems. Acres and their EJtternal Review Panel hold th.e same opinion. For the various possible s~lutions, estimates have be.en developed and are reflected in the project costs. We believe that the estimate is reasonable and :should cover possible contingencies that may develop as more infot.:ttation becomes available • SEISM:i:C DESIGN CONSIDERATIONS The Susitna Project is clearly located in an area of potentialJy strong seismic activity and must be designed to safely withstand the effects of earthquakes. For this reason, a greater than norrn.Ja.l effort has been devoted during the feasibli ty studies to determining the pos- 4 ... •• I I I I I I I I I I I I I I I I I I s ible source·s and magnitudes of saismic events which could affect the project and the intensity of shaking . which these events could produce at the proposed ~ites for Watana Dam and Devil Canyon Dam. The extremely comprehensive studies of the seismicity of the pro- ject area are probably more extensive than those conducted for any other hydropower projec-t; in the world. They have been conducted by a highly competent group of earth scientists and engineers and they have identified the major potential sources of seismic activity, the potential magnitudes of earthquakes which oculd occur on these sources and the levels of ground shaking whicn could occur at the project sites as a result of the largest earthquakes. likely to occur on these sources. Design ground mot.ions for the required studies have been selected with a deg!:'ee of co'o.servatism appropriate for critical structures, taking into account. the possibiJ.i ty of a great earthquake (Magnitude 8. 5} occurring on the Benioff Zone underlying the dam-sites as well as· the possibility oflocal earthquakes (Magnitude about 6 l/4} occurring within a few kilometers of either of the sites. Watana Dam ~he preliminary design of the_ Wa~ana Dam is a high embankment dam with gravel shells and an impervious central core. The design is sim- ilar to that successfully used for other very high dams (Oroville Dam in California and Mica Creek Dam in British Columbia, for example) and generally considered to be the most desirable for embankment dam con- struction. Sources of the required types of soils have been located and investigations have shown t.~at ample quantities are available. The proposed section of the dam is appropriately conservative with a proven capability to withstand normal loadings and excellent characteristics to enable it to withstand any anticipated earthquake loading. The proposed design is in fact very similar to that of Oro- ville Dam in California which has probably been subjected to more Je- tailed analysis of seismic stability than any embankment dam in the world. These studies have shown that the Oroville Dam would be stable even if a Magnitude 8 l/4 earthquake should occur within a few kilometers of the dam-site. The controlling design earthquake for Watana Dam is comparable in magnitude but is source is located about 65 kms from the Watana site so that the shaking intensity is less than that used in the Oroville Dam investigation. Furthermore, the proposed materials for construction of the upstream shell of Watana have equally desirable characteristics as the Oroville Darn shell materials. Consequently, there is no reason to doubt, and preliminary analysis by Acres American, Inc., confirm that, with appropriate attention to engineering details, the proposed Watana Dam section will be able to withstand the effects of the· conservatively evaluated earthquake shaking with n6 detrimental effects. 5 I I I I I I I I I I I I I I I I Devil Canyon Dam The proposed design of Devil Canyon Dam is a concrete arch and an evaluation of the design is presented in the following section. With regard to earthquake-resistant design, dynamic analyses have been made to determine the stresses developed by conservatively-selected design earthquakes: a magnitude 8 1/2 event occurring at a distance of 90 .kms and a local earthquake of magnitude 6 1/4 occurring very near the dam··site. The computed stresses are with the acceptable limits for concrete arch dams. · Furthermore, the ability of such dams to safely withstand e.xtremely strong earthquake shaking has been demonstrated by tbe excellent performance of the Pacoima Dam in California in the S.an Fernando earthquake of 1971. This 3·so ft. high dam safely withstood the effects of a Magnitude 6 1/2 earthquake occurring directly be.low the dam and producing some of the strongest earthquake motions ever recorded. This full scale test of a prt:>totype structure provides convincing evidence that such dams can be dl:=:signed to safely withstand the effects of strong earthquake shaking. Other structures In final design careful attention will have to be given to the earthquake-resistant design of other features of the project including spillways, powerhouses 1 intake structures 1 etc. The safe design of these structures is well \'lithin the state-of-the-art of engineering c]esign for the anticipated levels of earthquake shaking and should present no major problems with regard to unacceptable levels of damage or public safety~ Uncertainties in Design Probably the greatest uncertainty with regard to seismic design is in the required treatment of the bul:-ied channel on the right bank of the Watana reservoir. This uncertai:nty stems mainly from the fact that it has not been possible at this stage of project development to ascertain by borings the types of soils filling the buried channel and their en.gineering characteristics. However 1 this is not. a major problem since even if very unfavorable characteristic·s are assumed for these soils {and . this will not necessarily be the case), remedial design measures have been explored and developed to eliminate any problems which could · arise. Provisions. for the co.sts of these measures are included in the cost-estimate even though the mitigation· measures themselvesf which may not. be required 1 are not presented in the feasibility design reports. 6 1----------------------- I I I I I I I I :> I I I I I I I I I I I · Conclus io.n In summary, it may be stat,ad +.:.hat the feasibility stud.ies fc)r the Susitna Project included an extremely comprehfU1sive investi9ation of the seismicity of the project area and the development of design concepts for the major critical structures Tflhich, with appropriate attention to details in the final design and construction, Sihould certainly eliminate any concerns regarding the provision of an adequate level of public safety and the preve:ntion of any signifi ··ant damage to the project as a result of earthquake effects. D;EVIL CANYON DAM ----------------- The Devil Canyon Damsite is ideally suited for an arch dam. The canyon is narrow and V-shaped.. The abutment rock is sound and compe- tent. Devil Canyon arch dam has been designed and analyzed by use of the Arch Dam·. Stress Analysis System (ADSAS) computer program, which is the computerized version of the Trial Load Method of Analysis. This method was developed by the t1. s.. Bureau of Reclamation and has been thoroughly examined by rigorous mathematical analyses. In addition, results from this method have been successfully compared with structural models and prototypes in service. The design selected for Devil Canyon is a thin double curvature arch. It is curved in both horizontal and 'rertical Planes to Produce the most efficient distribution of stresses possible under the si.te and loading conditions to which it may be exposed at this site. The static loading conditions examined are the most. severe combi- nations of gravity, reservoir and temperature loads anticipated at the site. The resulting stresses i1:1dicate ·a factor of safety greater than four, based on the anticipated compressive strength of concrete in the structure. The maximum 1censile stresses occur on the downstream face of the arch, where, if cracking were to occur, no damage would result. The magnitudes of tensile stresses indicated will not occur since a redistribution of load in the dam will result as such stresses develop. The dynamic loads applied to . the dam are considered to be very conservative. Even so the resulting stresses will not cause serious damage to the structure. The analytical method us~d for stress. stud- ies is based on elastic theory. If the stresses indicated should occur, contraction joints in the upper part of the dam may open momen- tarily but would not result in ma:J,or release of wate.r or permanent damage to the structure. 7 I· I I I I I I I I I I I I I I I I I I The preliminary design for Devil Canyon Dam do,es, in every re- spect, respond to the seismic environment of the site. With proper construction control, the dam will provide adequate safety under .all load . .rMng conditions. It is extremely important that the very best construc~tion techniques be employed in this dam.. Proper concrete mix designs, consistent consolida:tion of the concrete and careful· treatment ~f the rock contact and construction joints are of the utmost importance. The resulting concrete must be a homogeneous and isotropic ~roduct. There are always risks of inadequate or inC(.)nsistent construction practices which would present problems in the behavior of a dam. For- tunately an arch dam has the capability of distributing load from weak ar·eas to stronger, more capable concrete. This is not meant to excuse any but the best concrete control possible, because any weak- nesses are not accepta!Jle in this important structure. Additional foundation investigations and insitu measurements will be required before a final design for Devi.l Canyon Dam is completed. Deformation moduli, joint orientation and continuity, and shearing re- sistance along joints will be required~~ Because of the preliminary nature of the .present studies, such investigations are not considered necessary at this time. Instead, conservative assumptions have been made to assure a safe and satisfactory structure. The proposed foundation treatment, consisting of consolidation and curtain grouting and adequate drainage, is satisfactory. The engineering consultant has used adequate conservatism throughout the design for Devil Canyon Dam. Very little change from the preliminary design is anticipated for a safe and efficient final design for Devil Canyon Dam. HYDROLOGY AND HYDRAULIC DESIGN CONSIDERATIONS Flood Potential The e_ngineering consultant's assessment of the flood potential in the project area has properly identified the potential magnitudes and frequencies of flood flows. ~he assessment utilized all available precipitation, snow survey and s ,:ream gaging data for stations within and adjacent to the Susitna River Basin. The probable maximum flood is based on the most critical combin,-ation of precipitation, snow melt, infiltration losses and flow 8 I I I I I I I I I I I I I I I I I I I concentrations that is reasonably possible~· The hydrologic analyses are in accordance with accepted engineerin9 praetice ·which has been dev-eloped in the United States and is being used in many parts of t..