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HomeMy WebLinkAboutAPA2902ALASKA POWER AUTHORITY - 334 WEST 5th AVENUE·ANCHORAGE,ALASKA 99501 SUSITNA HYDROELECTRIC PROJECT FERC No.7114 ALASKA Phone:(907)2n·7641 (907)276-0001 ~Ltl\ I","'I [I r'\}nv,(;1--."tUI..- ..... ..... Comments Submitted by Resource Agencies, Intervenors and the General Public on the Draft Environmental Impact Statement prepared by Office of Electric Power Regulation Federal Energy Regulatory Commission May 1984 - ARLIS Alaska Resources Library &Infonnation Servlces Anchorage,Ala~ka 5362/259 D3 -------------, ...... 1.Introduction: The Susitna Hydroelectric Project License Application was originally filed by the Alaska Power Authority (Power Authority)in February 1983.After the Federal Energy Regulatory Commission (FERC)issued a II non conforming ll letter,a revised license application was submitted to the FERC on July 11,1983.This was accepted by FERC on July 29, 1983.Subsequent to the FERC acceptance,comments on the application were fi 1ed by federal and state agencies with resource management responsibilities.The Power Authority responded to these comments in filings made January 19,1984,and February 15,1984.The FERC issued its Draft Environmental Impact Statement (DElS)on May 17, 1984,which recommended a mixed hydro/thermal generation scenario in lieu of the Susitna Project.The Power Authority responded to the DEIS in comments filed on August 23,1984. - Federal and state resource agencies,intervenors and the general public also submitted comments to FERC on their DEIS.Contained herein are copies of the comments submitted to the FERC as of September 4,1984.The following comments were received: Federal Agencies 1.Bruce Blanchard,Director Environmental Project Review U.S.Department of Interior September 4,1984 2.Robert W.McVey,Director Alaska Region National Marine Fisheries Service National Oceanic and Atmospheric Administration U.S.Department of Commerce July 3,1984 3.Richard D.Hull,Director of Lands U.S.Department of Agriculture June 20,1984 4.D.E.Olson,Chief Planning Division North Pacific Division Corps of Engineers Department of the Army July 25,1984 5362/2!59/D3/Fl-----,--------,---------------------------- 5.Robert J.Cross,Administrator Alaska Power Administration Department of Energy July 6,1984 6.Ernesta B.Barnes,Regional Administrator Region X U.S.Environmental Protection Agency July 31,1984 7•Thomas F.King,Director Office of Cultural Resource Reservation Advisory Council on Historic Preservation - ..... - - - August 29,1984 State Agencies 8.Robert L.Grogan,Assistant Director. Division of Governmental Coordination Office of Management and Budget Office of the Governor State of Alaska September 4,1984 The OMB letter represented a synthesis of two letters submitted to OMB . 8A.Carl M.Yanagawa,Regional Supervisor Habitat Division Department of Fish and Game August 13,1984 8B.Esther C.Wunnicke,Commissioner Department of Natural Resources August 8,1984 The ADF&G and DNR letters were not submitted to FERC. 5362/259/D3/Fl ,'~ - '""" ..... 9.David W.Hangen,Deputy Commissioner Central Region Department of Transportation and Public Facilities July 23,1984 The DOTPF letter was not submitted to FERC. Local Government 10.Gary C.Tucker,Attorney for Anchorage Municipal Light and Power Municipality of Anchorage August 15,1984 Individuals and Organizations 11.Paul Bratton,for Alaska Survival Box 343,Talkeetna August 14,1984 12.~1atthey Zencey,Energy Di rector Rural Alaska Community Action Program,Inc. and Jeff Weltzin,Chair Alaska Regional Energy Association August 22,1984 13.Ann M.Sugrue Alaska Consumer Advocacy Program August 22,1984 14.Roberta Sheldon, Talkeetna,Alaska 15. 16. August 20,1984 Becky Long Talkeetna,Alaska August 6,1984 Denis Ransur (?) Talkeetna,Alaska August 13,1984 5362/259/D3/Fl ..... 17.Jeff Weltzin Fairbanks,Alaska August 24,1984 (?) Containing several ADF&G memoranda. - '""" - 18.R.B.Stiles Coal Operators and Alaska Leaseholders July 5,1984 5362/259/D3/Fl FEDERAL AGENCIES- II.Synopsis of Comments on FERC·s Draft Environmental Impact Statement (DEIS) P"'" ..- .... Department of the Army,Corps of Engineers (07-25-84) Their review indicated that the treatment of the impacts of ~he proposed action on wetlands in the project area was too broad and general for an adequate impact assessment.They had no comments on other areas of responsibility,including flood control,navigation and hydropower. Department of Energy,Alaska Power Administration (07-06-84) Their comments focussed on three areas:load forecasts,fuel price assumptions,and other hydroelectric alternatives.They stated that forecast models have consistently underestimated short-term growth and suggested that FERC accept the Authority's submitted forecasts and examine the risk that the forecasts may be too low. They also suggested that FERC accept the Authority1s economic assumptions,which are consistent with the National Energy Policy Plan,rather than their current assumptions which fall well below the Tow range assumptions of the plan.In terms of other hydro- electric alternatives,the Department of Energy {DOE}recommended that four of the five sites suggested by FERC,Johnson,Browne, Keetna,and Snow not receive further consideration in light of underestimation of total costs by at least $1.0 billion,technical difficulties,and serious environmental problems which substantially exceed those associated with full development of the Susitna hydro resources.Available data regarding the fifth site,Chakachamna, supported the finding that Chakachamna is not more attractive than Susitna . The DOE concluded that over the long run,the Susitna project has acceptable environmental costs and will be of great and lasting benefit to the people of Alaska. Department of the Interior (08-29-84) The DOlls assessment concluded that the impact analysis as pre- sented in the DEIS in support of FERC staff's recommended hydro- thermal alternative was inadequate for an overall comparison of environmental impacts or mitigation plans to the proposed project; however,they further stated that FERC staff1s recommended alter- native would be significantly more damaging to fish and wildlife resources than the proposed project.In addition,they stated that information regarding eagle nests subject to disturbance from the proposed project should be clarified and that the taking of bald eagles or their nests may be permitted under eagle permit regula- tions (reference Bald Eagle Protection Act including recent amendment). 5362/259/03/F1 -------_.--------_.=-.~------~-------------~-------------- They recommend development"and incorporation of a specific and acceptable mitigation plan prior to license issuance,and that if hydroelectric development is authorized in the Susitna Basin,that it be licensed and constructed in stages.In an effort to provide a clear understanding on which to base decisions regarding the project,the DOl recommended that the EIS be augmented to adequat- ely and quantitatively address the impacts of both the proposed project and FERC staff'srecommended hydro-thermal alternative. National Marine Fisheries Service,Alaska Region (07-03-84) Concern was expressed that the DEIS is deficient in that sufficient information was not provided to allow project-related fishery impacts to be identified and mitigated and that it failed to satisfy NEPA guidelines.Further,they suggested that the FERC prepare either a second DEIS or a supplement. United States Environmental Protection Agency (07-23-84) Their assessment concluded that the DEIS provides a very unbalan- ced,superficial analysis of alternative systems,while providing a relatively thorough evaluation of the impacts of the Susitna project.They delineated impacts related to the Susitna project as well as to the ~lternatives,which were not adequately addressed, and stated that the economic analysis requires substantial re- working in order to provide an objective comparison of the alterna- tives.They determined that the DEIS was inadequate due to data gaps and lack of detail,and that the recommendation as set forth in the DE IS was essentially unsupported in light of the absence of appropriate data and analysis.This led them to recommend that FERC prepare a revised DEIS. United States Department of Agriculture (06-26-84) This agency felt that the DElS presented a comprehensive analysis of the effects of the construction and operation of the proposed Susitna Hydroelectric Project.The Director,Basin and Area Planning Division,had no objection to the plan,stating that it would have little impact on agricultural activity;however,the National Environmental Coordinator cautioned that any significant environmental effects be mitigated to the extent possible if the decision was made to proceed. STATE AGENCIES Department of Fish and Game (received 08-13-84) Based on their review,it was concluded that the DEIS does not contain sufficient fish and wildlife data on which to base project decisions.Major areas were identified as requiring more thorough consideration on which to base an adequate assessment of the 5362/259/D3/Fl - project's environmental impacts.The issue identified by ADF&G as being the most significant for inclusion in the EIS was an analysis of impact issues,subsequent identification of significant impacts, and a recommended plan to mitigate these impacts. They concluded that the information contained in the DEIS did not reflect the level of information available regarding the project, nor clearly identify mechanisms which would serve to incorporate information arising from ongoing studies and other sources into the impact assessment to mitigation planning process.They strongly recommended that the EIS be modified to accommodate identified concerns,such that it might serve as a useful document in making decisions on project feasibility. Department of Natural Resources (08-08-84) This agency concluded that,in general,the OEIS did not provide sufficient information on which to allow them to properly assess the project's potential impacts upon area resources.The request was made for additional information on which to base a meaningful project analysis.Issues which were not adequately addressed in the OEIS dealt with processing of DNR project applications,includ- ing the application to construct or modify a dam.It was further stated that these areas must be adequately answered in the FEIS in order for DNR to perform its adjudicative functions without disrup- tive delays. Department of Transportation and Public Facilities (07-23-84) Their preliminary assessment concluded that impacts stemming from the potential development of the Browne and Johnson sites would have to be addressed by their agency;however,the Keetna,Snow, Chakachamna,and Susitna sites did not appear to directly impact any of their facilities significantly. OTHER PART!ES Coal Operators and Alaska Leaseholders (C.O.A.L.)(07-05-84) This organization felt that the analysis was thorough and objec- tive.They stated that their analysis supported the conclusion as presented in the DEIS,that a mixed thermal-based generation scenario,supplemented with selected non-Susitna Basin hydropower facilities,would be the most effective approach to meeting the projected generation requirement of the Railbelt area. 5362/259jD3/Fl .... ""'" S'os ITfVA United States Department of the Interior OFFICE OF THE SECRETARY WASHINGTON,D.C.20240 AUG "l9 '984 ER 84/710 Honorabl~:l Kenneth F.Plumb,Secretary Federal Energy Regulatory Commission 825 North Capitol Street,N.E. Washi~teJn,D.C.20426 Dear Mr.Plumb: - - - The Depurtment of the Interior has completed its review of the draft environmental statement for the Susitna Project (FERC No.7114),MataJ1l~a-Susitna Division,Alaska. We have the fonowing comments and recommendations.Page specific detailed com- ments an~included as an enclosure to this letter. The FERC Staff's recommended alternative for energy development differs considerably from the applicant's proposed project.Although the FERC's recommended alternative of fossil fuel genera tion and selected hydropower development may be supportable,the im- pacts arull1ysis in the DEIS is inadequate for comparison to the applicant's proposal.From the document it appears that FERC Staff's recommended alternative would be signifi- cantly more damaging to fish and wildlife resources than the applicant's proposed proj- ect.It has been ackmwledged that fairly detailed site information is available for only one of the five hydroelectric sites favored by the Staff and that information on the other four sites is ''limited primarily to non-specific inventory data and resource maps"(p.2-41, par.1).Such data do not awear adequate as a basis fer an overall evaluation of the environmental impacts of the two alternative projects. The grea,test need fer additional information awears to be for the four hydroelectric ~rojecU:i requiring dam construction under the "hydro-thermal"alternative.Foundation conditions have not been adequately described ftl"any of those four sites.Geologic conditions of the reservoir areas have not been described in sufficient detail to permit even a rough estimate of the potential environmental impacts.Permafrost conditions and related impacts are mentioned in a highly generalized way for two of the four hydroele:!tric projects that would require new dams and reservoirs,but for all three sites that probably contain permafrost {Browne,Johns:m,and Keetna sites)there is a need for further information on any potential impacts resulting from degradation of permafrost. The larg,e extent of land area required by the ''hydro-thermal"altemative is of concern, since it would result in inundation of 102,000 acres (p.4-86,sec.4.5J.2)and would require t.he dedication of over 115,000 acres for project purposes (p.4-100,sec.4.92).By comparislOn,the proposed Susitna Project would inundate about 46,000 acres and require either inunda tion Cl"clearing of about 56,000 acres.' We find the DEIS inadequate in other impact analyses als:>o It does not contain a specific mitigaticm plan fer either the FERC Staff's <r the applicant's alternative.These defi- ciencies preclude identification or development of "all practicable means to avoid or ---,,-------------- ..