~e world. · Spillway Capacity and Dependability The proposed design adequately responds to the hydrologic envi- ronment in terms of spillway capacity and dependability. Both Watana and Devil Canyon dams will have low-level valve- controlled outlets to pass the once in 50-year flood, a ga.t:e control- led chute spillway in combination wit..h the valve outlets would pass the once in 10, 000-year flood and a fuse plug emergency spillway in combination with the valve outlets and ·chute spillway would pass the pt·obable maximum flood without overtopping the dams. Similar valve outlets and emergency spillways have been constructed and opera te.d elsewhere with successful service. There is no reason to believe that they would not be successful at the Susitna project. Public Flood Safety The proposed project adequately protects public safe.ty in terms of the flood danger and there are no increased flood risks inherent in building the project. The reservoirs will be drawn down in winters providing signifi- cant amounts of reservoir capacity for storage v.f summer floods. Virtually all normal river flows would pass through t-he powerhouses with very little spillway operation. Peak discharges for major floods would be reduced substantially. Consequently, project operation would enhance the public safety by reducing the magnitude and danger of floods in the lower Susitna River. · Spillway capacities and heights of dams are designed with conser-· va ti ve safety factors. The dams and water conveyance structures are designed and would be constructed with high safety factors in accord- ance with best engineering practice. For these reasons, there would be no increased flood risk inherent in building the project. Proje.ct Damage or Shutdown There is no reason to expect that the project would experience damage and/or require shutdown as a result of floods. Major floods may cause some cavitation erosion in spillway chutes, river bank and bed erosion downstream of flip buckets and valve outlets, and erosion in the unlined emergency spillway channel. 9 I I I I I . I •• I I I I I I I I I I I I Because of the infrequent occurrence and relatively short duration of major floods, none of these types of damage would become so extensive during any single flood t.o require project shutdown.. , One or more of the valve controlled low-level outlets may sustain damage during a major flood requiring temporary shutdown for repairs. This shutdown would not significantly affect flood regulation since each outlet dis charges a small percentage of the total flood flow. As the powerhouses will be underground, floods would not cause them to be damaged or shutdown • Design and Operation Assumptions The engineering consultant has not made any major assumptions re- garding design, operational mode, etc. of water conveyance structures that lack a satisfactory level of 6onservatism. The low-level outlets, main spillways, and fuse plug emergency spillways have all been designed in accordance with current engineer- ing practice which is based on conservative assumptions. Fixed cone valves are superior to any other type of valve for high-head opera- tion. Air slots will be provided in spillway chutes . to prevent cavitation erosion by high velocity flow. Pre-excavated plunge pools and/or bankprotection will be provided !lownstream of flip buckets and fixed cone valves to prevent excessive streambed and bank erosion. The fuse plugs are designed conservatively to withstand reservoir pressures until they. are overtopped and then wash out rapidly to activate emergency spillway operation. The assumption that e~cessive erosion would not occur in the unlined emergency spillway channel is conservative in view of the mild channel slope and favorable rock quality .. The proposed operation of the water conveyance structures is be- lieved to be the most reasonable and practical operational mode which provides a satisfactory level of conservatism with respect to down- stream effects and project safety. Reservoir Sedimentation The effects of reservoir sedimentation have been properly assess- ed in design of the project. Based on conservative values of the sediment inflow and reservoir trap efficiency, less than 5 percent of Watana reservoir would. be filled in 100 years, and deposits in Devil Canyon would be less than 25 percent of that deposited in Watana reservoir. A large percentage. of the sediment would be deposited in the dead storage portion of the 10 I I I I I I I I I I I I I I I I I reservoirs. Reservoir sedirnenta tion is not a controlling factor in project design as larger reser·.,oirs or higher dams a~e not required and power production due to reservoir sedimentation would . not be affected for well over 500 yea~s- Potential Downstream Effects The proposed design and operation of the water conveyance structures adequately addresses potential downstream effects on river morphology, fisheries and wildlife. Multi-level intakes will be provided for tbe power intakes and/or low-level outlets, as necessary, to permit release of reservoir water in the temperature range. sui table for the downstream fishery. The valved .outlets will discharge into relatively shallow basins, thereby preventing nii;Z"cgen supersaturation conditions harmful to fish. Spillway flip buckets and plunge pools will be designed to minimize nitrogen supers.aturation. Their infrequent operation of once in 50 years would also greatly reduce any potential for serious effects on fish by nitrogen supersaturation. Plannec increased reservoir releases during critical spawning periods togeth\~r with remedial river channel work in spawning areas would minimize detrimental effects caused by lower river water levels due to project operatione While turbidity levels of reservoir releases would be sharply reduced in the summer, winter -turbidity levels may be above natural levels due to suspension of fine sediments in the reservoirs; but this is _not believed to be significant. Project operation will cause the following addtional effects in the Susi tna River downstream of Devil Cany~n Dam: ·1) Eliminate and/or reduce thickness of ice cover for 20 to 30 miles downstream of Devil Canyon Dam in the winter due to release of reservoir flows above freezing temperatures which would prevent river crossings over ice by some wildlife and humans. 2) Sediment loads would be reduced in. the Susitna River upstream of the confluence with Talkeetna ca_using some degradation of river channels. 3) 4) Sediment loads would be essentially unchanged . below the confluence bec~use of the extremely large volume of sediment in the flood plain and contributed by tributary streams below the Talkeetna confluence. · Summer water stages in the lower Susitna River will be reduced by 1. 5 to 3. 5 fe.et which would reduce flooding in some areas and should not cause major impacts on navigation and other river operations. ll -t) I I I I I I I I I I I I I I I I I I I 5) 6) The lower river will become more stabilized, resulting in a decrease in the number of small subchannels and an increase in vegetative cover. The absence of annual floods may result in some loss of new lands for moose browse. In summary, the potential downstream effects do n·";;t. appear to be of such significance as to seriously jeopardize projec1:. construction. Mitigati9n Measures in Water Conveyance Structures Based on successful experience at other projec~s, measures that will be incorporated in the design of conveyance structures should be reliable and effective. mitigation t.he water Multi-level intakes would have ports at several reservoir levels and a gate control. system which would permit reservoir water to be released at the best possible temperatures sui table to the· downstream fishery. The fixed cone valve sizes and opera.ting heads for the susitna project are well within their aeeeptabie limitso Additional reliability of operation is provided by the use of 5 and 6 valved outlets at Devil Canyon and Watana, respectively. · This enables continued operation at a high level of reservoir release in the event that one or two outlets would need to be closed. Operation of the valved outlets, as proposed, will reduce operation of the main spill- way to once in 50 years, thereby reliably and effectively minimizing nitrogen supersaturation effects on the downstream river fishery. Conclusions In summary, it may be stated that the feasibility studies for the Sus i tna Project includes a thorough development of hydrologic aspects of the Sus it.na River and the development of design concepts for the major water conveyance structures which, with appropriate attention to details in the final hydraulic design, would assure an adequate level of public safety against flooQing and the prevention of excessive detrimental downstream effects on river morphology, fisheries and wildlife. MARKETSv ECONOMICS AND FINANCE FOR THE PROJECT This section responds to the basic issues of the macroeconomic forces impacting the economic viability of the project, the future de- mand f·or power, economic measures and risks for the project, financial 12 I I I I I I I I I I I I I I I I I I I opportunities and problems, marketability of power and suggestions for an overall strategy. Macroeconomics Two factors, future world oil prices and market rate of interest strongly impact {if not dominate) the economic and financial viability of the project. Both of these factors are in a large measure outside the control of the Alaska Power Authorityv Oil prices strongly affect the State • s revenues, which in turn influence the State's economy, . the rate of economic development in Alaska and correspondingly the future demand for power. These .prices; through competitive market forces, establish the long run competi ti.ve price of natural gas and influence the price of coal and thus strongly influence the costs of thermal alternatives to the Susi tna Project. These same prices affect State revenues ~and available funding from the State for the project, and the marketability of power. More than 90% of the direct costs of operating a hydro facility are interest charges. The market rates of interest, thus st.rongly de- termines the cost of the Susitna Project and its relative economics. The susitna project is economically attractive in an environment of rising oil prices and low interest rateso Interest rates for State Government bonds are the highest they have been in fifty years. With a growing surplus of crude on world oil markets, ·the spot prices of crude have declined and future price trends are uncertain. Demand For Power . We have reviewed the range of demand forecasts developed by. ISER and Battelle and employed by Acres in their report and it is our opinion that these forecasts appear reasonable. Actual growth rates will probably lie between the expected and low cases. This is true because essentially all of the power will serve the residential and commercial market, which tracks population and employment trends .. Economics of the Susitna Project The present value of the cost of 't;:.he Susi tna Project versus another source of power is related to the time horizon of the evaluatiol'l and the discount rate. The time horizon is important because the economics may be different depending on the period of evaluation. 13 I I I I I I I I I I I I I I -I I I I I -------------------,-~~~ Work done by Acres and Battelle, and supported by our independent evaluation show that over a 30 year period through the year 2010, the susitna projec~t WP\lld probably yield no ne:t benefits. With current interest rat-es and oil prices, over a thirty year period, power from the Susi tna could very likely be more costly than a thermal alternative. However, hydro proj~cts usually have long useful lives of many decades, and over a 60 year period, the Susi tna project appears to b€ economically attr-active. With this framework, there is a value trade-of£ for Alaskans to choose between * Receiving the/" current benefits from funds that would be invested in the Susitna Project or Ynvesting and receiving the potential long term benefits of hydro power in the next century. Sensitivity.and Risk Analysis The net economic al terna ti ves are highly rates, fuel escalation financing strategies. benefits for the Susitna project versus sensitive to load forecasts, real discount costs, capital costs of the project, and For the Acres' base case analysis, which has escalating energy price~ of 9-10% per year based on inflation of 7% per year and an implied interest rate of 10%1 the net gain over a 60 year period is abou·t $lo3 billion (1982). The investment in the Susitna Project corresponding to this gain is $5 .. 1 billion (1982). If the load forecast follows a low growth scenario, the net gain is reduced to nearly zero, or if the discount rate is reduced to 12% (5% real.) the project would yield a loss of $500 million or more. If the fuel costs escalated at an inflation rate of 7% per annum, the impact would also be a loss of $1.1 billion dollars. Conversely, if the escalation rate for fuel is 10%, the impact would be a net sum of about $1.5 billion. If the capital costs of the project were 20% more than estimated 1 the cost of the Susi tna Project and a thermal alternative would be essentially the same. There is a wide range of possibilities for forecasts of these · variables and corresponding values for the net benefits or losses. \!'hrough a probabilistic assessment of each of these variables, Acres estimated that there is about 25 -30% chance for a net loss and a 70 75% chance for a net gain. These assessments were made in an. 14 I I I I I I I I I I I I I I I I I I ,. environment of increasing oil prices and medium increases in load, ana did not directly account for the finan:c.ing and ma1:keting risks in these economic analysis. If we includ·1 these factors in todays environment,. the risks increase although the weight of the economics still slightly favors the Susitna Project. The major economic risks for the project are: { 1) Inability to obtain favorable bond rates and corresponding high financing charges for the project~ ( 2) Lower than expected -energy P,rice increases could make the project economically nonviable. (3) Capital cost estimates may be too low, placing sev·ere financiaJ strain on the project. ( 4) Possible opportunity losses, that is, ·foregoing the benefits of other investments in Alaska, for example, industrial development in enterprises which might generate net revenues or a stable long term employment base. The Susi tna project would generate jobs during construction. However, in the long term during operation, the number of jobs added to Alaska's economy is minimal. ( 5} Difficulty in entering into· long term contracts for the power .. { 6) A. possible combination of the above .. Management of Economic Risks Many of these risks can. be managed, the~eby substantially increasing the possibility of favorable economics for the project. The essence of this management is (1) timing and {2) additional low-cost studies. A strategy of waiting patiently for favorable bond interest rates and an increase of oil prices would substantially reduce the risks. Taking a long term view, over say ten years, there is a strong possibility that interest rates will decline giving the Power Authority a window to obtain inexpensive financ~ing. Correspondingly in the same time frame, it is likely that oil prices may start to rise again. In order to finance and start construction when these favorable events occur requires positioning now. This includes obtaining in advance all permits and licenses, and completing the engineering design and environmental studies. To further reduce the risks, Authority develop a business plan identify viable power alternatives or the demand forecast changes. it is recommended that the Power which would, among other things r if the Susitna project is delayed 15 I I I I I I I I I I I I I I I I I I -~;nancins !n the curl:'ent inflationary environment, the Susitna Project. would probal:>lY need state goverment pa.rticipation of about 50% of the project's value --$2,500,000,000 in 1982 dollars and more than $3,500,000,000 in actual costs. Because of the high level of risks, the debt portion of the project would probably require implicit or explicit state guarantees, or possible gen~ral obligation bonding. The State of Alaska effectively takes all the risk on the entire cost of the project including potential bonding of $2,800,000,000 in 1982 dollars and a correspondingly greater numbers of actual dollarss A combination of escalating construction costs, high interest rates, and declining state revenues could put a revenue cash flow squeeze on the project. Positioning, patience and timing are critical to minimizing this risk. These are some major opportunities in the financing area including the arbitraging of funds during the construction period or obtaining low cost debt financing. For example, if the project could be financed today at the lower rates that prevailed in 1977 and 1978 ( 7 to 8%), 1:he present value of the costs could be reduced by about $1,500,000,000 {1982 dollars). A recurrence of low rates would markedly affect the financing of the project. The tactics and strategy for financing needs further study and should be de·veloped in the business plan. Marketabili t,~ The power from the Susi tna Project probably could n:-";t be sold unless it we~re less costly than al terna ti ves. Anchorage, Fairbanks, and other t·eg ions within the Railbel t Area have different power sources and, correspondingly, different cost bases for power. This means that i.f uniform electric rates were. used for Susitna power, the cost of powetr may be pegged to the least costly alter~,ative~ This would furthel: exacerbate the financing and contracting problems. A solution lies in. organizational changes and a possible state referendum tQ gain support from the interested parties. This problem of marketing needs further study in the suggested business plan~ ~6 1-. ..,... ______ ...,_ ___ ___,.._.,._"'-~"'<~: ...... ~ ..... .._.<-~---~'EA..-~.---..~ ....... --""'!.W .... ""l'. l'I!J'.¥'"":·-~·~-~--~*':-'.s~u~""!'! •• "'!:.!l~--..=+~ .. lri!E!~.·,.,.!"'!«;~t ....... ':"'!. 4MIACL4-W""!! .. '::". ~;a- I I I I I I I I I I I POWER· AUTHORiTY SUSiTNA LE P5700 • '7 • • // /t SEQUENCE NO. DEP.-\RTME~T OF FISH :\.~D G.-\JIE I OFFICE OF THE COMMISSIONER f L t ! i I ! :1! • j , ! • JAYS. IIAMMlJ/I(J, GDVE/111011 P.O. BOX 3~2Dl'JO JUNEAU, A.LASkA 99802 PHONE: 465-4100 . RECEIVED APR 19 1982 ACRES htntr.fGAN UiCORPDRATED Statement of Commissioner Ronald o. Skoog to Alaska Power Authority Board of Dir~ctors regarding Susitna Hydroelectric Project Feasibility Report FR 16 APR 82 The Alaska Department of Fish and c;ame · appreciates the . invitation extended by Mr. Conway to provide the Alaska Power Authority (APA) Board of Directors with this Department' s views concerning the "featsibility report" on the proposed Susitna Hydroelectric Project. We have not had suffici~nt time to review the report in detail, but nevertheless do have some comments to make. In his January 26 letter to the Department, Mr. Conway stated, "Specifically, we wish to know if, in the area o£ your agency purview and based on information available to date, you judge the proposed project to be cost effective, environmentally acceptable, technically sound, and in general in the best interests of the people of Alaska." My Department's expertise is_ limited to the second area of •• concern--"environrnentall-y acceptable 11 --and therefore my ~~·!~~,.. .• \ -:..;;.:o.::=._\.r.~omments will be confined to that. Higher authority than ·-~--· ,./' ~:t: ·-·· ' .......... -.