- Honorable Kenneth F.Plumb 2 -. minimize,environmental harm from the alternative selected•••"[40 CFR,l505.2(c).As a consequence,we believe the EIS should be augmented,with opportunity for public review,&>that all relevant and reasonable mitigation measures are identified (even if they are outside the jurisdiction of the lead agency or cooperating agencies).This is essential if the FERC is to have the best possible information on which to base its decisions regarding the project. Inasmuch as the applicant is continuing to pursue the project as proposed,we are contin- ui~to work with it.Parallel deficiencies in the license application,in consideration of the magnitude of the proposed project,were the basis upon which we obtained intervenor .status in this proceeding.In the absence of a specific and acceptable mitigation plan,we would not suppcrt licensing of the project until such a plan has been developed and incorport:Lted as part of the project.Should the project be licensed without a satisfactory mitigation plan,we would recommend appropriate stipulations for incorporation into any Section 10 and Section 404 permits that may be issued by the U.S.Army Corps of Engineer:s. The DElS does not address the impacts of the project on the Denali National Scenic High- way des~~nation as proposed in ANILCA,Section l311 Although a negative recommenda- tion for designation has been forwarded to CongreSa.'S,the study corridor remains under a valid withdra wal pending Congressional action and the project's effects upon that with- dra wal should be discussed in the final ElS.In addition,any crossings of other public lands or native allotments would have to be approved by the Sta.te Director,Bureau of Land Management and the Area Director,Bureau of Indian affairs,respectively. The DElS,in our opinion,does not fully comply with the Council on Environmental Quality's regulations for implementing the National Environmental Policy Act,and, unless it is significantly strengthened to discuss adequately the impacts of both the proposed action and FERC Staff's recommended alternative,including available data on fish and wildlife resources and a properly considered mitigation plan,we will consider referring'it to the Council on Environmental Quality under 40 CPR 1504.As always,we would prefer to continue Working with the FERC to resolve the issues we have raised here.Fc)r continuing coordination on this project,please contact the Field Supervisor, Western Alaska Ecological Services Field Office,U.S.Fish and Wildlife Service,605 West 4th Avenue,Anchorage,Alaska 99501 (907 271-4575)and the State Director,Bureau of Land Management,701 C Street,Box 13,Anchorage,Alaska 99513. Sincerely, Erx:losure ,....cc:Mr.Fred E.Springer Alaska Power Authcrity .... .... Comments of the Department of the Interior on the Draft Environmental Impact Statement for the Sus i tna Project,FERC #7114, Matanuska-Susitna Division,Alaska (ER 84/710) GENERAL COMMENTS The draft statement lacks needed information and is deficient on many points essenti 411 to a clear understanding of the environmental impacts that would result from the project.More specifically,the statement lacks a quantitative basis fl)r many of its conclusions.Descriptions of existing resources,poten- tial impacts,and mitigation opportunities are frequently only Qualitative. It is d'ifficult to compare alternatives on the basis of the information provided.Although quantified information may not be readily available,we believe the discussions of alternatives could be better supported.Quantified information in the license application provided by commenters could be used to substantially improve discussions on baseline resources,impacts,and mit i gat 'ion • Another major deficiency is the lack of a coherent,specific mitigation plan. The statement should contai n a mit i gati on pl an endorsed by the Federal Energy Regulat()ry Commission (FERC)Staff which is specific and contains assurances that it would be implemented.The mitigation plan should be composed of those element!:;proposed by the applicant,by agencies and by other commenters on the license application and the draft statement,as well as those measures that the FERC Staff has independently formulated.The Department of the Interior (001), through its comments on the application,proposed a number of specific mitiga- tion mei!SUreS that should be incorporated into the mitigation plan.The state- ment shlJuld include recommended mitigation measures,or state why specific .me asures recommended by others are not cons i dered appropri ate. We belil:!ve that if hydroelectric development is authorized in the Susitna Basin,it should be licensed and constructed in stages. SPECIFIC COMMENTS Main Text Page 1-:33,paragraph 6:Attention should be given to the Mt.Spurr geothermal site.This site was the first geothermal lease sale made by the Alaska Department of Natural Resources (AONR).Although the interest level (as ref'lected by the bids offered)was low,the AONR considered this the best potenti ,a 1 geothermal development site within thei r jurisdict;on. Emphasis should be placed on utilizing geothermal energy for electrical generation rather than as a direct heat source. Page 1-37,Table 1-20:The construction schedule should reflect the FERC Staff's analysis of when power upgrades would be needed and a realistic appraisal of when the alternative units could be brought on line. "'...,~:-- - 2 Page 2-2~O,last paragraph:The major deficiency of the proposed recreation plan is that it was developed without an appropriate level of input from the resource management agencies,such as the U.S.Fish and Wildlife Service (FWS), Bureau Clf Land Management (BlM),and the National Park Service.For example, develop"~nt of access and facilities on the south side of the Susitna River, particullarly in the Fog Lakes and Stephan Lake/Prairie Creek areas,would result i:n conflicts with existing use of these areas by guides,lodges,and high seclsonal brown bear concentrations.The FERC Staff should encourage the applicant to initiate discussions with resource management agencies so that a recreation plan can be developed free of conflicts with other components of the proposal.(See also our comments regarding Page 5-8,paragraphs 3 through 5.) Page 2-22,paraQraphs 5 and 6:To prevent significant habitat losses and disturbcLOce,we have recommended to the applicant that no borrow activities occur in the portion of borrow site E at the confl uence of Tsusena Creek with the Susftna River.If use of floodplain gravel from any of the proposed borrow pitswolild cause ice buildup as a result of groundwater overflow,the statement should discuss mitigation. Page 2-24,paragraph 4:Since the design criteria manual and the construc- tion practices manual are integral to the proposed mitigation plan,it is highly desirable that these manuals be subject to public review and comment. When found acceptable,these manuals should be incorporated into the license. Page 2-25,paragraphs 7 and 8:We recommend that the FERC Staff comment on the adequacy of the applicantls efforts "to minimize impacts to vegetation ••• so as to reduce clearing requirements or effects on sensitive areas such as wetlands.1I in proposed facilities sitings and designs.We concur with the FERC Staff's comments on problems with the "liberal"correlations used to determine wetland areas from Viereck and Dyrness vegetation types and the need for more detailed studies (see page J-79,paragraph 3;.page J-86,paragraph 1). Page 2-~~5,paragraph 9:Until we are·informed of the locations and proposed maint~nance and public access of transmission corridor access trails,we cannot be sure how well potential impacts may be mit igated.Resource ma:nagement agencies should also be involved when contractors prepare detailed access plans.A plan for minimizing public-use impacts,such as off-road vehicle use of project access routes,should be provided in the statement. Page 2-:~7,paragraphS:Please refer to our comments on requirements of the Bald Eagle Protection Act (page 4-45,paragraph 2).The FWS,which has statutol'"y authority under this Act,has not agreed to the applicant's proposal of constructing artificial bald eagle nests (See 001 comments on page E-3-443 of the license application). Page 2-:27,paragraph 9:The first sentence should be changed to read "Compensat i on through habitat manipulati on ••••II Enhancement can on ly occur. after full mitigation has been aChieved.We would caution that the feasibility of using controlled burning for habitat improvement is probably low. Page 2-:27 ,paragraph 10:Please reference the FWS letter dated October 12, 1983,tlO Lawrence Anderson (FERC)in which the FWS expresses concern over the I"~"~ - ..... ~. .- 3 siting I:lf the trans,ission lines near Nenana.The transmission lines pass within five miles of four,or possibly five,historic peregrine falcon eyries between Nenana and Fairbanks.Although these sites have not been recently used by peregrines,the FWS believes this nesting habitat may be reoccupied as pere1~rine populations increase to the levels preceding their decline. Considel~able discussion has taken place between the FWS and the applicant, the Alaska Power Authority (APA).During an April 25,1984,meeting,the APA representatives indicated their intention to consider rerouting the lines at least one mile from any historic eyries.Subsequent to that meeting,D. Roseneau of LGl Consultants reviewed all historical information on peregrine nesting and surveyed the peregrine habitat along this reach of the Tanana River.Roseneau presented his findings in a June 26,1984,meeting at which representat i ves from FWS and AP A were present.Roseneau reported that at the one location where the proposed transmission line closely approached historic peregrine nesting habitat (about 4 miles east of Nenana),the line would be approximately 1 3/8 mile from the cliff.Another cliff,located within 0.5 miles of the transmission line,which FWS considered possible historic nesting habitat,proved to lack suitable nesting sites.This finding lessens our concern over the present transmission line alignment,but does not remove the potenthl for disturbance to any peregrine attempting to reoccupy this habitat (i.e.,the cliff located 1 3/8 miles away)while construction or maintenance activit'ies were taking place. Section l(c)of the Endangered Species Act of 1973,as amended,requires' Federal agencies to prepare a Biological Assessment (BA)when threatened or endangered species have been identified in the vicinity of a proposed con- structic)n project that is a major Federal action significantly affecting the quality of the human environment.Since the DEIS acknowledges (page 2-27) that thE~endangered American peregrine falcon (Falco peregrinus anatum) could bE~impacted by construction of the Healy to Fairbanks transmission line, a BA is required.The assessment should be completed in conjunction with the Nationa'\,Environmenta1 Policy Act (NEPA)process and can be a section within the EIS that closely examines the potential effects of all components of the action on the peregrine.In general,a biological assessment should include the fol'\owing: A.An I:lns ;te inspect i on of the area affected by the proposed project. B.Intc~rviews with recognized experts on the species at issue. C.A literature review to determine the species distribution,habitat needs, and other biological requirements. D.An analysis of possible impacts to the species,including cumulative effects. E.An analysis of measures to avoid or minimize impacts. Biological assessments may be prepared by a designated non-Federal ent'ity.If, as a result of the assessment,it is concluded that the proposed activity may 4 affect the peregrine falcon,then a request for formal consultation should be submitted with a copy of the assessment to the Fish and Wil dl ife Service. Page 2-28,paraQraph 4:Different scheduling,worker transportation,and camp feclture scenarios should be compared in regard to project socioeconomic impacts,and in later sections,mitigation. Page 2-29,paragraph 3:In the discussion of cultural resources mitigation measures,there appears to be no provision for consultation with the Advisory Council on Historic Preservation as required by section 106 of the National Historic:Preservation Act of 1965.The applicant has consistently been advised of this requirement by the National Park Service. Page 2-41,paragraph 4:It should be clarified where the Johnson hydroelec- tric project would be located.Several references (including this paragraph) indicate!it would be located on the Tanana River while other references state it would be located on the Johnson River e.g.,page 3-65,paragraph 1).In additiorl,we recommend that a figure be provided illustrating a probable design configuration for this alternative. Page 3-17,paragraph 6:The most valuable aquatic habitats are the lower reaches of these tributaries,and their confluence areas with the Susitna River.These are the habitats that would be inundated by the applicant's proposall.Quantification of the resident fisheries should be provided,given that they are available from the applicant. The res;i dent species shou 1d be indi vidual1y descri bed.Habitat usage and populatilon levels should be provided in the statement. Page 3-:11,paragraph 2:Results of the FWS's ongoing wetlands mapping, under contract to the APA,need to be incorporated into project analyses. These maps will allow a more adequate assessment of wetland impacts and siting of project features to minimize those impacts. Pace 3-31,paragraph 3:For each of the wildlife species in the project area,population levels and seasonal habitat usage should be provided. Page 3-41,paragraph 1:We concur with use of both low and high population growth scenarios in evaluating the project area. Page 3-44,paragraph 7-and Page 3-49,paragraphs 1 thro~gh 5:Quantifi- cation of wildlife harvest (including that portion of the harvests that can be classified as subsistence,non-consumptive wildlife use,and commercial benefits of these uses should be provided in the statement.Subsistence use patterns should be established by surveys.This information should be containe!d in the statement. Page 3-55,paragraphs 1 through 4:Quantification by vegetation type Of the areiiS to be impacted should be provided to allow comparison of the alternatives. ',".,_"".",_~,C·~·".·~._'_._~."-_-._'''',_'..'-._-----..,-,-.'::.~.'"..---. 5 Page 3-59,paragraphs 3 through 5;Page 3-63,paragraphs 6 and 7;and Page 3-69,par'agraphs 3 through 8:Lack of quantification precludes meaningful comparison among wildlife resources that would be affected by alternative power generation slcenarios. Page 3-64,last paragraph:None of the alternatives described are sufficiently developed quantitatively to allow an adequate comparison of potentia'!impacts.The statement should provide this basis of comparison, particulclrly in regard to the aquatic and terrestrial resources. Page 4-5 l1 paragraph 1:Delay in ice formation in the reservoirs and down- stream would lead to ice fog formation during severe cold periods.The surroundling vegetation would become coated with ice,reducing its value as moose browse. Page 4-6"paragraph 8:The location and purpose of the .138-kV transmission lines should be indicated in the statement. Page 4-9 11 paragraph 3:The conclusions on how side sloughs downstream of Tal keetna waul d be affected by project-modified flows apparently is based ~upon a preliminary investigation of only Rabideaux slough.Investigations of addit'ional 10Wt r river sloughs should be included to support the instream flow an a"ys is. Page 4-23,paragraph 7:Pre-project,high spring flows often overtop the upstream berms of the side sloughs,flushing out the ice and also juvenile' salmon.The implications of the ice slowly decaying in place post-project should he discussed. Page 4-2!5,paragraph 2:Post-project,light penetration would still be extremely limited.We would not anticipate significant increases in benthic aquat ic 1;>1 ants and invertebrate producti vity. Page 4-215,paragraph 2:The two most valuable salmon streams in the upper Susitna River,Portage Creek and Indian River,are relatively close to the proposed Devil Canyon dam site.The potential for disorientation of spawners migrating to these two streams in the years immediately following closure shou ld ble addressed in the statement. - Page 4-26,paragraph 5:Given the paucity of data for downstream of Talkeetna,we find there is very little basis for reaching the conclusion that spawning in sloughs downstream of Talkeetna would not be significantly affected during filling of the Watana reservoir. Page 4-32,paragraph 5:The suggestion that Kokanee salmon be introduced into the reservoirs may warrant further investigation.However,we believe the potential of the reservoirs for establishment of viable fisheries to be low.Our primary fishery concern in the reservoir area is the unavoidable inundation of Arctic grayling habitat.The FWS mitigation goal for this species is no net loss of habitat val ue while minimi zing loss of in-kind - ..... 6 habitat value.The introduction of Kokanee salmon could lead to further reductiol1S in Arctic grayling due to competition,in which case we would be opposed to such a program.Efforts by the State of Alaska to artificially propagate grayling have been largely unsuccessful to date.If in-kind mitigation should be determined to be infeasible,then out-of-kind mitigation should be instituted. Page 4-35,paragraph 3:The sentence should be Qualified to state that early seral stages wi 11 be beneficial for some wildlife species such as moose.,Some other spl~cies require habitats of climax vegetation;it would be some time after construction is completed before suitable habitats are again available to such animals. Page 4-315,paragraph 5 through Page 4-37,paragraph 4:The statement should include an analysis of flows which would maintain existing patterns of down- stream vt~getation.The applicant's proposed flow regime,Case C,should then be compared to these alternative flows in regard to post-project vegetative patterns. Page 4-3B,paragraphs 4 and 5:Please provide the methodology and analysis which lead to the prediction of a doubling in consumptive,and quadrupling in nonconsumptive,use pressures. Page 4-38,paragraph 4;Page 4-41,paragraphs 2 and 3;Page 4-43,paragraphs 2 and 5;and Page 4-4b,paragraph 1:Harvest restrictions are established by the A')aska Board of Game.As discussed here,the project will likely result in impacts to game populations that the Board can minimize through changes in seasons l)r bag lim~ts.However,it should be acknowledged in the statement that those changes represent further project impacts by foreclosing management options otherwise available to the Board. Page 4-43,paragraph 6,last sentence:At least 35 wolverine would be impacted to some degree by the impoundment alone;home ranges of 45 percent of all instrumented wolverine overlap the impoundment zone (reference our :omments on page K-46,paragraph 10 and page K-48,paragraph 3).This infor- mation should be included in this section. Page 4-45,paragraph 2:Bald and golden eagles are protected under the Bald Eagle Protection Act (16 USC 668-668c).That protection makes it generally illegal to take bald or golden eagles,including any part,nest,or egg of either species.Under'a recent amendment,the Secretary of the Interior may permit the taking of golden eagle nests which interfere with resource develop- ment or lrecovery operations (16 USC 68Ba).The Act provides for the taking of bald eag'les or their nests only for certain specific exhibition or scientific purposes when compatible with the preservation of this species.Such taking may be pl~rmitted by the appropriate FWS Regional Director under eagle permit regulations (SO CFR 22).IITake ll is defined to include molest or disturb.For additional information,please consult our comments on page E-3-451,paragraph 2 through page E-3-454,paragraph 1 of the license application.Discussions in the statement should recognize the legal protection provided for these two species.The proposal,if authorized,should be consistent with the Act.The ..... ..... 7 statement should clarify the number of bald and golden eagle nests,in addition to those which would be inundated,that are subject to disturbance from the proposed project.Conflicting information is found in Appendix K (Tables K-18, K-19 and K-21)and the license application (Exhibit E,Volume 68,Chapter 3, Tables E-3-160 and E-3-161). Page 4-49,paragraph 6:The statement should include an analysis of the different population growth and impact scenarios possible under alternative worker tr'ansportation plans.That analysis would be a reasonable basis for planning project transportation features to best mitigate potential project impacts. Page 4-55,paragraph 5:The analysis of subsistence use could be more in detail in line with the recent Federal Court decision on subsistence.The analysis relative to the threshold of significant restriction to subsistence uses,as defined in this decision,should be included.The analysis should include more than the brief discussion presently given to impacts associated with the work camp •.Subsistence use should also be expanded to include vegetal and cultural materials.Quantification should be provided for the numbers of Alaskan residents,both Native and non-Native,who depend on project area resources for at least some part of their food and other resource suppl ies • Use by non-Native Alaskans is not addressed despite the fact that the railbelt has a relatively high population ratio of non-Natives to Natives.This is particu larly important where the Bureau of Land Management wi 11 be expected to issue subsequent land use authorizations in support of FERC's proposed deci- sions as outlined in the DEIS.The State has collected significant data in portions of the area,and we suggest FERC contact the Alaska Department of Fish and Game if they have not alr=ady done so.. Page 4-56,paragraph 1:The positive economic project effects described here may be negative to that portion of the area population dependent on subsistence opportunities for their food and other resources.Furthermore, the likelihood that guides "displaced"by project construction can reestablish their businesses in other areas should be discussed here. Page 4-74,paragraph 6:Although the proposed action (page 2-12,paragraph 3,and Figure 2-11)addresses only proposed transmission line routes downstream from the l~atana and Devil Canyon sites,alternative routes are inferred in Figure 2-14,IIAlternative Transmission Line Corridors"and here.If there are additional alternative routes or additional data,they should be added to the final document.The transmission line alternatives are inadequately evaluated for wildlife impacts.The final EIS should point out that the potential for indirect 'impacts,if access is improved during the construction of powerlines, is great. Page 4-79.paragraph 4;Page 4-84,paragraph 2;and Page 4-88,paragraph 6: Given the vague descriptions of the locations of primary and appurtenant facilities associated with this and other out-of-basin alternatives,it is premature to assume that no Federally 1i sted or proposed threatened or endan- gered species would be impacted.If any of the alternatives were to be pursued,they would have to be assessed for potential conflicts • 8 Page 4-86,paragraphs 8 and 10:The statement should be corrected to indicate that the applicant's design for the Chakachamna site includes a 50-foot dam and minor water level changes • .-Page 4-88,paragra..e!:Ll:Quantification should be provided concerning the fisheries to be affected by the hydroelectric projects,both directly through migration blockage and indirectly through modification of downstream condi- tions.Discussion should also be presented in the statement on the potential for miti~~ation at the proposed alternative sites.For example,whether passage faciliti~s are viable at the Keetna site should be discussed.Also,the Chakachamna project could be limited to one basin,the Chakachatna River,thus reducing potential adverse impacts to the McArthur system. Page 4-813,paragraph 5:Comparative quantitative information should be provided actions and habitats to be directly impacted by habitat loss,altera- tion,and migration blockages,as well as by potential indirect impacts of increased and di sturbance. Page 4-89,paragraph 2 through Page 4-90 paragraph 3:Comparative infor- mation should be provided on the magnitude of subsistence,recreational,and commercicll uses of fish and wildlife resources and potential impacts to those resource uses from non-Susitna generation alternatives. .... Page 4-96,Table 4-13:The statement should provide the criteria used to determine relative impact potentials of alternative generation scenarios. Differenc:es among habitat losses quantified here,as compared to those given in Table J-45,page J-87,should be clarified for all Susitna alternatives. Page 4-100,paragr,~:The ADNR t s Susitna Area Plan,recently circulated for agenc:y review,and the completed Willow Subbasin Plan interagency project area planning efforts should be discussed here. Page 4-101,paragraph 4:Fish and wiT dl ife resource impacts wou ld also result in:irrevers'ible subsistence-related,as well as recreation-related, impacts in the project area. Page 5-7?paragraphs 1 through 3:Selection of individual components within a thermal-based with hydropower generation scenario would necessitate careful evaluatio,n.The h.Jfdropower sites examined in this statement do not?as a group?appear to be environmentally appealing.For example,we would be very concerned about thE!blockage of upstream salmon mi grat i on with the Keetna site,and the large inundation area with the Johnson site. Page 5-7,paragraphs 4 through 6:We concur with the FERC Staff conclusion that if hydroelectroic development is authorized in the Susitna Basin?it should be licensed and constructed in stages.We concur that,based upon the infor- mation and analyses presented in the statement?~atana I with a downstream re-regulation dam ~tOuld be the most environmentally sound Susitna Basi·n development.. .- 9 Page 5-8,paragraphs 1 and 2:Numerous ideas concerning instream flow releases are raised in this section and in Section 5.3.3.The statement should cl:)ntain a coherent instream flow regime that would adequately protect the fishl:!ries and other resources,and their use,of the Susitna River.We intend to work directly with the applicant to formulate this instream flow regime. fage 5-8,paragraphs 3 through 5:.From a fish and wildlife resource perspective,we agree that the Denali Highway access proposal should be abandoned,and that the preferred access alternative would consist of rail access to Devil Canyon from Gold Creek along the southern side,with road access fy"om Devil Canyon to Watana along the northern side of the Susitna River.Should there be continued interest in the originally proposed route, there should be further consideration of additional mitigation,including alternative alignments,habitat improvements,and construction stipulations,as we 11 as further cOlordinat i on with FWS and BlM. If the FERC Staff's recommendation is adopted,there are several recreation resources;identifiled in the recreation plan (pages 2-14 through 2-20)that may no longer'be considered reasonably accessible,and other potential resources that may now be considered appropriate.We suggest that if the transportation plan is c:hanged,the recreation plan be reconsidered and revised accordingly. The proposal and the analysis fail to address the impacts on existing users of these campgrounds in the event that extensive development takes place.Gener- ally,the loss of remote wilderness type recreation opportunities cannot be mitigated through developing more or larger campgrounds. Page S-8,paragraph 8 through page 5-9,paragraph 1:We concur with the proposal and objectives for the applicant's continuing coordination with governi n9:agencies and landowners throughout project p1 anning,construct ion, and operation.DOI and its bureaus will continue to participate actively in such efforts. Page 5-11,paragraph 1:Arctic grayling would sustain significant adverse imp~cts due to the inundation of habitat by the reservoirs.Our preference would be to mitigate in-kind,that is Arctic grayling for Arctic grayling.As mentioned previouslly,efforts by the State of Alaska to artificially propagate grayling have not been successful to date.If in-kind mitigation of unavoid- able grayling loss is determined to be infeasible,a plan for out-of-kind mit i gat ion shou 1d be di scussed in the EIS. PageS-II paragraph 4 through page 5-12,paragraph 4:We concur with the FERC Staff1s analysis of the problems with the applicant 1 s mitigation plan for terrestrial communities and with the Staff's recommendations for continued coordination with resource agencies by the applicant~further studies,and continued monitoring.The statement should quantify areas and locations of potential mitigation lands as well as cite research documenting the success of recolTll1ended vegetation manipulations.We have recommended that an ,inter- agency team be an integral part of monitoring and refining mitigation during and post-project.Results of ongoing vegetation and wetlands mapping should .- I 10 be used to refine mitigative siting of project features and modeling of moose, bear,and beaver habitats to determine mitigation needs and potential values of proposed habitat manipulations. The Bure,au of Land Management is concerned with the proposed mitigation of habitat loss through designation of "replacement"lands because the proposal fails to identify those replacement lands,and,specifically,whether Federal lands administered by BLM are suggested • Page 5-1~~,paragraEl!...i:The statement should clarify exactly which agency mitigation recommendations,including alterations in proposed project plans, have been incorporated in the Staff's recommendations.For those recommenda- tions not so adopted,an explanation should be included in the statement. ~Page 5-1~~,paragraphs 5 and 6:Given the FERC Staff recommendation that .construction access only be provided to Watana from Gold Creek (see page 5-8, paragraph 5)it is inconsistent for the FERC Staff also to endorse a recrea-. tion plan is stron!gly dependent upon public access being available from the Denali Highway to the Watana dam.The recreation mitigation plan should be consistent with the FERC Staff recommendation of no Denali Highway access to the Watana dam sitle. Page 5-12,paragraph 7,subparagraphs 1,2,4,and 5 and page 5-13, subparagraphs 2,3,4,5,6,9,13,and 14:001 also concurs with the need for these mitigation strategies that will help minimize impacts to fish and wildlife resources and the subsistence use of those resources. Page 5-13:,subparagraph 3:We strongly concur with the mitigation proposal to establish a project-funded interagency monitoring board.The board should serve to monitor all mitigation during construction and operation of the project,not just socioeconomic impacts.On-site representation from the FERC would be highly desirable to maximize the responsiveness of this board. Page 5-13,subparauraph 9:We recommend that Federal agencies be included in this listing of agencies to which the applicant should communicate project informat ion. Appendix E.Geology and Soils We have two main cclncerns with the information provided here.First,while possible impact issues .are generally described,they are not Quantified,thus precluding a full assessment of impacts (see page E-39,paragraph 3,;page E-40, paragraphs 2 through 6).For example,slope failures and erosion would result in vegetation losses.These sites should be evaluated for their value as wild- life habitat.Our second concern is that recommended mitigation measures are not quantified. Identified information needs should be pursued,and then presented in the statement (e.g.,page E-ll,paragraph 7;page E-41,paragraph 6;and ~age E-48,paragraph 3).The U.S.Geological Survey and the Soil Conservation Service should also be consulted during the analysis of all site-specific construction plans (page E-59,paragraph 5). .... """! ,.,.. 11 Appendix H.Water Resources Page H-7,paragraph 4:Seven distinct habitat types are cited,yet the ensuing descriptions cover only three habitat types.The four other habitat types should be described,and distinguished in regard to their physical and biological characteristics. Page H-l~~,paragraph 1:The side slough habitat is biologically significant and is hiigh1y resp,onsive to changes in mainstem discharge.However,tribu- taries support greater numbers of spawners and thus could be considered of greater biological significance.Tributary mouths are also highly responsive to mainstem discharge changes. Page H-21,paragral~The acceptability of the applicant's upward revision of the r~~cord drought year 1969 shou 1d be assessed.We bel i eve the imp 1i ca- tions of water year 1969 alone,and in conjunction with low water year 1970, should be!examined in regard to meeting biological versus power demands. Page H-4Q1:Given that the applicant proposes flow no greater than 12,000 cubic feet per second (cfs),comparisons should be provided for flows less than 12,000 cfs versus wetted surface are-a.Discharge flows at Gold Creek.of 6,000 cfs,8,000 cfs,10,000 cfs,and 12,000 cfs versus wetted surface area would be i1lustrat~ive of various post-project conditions. Page H-44,paragraph 1:Discussion should be provided on why the applicant's computer models,in this case SNTEMP,were not used.A comparison of the strengths and weaknesses of the applicant's models versus those relied upon by the FERC Staff should be included in the statement.This is particularly important since emphasis in Appendix I on downstream adverse fishery impacts is placed on model-predicted temperature changes. Page R-45:Two additional water quality parameters that need to be examined are heavy metals,particularly mercury,and pH.Pre-project,several trace e1ements,including mercury,exceed water qUd1ity guidelines (see page E-2-36 in the license application).Given the high level of back.ground mercury and the noted increases in mercury concentrations in fish in other northern impoundments (see Appendix I,page 1-64),attention should be focused on this element.Also·,pH levels up to 8.1 (see page E-2-34 in the license applica- tion)have been Observed.Discussion should be provided on the post-project implications of these -high pH levels,particularly in association with the other water quality parameters that exceed recommended standards (see Table E.2.17 in the license application). Page H-48,paragraph 2:We have on several occasions requested that the potential for shoreline erosion and bank slumping be assessed,most recently by letter dated April 23,1984 from the FWS to the applicant.Soil sampling should be conducted to examine the amount of fine-grained materials and the heavy metal and pH levels.We do not believe these studies are presently planned.Based upon information provided by this type of study,the state- ment should quantitatively discuss the potential for impacts,both within the reservoirs and downstream. - ..