-·- ,.,, L.H I I I I I I I I I I I I I I I I I I I mine will judge whether or not the project is "cost effective", "technically sound", and "in the best interests of the people of Alaska." In support of my response to Mr. Conway' s request, I am providing the Board a copy of a March 12, 1982, letter and enclosures from my office to the Northern Alaska Environmental Center. This correspor1dence will provide. additional background information outlining this Department's viewso My comments today restate many of our prior positions, comments, or advices pertaining to the proposed Su Hydro project. At the present time, this Department does not believe that the potential environmental impacts of the proposed Susitna Hydro Project from the fish and wildlife perspective can be evaluated adequately, because 1) The information and analysis to date are not sufficient to identify the full range and magnitude of po.tential impacts the project will have on fish and wildlife; and, theretore 2) It is unknown as to which mitigation alternatives can or should be applied to offset these impacts • •• • Absent an adequate evaluation of impacts and applicable mitiga.,tion alternatives, we cannot hope to evaluate the environmental costs, the feasibility of mitiqation, or the I 'I I I I -I I .I I I I I· I ·t I I I I I -3- tradeoffs of fish and wildlife resources and habitat that may be involved. The costs of mitigation. should be! included as an integral part of the appraisal of the overall costs of the proposed project. This Departmen.t also is unable to conclude at ·t:his time whether this proposed hydro project is envircmmentally sound. It has been this Department 1 S general advice that a minimum of five years would be required to assess and understand project impacts to provide the basis for developing mitigation alternatives. To date, the limited data and impact analysis by the APA' s contractor, Acres American (Acres) , and the incomplete analysis of mitigation measures do not reflect accur.ately the actual level of knowledge available thusfar from data collected by the Department this past year. Another constraint upon an acceptable environmental evaluation has been the inadequate time scheduled for impact evaluation arid mitigation. plannin.g to meet the .requirements of State anq Federal laws, regulation,· and policy regardin-g fish and wildlife resources. It has been our general perception that ·in order to meet predetermined project qonstruction deadlines, the Alaska Po¥1er Authority has tended to diminish the views expressed by our agency and others concerning 'important resource issues, including the level of information that agencies I I I I .I I I I I I I I I I I I I I I -4- eonsider essential to minimize or avoid conflicts on unresolved issues or informational deficiencies which can arise during the review process of the Federal Energy Regulatory Commission (FERC) license application. The APA has had an opportunity to address agency concerns on project "" issues for over two years, yet generally has remained unresponsive to suggestions to develop a process for formal substantive interagency coordination. Instead resource agencies have had to work on an informal basis through the 0 Susitna Hydro s·teering Committee (SHSC). ADF&G recommended in 1979 that this committee, which includer: members of my staff, be established with a ·more formal role than it has now.; I would like to reaffirm that I fully support this committee and the advisory role to the APA they have attempted to fulfill.. The SHSC has made a serious attempt to provide advices on .project deficiencies and on interagency and interdisciplinary study coordination needs to the APA. (See enclosed copy of letter to Eric Yould from Alan Carson.) APA should recognize and give attention to the concerns the SHSC has advanced even though it has operated only on an ~nformal, advisory basis • •• • I suggest that the resolution of these concerns about the project prior to initiating the FERC license process application. might well be a more prudent course to follow I . I I II I I I I I I I I I I I I I II • I ... s- and might well J:'esult in a short~r time-frame for license approval than what might occur should the license application later prove deficient. Additionally, to initiate t:he application process prematurely with insufficient: data probably will result in an undesirable pola.rizatio11 between the APA and the State/ Federal agencies on unresolv·ed resource issues. There are two fundamentctl elements of resolution that we believe would be desirable before the .application for a FERC license is made: 1) Cc:>mpletion of one additional year of fish and wild.life baseline data collection, incllldinq - cc1rrani tment of budgetary and manpower resources 1 before attempting an evaluation of habitat-wildlife relationships. Par·ticular emphasis needs to be given to the aqua.tic habitat and instream-flow progra.I!l of the Alaska Department of Fish and Game. The methodologies involved and data collected are essent:.ial to quantifying project impacts on Susitna River fishery resources and to some extent can be applied to impacts on terrestrial wildlife resources. This past year, the ADF&G aquatic .. studies were limited to collection of baseline • .&: • J.n.~-ormatJ.on., I I I I I I I I I I I I I I I I 'I I I 1- -6- The impact analysis and mitigation alternative planning role was delegated solely to Acres-American and Terrestrial Environmental Specialists (TES) • In ?Ur opinion, Acres and TES underestimated the time and manpower resources required to analyze and prepare an impact evaluation from the large amount of information coilected by this Department and other project participants. In recent discussions with APA staff, it has been suggested that ADF&G perform the technical analysie of data we collect in FY 83 to assess project effects on habitats. We would accept this role and function provided that a comprehensive interdisciplinary instream flow study program is implemented. The FY 83. program that ADF&G proposes should be 'I supportive to and supported by field data collection and efforts of other study contractors. There should be some assurance that other important study elements in water quality and hydrology, for exan1ple, will be collected and,. when applicable, analyzed and made available so the ADF&G can make an objective assessment of • project effects on aquatic habitats. I I I I I I I I I I I I I I I I I I I -7- , 2) It is of primary importance that APA initiate a formal program of coordination with State and Federal Agencies to review and identify unresolved project issues, scope of studies, and agency expectations with regard to mitigation planning. Jl APA needs to respond to agency recommendations and to develop an organization, process, and strategy to deal with unresolved project issues orior to submitting the FERC license application as well as with any issues identified after submission during the application review process. Thank you for the opportunity the APA BoarcL,of Directors has . . afforded the Department of Fish and Game to express our views. •• • . ; Ronald 0. Skoog 16 APR 82 ----~----------............................................ .... I I I I I I I I I I I I I I I I I I I JAY$ HAMMOND~ GDY.ERIIOI: Dl-:t• \RT'IE~T Of." FlSII "-~D G~\ lit-: OFFICE OF THE COMMISSIONER . P.O. BOX :1·2000 JUNEAU. ALASKA S9Bf12 I'HONE: 4 6 5-41 00 Mareh 12, 1982 Mr. Jeff Weltzin Northern A1aska Environmental Center 218 Driveway Fairbanks~ Alaska 99701 Dear Mr. Weltzin: This is to c1arify further the Department of Fish and Game's position pertaining to the Su-Hydro Project. Copies of prior correspondence between our agencies are necessary for the conveui.ence of the ~ersons and agencies who w:tll receive a eopy of this response to insure they can view the context of these letters aud the questions you have asked the Department.. Therefore. we have enclosed: your original inquiry. of December 3 • 1981, our response January 19, 1982.~ and your letter uf February 1. 1982. The first question you advance in your February l, 1982 correspondence basically asks i.f ADF&G can grant a Title 16 permit to the Alaska Power Authority (APA) if the APA files a Federal Energy Regulatory Commission ·(FER.C) application thi.s summer. The answer. to this question is "perhaps." In ouT opinion~ however, ~t would not be advisable or reasonable fer the APA to make such an application or request au approval o:f a permit from this Department under Alaska Statute 16.05.840 or 870 at this time or in the near future. Some of the reasons are as follows: 1. Because of the si,ze of this proposed project:~~ a FEB.C License applicati.on und.oubtedly wil.l receive a broaa rau.ge of public., governmental agency, and special interest scrutiny. It is therefore most preferable that the FERC license. application proc.es.s be implemented and basiea.lly concluded before an ADF&G Title 16 permit is requesteda To apply for and receive a Title 16 permit from the ·ADF&G would be a disruptive and delayiut influence on the FERC license application process. Essentially the FEltC license application vill start a "clearing house" process within which issues and I I I I I I I I I I I I I I I I I I Jeff ~el~%in c:.oneerus about the suffieieucy of available data, atu! the adequac: cf f~sh and vl.ld.lif~ mi,tigat.iou 'Plauuiug .and 'i-mplementation c..an be addressed be.~Veffn the Alaska Pove: Author~~' and -the State and F~dera~ resource agenei.es. Yith the successful conc:lusio~ of the !ERC process, AD:F&G should be able to issue a Title 16 permit. pu~suant to its_ au.thori'Cy with :coudi.ticns. or $t~pu1at~ous speeif~cally relevaDt to the hydroelectr~c proj e.~ t const'ruc: t~on plan, and eo~~i.st._ent wi tb a mit~gation plan accepted by ADF&G, as vell as the U.S. Fish and ~ildlif~ Service and ether resource agencies. e 2 • l t i.s e xp l ic ~ t i.n S e e t ion (e) of A,. S • 16 • 0 5 .. 8 7 0 (enclosed) that the a"D"Dlicant: provid~ complete plans for tbe proper protection of fish and game before ccnstructl.ng a hydroelectric p:-oject': I.£ these plaus are not su£ficient in the viev of this Department, the approval mcty be conditioned by this Department with those measures or requirements "\Jhich must be met ~o protect. fish and game resources before. eonstructiou of the. project may begi.u. !he need and value of the addi.t~onal studies and mitigation planning vhi.c.h we see as being required for the Susitna Hydroe.leetric Project are to insure that the mitigatiou and resource trade-off cption.s are clearly spelled out by the applicant and .that the "conditioning" and "stipulations" of our permit are minimized. It is not advisable nor. reasonable for APA t.o initiate a "second front" of permit applicati.ou· vhi.c.h ~ould demand an unreasonable amount. of time and effort vhe.u th.e :FE'R.C license application process is set up to accommodate this Department's as ve.ll as othe.r . · agencies' concerns. Your second questi-on asks this Department: · to adv:ise the Governor, l.egi.slature and Authority of your assessment regarding what be said about impacts to Susitna fisheries project at th~s t~me?" " .... do you p~a.u the Alaska P.ove.:r can and cannot from the proposed Tbe Department has stated its position tc the Alaska Pove.:r Authority numerous times in the past: regarding the level of ex'istin~ fisheries information available prior to the initiation of this year's Phase I study, and t"be time frame. ve believe vi.~l be requ:ired 1:.0 complete a :reasonab.l.:e assess-ment of fisheries resource impacts. Our bas i.e. advi.~e bas been that an acceptable mit~gation plan vould require a minimum .of five years of comprehensive fisheries and aqua.ti.e habitat assessment. ~itb that time frame a 1evel of information co.uld be attained .vhich vould euable resource impacts. to be evaluated objectively~ and a feasible and prudent mitigation plan to be approved and adopted for imp lemellta t ion. I . I I· I I I I I I I I I I I I I I I I Jeff 'Welt::. in March 10 • 1982 l't mus~ be pointed out, bovever, that the Su-Bydro Aqua tie Studies ha\'e ma·ny t.asks or sub-element:s ~hieb aft~r a'll annual :revie'Cr1 may be · ·\iroppe.c1 or continued, concis~e.nt with a det.ermina~iou that the data generated from these tat;k$ is sufficient ~o define or net defi.11e a speeifie i.mpaet. 'We b-elieve the AD'F&G Su-Bydro Aqua ti.e Study Pt-~grau must be continued at it~ current level in all task &reas, and intensified in the "Aquatic Rabitat and lnst~aam Flov~ proj ec.t. Ye ·see major res coping · be.i.ng required for the program to be condueted after June 30, 1983, to resolve probable lieens~ appl:lcatiou de.fl.c:.iencies that may come up i.tl. the FERC review process. 'We believe it should be the APA' s responsibility to define "all of the issues about this project that concern the public. special ~nt:erest. groups. and the resource agencies. 'We kuo._. that resource agencies have fo1:warde.d tb.ei.r concerns about the r.:r:ojeet to the A.PA. Rovever, we have never se.en a.ny publication or presentation of tbes·e agency concerns to the public. Governor, cr the Legislaxure. Ample opportunity for APA to publi.c.:Lze th.ese conce.rns has been afforded si.uce 1979 through tb~:Lr public participati.on program and reports to the Governor and the Legislature. Such an opportunity.· for example. could have been afforded :ln the Susitna Iiydroelec trie Proj ec:t Mid Report to the Governor and ·the Legislature. ~e believe the Governor and Legisla;ure should have been informed in March 1981 ~n the Hid Report that there. are issues of concern vithiu the State about _the Su-Bydro Project. It is important .to recognize too that many of these issues are not r~lated to the fi.sh and wildlife resources. Your thi.'rd and fourth questions ask our opinion on whethe-r ".o.it ~s appropriate for the State t~ judge project feasibi.1ity and -commit ·to -project_· construct'iou: ·at·-thi.s ti.me1n. and " .... if you do not feel an i.nform~d dec.i.sion e&u be made on Sus~tna Bydro at this time, how much addit~onal fishery study does A.DF&G need before enough is knovu to determine project feasibility?" ~e believe that the feasibility of the Susitua Hydroelectric 'Project presently i.~. being based on vhether a benefit-cost ratio of 1.0 or greater can be obtaine~ for the proje~t. X£ the benefi. t-c.ost, · ratio c:.alcula ted for ·the project · i.s proj ectec1 to be less than 1. 0, ve assume that the project vould be determined to be "not feasible" from the economic. perspective. This Department is not aware to what extent the cost of mit:.i.gati.ng fish and wi.ldl:lfe impacts :t..s being included :t..n benefi1:.-cost calculat:ion.s as a part of determin~ng overall project feasibility, nor are we aware how socioe~onomic impacts are being calculated. In our •iev it logically follows that. if project impacts are neit.her adequately determined at this time nor prudent and feasible mitigat~on options described, then the costs of fish and vildlife mitigation effotts in the benefit-cost aualysi$ I ' I I I I I I I I I I I I I I· I March 10, 198.2 e.a.~no~ be pre.s:t:.'Q.ted obj ec:t,i.v1!lY· bec.ause ve believe the.se costs a.re u.bt p re.se.n tly k1lOUJl. ... 1t should be noted also that it ~s a fundamental requirement of the 'Federal '9 Fish aD.d ¥7ildlife Coordination Aet'' (48 Stat. 401. as amended. 16 tl.S.C. 661 et. seg.) that the eost of mitiS:tAt,ion must be inco-rporated in the benefit-cost assessment relat1ng to proj e.c:.t feasibility. Sol'ely from the fish and v~ldlife resource standpoint yroject feas~b~lity has uot been shovn either positively or negatively. that is, vhile the ran.ge of project impacts cannot be addressed adequately . nov and feasible mi.tigatioD alternatives or options outlined, these should occur in due time.. As l previously commented iu my January 19 letter to you, Terrestrial Environmental Servi.c..es had a diff:lcult: charge to determine f~sheries impacts and 1;itigation alternatives by February 15 of this year. We doubt that the recent delay of FERC licensi.ng to September 30 by the A.PA. Yi.:Ll change the quality or objectivity of that effort significantly, due to t~me and ~nformatianal restraints. As stated earlier herein. ve believe tha~ a five-year study program would be needed as a minimum to assess the imp~cts of the project from the fish and vildlife perspective. '!hat es .. timate continues to be this Department's fundamental positiou. l~ you have further questions do not hesitate to contact this Departmeuto Sincerely, ~~J.~--.. Ron };I~ 0 • Ko o g Commi.ssio er Enclosures cc.: Governor Hammond John Kat~ -Commissioner ADNR Ernst Muelle-r Commissioner ADEC~ " I . I I I I I II II II I I I ·I 1·- I I I I I c • • Se~ 16.05..870. Pro~tion or fish and prn~ {a) The commissioner ahall, in a.ceorda.nee.'trith the Administ:ra.tive Procedure Act CAS 44 .. 62) ~pec:ify the various men. lakes., and a~ or-parts of them that are important for the spawning or migration of Zna.dromo~ fmh. Before December 31, 1968, the specification may be. made by designating a.rea.s within which all rivers, lakes, and streams are eomidered important for the spawning or mign.tion of ana.dromous fish; provided. that the areas lie within 50 mnes of the coasUine extending from Dixon Entrane:e through False Pass to Cape .Menshiko!, including all islands east of False Pass. A person giving notice under (b) of this .section before December 31, 1968, may, if the activity is to take place within sue.h a designated area., request the ·c:o-mmis~ioner to specify individually by name or number, the particular rivers, lakes, and streams .or parts o! them within the area of operations described in the notice which are important for the spawning and migration of a.nadromaus f"z.sh. Upon · receipt of the request the commissioner sba!l promptly make the desigmtion. (b) If a. person or governmental agency desires to CDDS'l::nlc:t a bydr:aulie project, or use, divert, obstn.l~ J)C?llute., or change the na.tnn.l flow or bed of a specified river, lake...or ~or to use wheeled, . traCked. or excavating equipment or log-dragging equipment in the bed of a spec:ified river, ~ or stream, the person or govermnentzl ageney shall notify the cmnm;ssioner· of tbis intention before the beginning of the constroction or use. (e) ·The commissioner sb.a.ll acknowledge ~t of the notice. by return air man. If the commissioner det.e::m.illes to do so, be shall. m the letter of aclQ:aowledgement, require the person or govemment21 ~ to submit to him fnil plans a.nd specifications of the proposed constrnc:tion or work, complete plans and specifications far the pmper protection of fish and game in connec±ion with the const::ruction or worlc. or in cormection with the use, and the approxim.a.te date the ccn:zstruction. work, or use will be~ and shall require tbe person or govc:ornment:d agency to obtain written approval from him .as to the suffic:ienc:y of the pbms or specific:::a.tions beiore the proposed c:anstruc:ticm or use is beg an.. (§ 31 art I ch 94 SLA 1959; am § 1 ch 180 SLA.l960; am. § 1 ch 132SLA.. 195~ am § l eh 89 SLA 1566) h1"PO'JC--The purpose o! UUs'·secDc::m is to protee. ud CDIJ3Clte fish and game &Dd.othermtmalresom=:s..l9&1 Op.Atry Gt=.. Na.. 10. Alaska. baa jwUC.id.ion t.O ~nron::e ita riSh and. p.me laws iD naJ.ioa.al (oi"':Stt.. 1964 Op. Aa.'y Gc.. Nc.. 10. r • . Al:asi::a·s ~fish aDd p.me ia.vs.. especi:z.Uy INs ~ compact~ thazl eollfl:if:t 'lrit.h feder21 fOYel"D.J:DC!lt fUDaions m m.z:XJz:r.al fon:sQ alld shi,WC.bt enfon:ed by both fede1'2l and. sw.e ci'ficitlt. 1~ 0p.. Ar:•y Ge=... ~a.. 10.. • I 1 • . ~ t ' . .. t f . ' I I I I I I' I I I I I I I I I I I .~ ~.~ ,. .. ~ ,_.. j J • ......... .. '! .,..,. 1 • • • •. \... , ~ ~ r--:""'\ .-..., ,.. ~~ r: ., , · ~.i :r..s;• · \ • • I 1 j ' \. . f' I .~. . ' " I\ I ti..,.·. . tii ~ : .