- .- 12 Page H-49,paragraph 2:In addition to discussing the potential for nitrogen supersaturation during an average year,the statement should also address startup and testing of the turbines and ~,e greater-than-50-year flood event. Adequacy of the applicant's proposed mitication,as well as the practicality of additional mitigation should be discussed (e.g.,requiring control of nitrogen supersaturation up to the lOO-year event). Appendix I.Fisheries and Aquatic Resources Page 1-215,paragraph 2:The applicant categorized the aquatic habitats into seven di~)tinct types:mainstem~side channel,side slough,upland slough, tributary,tributary mouth,and lake.These seven habitat types are acknow- ledged on page H-7 of this statement.The ensuing discussions should focus on these distinct physical and biological habitats. Page 1-26,paragraph 7:.Reference is made to an Appendix A in this and several following sections.The indicated discussions are not contained in Appendix A of the statement~Load Growth Forecasts.Please clarify where the discussions can be found. Page I-3S,paragraph 6:Current harvest levels and project impacts on sub- sistence activities need to be evaluated.The referenced ongoing assessment should bE!incorporated into the statement. Page 1-4~1,paragraph 4:The ensuing impact discussions are essentially limited to the five salmon species.Although not all the fishery species occurrin9 in the Susitna River need to be discussed to evaluate the project's potential impacts,we believe several additional species warrant discussion. We recommend that the FWS evaluation species,which include the five salmon species,Arctic grayling,rainbow trout,burbot~and Dolly Varden,be discussed in the statement. Page I-50,para9raA~Although the application proposes limiting operat i OlliS to base"load,the applicant anticipates exami ning during the next Yl?a r :co"stant discharge,baseload variable discharge,load following,and peaking operations (see applicant's Task 58 in the Draft Aquatic Plan of Study, Fiscal Ye!ar 1985).The statement should compare these different modes of operation in regard to the biological resources of the Susitna River. Page I-57,paragraph 4:Although sulTlt1er turbidity would,pos.-project,be greatly reduced,the levels would probably still be high enough to inhibit significa.nt increases in benthic productivity.Also,the elimination of the natural high flows cou1d res41lt in 1009 term siltation of spawning gravels • ~e consider to be speculative and premature the conclusion that,"Undoubtedly, reduction in turbidity and flow stabilization offer important management opportunities for Susitna Riversalmon.I ' Page 1-62,paragraph 4:The conclusion that adverse temperature impacts in the mainstem would be ameliorated by fish congregation in the sloughs should be tempered through a discussion of the anticipated reduction in wetted usable area and the potential for increased losses due to predation.Increased - 13 concentrations of juvenile salmon and low turbidity would increase vulnera- bi 1ity tiD predation. Page 1-62,paragraph 5:The turbidity levels would prob,bly still be too high to anticipate markedly increased productivity of benthic organisms. Coupled with the expected decrease in summer temperatures,benthic productivity may not increase over pre-project levels. page 1-63 2 paraqraph 1:We anticipate that the Devil Canyon reservoir would provide marginal fishery habitat.Turbidity levels probably would not be sufficielrltly reduced to be of benefit to the aquatic resources • .Page 1-64,paragraph 3:To state that diverting salmon up the Talkeetna River would result in increased productivity assumes that the Talkeetna River is presently underutilized by salmon.The statement should pr ...vide quanti- tative support for this contention.The other assumption that would need to be slJpPol"ted is that warmer temperatures from the Tal keetna River would provi de a strong~~r attractant than the chemi cal trail of the natal stream. Page 1-6.',paragraph 6:The sport fishery is strongly associated with the natural salmon holding areas.Fishing pressure primarily occurs at the tributary confluences where the fish concentrate.How severely the project would impact the sport fishery is therefore directly related to how the project would influence these tributary mouth areas.The statement should relate project impacts to the tributary mouths to impacts to the sport fishery. Page 1-64,paragraph 8:The references noted do not examine the potential for mercury accumulation in fish downstream from impoundments.Oiscussion of this potential problem should be provided.Post-project impacts due to the high background pH (see page E-2-34 in the license application)and several other water quality parameters (see Table E.2.17 in the license application) should be discussed. Page 1-66,paragraphs 2-4:Individually,the access road stream crossings a not constitute a serious adverse impact.However,the potential effects of turbidit.l"siltation,improper placement of culverts,inadequate culverts, erosion,etc.,resulting from crossing over 100 streams,many of which contain excellent Arctic grayling habitat (e.g.,Brushkana,Seattle,and 1:>eadman Creeks),should be classified as a potentially significant adverse cumulative impact. Page 1-67,paragraphs'2-4:Unless adequate mitigation measures are incor- porated 1into the designs and construction,the cumulative adverse impacts, primarilJ'to wetlands and streams,resulting from the construction of the transmission lines,would be significant.Potential impacts would include turbidity,siltation,erosion,inadequate culverts,and improper placement of cu 1VeT"ts • ,Appendix J.Terrestrial Botanical Resources ,-Page J-3"paragraph 3:Further vegetation and wetlands mapping is currently being undertaken to refine and improve the mapping described here.The state- ment should incorplorate preliminary results of those efforts.This mapping '. 14 would allow more accurate and detailed impact assessments,facil ity siti ng which better avoids wetlands and other sensitive areas,and improved evaluation of wildlife habitat. PagE!J-12,paragraph 2:We question the usefulness of correlating Viereck. and Dyrness vegetation types to the more general types and resolution mapped by C:ommonwealth Associates for the Healy-to-Wi 11 ow transmi ss ion corri dor segment.Although this correlation was made lito provide some basis for comparison between the two systems •••,·there ;s no corresponding correlation or interpreti've analysis quantifying vegetation types within that corridor (Table J-14).Until the Healy-to-Willow transmission line segment is typed at the 1:63,360 scale according to Viereck and Dyrness,a cumulative assessment of all transmission corridor segments,as well as of all project features,cannot be -made.-Page!J-25,paragraph 1:To evaluate borrow site impacts and mi ..igation needs,material needs and the probable sequence in which identified borrow arealS would bl~used should be described. ..- .... Page J-37,pa1ragraph 4 and Tables J-13,J-14,and-J-15:Use of Commonwealth Assolciates l c'Jassification system precludes an analysis of cumulative impacts from all transmission line segments.Please refer to our earlier comments on the need to consistently classify the entire transmission corridor (page J-12, paragraph 2 and 001 comments on page E-3-217:(e)of the license application)• Pages J-44 through J-46:Wetlands have been mapped as part of the FWS's National Wetlands Inventory for several of the areas affected by the non- Susitna generation alternatives.Those maps should be used in any further analyses of these alternatives. Page~J-46,paragraph 5 and Tabl e J-18:The 1100 acres of vegetated area to be cleared for permanent access (Table J-26)should be included in the discussion of total permanent vegetation losses. Page J-48,Table J-19 and Page J-49,paragraoh 1:Further information is needed to assess fully the impacts and mitigative uses planned for proposed borrow areas.Those portions of proposed borrow areas partially or completely located within the eventual inundation areas should be quantified,and use schedules out"'ined as recommended previously (page 25,paragraph 1). We concur with the recommendation that power development in the Railbelt region be phased wi til actual area growth and power demands.Thus,if a Watana dam is developed and the Devil Canyon dam is not,then removing borro\"from portions _of the Susitna River downstream from the Watana dam site may unnecessarily impact existing and potential fisheries.Consequently we recommend that proposed borrow areas E and I not be used in construction of the proposed Watana dam and associ ated faci 1it ies. Alteration of forest habitats to tall shrub or lower vegetation types in the transmission corridor should be tabulated here to allow an assessment of overall project impacts. 15 Page J-49 t paragraph 3:The potential'for overbrowsing would be greatest in areas closest to the impoundment and other-impact areas where available habitats will be reduced. Page J-49,paragraph 4;Page J-50,Table J-20;and Page J-51 t Table J-21: Accurately identifying wetlands is a prerequisite to required permitting under Section 404 of the Clean Water Act.It should be determined,based upon accurate wetlands maps,whether each proposed project facility,borrow area, access road,etc.,could be sited to avoid wetlands areas.We note that while 53.2%of the entire upper and middle Susitna River Basin is classified as potential wetlands ·Table J-12),75.5%of areas to be permanently lost (Table J-20)and 80.8%of areas to be temporarily lost (Table J-21)are classified as potential wetlands. Page J-53,paragraph 3:.Whether increased nutrients and productivity on disturbed soils would be beneficial or detrimental to wildlife species of . concern would depend upon the resultant plant species composition.Generally shrubs,which are here described to decrease,while graminoids increase after disturbance,are of greater value to wildlife on a year round basis.. Page J-54 t paragraph 1 through Page 55,paragraph 2:The statement should reflect results of the latest modeling projections of icing,water tables,and other hydrologic changes.These probable changes should then be related to potential vegetation changes. Page J-57 t Table J-22:Permanent access roads should be included here to allow a complete assessment of cumulative project impacts. Page J-62,paragraph'6:We recommend that FERC Staff assess the adequacy of access routi ng "to avoi d important wetland areas near Deadman and Tsusena creeks and to minimize crossage of other wetlands areas,"given the liberal correlation of wetland types to the Viereck and Dyrness vegetation classifi- cation system (also see page 4-34,Table 4-3). r.aSt!J-62,paragraph 7:We recommend that the statement include maps and verbal descriptions of the nine potential borrow areas for the proposed Denali -Highway access route. Page J-64,paragraph 3:We recommend that the statement include maps and verbal descriptions of the five potential borrow areas along the Watana to Devil Canyon access road segment. Page J-65 t paragraph 6:We concur with use of a worst-case estimate in assessing vegetation impacts.The statement should reflect the status ;f and problems encountered during construction of the Healy-to-Willow Intertie.That transmission facility,to be completed by fall,1984,is proposed for upgrading to serve as a Susitna hydroelectric transmission corridor. - i'W'lm Page J-65,paragraph 7:While we concur with use of a worst-case methodology in assessing impacts,we again recommend that the statement include an accurate ..- - - ".. 16 identification of wetlands so that the mitigative siting of transmission line corridors and associated access trails can be fully evaluated. Page J-66,Table J-28;Page J-70,Table J-30;J-72,Table J-32;and Page J-74, Table J-34:Discussion of transmission corridor impacts should include a quantitative analysis of probable pre-versus post-construction changes in vegetation types.Wildlife yalues of those types and how they would be impacted under the proposed maintenance schedule should be displayed. Page J-67 2 paragraph 1:We recommend that transmission line access corridors be clearly defined so that they can be considered in assessiing total project impacts;access trails for maintenance should be minimized to occur only between major river crossings or topographical barriers such as deep ravines (001 comments on page E-3-245 of the license application).We are concerned that Appendix F refers to creation of a minimum standard access road along the entire length of the transmission line (page F-39,paragraph 6).Resource agencies such as the FWS,BlM,the CE,and the ADF&G should be consulted in all access sitings to ensure that potential adverse impacts to wetlands,fish streams,and vegetation from off-road vehicles are avoided or minimized. Page J-75 2 paragraEhs 1 through 4:Specific losses or changes in area vegetation types wl11 determine the magnitude of alternative project impacts to area wildlife as compared to the proposed Susitna project.We recommend that such impacts be quantified to support the alternatives comparison.Quan- tification should also be provided for Susitna development comparisons of con- struction camp and scheduling alternatives. Page J-79,paragraph 3,last sentence:Potential borrow needs,an analysis of alternative as compared to proposed borrow sites,and the proposed order for using those sites should be better described here. Page J-84,paragraph 2:Terrestrial areas to be inundated by the 50-foot dam associated with the proposed Chakachamna project should be quantified here. Page J-85,paragraph 2:This comparative analysis should include the FERC Staff recommended access alternative which eliminates the Denali Highway road connection. Page J-86,paragraph 1 2 last sentence:We concur,and recommend that these information gaps be filled in the statement. Page J-86,paragraph 3:We recommend that the FERC Staff provide their comparative rationale for recommending the Johnson hydropower alternative, which would inundate over twice the area of the proposed alternative. Page J-87.Table J-45:To compare adequately the alternative energy proposals,some quantitative assessment of potential access areas should be made here. The figure of 36,900 acres to be permanently removed with con$truction of both Watana and Devil Canyon dams,impoundments,and other permanent facilities does - ",.., '. 17 not agree with previous data that 37,000 acres will be permanently lost with construction of the Watana dam and facilities (Table J-1S)and an additional 7,900 acres will be permanently lost with construction of the Devil Canyon dam and facilities (Table J-22). Page J-88,para-graph 1:Potential increases in human access and resultant impacts should be discussed here. Page J-88,paragraph 7 through Page J-89 paragraph 4:We recommend that FERC comment on the adequacy of the applicant's efforts l'to minimize impacts to vegetation •••so as to reduce clearing requirements or effects on sensitive areas such as wetlands,"in proposed facilities sitings and designs. Page J-89,paragraph 5 through Page J-90,paragraph 3:We concur with the general mitigation scheme for transmission corridor clearing and maintenance with the exception of r-eferenced longitudinal and other access trails.Unti 1 locations,maintenance,and public access proposals for those trails are pro- vided,we cannot assess how well potential impacts may be mitigated.Resource and permitting agencies such as the FWS,the ADF&G,and the CE should be involved when contractors are required to prepare construction and maintenance access plans.Rather than including only potential options,the statement should clarify what plan for managing human access impacts of project routes is recommended. Page J-90,paragraph 4 through Page J-91,paragraph 6:-We recommend including rectification for the up to 17,000 acres of reservoir slopes that may be affected by beaching,flow or block slides,erosion,slumpage,and other subsequent vegetation losses.