~ ,_, •• ' • .. \ .. t :-1 t...... ~i\\.)1H ~tMl ... : \.. ~ ~ l.J '"-"' 1.1 '...11..1 u DIVISION OF RESEARCH &OEVELCPMENr March 5, 19 82 Eric Yould Executive Director Alaska Power Authority 334 West 5th Avenue Anchorage, Alaska 99501 Dear Mr. Yould:·. I ' ! ( . f JJ.Y .t HJJIIIDIID. &DYCINDI I Pouch 7-005 I ;~KA~995l0 t:tEcErv~ . ... ii;;Q ~AAJ? 9 2982 Alaska 0 s. ept ot M' Port Fish;s . iSh &. Gam • . . IJStfna HYdro e ln the past 18 months, the Susitna Hydroelectric Steering Committee (SHSC) has reviewed many aspects of the Susitna Hydroelectric Feasibility Plan of Study. We have been briefed by, and have consulted w:i.th many of the Acres American, Inc., contractors and subcontractors. On November 21, 1980, the Sl:iSC transmitted to A£A a comprehensive review of the entire !ask 7 {environmental and socio-economi.c) Plan of Study for .the proposed Susitna Hydroelectric Project. During the summer of l98i, most of the SHSC members participated in a. field trip to the proposed dam sites and to some of the field camps.where investigations were ongoing. As a result of these and other Susitna liydroelectrie related meetings and discussions, the members of the Steering Committee. are probably the best informed representatives of those agencies who will participate i.n the decision making and pe:nnitting process.. The SHSC members believe it is desirable to identify the most important issues prior to the issuance of the draft feasibility study for revie~ and comment. ~e hope this ~ill achieve three things: (1) provide a. basis for agr'eement between SHSC and the Alaska Power Authority on the status of important !ask 7 issues and concerns; (2) provide the vital information to those not vell informed so they can be al..'are when they revie-w the findings provided i._u~ the draft feasibility study; (3) where appropriate, to identify potential remedial actions to the .A:PA to m.i.nimize if not resolve the concerns that. are raised. !he process that the SRSC went through in creating this letter was to request all the SHSC members to compile a list of issues and concerns tha~ merited attention of the APA. This list was then drafted, re- viewed, and· approved by the SHSC members. The issues ~dentified below have been placed in two categories. The first entitled "Overall Study Approach" deals Yith those issues and concerns wh~ch transcend specific studies. These concerns are not entirely i.n the scope of the feasibility study contract or necessarily the sole responsibility of the PoYer Authority. However, the decisions the ~A and Legislature may make lo."ith respect to the Susitna project in the nex.t: 60 days could obviate these concerns.. The other category is entitled "Study Specific: Issues" and is self-explanatory. ., •• I I I •• I I I I I I I I I I I I II I ~· Eric.Yo~ld 2 Ma:z:ch 5, 1982 The. follo'Wi.ng are the overall study approach problems identified: OVERALL S!UDY APPROACH 1. Tne most urgent and most important issue is the relationship beeween the tim:ing of findings from studies conducted by Acres American 3.!lci i.ts subcontractors and ~hen th.e State of AJ.aska will decide whether to. build Susitna. The problem is that existing la~ may r~sult in a decision by the state as t,o whether the dams should be built before the socio- economic and environmental costs, impac,ts; and trade-offs are known • Although the MarCh l5, 1982, Susitna Hydroelectric. Feasibility Study may assist in determ~ng if the dams can be built in a narrow technical (engineering and constructability) sense, it cannot speak to significant public policy questions such as: a. is it i.n the best interests of Alaskans to use their money ·to .build the dams? b. lJhat are the ~nvi.ronmental and socio-economic impacts a.nQ trade-offs that have to be made if it is decided to build the dams? In de~er.mining answers to such questions, there are accepted methods .vhich should be rigorously applied. No one would consider building the Susitna dams without anwering all questions about soi.ls stability and earthquake hazards. The same level of assurep knowledge needs to be acquired to answer questions about environmental and socio-economic effects of the dams. This issue may be outside the scope of the Acres contract and the sole purview of the Power Authority. A combined effort of the Power Authority and the Governor 1 s Office may be needed to comprehensively frame the issue and devise methods to deal v~th them. 2. There appears to be a lack of necessary coordination between the various study taskso Unless extraordinary corrective efforts are made, it is unlikely that an integrated, relevant, and complete environmental assessment which i.s acceptable to state and federal agencies and to the Federal Energy Regulatory Commission (~ERC) ~ill be produced. This need ttras identified early by the SHSC. The November 21, 1980, review of the Plan of Study says: ,.Ihe Steering Committee members believe the most compelling need is for a well conceived process to i:mpro'!e the linkage and coordination of the various studies." As an example of this, I refer you to point number l below. The f.olloldng ar.e studies specific issues: SPECIFIC ISSUES 1. .A coherent. and coordinated Fish and Wildlife mitigat:ion policy and plan needs to be established itmDed.iately. It is oo:r understanding that, unlike the wildlife mitigation options, the fisheries .mitigation options .. I·' . I I I I I I I I I I I I I I I I I I .. E~ie.Yould 3 Match 5, 1982 4nd the overall Susj.tna Hydroelectric Proj eet: fish and wi.ldlife ~itiga ti.ou })Olir;.y have yet to produce an agreed upon product.. '!he. following issues st:tll require resolution: agreement on mitigation policy) agree- men~ on t:he roles definition of the A'PA, the agencies tdth fish and wildlife authority and expertise, the Federal En~rgy Regulatory Com- mission {FER.C), and those agencies ~th land and water management . authority. Until these issues have b.ee.n resolved, dete:mination tt£ the full costs and impacts of the proposed Susitna Hydroelectric project are. not possible. Failure to settle these i.ssues 'Will dramatically increase the probabi.l.ity of delay in action by the FERC, unnecessary confrontation between the APA and government managmnent and regulatory agencies and l~.tigation i.n the courts. Once resolution. of the i.den~:i.fied :i.ss.ues occ.~=s, the FERC application process may be the approp:~te forum to resolve speci.fic miti.ga~ion issues. 2. Tnere ~s a lack of information to describe the relationship bet~ean various stream flow levels and the productivity of fisheries and aquatic h~bitat do~stream from the proposed Devil Canyon Dam. Exhibit E of the FERC application for license requires quantification of the anticipated downstream ~pacts. 3. The fisheries studies have not been going on long enough to acquire the comprehensive data and knowledge needee to assess project impac'ts. '!'his, coupled t.r.i..th inadeguate instream flow .studies,. provides .. for a less-than-satisfactory answer to questions on the impact of the proposed hydroelectric. project on fishery populations. 4. Wlldlife studies and ~ildlife mitigation appear much further developed than the fisheries issues described above. However, there are issues yet to be resolved in the Wildlife area. l refer you to the February 16, 1982, letter from the Department of Fish and Game to Robert Mobn of KPA. It appears that additional ~ork is needed to.i.dentify realistic mitigation measures for lost Yildlife habitat and on relating wildlife use of an area to habitat the characteriStics. 5. Public review of the Phase I environmental reports and of most mitigation optio.ns discussion papers is now sc;.heduled to occur separately from t.he distribution and public review of the d.raft feasibility report .• 'We do understand that the decision to delay for 90 days the application for a license to FERC (assuming that that is the decision from the State of Alaska), the public and agencies ~ill be pro~ided the .opportunity to revie~ t.h~ detailed study results and data reports for a period of 60 days before final agency comments on the feasibility study are due. 6. The Fairbanks-to-Anchorage lntert.ie study and the Susitna feas.ibility study should be integrated. 'We suggest that t.he :intertie assessment be included in the Susitna feasibility study review package. 7. Tne decision on access to ::he dam sites and the policies surrounding their use after cons~ruction will be one of the mtlst significant impacts ., lq .-.. I I I I I I I I I I I I I ·I I I I !:. I -.~ . . , ,_t, ., .. - Eric Youlo 4 March S, 1982 of the project. l'hf! Yukou Rive.:r to P:rucihoe Bay Ha1.1l Road puilt in c:on- j unction wi.th the construction of the. tratLs-Alaskan oil pipeline is a compaz-able situation. There is no need to restate tbe comments made by the SHSC and their parent agencies to the .APA on this matter. }lowever·, it is appropriate to identify t'Wo of the major issues -w-ith respect to the access question. First, KPA 1 s need to begin construction of a pioneer road p::ior to FERC licensing of the. dams. raises some serious public policy issues. Second, the decision as to the 1Dode of access (rail versus conventional road) may well be the detertnining factor for the extent and type of public access once constructicm is completed. 8. !he socio-economic implications of the avail~bility of 1600 megawatts of electrical power in the railbelt :region of Al.aska need to be ·fully described and discussed in a public forum. lt would appear that this amount of electrical energy could result in indus~rialization and socio- ec:.onomic impacts on the same order o.f. magnitude as v:rould petrochemical dev2lopment. Because the State of Alaska is sponsoring thi~ hydroelectric proposal, it is incumbent upon the state to provide and present in a public forum, information regarding the end use of the power and advan~ tages and disadvantages of the socio-economic impacts of this eud u$e. The SHSC recommends consideration of an approach similar to that ~ich was done for the Dow-Shell petrochemical proposal: The SHSC lori.ll be advising their respective parent agencies of the c.ont~ts of t.his let'ter in order t.o insure that formal a.gency comments to the proposed Susitna feasibilit:y study fully address the issues and concerns detailed above. In order to alleviate the problems identified above, the SHSC recommends the following: (l) The APA should take an interdisciplinary interagency approach in identifying ~ays to improve coordination of the environmental and socio-economic studies to insure that the scope of and the methodology used j,n the studies are acceptable and germane. This approach should be funded and staffed appropriately and should have the :responsibility, au.~ho:rity and independence to ac.c:.omplisb this objective. (2) T"ne draft instream flow study plan should be updated and made public to provide .opportunity for agencies and other groups to pa~ticipate in the development of the necessary instream flow studies. (3) Comprehensively eyaluate a~l potential and sec.ondary impacts to f . .ish and. wildlife both above and belo~ the Devil~ Canyon and Watana Dam sites. (4) Provide public participation oppor- tunities t.o: inform the public of the feasibility st.1.1dy and the st:>cio- ec.onomic impacts of this p:roj ec.t and to provide an oppor;unity for t:he public to give comments and advice to the Power Authority Board of Directors before the state. determines ~ha~ course of action it should take on this project. Because of. the nature of some of these suggestions as lorell as the e>ttent of discussion we anticipate will be r.equi:red before K2A. and its .. l ' I I I I I I I I I I I I I I I •• I Eric "iould 5 cont:rar;:tors fully comprehend our concerns • the SHSC is prepared to meet with you; your staff ana eont:ract.ors whenever you wish. Sincerely, Al Carson, Chairman Susitna Hydroelectric Steering Committee cc: SHSC Hembers Charles Co~way, Chairman, APA Ernest Mueller~ Commissioner, Dept of Envirotmlental Conservation Ronald Skoog, Commissioner, Dept of 1:-ish & Game John Kacz, .Commissioner, Dept of Natural Resources Lee 1'1cAnerney, Commissioner, Dept of Community & Regional Affairs Curt.is Mc.Vee, State Director, Bureau o.f Land ~~nagement Robert NcVey, Regional Director, National Marine Fisheries Keith M. Schreiner, Regional Director, US Fish & Wildlife Service Reed Stoops, Director, Division of Research & Development S. Leopold Quen~in Edson, FERC .. I I I I I I I I I I I I I I I I I I I Testimony presented to theAlas~ Powex Authority Board.by Deputy Regional .Director LeRoy Sowl, U.S. Fish and llUd~ife' .Service, on Apr.il 16. 1982. concerning the Susitna Hydroelectric. Project. T'ne mission of the U.S. Fish and 'Wildlife Service is to: Provide the federal leadership to conserve, protect, and enhance fish and wildlife and their habitat for the continuing benefit of people. ALASKA POWEf't AUTHORITY SUSlTNA FJLE P5700 -~ JJ. ?/ " SEQUENCE NO. ,.,., '-"'\. , •" ,~ :,_.---1~~ }-· ~~ I . I : ... ci l % ~ ~·: ...I o·~-:.:::. cr -0: .... . i:: u! ~.L. " r./') ' I z <i:! 3 I ! - ~·-··"""-"~--· l .., .. ·" v· : . .. _,_ ···--· I /1 . ~ t ... • -··--I .~ ;.. ., • -. You might ask, ther~fore, why is the Fish and Wildlife Service concern- ing itself with a State energy project? ~·~~ ... -... -1 .. ~-ltd I .. ~<wt~~·r-; ., ~-r ··-. . . The Susitna Hydro Project must be licensed by FERC bef~re construction • J -• 11 ~-.. " begins. The Fish and Wildlife Coordination Act requires that --;·lP-iD-=11 fish and wildlife conservation be given equal consideration with other features of a proposal throughout the planning and decision processes. FERC is further required to consult with state and federal fish and wildlife resource agencies to determine whether there will be project related losses of fish and wildlife resources. E ..=::. J_ w. :.:..j ,--~ENS. ~---j--\ .. -I SNT . --1---_:_:_t -#~---I ! L: ,n i r--l t M c~ V I :-!--·-~ t.• R r 1 "''t. w ~1 f-~/;1 .. l( I 'I"Jlt··~ -----.•""' '--' The Coordination Act and Section 102(2)(3) of the National Environmenta Poli~y Act both require: ~ ~ 1::12 -r-" I t!A.s:... •• - (l) A description and quanti.fication of the existing fish and ~ildlife and their habitat ~ithin the area of project impacts .;~ 1i'.~ ... , ... ,, ".,-~ (2) A desc.rip.tion and quantification of anticipated project impacts on these resources; and . , (3) Delineation of specific mitigation necessary to avoid, minilnize, or compensate for these impacts. The Fish and ~ildlife Service has reviewed the draft feasibility report with respect to its area of expertise. Deficiencies are readily apparent with respect to all three requir~ents. There has been a failure to quantify the habitat types present, anticipate the impacts or to identify required mitigation.. All of these deficiencies are directly realted to the unrealistic time constraints placed on data collection. Some of the specific deficiencies we have noted are, as follows: (1) Terrestrial studies have focused on the impoundments and their immediate vicinities. The assessment· of wildlife and fishery resources must be extended to downstream areas, transmission ,I.\' "'1-l..tl·} ? Ct. t .. '·· _.... J ~FILE and access corridors~ and areas of secondary or indirect impacts. RECEIVED APR 19 1982 '· ·., --· •• I I I I I I I I I I I I I I I I I I '· ., ~ .... -__ _._....... .. _....., ____ _ __,,........... ____ ..,.. _____ ., ·--~·-~-.. -·......; (3) (4) {5) (6) (7) {8) l'he terrestrial studie$ have been qualitative. Qu.Blltification, through ~n acceptable methodology~ is ess~eial to the ev&luation of habitatvalues. the probable impacts and the .-election of appropriate mitigation.. MA bas stated its objeetive .as ''no net 1oss.u Without methodology to quantify either losses or mitigation there is no way to assess when this goal bas been achieved. Fisheries studies have been conducted for only one year. A study of this scope is sufficient only for a preliminary evaluation of the impa~ts and to provide for refinement and focusing of longer term studies. One year is not enough time to provide the data necessary to fully describe the resource. Any attempt to assess ±mpacts or plan mitigation within the context of the license application would be inadequate. There are inadequate data to describe the relationship between various stream flows and the productivity of fisheries and aquatic habitat downstream from the proposed Devil Canyon Dam. A fully thought-out instream flow study would prqvide the quantification necessary far any impacts evaluation and mitigation planning. Without this information any evaluation of project impact on fishery resource is missing an essential component, and effective mitigation planning is seriously hampered. Anticipated water temperatures and turbidity levels in the reservoirs and do*~stream from Dev~l Canyon have not been satisfactorily investigated. An adverse temperature regime has severe implications for the fisheries; downstream from Devil Canyon as well as any potential fishery in the rese'i:'Vv:irs., The terrestrial ±=pacts assessment and mitigation options put forth by the consultants are quite general, not sufficiently thought through, and p~ovide an inadequate basis for a full discussion of the project. This is directly related to the lack of an acceptable methodology fcJr quantificat .. ion. Public access and the mode and route of construction access .need to be fully addressed ~ithin the context of mitigation. The environmental consultants have recognized that public access poses the greatest threat to the terrestrial resources, principally through disturbance. It is completely incongruous given this assessment and APA' s goal of "no net loss'' that the consultant should attempt to divorce aceess from consideration of mitigation as they have done. A pioneer road cons.tructed prior to FERC licensing, is p:ro~osed. The sole purpose of this road is to facilitate project coK&struction. We do not expect FERC approval for this proposal. FERC cannot ~"-... .,. I I I I I I I I I I •• I I I I I I I I ______ , _______ _ -3- give i._ts approv-.1 'Without an environmental imp~ct statement. In addit-ion, habitat losses. sustain~ must be justified by the need f.or a proj ec.t. The need is proven when, in the case of a po\{er £acUity~ the .license is; issued. Prior to that point, there is no project and there i.s no habitat degradation that ean be justified. We believe that .alternatives to Susi.tna must also contint'e to be stud.ied. Compar:i.son of tradeoffs for fish and wildlife resources attendent to the North Slope natural gas~ Cook Inlet natural gas, Beluga cc.,al, other hydroelectric generating alternatives,o conservation, and other options have not been evaluated to an accep.table level. Continued studies woul.d allow for a full evaluation of the environmental costs. The APA proposes to submit a licence application to FERC on September 30, 1982. The application will be based on the feasibi~ity report. Given thE~ numerous deficiences I have just noted a submission on the .proposed date would be premature. The Fish and Wildlife Service has had minimal involvement with the Susitna project during the last 2 and 1/2 years. We believe we have considerable expertise to offer APA in developing an adequate license application :for submission to FERC. One particular area. in which we believe we could add substantially to the study is in quantifying the fi.sh and wildlife data for evaluating impacts amd formulating mitigation plans. The Service's Habitat Evaluation Procedures would provide a framework -~thin which habitat value can be evaluat~l. This methodology was used in both the Terror Lake and the Bradley l.ake Hydroelectric Projects. Our Incremental Instream Flo-w Methodology allows for the quantification of the anticipated .impacts of proposed flow regimes on aquatic habitat. Modifi'cation would·need to occur to this methodology but we fully believe that i.t provides the groundwork upon which to build. It was utilized in the Terror Lake Project 1:o evaluate impacts and formulate mitigation measures to protect the f ishE~ries resources. The Board should realize that the very decision to file the application with FERC would automatically change the relationship between APA, its consultants, and the Fish and Wildlife Service. With. the decision to file, our attention must immediately focus on the licensing process. l~e no longe1: would have sufficient time and manpower to assist and provide expertise to APA and its consultants. We would expect that other federal agencies would be similarly affected. 'We recommend that the d.ecision whether or not to submit an application to FERC should be deferred until data gathered this year has been evaluated. \1e must. have a better understanding of the fishery-habitat relation,e~hips; a more thorough understanding of the relationship of ·the aquatic l~bitat to flows and temperatures; an understanding of what the t.errestr:jLal tradeoffs are; and a greater comprehension of the reservoirs' temperature and turbidity regimes. I •• I I I I I I I I I I I I I I I I ~---~------, _ _, __ --· ...._,__...,....,. -,--~-~ ---._o;-.. -4- 'We greatly appreciate the opportunity to present this te;;timony and look forward to a continued working relationship. "Ci:'·'~ I I I I I I I I I I I -I UNITSD STATES GOVSRNMENT · · memorandum TO: Hedy Ahluwalia (LW) Tammy Jameson (BSP) FROM: Linda Kelso (ARD-E) SUBJECT: Training U. S. FISH AND WILDLIFE SERVICE 101'1 E. TUDOR AD. ANCHORAGE. Ai.ASKA 99503 (90?) 276-3800 DATE: l 5. APR 1982 . Please check with your immediate supervisors as to who may need warrant training or if they feel there may be a need for any other type of traini.tlg (personnel actions, timecards, procurement regulations, travel regulations, etc.). Please let me know by May 3, 1982 so that we can check into it. Note: This is the type of training that the field people attended last month. • Thank you. R7-3 I I I I I ·~--- 1 I AI..ASKA POWER AUTHORITY SUSITNA F.JLE ?5700 UNITED ~TATES DEPARTMENT OF COMMERCE Netianaf Oceanic and Atmosphel"ic Administration Na.tiona~ frkutine Fishe'/'ieS: S~roice P.O. Bc:D 1668 Junern.;.., Ataska ~99802 s~roa ALASKA. mm:R AUTHOR:r'i~£ :BClAm> OF Dimx::IORS RECEIVED APR 19 1982 :.