- Page J-92,paragraph 8 through Page J-93,paragraph 1:The mitigation plan should include a process for implementing additional mitigation measures,with resource agency concurrence,should initial measures prove ineffective. Page J-93,paragraphs 5 and 6:We concur with the FERC Staff's recommen- Jdtions on further and ongoing studies. Appendix l.Terrestrial Wildlife Resource Page K-3,paragraph 2:The following reference was omitted from the References list: u.S.Fish and Wildlife Service.1983d.letter from Melvin A.Monson, Acting Assistant Regional Director,to Eric P.Yould,Executive Director, Alaska Power Authority (24 January). Page K-3,paragraph 5:The ADF&G continues to be the principal organization conducting wildlife studies in the Susitna River Basin.Work on furbearers and birds has been,and is being,conducted by University of Alaska researchers and consultants under contract to the applicant.We are concerned that results of all those studies as presented here are 1 to 2 years old.The statement should be updated to reflect findings of the 1983 studies. 18 Page K-8,Figure K-2:The quantitative basis for classifying the delineated areas as having high,medium,and low densities of moose should be included . here. Page ~2,paragraph 4:The Nelchina herd was estimated at 24,825 caribou in 1983. Page K-17,paragraph 2:The most sheep observed at the Jay Creek mineral lick at one time,31 individualsK(~pproximatelY 21 percent of the population) was during 1983 project studies.- Page K-26,paragraph 7:GMU 13 accounts for 5 to 14.5 percent of statewide big game harvests.The importance of this unit is apparent given that GMU 13 constitutes barely more than 1 percent of the state I s total area. Pages K-26 through K-29:This discussion on IIHuman Use and Management of Wildlife"includes several descriptions of data gaps.Information should be provided on ongoing efforts and the timetable for filling those gaps.Surveys allowing analysis of the subsistence portion of wildlife and fish harvests should be incl uded in further project studies.Please reference our cormnents on page N-75,paragraphs 3 and 4. Page K-30,paragraph 1:Presence of several historic peregrine falcon eyries within a few miles of the transmission line north of Nenana should be described here. Page K-34,paragraph 6:Both consumptive and non-consumptive human uses of wildlife are intensLe in the lower Susitna River Basin because of adequate access and proximity to the major population centers of Southcentral Alaska. Discussion of area harvests and non-consumptive wildlife uses,as was done for the upper and middle Susitna River Basin (pages K-26·through K-29),should be provided. Page K-35,paragraph 2 through Page K-37:Lack of quantification precludes G~Y ~~aningful comparison among wildlife resources that would be affected by alternative scenarios for Susitna River Basin development,natural gas or coal- fired energy generation,and the various components and component combinations of a combined hydro-thermal energy generation source.No data sources,other than a general resource review,are provided to substantiate qualitative assessments that an alternative site provides lllimited"or "high quality"wild- Ki~e habitat,or that 'moose "concentrate"in various areas and seasons. -Page K-35,paragraphs 5 through 9:More recent detailed data on Chuitna and ~eluga river area wildlife resources are available in reR~~ts preparat~ry to Dlamond Shamrock's plans to develop ~oal resources there.Area studles include ongoing moose radio-tracking by ADF&G. Page K-38,paragraph 1:We recommend that the statement include a general discussion of overall impacts on the ecosystem's wildlife from the Watana impoundment,as is later provided for the Devil Canyon development (page K-60, paragraph 4). ~..... -~19 ..... ..- Page K-38,paragraph 2:The statement should clarify how the vegetation types and project impacts defined in Appendix J relate to the lIhigh quality habitat 'l to which moose use is here attributed.Habitats and their relative quality will not be geographically defined until ongoing vegetation mapping, browse analyses and food habits studies,and the moose carrying capacity modeling are completed over the next couple of years. Page K-38,paragraph 4:The statement should be updated to include 1983 survey estimatei shat the ~atana impoundment area was inhabited by 580 moose in spring 1983.-.. Page K-39,Table K-6:Indirect impacts of altered moose use patterns, resulting from habitat losses and alterations as well as from changes in harvests,should also be quantified here (e.g.,page K-41,paragraphs 3 and 6 and page K-43,paragraphs 2 and 3). Page K-41,paragraph 3:Figures provided here should be updated.The 19~36 fall census shows the primary impact zone was used by 2836 +/-301 moose.- Pages K-41,paragraph 4 through Page K-43,paragraph 2:Vegetation type losses and changes over time should be quantified in the statement according to expected worst and best case expectations for vegetation succession.Those losses/changes should then be related to potential wildlife uses throughout the project life,including project construction. ~e K-43,paragraph 2,Page K-48,paragraph 3,and Page K-64,paragraph 4: The temporary displacement periods described here should likely be expanded to include a recovery period befor2 wildlife species will return to fully or par- tially utilize those areas out of production or subject to intense disturbance during project construction. Page K-45,Table K-l1,and Page K-46,paragraph 2:According to the latest ADF&G reports,15 of 26 blRc~bear den sites (58 percent)would be inundated by the Watana impoundment.- Page K-46,paragraph 10 through Page K-48,paragraph 3:Impacts to wolverine are apparently underestimated.Inundation of low-level areas will result in permanent loss of winter habitat.Since 45 percent (9 of 20)of all instru- mented wolverine have home ranges overlapping the impoundment zone,~t8least 35 wolverine would be impacted to some degree by the impoundment alone.- Access roads,transmission corridors,and other project facilities will likely further decrease wolverine habitats. Page K-54,paragraph 3:A general discussion of operational impacts on area wildlife should be provided here. Page K-54,paragraph 1 through Page K-56,paragraph 2:Quantification should be provided for vegetation types to be impacted and moose populations likely to be affected by vegetation changes over time.An evaluation of downstream - - ". 20 succession patterns and associated values for moose should be based upon detailed vegetation mapping and modeling. Page K-59,paragraph 6:As later described,beaver may be excluded from sloughs which are to be managed for salmon spawning (page K-82,paragraph 6). No quantification is provided for sloughs which may be managed for beaver and expected positive population impacts,as compared to the negative population impacts likely near upstream project facilities.Thus it is impossible to ascertain whether the net result will be enhancement of beaver habitat or partial compensation for overall "habitat losses. Page K-64,paragraph 4:For the Terror lake hydroelectric project at Kodiak Island,Alaska,it was estimated that the full recovery period for brown bear habitat utilization would be 20 years.The 10-year loss of habitat described here is probably optimistic and should be reassessed. PageK-65,paragraph 4:The statement should provide quantifiGation for the impacts listed here. Pages K-66 through K-69,paragraph 3:The section provides numerous examples of significant negative impacts that could occur to wildlife with the proposed Denali Highway to Watana access segment.We concur with the FERC Staff recommendation that this segment be dropped from project plans. Page K-70,paragraph 2:The statement should clarify the methodology used to calculate the percent of impoundment-caused winter carrying capacity losses that will be compensated for by enhanced forage avail abi 1ity along the trans- mission line right-of-way. Page K-70,paragraph 7:Collisions of birds with towers or conductors and electrocution,are not covered in Appendix 0 as stated here. Page K-74 1 paragraphs 3 through 7:We concur that project impacts to wild- life would be reduced with construction of the smaller Watana I alternative. Page K-75,paragraphs 2 through 5:We concur with the FERC Staff recommenda- tion that the Denali Highway to Watana access segment not be constructed (page 5-8,paragraph 5).However,this analysis of alternative access routes does not clearly identify which specific alternative or combination of alternatives constitutes the FERC Staff1s recommended access alternative.Page K-76, paragraph 1:We support the concept of only using borrow areas that would be inundated or otherwise lost due to project construction.The statement should clarify potential borrow areas and a timetable for using each proposed borrow site (page J-48,Table J-19 and page J-49,paragraph 1). Page K-76 1 paragraph 2:Comparative information on the locations and habitats to be impacted by the construction camp,permanent workers,access roads and other infrastructure features essential to n~tural gas plant development should be provided here. - ", 21 Page K-77,paragraph 7:Alternative scenarios for different hydro-thermal development combinations should be described.Those scenarios should include comparable quantitative information on wildlife habitats to be impacted,as we 11 as on associ ated infrastructure needs. Page K-77,paragraph 8:We support rail access from Gold Creek to Devil Canyon south of the Susitna River,and road access from there to Watana north of the Susitna River.as the best access alternative for minimizing impacts to fish and wildlife. Page K-79,paragraphs 1 through 3:Unless the statement includes comparative information on the relative values of different wildlife habitats,as well as acreages to be potentially impacted,it will not be possible to realistically compare and choose among the energy development alternatives. Page K-79,paragraph 6 through Page K-82,paragraph 8:We provided numerous mitigation recommendations in our comments on the license application.These included a set of tlBiological Stipulations ll and IIRecommended Construction Methods for Mitigating Impacts to Wetlands Which Cannot be Avoided by Project Development ll (Attachments A and C).The statement should fully incorporate those recommendations here or include reasons why they have been omitted. Page K-79,.paragraph 9 through Page K-80,paragraph 1:We concur with the transmission corridor clearing and maintenance proposal to optimize browse enhancement for moose and other wildlife that prefer vegetation types in early successional stages.However,the statement should quantify the actual compensation that may be gained for other project-caused habitat losses.On a strict acreage basis,the project will result in pLrmanent loss of 38,000 acres and an additional loss of 6,400 acres for 10 years during project construction and beyond during habitat recovery (according to Table J-45, please see our comments on Table 4-13,page 4-96,which list total project habitat losses at 64,000 acres).Comparative values of all these areas as wildlife habitat have not been determined.Their location relative to moose use patterns has not been assessed.The statement (page K-79,paragraph 8) Questions the likelihood that moose will take advantage of forage available after transmission corridor clearing.The mitigation potential of this project feature would equal the incremental improvement of browse along the approximately 6,200 acres of forest habitat within the transmission corridor from Tables J-30,J-32,and J-34).Thus the possibility of obtaining up to 40 percent compensation from both permanent and temporary project losses as postulated earlier (page K-70,paragraph 2)would seem greatly exaggerated. Page K-80,paragraphs 3 and 4:We concur with these analyses. Page K-BO,paragraph 5:Project impacts that may cause the Alaska Board of .Game to conduct a controlled moose hunt or otherwise restrict harvest seasons .-and bag limits may foreclose or otherwise limit Board management options available without project construction (see DOl comments on page E-3-510 of the license application). ..... 22 Page K-80,paragraph 7,subparagraph 2 and Page K-81,paragraph 1,subpara graph 2:Additional restrictions recommended by ADF&G,with which we concur, should be incorporated here:restrict timber harvest within 2 air miles of the Jay Creek lick area to late August through April;prohibit clearing activities within 0.5 miles of the lick area,including roads,logging equipment,and debris,except for those portions below the minimum operating water level; prohi bit ai r traffic below 1,000 feet above ground level and di scour age it between 1,000-1,500 feet above ground level within 1.0 mile of mineral licks, 1 May-IS July;prohibit helicopter landings within 1.0 mile of mineral licks during 1 Ma-r-1S July;prohibit ~oat and.ground access within l.R_~i1e of the Jay Creek 11Ck area and other mlnera1 11Cks from 1 May-IS July.These restrictions would also be necessary during project operation and in managing area recreational activities post-construction. Page K-80,paragraph 6 through Page K-81,paragraph 1:The mitigation plan should allow for changing designated sensitive areas and restricted activities based upon interagency monitoring.Changes in wildlife use patterns,unusual weather conditions,and other factors could warrant temporary or permanent changes in the plan. Timing and activity restrictions should be established,in consultation with ADF&G,on aircraft and major ground activity near active fox dens. Page K-81 2 paragraph 3 and Page K-83,paragraph 3:The statement should evaluate out-of-kind mitigation,and its acceptability to the resource agencies. Page K-81 2 paragraph 4:We support severely restricting recreational access and activities in the vicinity of the Jay Creek mineral lick to further minimize project impacts to sheep (page K-57,paragraphs 5 and 8). Page K-82 2 paragraphs 3 and 6:Quantification of downstream increases in beaver is necessary to support the contention that there will be enhancement, beyond all other impacts to aquatic furbearers. Page K-83,paragraph 6:The statement should provide the analysis leading to postulated two-fold increases in hunting pressures and four-fold increases in non-consumptive wildlife users with project development.How those postulated increases would be affected by eliminating the proposed Denali Highway to Watana access route should then be analyzed in the following section,K.S.2. Appendix l.Recreation Resources Page l-4:The table should be corrected to indicate the acreage of the Kodiak National Wildlife Refuge as 1,817,600 acres.Distinctive wildlife of the refuge include brown bear and introduced Sitka blacktail deer. Page l-22 2 paragraph 4:Figures displaying the additional alternativ~s discussed should be provided in the statement. Page L-27 z paragraph 4:The discussion should recognize that the type and quality of habitat is usually a more important consideration than the actual inundate the Oshetna prov i de hi gh Loss of thi s - .... 23 acreage.Habitat is not an amorphous commodity,but quite variable in type and usage made of it by the species with which we are concerned.If,for example,an area being inundated is highly important for black bear denning, then the carrying capacity of a large surrounding area could be severely affected. Loss of the habitat would mean loss of the wildlife supported by the habitat. One should not assume adjacent habitat is capable of supporting 'ldisplaced" wildlife.The statement should also address the loss of preferred hunting opportunity. Page L-27,paragraph 8:Filling of the Watana reservoir would port ions of Deadman,Watana,Kos ina~Jay,and Goose Creeks and River (page E-3-86 of the license application).These streams quality Arctic grayling habitat supporting thousands of fish. aquatic habitat would adversely impact sport fishing. Page L-28,paragraph 2:The proposed access route could create severe adverse impacts to numerous Arctic grayling streams,beaver,caribou,and indirectly to wolves,brown bear,and fur bearers.By opening the route to the public,increased hunting and fishing pressure would be exerted upon diminished resources.This would lessen the quality of the experience,and could be considered a net recreational loss.It could also require the Alaska Boards of Game and Fish to limit seasons or bag limits,thereby decreasing their existing management options. The effect of the proposed access route on the guides dependent upon the upper Susitna River basin should be examined in the statement. -Page L-29,paragraph 2:Given the implications to fish and wildlife resource impacts,the decision on public access should be made prior to license issuance,and stipUlated within the license.The statement should examine alternatives of no public access,controlled public access,and full public access for both the FERC Staff's recommendation for construction access (see ~age 5-3,paragraph 5)and the applicant's proposed access route. Page L-36,paragraphS 2 and 3:Fulfillment of the public desire to see more hiking trails could be accomplished adjacent to existing roads such as the Denali,Richardson,Seward,Glenn,and Parks Highways.Construction of trails and facilities where public pressure exists would be desirable and would allow the development of a tecreation plan compatible with the FERC Staff recommenda- tion on access (see page 5-8,paragraph 5).This'alternative would avoid ' adverse impacts to fish and wildlife resources due to the proposed recreation plan.The statement should examine a recreation plan that incorporates the above concepts. \"""Page L-36,paragraph 4:Comparisons between alternatives should be based upon the types,quantities,and relative qualities of habitats to be affected and how evaluation species would be impacted.Total acreage comparisons are virtually meaningless.Impacts to the fish and wildlife resources should also be related to sport hunting and fishing. .. 24 Page L-38,paragraph 1:Elimination of high flows through Devil Canyon would probably lead to salmon expanding their range into the tributaries of this river reach.This potential added production should be assessed in regard to potential benefits to sport,commercial,and subsistence fisheries. Page L-40,paragraph 6:The description of the potential adverse impacts to recreation with the development of the Chakachamna site is inconsistent with the more accurate synopsis of the recreational resources of this area provided on page L-25,paragraphs 4 and 5.This discrepancy should be corrected in the statement. L-42,paragraph 8:Here,and in other references to the Susitna project,the inundation area is estimated to be about 37.000 acres.This should be corrected to indicate that the inundation area would be approximately 45,800 acres (see page 2-1,paragraph 3,and page 2-2,paragraph 4). Page L-42,paragraph 3:The agency recommendations considered reasonable should be incorporated into a mitigation plan endorsed by the FERC Staff.An explanation should be provided for those agency recommendations not included here. Appendix N.Socioeconomics Page N-ll,paragraph 7 through page N-12,paragraph 1:As recommended in the final section of this appendix,continuing and new studies are necessary to respond to the data gaps identified here (page N-75,Section N.4). Project impacts may necessitate changes in fish and wildlife harvest restric- tions in response to legislative protection of subsistence uses.Such changes may foreclose future management options of the Alaska Boards of Game and Fish and should be considered in mitigating project impacts. Community sharing has been documented in Tyonek area su~siiteBce studies and ~hol.lld be considered in analyzing subsistence harvests.- , Page N-12,paragraph 5 through page N-15,paragraph 5:The attraction of the project area to tourists and resultant importance of tourism in the area economy is largely due to area fish and wildlife resources.Thus,project impacts to those resources should also be addressed as project impacts on the tourism industry. Page N-12,paragraph 9 through page N-13,paragraph 2:Given the importance of hunting and fishing to the project area economy and the potential for the project to adversely impact the fish and wildlife resources supporting that hunting and fishing,the statement should include an analysis of trends in both consumptive and non-consumptive'fish and wildlife uses relative to historical population growth and settlement areas. Page N-30 z paragraph 4 through page N-37 z paragraph 8:We appreciate the provision of Quantitative socioeconomic information in discussing project -~---_.~-------------------------------------- .... - 25 alternatives.Such information allows a more informed basis for choosing among alternatives;similar data should be provided in other appendices. Page N-35 z paragraph 1:The development of a year-round road connecting the Selusa area,Tyonek,and Anchorage would appear probable with the alternative energy development scenarios described here.Impacts of that road to fish and wildlife,and to subsistence uses of those resources should be discussed in the statement. PageN-3e,paragraph 6:Projects that should be examined in making projections about construction worker settlements and other socioeconomic concerns are the nearly complete Terror Lake hydroelectric project on Kodiak Island and the Healy-to-Willow Intertie transmission corridor,which parallels transmission lines proposed for the Susitna project • Page N-38,paragraph 7 through page N-40,paragraph 6:We concur with use of both highland low growth scenarios in analyzing expected changes in area population expected with the project.This range of growth projections is necessary to plan reasonably for possible impacts and mitigation needs such as designing worker access,camps,and work.schedules to best minimize impacts to area resources.A comparison of the high and low alternatives with air trans- portation provided,allowing greater worker settlement in Anchorage and Fairbanks,versus allowing workers to settle closer to the project,would help show which alternative is preferable for minimizing impacts to area socio- economics,fish,wildlife,or other resources. Decisions on transportation plans,onsite camp features,work schedules,etc. should be made in the statement in order to determine project impacts and how transportation,camp,and other project features a need to be modified to better mitigate those impacts. Page N-47,paragraph 1:Estimates should be provided for the numbers of Alaska reSidents,both native and non-native,who depend on project area resources for at least some part of their food and other resource supplies. Page N-50:This page was not included in our copy. Page N-62 z paragraph 7:We disagree with the conclusion that construction and use of project access routes would have only a few minor socioeconomic impacts.Please refer to our previous comments on the potential for project impacts to negatively affect area residents·ability to obtain subsistence resources for cultural,nutritional,religious,and other socioeconomic factors,or to depend on guiding for their livelihood (page 4-56,paragraph 1). Presence of project access roads,particularly the proposed Denali Highway segment,would be the primary cause of those impacts.Management options for construction access and public access through project operation are potential mitigation means that should be fully analyzed in the statement. Page N-63 z paragraph 3:Surveys of Healy-to-Willow Intertie workers'would provide pertinent,current data applicable in determining worker settlement ____~rn __ - """ ·...·r 26 patterns,projecting socioeconomic impacts,and establishing necessary mi t i gat i.on. Page N-64,paragraphs 4 through 6:The statement should include an analysis of FERC Staff and resource agency recommendations to el iminate access from the Denali Highway.That alternative would significantly reduce impacts to existing subsistence and guiding activities,as well as better protect current patterns of other consumptive and non-consumptive fish and wildlife uses. Page N-64,paragraph 9 through Page "-72,paragraph 6:We have previously described how the statement inadequately quantifies fish and wildlife resources to be impacted by the non-Susitna generation alternatives (Appendices J and K).Information on subsistence,recreational,and commercial uses of those resources and potential impacts from non-Susitna generation alternatives is also lacking,and should also be incorporated into the statement. Page N-65,paragraphs 2 through 7,Page N-69,paragraph 5,and Page N-70, paragraph 7 through Page N-71,paragraph 2:The ADF&G has undertaken numerous studies of subsistence harvests and resource uses by the village of Tyonek Wh~ch document the importance of area fish and wildlife resources to Tyonek.-.Ongoing plans for Beluga coal development favor construction of an on-site construction camp/permanent village to minimize potential impacts to area lifestyles.Tyonek residents favor projects that would provide employment opportunities but 3not interfere with their ability to pursue subsistence resource uses.N-These subsistence concerns,alternatives for not providing worker housing in Tyonek,and alternatives for providing or not providing road access to Anchorage should be considered in discussing the range of development scenarios and level of impacts possible with non-Susitna generation alternatives near Tyonek. Page N-66,paragraph 3:The possibility of obtaining coal from Beluga area coal development should be discussed.The Diamond Shamrock corporation is pursuing coal development for export to Pacific Rim countries by 1990. Page N-73 ¥aragraph 4:Impacts to the subsistence,recreational,and commercia;ishery with development of the Chakachamna site should be cons i dered here. Page N-79,subparagraphs 1,2,4,6,7,8,9,10 and 13,and Page N-75, paragraph 1,subparagraphs 17 and 18:We particularly support these miti- gation recommendations,which will minimize impacts to fish and wildlife resources and subsistence use of those resources.Coordination among mitigation measures for these different resources should be clarified. Page N-75,paragraphs 3 and 4:We support speedy completion of all the applicant and Staff recommended studies suggested here.Results of these studies should be coordinated with mitigation planning for other area resources,e.g.,fish and wildlife resources,and their use. ,-, 27 FOOTNOTES -- - K-l Pitcher,Kenneth W.1984.Susitna Hydroelectric Project,Phase II,1983 Annual Report,Big Game Studies,Volume IV --Caribou.Alaska Department of Fish and Game.Submitted to the Alaska Power Authority. K-2 Tankersley,Nancy G.1984.Susitna Hydroelectric Project,Phase II, Final Report,Big Game Studies,Volume VIII --Dall Sheep.Alaska Department of Fish and Game.Submitted to the Alaska Power Authority. K-3 Selkregg,L.L.(ed.)1974.Alaska Regional Prof;les --Southcentral Region.Arctic Environmental Information and Data Center,Anchorage. 255 pp. K-4 Environmental Research and Technology,Inc.1984.Diamond Chuitna Project,Terrestrial Wildlife,Baseline Studies Report.Volume I -~ Text;Volume II --Figures.Prepared for Diamond Shamrock --Chuitna Coal Joint Vent~re,Anchorage,Alaska. K-S Ballard,Warren B.,Jackson S.Whitman,Nancy G.Tankersley,Lawrence D. Aumiller,and Pauline Hessing.1984.Susitna Hydroelectric Project,1983 Annual Report,Big Game Studies,Volume III.Moose --Upstream.Alaska Department of Fish and Game.Submitted to the Alaska Power Authority. K-6 i bi d. K-7 Miller,Sterling D.1984.Susitna Hydroelectric Project,Phase II. Second Annual Progress Rpport.Big Game Studies,Volume VI --Black Bear and Brown Bear.Alaska Department of Fish and Game.Submitted to the Alaska Power Authority. K-8 Whitman,Jackson S.and Warren B.Ballard.1984.Susitna Hydroelectric Project,Final Report,Big Game Studies,Volume VII --Wolverine.Alaska Department of Fish and Game.Submitted to the Alaska Power Authority. K-9 Tankersley,Nancy G.1984.Susitna Hydroelectric Project,Phase II, Final Report,Big Game Studies,Volume VIII --Dall Sheep.Alaska Department of Fish and Game.Submitted to the Alaska Power Authority. N-la Fall,James A.,Dan Foster,and Ronald T.Stanek.1983.The use of moose and other wild resources in the Tyonek and upper Yentna areas,a back- ground report.Alaska Department of Fish and Game,Division of Subsistence.Anchorage.44 pp. N-1b Foster,Dan.1982.The utilization of king salmon and the annual round of resource uses in Tyonek,Alaska.Alaska Department of.Fish and Game, Division of Subsistence.Anchorage.62 pp. N-2 ibid. N-3 Darbyshire and Associates.1981.Socioeconomics impact study of resource development in the Tyonek/Beluga coal area.Anchorage,Alaska. - - - ,-- ••I..... .. July 3,1984 Honorable Kenneth Plumb Secretary Federal Energy Regulatory Commission 825 N.Capital Street,N.W. Washington,D.C.20426 RE:FERC No.7114 ~ a 11/4f UNITED STATES DEPARTMENT OF COMMERCE Naclanal Dc_nlc and Acmaapherlc AdmlnlacraCian NationatNaZ'i.ns Fis1uJ'zti.S8 SBFrJWS P.O.Bo:1668 . RE eEl V E 0 Juneau,Alaska 99802 i-JUL 171984 RI~~AUTHORITY .JUL13 1984 PiIIsbulY.Madison·&.rut~_ ~.~ l""t·;- . ... Dear Mr.Plumb: The National Marine Fisher;es Service (NMFS)has reviewed the DElS 8405.22 - Susitna Hydroelectric Project (FERC No.7114)Alaska (Federal Energy Regulatory Comnission -Office of Power Regulation). In order to provide as timely response as possible,we are submitting the enclosed CORllller.ts to you directly in parallel with their transmittal to Department of Commerce for incorporation in the Department response.These comments represent the views of the Alaska Region of the NMFS.The final comments of the Department should reach you shortly. Sincerely, ;'~'~f?/~ t ~ir.ctor,Alaska Region ! I.r;.tf.:J.. /~•.i .- P- , _. - 2 1n sufficient detail to understand the effects of proposed alternatives,and discussion of the environmental consequences must include direct and indirect effects:of the proposal and alternatives to that proposal (See '40 CFR'. 1502.15;11502.16).The subject DEIS generally suffers from-Tnadequate or incomplete descriptions of the physical processes and biological resources of ·the project area.Similarly,post project conditions are rarely quantified. Efforts to predict the project1s effects on such important issues as down- stream temperatures,turbidity,ice conditions,fish populations,and ground- water have been inconclusive.Many of these issues are the subject of on-going study by the applicant,the Alaska Power Authority (APA).The Draft Statement accurately identifies these data.gaps and infonnatiQnal·.needs, often stating that certain impacts cannot be quantified at·this time. Clearly,these deficiencies prevent the requisite thorough analysis of the full scope of environmental impacts associated with the Susitna Project •.As will later be discussed,until an adequate EIS is developed addressing the needs identified in these comments,no project approval can occur.NEPA clearly requires that an agency consider the environmental impacts of a proposal before project authorization not afterwards (See CAd~v.Morton,527 F2d.786,794 (9 Cir.1975);Environmental "Defense Fund v.n rus,596 F2d. 848,853 (9 Cir.1979». Mitigative measures to avoid or minimize adverse impact were presented in the applicant's license application.The DE IS concludes that lithe long-tenn effectiveness of mitigation measures remain unclear.-We must concur with this assessment.Although we are aware of the applicantls continuing efforts to refine these conceptual mitigative measures,they remain unproven,untest- ed,and often based on inadequate data from physical models.Selection of a project release schedule which will minimize impact to fish species is a basic component of the mitigation plan,yet the OEIS does not present a. specific flow schedule which can be demonstrated effective.The OEIS must present an effective,implementable mitigation plan which could be incorpo- rate~into the license as specific conditions or stipulations (40 CFR 1502.16(h).The mitigative measures identified in this document do not constitute such a plan and we find the OEIS deficient in this respect. Regarding the Statement1s analysis of alternatives,we believe additional data must be presented to allow for an informed selection to be made.Many of the alternative hydroelectric sites would be,in themselves,major pro- jects involving significant resources and associated impacts.The infonna- tion presented in the DEIS does not permit the selection of one project over another based on biological considerations.The DEIS should present each alternative's impact in comparative form so that a clear basis for choice is presented to the decision maker and the public (40 CFR §lS02.14).Substan- tial treatment must be given to each alternative discussing their potential impacts (40 CFR 1502.14(b».We are,therefore.reluctant to concur with the reconmended alternative until additional data are presented in comparative form to allow a clear basis for choice.Given the need for power projections and oil price scenario presented in Chapter 1,we concur with the staff conclusion that.should any hydroelectric development occur in the Susitna Basin,it should entail staged licensing and construction,beginning with the Watana I dam,to be followed by a modified High Devil Canyon,Devil Canyon, or a re-regulation dam/tunnel. ,r,;;.... '\ ...., GO., ;"~o'l-. ..,.. 