~ Anchorage, Alaska April 16, 1982 ACRES AttltHi~AN lfi&ORPDRATED by K>BF..Rr w. M:.VEY RFGIONAL DIRe:'IOR NATIONAL MARINE FISHERIES SERVICE Juneau, Alaska 11 The National Marine Fisheries Service (NMFS) , within the Depart::nent of camerce, has Federal responsibility for marine, estuarine, and anadrcrn:::lus fisheries. Several laws, i."lcluding the Fish and Wildlife Coordination Act, require our agency to assess the jmpa.ct of water resource developtents on fishery resources.· Regulations of the Federal Energy Regulatory Ccmnission (FERC) specifically require applicants for license of a major hydroelectric project to consult with NMFS and respond to those concerns or recamendations our agency feels are necessary to protect fishery resources. Our responsibilities for anadrcmous fishery resources have resulted in the developtent of considerable NMFS expertise in addressing the potential ~cts of hydroelectric facilities on the sa1non resources of the northwestern u.S. • The NMFS and its predecessor agency, the Bureau of Comrercial fisheries, has been actively involved in efforts to study and. preserve sa.lrron runs to the ColUl't'bia River basin over three decades. i-aule the cm:rent scope of our involvenent with hydropc:Mer developne.nt in. Alaska is considerably less than in the northwest states, we ~ to draw tl;pon our agency's overall expertise and involve:rent \tr.i th sucl! develop1'ents during our review of the Susitna dam prcposal. We recognize the requirerrent placed upon the· Alaska Power Authority (APA) to sul:mit recamendations to the Governor and the legislature on a future course of action regarding the SUsitna project. Accordingly, we appreciate the need for APA to have resource agencies • opinions available for consideration at this tine. We feel, ho;.1ever that it is prerrature for NlwlFS to give a definitive evaluation on the acceptabili~,. of the project with respect to energy benefits versus fish losses. It is nore appropriate therefore, that we describe our basic exfeC1:ations with the coordination process ai"..d our general environmental concerns. ____________ .....__ ___ .........,~---------------..;......,.....· •· ... \ ' . I ·- I I I ·I I I I I I I I I I I I I I 2 First, I. would like to enphasize the need for a canprehensive t'U"lderstanding of the importance of fishery resou:cces within the project area. The Susitna River. drainage is an ext:rem=ly pr~~ve system with an annual salnon run prcducing a large percentage of the carmercial Cook: Inlet catch. These fish are very inportant to ooth the coruercial fishing industl:y and the sport fishing sector. Salm::m and several resident species such as rainb::M trout, Dolly Va.J:den and grayling are sot1ght by sport fisherrcen. The fish of the Susi't::na River .also contribute to the ecosystem of the area by provicling fCxxl to other fish, birds, and wildlifeo Here in Alaska our fisherie~s represent part of a lifestyle which, wh:Lte difficult to describe a"ld irr;ossible to place value on, is no less real. The two-dam proposal will in"pact these fisheries. While not all of those fish utilizing the system will be directly impacted, we are concerned about any loss of fisheries resources. Only with an in-depth understanding of the fish and anticipated jnpaots, can we fully weigh the costs associated with hydro developrent, and perhaps, find ways to acccmn:x1ate both. It is .iirportant, therefore that fisheries research and studies not only identify the species of fiSh occupying the Susi tna drainage and describe their ecological chara~&..£:ristics and needs, but also identify areas of in;;act and mea.Sl.'l.re to avoid or mitigate those impacts. The necessity of obtaining eooprehe:nsi ve enviroim1::ntal data is also recognized by the FERC in their requirerre."lt that :such information be specific, accurate, and sufficiently quantified to convey a precise picture of the project and its probable effects. This leads us to my second point in which I would like to discuss several aspects of the Susitna dam project that are of concem to our gency. The Susitna Hydroelectric Project Feasibility Rep:trt has been prepared to assist decision makers by describing the econarci.c, social and environmental concerns associated with tl"le project. In this regard the document perfonns well. However, the Feasibility Report is also · intended to provide the basis for application for license to the FERC. Tlle regulations of the FEOC are clear in describing the ~rtance of including adequate envi.rormental data in the license application. Further, they require this infonration to be provided on a level ccrmensurate with the scOPe of the project._ At this tine we do not feel this level of detail has been reached. Without the results of " --~ .. 1: -· I I I 1--- I I •• I I I I " I I I I I I 3 additional study in several areas, various aspects of the proposal will be poorly described or understoo:i. These deficiencies do not jnply that the Feasil;>ility Report was inp~-rly prepa.ted or presented.. Rather, they reflect on the limited information available _as of this date. •" One area of l:United information i:n the Feasibility Rep:>rt deals with the effects of post project flCMs on the fisheries-resources.. The Feasibility Beport discusses the ~rtance of side channels and sloughs between Talkeetna and Devil canyon. These areas are heavily utilized by spawning and rearing salm::m. The inpact of project .flows to these areas will deteJ:mine , to a l.a.rge extent, the fishery inpact attril:mted to the project. These sloughs therefore represent an. area requirin; consideration of potential mitigation and/or enhancement nea.sures. To date, less than one eighth of the side channel and slough areas have been sw:veyed. Further, the .impacts of various flCM reg2nes on the habitat .are unknown .because the hydrological and ecological relationships between the trainstem SUsitna and these areas have not been ad...~tely studied. -An in-depth study of projected flcm regines is needed. The results of a ccxrprehensi ve In-Stream Flov.; St.uqy would allow a balancing of fish habitat losses against _}::OWer generation, and other mitigation possibilities that could be evaluated • Terrpe.rature changes within the Susitna River are expected to result fran construction and operation of the dams. These changes could present both positive and negative changes to fish P=',PUlations. The APA has used a carputer mx1el to predict and describe these changes. Currently, we do not believe a high level of confidence exists in. the projected post project t~ature within the two reservoirs, the SUsitna mainstem, and the side channels and sloughs. Thel:mal changes xray present significant problems to sa.lnon, and additional study will be necessa:cy before possible J.n;acts can be adequately defined. The ·Feas:iliility Report states the objective of the Susitna mitigation effort is to achieve no net loss.. To achieve this goal, spec.ific studies must occur which will develop mitigation options identifiai in the Feasibility Report.. We do not believe that a mitigation plan can ba developed, based Ul:XID available infoi."IIation,~which would satisfy the reguirercents of the FERC. Basic to any mitigation plan is a carprehensive understanding of the resource and the potential iltpact the project will present to the resource. Again, we do not believe this level of understanding has been reached. The FERC regulations concerning license· application require a report that describes the fish, wildlife, and botanical resources. Infonnation in this report is to include tetn};:Oral and spatical distributions of certain fish species. As sate salm:m within the Susitna River have ljfe cycles of five or nore yea:rs, it would seem reasonable to allcM at least I I I I I ·I--- I I I •• I I I 'I I 4 this long .for fishery studies. To date, t:he fisheries studies specific to the APA prop:>sal. have occurred for only one fielri season. It.~ not reasonable to asSl.ltte that such an abbreviated sanpling is adequate for proper characterization of resources. For exanple, pink salm:>n exhibit a two year cycle with even year runs being m.1Ch st.ronger than the odd years runs in Upper Cook Ir..let.. At this tine,. we have no information on the size of even year pink sa.J.Iron runs to the uppel: Susitna or the areas of the River in which these fish spa'WI'l. We feel it is unreasonable to discuss mitigation detajls before adequate knowledge of the fishery resources exists. The Pcwer Authority has been infonred of these concems and data gaps, and of the steps necessary to correct them. OUr agency has previously stated that the e.nvirormenta.l data available fran Phase I studies will not 5UppC)rt an adequate evaluation of project ¥rPact. We continue to r~cmnend that the anticipated date for sul:rnitting the license application be delayed to allCM additional data collection. · It is our m1derstanding that the draft license application for the Susitna project will soon be available for review'. We are concerned tl't..at the application w.W.l .reflect the serious deficiencies we have mentioned.. If our review shoos this to be the case, we feel our agency will have no altemative but to request the FERC to reject the application or direct that the deficiencies be corrected. We very mJch desire to avoid this situation . Finally, I 'WOuld like to close rn,y statenent with a loo.1c, t..owards the future and a word of encouragercent. The undertaking of an environmental study for a project such a.S SU.Sitna is an enor.nous task. Accordingly, the Paver Authority has initiated a very cacprehensive series of studies which when completed will provide us with a better understanding of the full range of project related effects. Indeed, it may be p:>ssible to construct and operate the dams in such a way as to achieve the Authority • s no net loss goal by mitigating fishery inpacts, ~/or ,by enhancing fishery habitat in certain areas. · I knCM the Board of Dirctors appreciates the importance of our fisheris. I hop; I have conveyed to you the benefits of detailed studies to obtain essential information. In foJ:Imllating its recomrendations to the legislature, I sincerely encourage the Board to consider the critical · need for this information and the implications of proceeding in its absence.