3 Specific Comments XXV ara.3,Water ualit and uantit The 'statement that nitrogen super- saturatlDn wou occur at tlmes or a most every year of operation seems to conflict with the discussion on gas supersaturation presented on page 4-18. We assume that the proposed mitigative feature (cone valves)would reduce the annual occurrence of supersaturation. 2-21.,Miti ation Measures Pro osed b the licant The discussion of mitigation does not present an imp ementab e p an to avoid or minimize resource loss (see.General Corrments).Where available,detailed,diagrams and plans for the various mitigative features should be given.The.OElS indi- cates that much of these features are unlikely to achieve the desired effect or are subject to the results of on-going study.We do not believe this provides for full consideration of the fishery resources within the Susitna River System,nor does it present an acceptable approach towards the goal of mitigating project impacts..0 rf..~w..r-c-..(.\to~,,-t~'t ~0 i?S~c.~W t.oJ,ii-~S~..+L.....2-23,para.6 Although the Watana ~flow Tor the October to April ,J period would be approximately 5,000 cfs,the potential exists for signif-~J"~... icantly higher flows.On page 4-7 the maximum winter flow for Watana operation is given as 14,700,five times the maximum historical monthly flow for December,January,or February.Should ice develop,the resultant staging at these flows would create water elevations sufficient to inundate the sloughs..We question whether this impact could realistically be con- trolled by heightening benns..Before this can be detennined,additional information must be presented on post-projeet ice formation,maximum winter powerhouse releases,and elevation (survey)data for the slough berms and the barrier islands separating slough and mainstem waters. The eight sloughs whose streambeds are to be structurally modified should be identified,and working drawings presented for each.A generic or conceptual diagram is not sufficient for analysis,as the sloughs often vary in certain respects such as upwelling,substrate,length,gradient,water qual-ity,etc. page 3-17,Fish Communities This discussion should incorporate the most recent data available from the Alaska Department of Fish and Game study efforts.Much of the discussion presented in this section is too general to provide insight into the habitat relationships associated with the important fish species of the system.For instance,recent work indicates that over- Wintering habitat is probably a major limiting factor for fish and that resident and juvenile species select ground water or other thennally affected areas to overwinter.Chum salmon have been shown to remain within the system for a period of time (up to three months)after emergence.Such life history detail is necessary for a thorough understanding of the potential project impacts on the fishery resource. page 3-17,para.9 The statement that tributaries and sloughs have the clearest water and thus the largest numbers of rearing juveniles should be qualified by identifying wh;ch species are being discussed and during which season.Very little data are available concerning overwintering within the mainstem,yet considerable use could be inferred from infonnation on the fall outmigrations from tributaries. ---------'----------------- 4 ----...._.._,.,.~.._._..:.:...,.:.,.-->_._,.~.-.-.•~~.~---..-..'.-.....~.'-_•.-...._-_.:_.:..._:,",.~-~--_.- ..- 1""" _page 3-24,para.2 Recen~studie~have not s~own a wel~defined correlation lHftween temperature and d1stribut1on of juven,le salmon1ds.rhe mafnstem'and mainstem-influenced areas appear to be particularly significant to rearing chinook salmon.Thus,although principally a tributary spawner,this species may be subject to impacts of altered mainstem conditions. 3-25,para.3 While the numbers of salmon migrating past Talkeetna Station are generally less than 25 percent of those passing Sunshine,we suspect that a high percentage of the sport,catch above Sunshine occurs within the upper Susitna.Sport fishing sites along the lower Susitna are heavily utilizedi pressure along the upper river is currently low but can be expected to increase.The statement should discuss the importance and potential of the Talkeetna to Devil Canyon reach to the sport fishery. page 4-7,para.3 The issue of in-stream flow releases has been a major concern to our agency in addressing the impact and mitigative measures of the Susitna Project.As noted in the DEIS,the APAls proposed release schedule (Case C)would result in reduced access to sloughs by adult salmon.We have advocated a quantitative approach to the flow issue in which habitat vs.flow relationships are derived.This 1nfonnation is needed before an infonned decision could be made on project flows. Selection of a project flow regime will requi·re a better assessment of power needs and costs.The DEIS suggests that present demand projections prepared by the appl icant may be overestimated (Section 1)and that the reservoir operations model used by the applicant does not allow for the most efficient allocation of flows for both power generation and fishery needs (p.5-10). Accordingly,we believe the presented release schedule is neither economi- cally or biologically supportable.While the DElS attempts to accommodate fishery'needs by providing for a high flow release for adult access to sloughs,this recommendation alone will not mitigate flow related impacts. Maximum winter flows may be necessary to avoid slough overtopping and result- ant impacts to developing eggs/fry and overwintering fish.Such limitations are not presented.The DEIS notes that no evidence has yet been provided to support the assumption that the 6,000 cfs minimum flows for May,June,or July have been shown to protect salmon.Clearly,adoption of Case C flow is not supported,nor does the OElS present a flow regime which fully provides for the fishery resources of the Susitna System. ~age 4-13 9 ¥ara.4 Extrapolation of the information gained on Rabideaux lough to a 1 sloughs below Talkeetna may not be appropriate.The biological values associated with this slough should be presented.What additional sloughs below Talkeetna have been studied? pa~e 4-13,para.6 The DElS should present the,species and numbers of fish ut,liz;ng tributaries where fish passage problems are expected.For those tributaries whose entrances are expected to cut down to the new water levels, how long will this process take?What mitigative measures are proposed? page 4-13,para.3 The existing modeling efforts which predict post-project icing are being revised.At this time there is no confident prediction on the existence or location of a post-project ice front. .~. .. ~ .~ 5 page 4-17,~ara.4-·The statement that a four-fold increase in winter sus- pended soli s levels falls within the range of natural variation at Gold" Creek during winter should be referenced.Thb would seem to-conflict with the statement that wintertime turbidity levels are at or near zero (page 3-10,para.8).The model used by the applicant did not consider many important factors such as reservoir ice formation,effect of suspended sediments on density layering,or reservoir mixing.Therefore,the suspended sediment values presented may not be overestimates,as suggested on page 4-16,para.5. This section should discuss the relationship between suspended sediments and turbidity within the Susitna,and their biological significance. page 4-21,Temperature The temperature analysis indicates that only the most preliminary estimates of downstream temperatures can be made at this time (e.g.,winter temperatures near 4°C or less,summer temperatures ranging from 5°C to 10°C).In view of the importance of temperatures to the fishery resources within the Susitna River System,this analysis is not acceptable for purposes of impact identification or mitigation planning. page 4-23,Sloughs This section should discuss existing and post-project ice staging and the resultant inundation of the sloughs with cooler mainstem waters. page 4-23,Ice Processes Ice formation and break-up represent important physical factors affecting the fish species within the Susitna and their habitat.It is apparent that this important process is not yet sufficiently understood to allow for full project impact to be assessed.The reservoir model,which drives the downstream temperature and ice models,has been questioned.Projections for the location of a post project ice front have ranged from just below Devil Canyon to Cook Inlet.The applicant has stated that ice is not expected to fOnD on Devil Canyon Reservoir,in contrast with the DEIS projection that both reservoirs would have similar ice formation and decay.Again,no assessment of project related impact,or recommendations for mitigation,can be made from the infonnation presented. ]age4-25,Groundwater The paragraph seems to recognize a distinction between groundwater and mainstem infiltration.The sources of groundwater are likely to include the mainstem,deep and shallow aquifers,and lateral- runoff from snow melt and precipitation.A reduction in mainstem infiltra- tion may reduce the amount of upwelling within sloughs.Slough groundwater temperatures t however,may be relatively independent of the mainstem.The importance of groundwater to salmon spawning habitat has been discussed,and we believe this subject deserves further attention.How would flow reduction in the mainstem affect upwelling areas in sloughs?Which systems drive the groundwater within the major spawning sloughs BA,9 t 11,and 21? page 4-25,para.2 The anticipated reductions in summertime turbidity should be quantified in this section.A large decrease in turbidity may still result in turbidity levels;too high to allow suffi-eient light penetration for grov:th and development of aquatic plants.What woul d'be the post-project turbidity during the ice-free season? ·.'-."~. ..-"-- .- - /," \~ 6 ~e 4-27,para.2 ",The additional spawning and rearing habitat made ~vail­ ibTe with a Watana alone.-Watana I-High Devi 1 Canyon,and Watana I .' " " re-regu1ation dam should be quantified.Would these alternatives present a significant enhancement opportunity within the basin? page 4-32,para.9 The assessment is made that salmon migrating toward the upper Susitna may avoid this reach and migrate into the'warmer Talkeetna River.Provided that filling temperatures are within the range of tolerance for these species,it is unlikely that these temperature differences would offset the chemical attraction of their natal waters.Additional displace- ment into the Tal keetna may resu1 t in overcrowdi,ng on spawning ""grounds, superimposition of redds,and increased competition among rearing juveniles. Therefore,any production lost on the upper Susitna may not be offset by increased use of the Talkeetna. ¥a ge 5-8,tara.5 We concur with staff's recorrmendation of an access route rom Gold reek only.The DEIS should make clear that this would be a rail only access,and may consider further advantages to an all-rail access system (e.g.,reduced staging areas,increased access control). ~age 5-9,para.8 Two flows are presented for the 3 day access release; 0,000 and 23,000 cfs.Which is correct? page 5-12,Pera.5 The staffs'concurrence with the proposed recreation plan seems inconslstent with the recommendation against access from the Denali Highway.The bulk of this plan is associated with this northerly route and, without its adoption,would provide relatively few recreational opportuni- ties. page 5-13,~ara.3 We support an inter-agency monitoring effort for all mitigativeeatures.We are continuing to discuss this possibility with the applicant. page 5-15,para.2 We concur with the staff recommendations for further aquatic stUdy.The applicant's FY85 study efforts,if funded,should effect- ively meet these recommendations and will significantly advance our under- standing of the fishery. page H-7,para.4 The discussion of Habitat Types should characterize each of the seven identified in this paragraph.. page H-34,Table H.3-1 The overtopping flows presented are higher than recent projections from the applicant.These are:slough SA-2a,OOO;slaugh 9-22,000;slouSh 21-24,700. ~age H-37,eara.2 This analysis uses a figure of 12,500 cfs as the cut-off or unrestrlcted access for 50 percent of the sloughs.Post project flows (minimum flow,Case C)will be 12,000 cfs~What is the significance of this difference?Slough SA,for example,has unrestricted access at 12,500 cfs. What would be the magnitud~of impact resulting from ~2,000 cfs flows? -----------~-,--------_._--,------------------ .:.="~-~..~~.'-.....,- ----",~-------""":_,--.-:':':'.----',._,.--..'"...';-'-'..-.'~.,......'..'....~-.'.-':"0"';..-:.~' _..---.:......':.-'-'.. ---.~ ...... - C",.,,"'.-'.,....., I'''' ,..".,. 7 Sunwnary In our November 7,1983,comments to the FERC regarding the Susitna license Application,the NMFS identified several data gaps,including accurate description of various post-project physical conditions (e.g.,river and reservoir thermal structure,ice conditions,and turbidity)and a failure to provide an adequate fisheries mitigation plan.In that correspondence,we requested that these concerns and deficiencies be specifically addressed in the DEIS,and noted llAt this time it does not appear that infonnation pre- sented within the license application would support preparation af a OEIS fully in compliance with the National Environmental Policy Act.",.Our review of the OEIS found no significant improvement beyond the license application. Many important impacts cannot be quantified at this time in light of existing data.Questions remain concerning the accuracy of many of the applicant1s modeling efforts,including such critical areas as oil price projections, suspended sediment levels,thennal structure within the reservoirs,down- stream temperatures,and ice fonnation. The CEQ Rules and Regulations require an agency to identify where data gaps exist (40CFR 1502.22).A worst case analysis is to be presented wherever A) the information relevant to adverse impacts is essential to a reasoned choice among alternatives and the overall costs of obtaining the information are exorbitant,or B}the infonnation relevant to adverse impact is important to the decision and the means to obtain it are not known.id.Neither A nor B above apply to the Susitna project.Many of these infonnational needs are not only affordable and obtainable but have in fact been undertaken or completed by the APA.The DElS clearly suffers from omission of thisneces- sar,y data and must be revised to cure this deficiency. As FERC is aware,in general,prior to the issuance of a license authorizing a projects'construction,fish and wildlife inlpacts must be addressed and minimized.Specifically,an EIS must be prepared which provides full consid- eration of the fishery resources which would be affe:ted by the project (See Confederated Tribes and Bands v.FERC,No.82-7561 (9 Cir.June 7,1984);--- Environmental Defense Fund v.Andrus,596 F2d 848,853 (9 Cir.1979);Cady v. MOrton,527 F2d 786,794 (9 tiro 1975».Apart from the requirements of NEPA,this stricture briefly stems from several statutory precepts.The FPA, 16 USC §802(a)requires FERC to assess whether the proposed project will adequately preserve anadromous fish prior to the issuance of a license (See Udall v.FPC,387 US 428,450 (1967».Moreover Section 1 of FWCA,16 uSC- §661(a)requires that the FERC,before authorizing the damming of any stream to first consult with the NMFS with a view toward conservation of the re- source (See Udall v.FPC,387 US at 444;Zabel v.Tabb,430 F2d 199,209 (5 eire 197QT;Cert den.,401 US 910). Recognizing the importance of quantifiable descriptions of the project's physical and biological impacts,we believe that the DElS should be re- written or supplemented with the requested information.Without such an action the public process would suffer,as the DElS would not allow for an informed decision(s)to be II1ade regarding biologica1 efJects,selection of preferred alternatives,or mitigative measures.As stated,these actions must be 'taken in order to provide full consideration of fishery resources as required under the above mentioned statutes.Until the OElS is revised to cure the deficiencies noted in these comments,we must caution FERC that orgject aythQrizat;Qn should not continue. .JULI3 1984 .JUL 171984 RIC!m~AUTHORITY ......, (.",./ a ?111f UNITED STATES DEPARTMENT OF COMMERCE N.,lon.1 Oc..nic .nd Atmosph.ric Adminis'r.'iDn Nati.ont:z1.Mt:zrins Pishsris•.Ss",ic. P.o.Bo:::lSSS RECEIVED Juneau,Alaska:99802 Pillsbury,Madisoo·&.Sutra !...' :•.:.B July 3,1984 Honorable Kenneth Plumb Secretary Federal Energy Regulatory Commission 825 N.Capital Street,N.W. Washington,D.C.20426 RE:FERC No.7114 c:~Dear Mr.Plumb: ("'r':•. .. The National Marine Fisheries Service (NMFS)has reviewed the DEIS 8405.22 - Susitna Hydroelectric Project (FERC No.7114)Alaska (Federal Energy Regulatory Commission -Office of Power Regulation). In order to provide as timely response as possible,we are submitting the enclosed COmnlE:t.ts to you directly in parallel with their transmittal to Department of Corrmerce for incorporation in the Department response.These comments represent the views of the Ala~ka Region of the NMFS.The final comments of the Department should reach you shortly. Sincerely, .- L ~~:P-.:bZ--4-~t ~ir.ctor,Alaska Region ! - .- - ·.:..~"...-•__~•.·~._,..••E'.-,:l.:;..·""'·'::"p",__'_'-~~.,:·:"__:':"_.'.1".:.;:,,,=,0 __:-_..,. ~.~,~..,-~".-:... ,;,--:p--'1 "'I .'-..waabiDl=n 12th •IDdependence,SW ..~~,United States Forest Office P.o.Be.2417 . .'l Department of Service 'FILED Waabington,DC 20013 r~_A_g_riC_u_ltu_r_e .....;t);..;.F..;.F...;,;'C;:.::::....::Of~Tl.IoH...F'_..llS:l.f.i.r.AR.;.;.r"...TA~::"..;.'-:--__ '", 198.JUN 28 AM 9=33 FCI:E:RAL Elif:RGY REGUlATORY C011MlSSIOH I'lecov 10 Oale 2770 JUN 2 C 1984 r L Mr.Kenneth F.Plumb Secretary Federal Energy Regulatory COlllJlission 825 North capitol Street,HE Washington,DC 20426 Dear Mr.Plumb: RE<;E.~VED JUL131S84 Pillsbury.Madison &Sutro: Thank you for providing us the opportunity to review and cCDlent on the SUaitna Hydropower Project No.7114,Draft Bhvironaental Iapact StateJIent (DBIS)• The DBIS is very well written and presents a very comprehensive analysis of the potential t.pacts.Bnclosed are acme additional ee-ments for your consideration. - llIc:::DRJ)D.BOLL Direc1:Or of Lands Enclosure c-", U3,<::0--~--,~..",J,.(.-:,-~r--.~n~o_, ;,.,.,Iz_···!'..::=:::..- ."c;;:-......~ ~'.- ,,~'l-" C'+:- ,. 'J ·...:.-.~-~-:._--~. - p.o Bo.2880 WUf'lington.D.C. 20013 5ullject: .....To: BAP -Review of Draft Environmental Impact Statement (EIs)for Susitna Hydroelectric Project.Alaska Ed Nelson.Director of Basin and Area Planning,sCs e.t.: File co...: June 7,1984 r"c.","~~ The subject document has been reviewed in response to your Hay 2S.1984. request.The docWHnt pTesents a very comprehensive analysis of the effects of the construction and operation of the proposed susitna Hydroelectric Project.Significant environmental consequences would occur as a result of the proposed action and include: (1)large population increases in the project area (2)loss of fish and wildlife habitat (3)nitrogen supersaturation of stream water (4)selective clearing of 56,000 acres of vegetation (5)construction of 2 dams with a combined storage of over 10 million acres-feet. ...... - We can only caution that these and effects be mitigated to the extent pro~ed with the proj~ct. ().4 A.r<':I_,.~./)-;I'~-l~P g(,1 I;'-3" CARY A.MAllCHEIM National Envir~~-·~~~'r~~~~~~!!~r other significant environmental possibl~if the decision is made to ,'-'/4-41'-4--J /'- O~ "·f ..,......,~,'....:.~..:.._....._..--,...._7._··.:..·.:.::..:.-.....•._.__.~,.•_. ..G:.·A~United StatesUi'J Depertment of /0 :~Agriculture File Code:150-7-6-5 Subjec:t:-BASIN AREA PLNG -OAR -Application for Susitna Hydropower.Project,Alaska Date:JUN 15 1984 To: Richard D.Hull,Director of Lands,Forest Service, Washington,D.C. -F'" We bave reviewed the Susitna Hydropower Project Draft Environmental Impact Statement (DElS).The llaska Power Authority proposes to construct a 1.6 gigawatt capacity hydroelectric project on the Susitua River about 140 miles north-northeast of Anchorage.The proposed action would include an 885-foot-high earth-fill dam (Watana)that would create a 38,OOO-acre reservoir with 9 million acre-feet of storage;and a thin arch,646-foot-high concrete dam (Devil Canyon)that would create a reservoir of 7,800 acres and with 1 million acre-feet storage capacity. The proposed project would require 64,100 acres of land (table F-12).Most of the land is owned by the U.S.Government and managed by the Bureau of Land Management (page F-6).There is no large-scale farming activity and no prime or unique farmlands with1n the project boundary. The DElS is very well written.and presents a very com.prehensive analysis of the effects of the proposed construction and operation of the project. Dr.Gary Margheim,our Envircmmental Coordinator,bas prOVided us with a memorandum of comments on the DElS.His memorandum is enclosed. The proposed project would bave little impact on agricultural activity.We have no objection to the plan. -5'~d7~,&idj L !EDGAR H.NELSON~~Director,Basin and Area Planning Division Enclosure l ".l'"~...O!-..,~"•.-~ ~UN19 '984 Oi~!~"-V_0' f "o.•:.~'._. ~-._----. I . j ~... •\'.0 ••°0 _O~ 1 0' ---..........::==================================::1j=.::::::::-:::-::-._~-~~:.=---=.~=-~__._o--=.;::':J=-'__ - - Envf rormentll Resourcls ..:....~.--.- I .. /-I~"'",~D."ARTMIENT Ofl"THE ARMY NOM..."ACt"C OIV'8tOH.c:aR"O~.NGt........p.o.lOX :.nI IIIOML.AND,OAEQCIN trial July 25.1984 RECE1VED AUG 2 1984 PJIJabu".Ab£1i.satJ J Ju.t:o - - - Director Division of Environmenta'Analysis Federal £n.~y Regulatory Commission Roan 308-RB 825 North CApitol Street HE Wlshington.D.C.20428 DI.r Sir: We have reviewed the Draft Env1ronmenta1 Impact Statement for the Susitn.Hydroelectric Project.FERC No.7114.Alaska.In regard to the U.S.Army Corps of Engineers areas of responsibilities for flood control, n,vigation.and hydropower,we haye no conmants. The draft document indicates that the Corps of Engineers is a cDO~erlt1n9 agency under National Environmental Policy Act criteria. We wish to adVise that we are not I cooperating agency. Our review of the draft statement.taking 1ntQ consideration our Sec.404,Clean Water Act regulatory responsibilities.indicates that the statement d~es not adequately address the impacts of the pro~osed action on wetlands in the project area.The treatment of baSeline wetlands data and project impacts is too b~oad and general for an adequate Sec.404 1mp4ct assessment. Sine,rely. ,At']l;:;) D.E.Olson Chief,P1ann1ng Division ... " -- - - -•Department of Energy Alaska Power Administration P.O.Box 50 Juneau,Alaska 99802 ((,.' R .EpEJ.Y-.t:;,Q jUL 91984 'AlAS~}OWER AUJHORlTY July 6,1984 *.J.Haft Iabl1uloa 'Meal IuqJ Iaplacory CD i ••1oD 825 ••Capitol St••JIB Vu1:d.llltaa,D.C..20426 Dear Ifr'.lGbiPacms RECEIVED JUt _1984 ALASKA POWER AUTHORITY -: ~~r .... ,~ .;I'-.l ........ !Jaak ,..f_t:!ae opporC1l:A1C7 to w _t _Che Uaft ID faw tba s..'JbIa JlyUoelectd.c h'oj eu.Alaka (:rBIC ]fo.7114).. 0.CJI aCa an _~_..··~...ol,""'t'''.II:t -LoIMl I ;~1 Priee .....,tUua 'tw 0tIa8'a,uoeleecn.c jitallad . JDC'.10acl forecuu 11M the __CGIIPUtar WHIel...tho..of the appl1caac.J'B3C'.-....zo.ar.lonr becrMH of da8 1-.oU pJ:'1ce .....dou.'the d.UfU"8DC"&1:.mall -1ft _"'Pl.rJaC'.a.tfeaC•• of __'"h411IU_U-1D.the ,...,.2000 rap Ina 92 to ta t of tba APA ntuace.....~1a 'AOC a 81...1«_.,41ff b tan8 of f~cuc &=-U)'. We haft IIOCeG that tba foncut ".1.-'el.opM fK Iwd.tIIa G9C the ,~fOG',.u.or -haY.&OII8ue_t1y u-te4 a1Iort-tenl crawch. POZ'.....u.the DBIS c:-.um.c1a:ne UlllNte%-pa••ted .'sMc.for .....,ncpd.nMata izl the 1983 "h...,.r'.!b._an 2803 QIh (DA nI eue).2802 (JDC -..It,.oil prlce .-uiD)...2814 (J'II1: 1d&h oil pri.ee ....n.o).Mbial UI a.-for 1983 fo~tbe Suicu urut area ...3025 GWb,or G.abC ,.....t 1M DBII . 1Jau_J 11 11114 _ther 1Il the lace.pan of ~tu Ulp"bolA tHau.,of t1le 4Uf.....Baed OD 1983 _bIal _.the "..1,.ram... caM a.11on for •3J .,.,fNIId Invth of ....,.~~f.tbe Nl ...of tile 1980'.;the JIIt:.....a1.low for ~I CD.1.42.!H ••d.oM1laeqy PoUay naa ..uu s.n ..•_.....1 ftpn for tlaa ped.o4.Aamal!aU__far &he lultBa .....ana lIM Mea 5.' ,.eat:,_7M1'"".the 1u&tbne ,...•• fta •.a.ha ..nat ~ly thIa -_...baD 1IGI'tiw Ita_••uoaa alii ar-..e •••".-.,1:s.c...1a.u tte4 f 81.·.....,. ....t snwtb .....dau...c IBIC t1lMa fo .. .....,_Qa riIIk 1:ba&eM fonuau M7 "..laIf. are - - fF',.,'. \21- .-. '- ( 2 Fuel Price Assumptions Alaska Power Administration does not claim expertise in this area. However,it is obvious that !'ERe's ••sumptions of future fuel prices much lover than those from other sources.The oil price assumption rece1vaa the DIOst attention in this DEIS because of the reJ.atio11Ship :1n the load forecast models. It 18 noted that the applicant's 011 price assumptions are compatible with the SCenario B projections of DOE's National Energy Policy Plan, while JERC's asaumpt10ns fall well below the low range assumptions of the plan. We suggest that lERC should be in a position of accepting econODlic a.8UIIIPt1oua by applicant.which an consistent with the National Energy Policy Plan. Other Hydroelectric Alternatives PERC wuest.a aeries of maller hydroelectric alternatives -namely .robDson,Browue,!Cestna,Snow,and Chakachamna --may be more attractive and more acODOlDical than development of the Susitna Project.These five projects have a total estimated firm.energy capabUity approximately eq,ual to the Watana Project. In our opinion,four of the five FERC sites -.rohnson,Browne,ICeetna, and Snow -should not receive further cons1.deration as possible alternatives to Su.1tna by reasoD of higher costs aDd serious environmental problems. By way of background,our office bas been involved in iuvestigad.oDs of Alaalum hydroeleetr1c resources since 1948,first as the Alaskan program of the Bureau of Reclamation aDd since 1967 as the Alaska Power Administration. ',l'he Browne,K.eetua,Johnson,and Snow aites were identified in USBR 1J:rventonea completecl by the mid-1960's.The inventory work consisted of rough hydrology,geology,engineering,and east studies to determ1.ne wbich of the potential projects were sufficiently attractive to warrant DlOre decaUed study. Sub_queut work on the four sites,also of iuventory grade,appears in the Suaitua 1!'eas1b:Ll1ty studies by ACRES,as reported in a somewhat aod,1f1ed form,in the 1!'ERC DInS. The available data show the Johnaon _Jot.to be a particularly poor choice.The site 18 located.on the Tanana River,the largest tributary of the Yukon 1l:1ver.Development would require a massive dam with struetural heiaht of ewer 200 feet and crest length of about 6400 feet • 'l'haUSn atv.d1..rai•••significant queat:iaDs about fOUGCia~au:1tabUity- surface aeology auaaeat8 a deep valley fill of permeable,1IDconeoUdatad sedimeDts. _0._._.~.~..,",_>',~_••~-o,.:_....""__~..-.:..~".~..':..": ;~-=--~-~.---.-"-?'--.:....~......"- -- • r' .- ( , pmf<! ..... Co, . .....(.,~ 3 The Johnson Reservoir would be huge --about 2~times as large as Watana --and would impact areas with much greater fish and wildlife values than the Watana site.The Johnson site would require relocation of about 50 l:lliles of the Alaska Highway.and at least one small community. We note that !'ERC shows a developmen.t cost of $1500!kw for Johnson,and suggest that figure is seriously underestimated.Indexing of USBR data gives a 1982 construction.cost in excess of $5000 per kilowatt. The Browne site would require a large,main-stream dam on the Nenana ll1ver and relocation of significant portions of the Alaska Railroad and Parkes H1ghway.Keetna would require a large dam in the heart of Talkeetna Mountains.The dam,its transmission lines.and access roads would involve major intrusion into areas which are now essentially undisturbed.M indicated in the DEIS,Browne,Keetna,and Snow are all. very high cost projects. ChakacbamDa has received more attention than the other four sites recommeuded by FERC,·1nc:J.uding recent studies by the Alaska Power Authority. The available data supports a finding that Chakachamrt.a is a potentially excellent project,but does not support a finding that it is more attractive than Susitna. It is questionable whether any of the projects suggested by PERC could be bought on-line by 1993,since virtually no detailed data is available for them.It is certain that Johnson could not be developed that quickly as assumed by FERC. The transmission system requirpd for development of the five hydro sites appears underestimated.FERC staff assumed that the new projects would be tied into the new Anchorage/Fairbanks inter tie or tied into the nearest transmiss:1on line.Apparently,there were no rough systems studies made.In most eases,the projects would be tied into fully loaded or II s hakey'"systems,therefore.major new trausmission systems would be required to distribute the power to load centers. In our opinion.the total costs for the five hydro projects are underestimated by at least $1.0 billion.This is based on significant underestimate of the .Johnson Project (and possibly the Snow Project)and the need for major new transmission facUities.When these costs are added to the PERC thermal/hydro scenario,it becomes questionable whether this alternative is a true alternative to Susitna.The many unknowns about the five hydro projects increase the probability of further.cost increase. W.belieYe the envir011llleUtal costs aS80c:f.ated with the FERC hydro alternatives substantal1y exceed those associated with full development of the Sus1.tna hydro resources.and that no additional study is necessary to establish that fact. .,-~~._.,•..,-'...._..'.-.~.-...,-.~.~.•:,"-:"..--. 1Il... Conclusion ( ".---:,. The applicant proposes to finance and develop the upper Suaitna hydroelectric project,having made intensive investigations of Susitna as proposed and of many alternatives,and having noted clearly that,at least for the short run,alternative costs for ther=al power would be less expensive. The State position generally reflects the findings that,over the long run,this excellent hydroelectric project will be of great and lasting benefit to the people of Alaska,and that the environmental costs are acceptable. PERC staff finds that thermal alternativea and five smaller hydroelectric . projects--w1th firm.energy capability roughly equal to the W'atana dam as proposed by the State -should result in lower power costs than would Susitna.That finding is tTanslated into •recommendation that the State pursus a hydro-thermal program iDYOlving those five projects, coal,and natural gas,instead of Suaitna. Alaska Power Administration bel.1eves lE1tC staff has underestimated the teehnic:al diffieulties of developing the five smaller hydro sites and underestimated their economic and euviroDmental costs.This is particularly true for the J'ohnson site which would require a large,mainstream dam on the Tanana R1ver (largest tributary of the Yukon)and reservoir area 2 1/2 times that for Watana. We suspect that,by the time nRC fina1ues the environmental statement, four of the five non-SusitD&hydro alternatives will be scrapped (J'ohnson, Browne,Keetna,and Snow). There have been extensive studies on environmental implications of the Susitna deve.lopment.Adver••impacts are remarkably minor for such an important l1ew energy source.Environmental costs are not of a magn.1tude to warreut denial of license. The State wishes to make a major investment in its renewable energy resources for power production inatead of pursuing natural gas and eoa! alternatives.The State should be pumittad to do so. Again,we appreciate the oppoTtunity to comment. Sincerely, Robert J'.Cross Adm:i nistrator cc:Alaska Power Authority - •"'(f.'.-..'....~,, U.S.EN V I RON MEN TAL PRO TEe T ION AGE N CY REGION X 1200 SIXTH AVENue seATTLE,WASHINGTON 98101 / \ !"'" lEPLY TO MIS 443 ATTN Of: July 23,1984 Mr.Kenneth F.Plumb,Secretary Federal Energy Regulatory Commission 825 North Capitol Street N.W. Washington,D.C.20426 RE:Susitna Hydroelectric Project Draft EIS FERC No.7114 Dear Mr.Plumb: The Environmental ~rotection Agency (EPA)has completed its review of the Draft Environmental Impact Statement (Draft EIS)for the Susitna Hydroelectric Project.This Draft EIS was prepared in connection with an application for license from the Alaska Power Authority (APA)to construct and operate the proposed project.The project is located on the Susitna River about 140 miles north-northeast of Anchorage.The APA proposes to construct two dams (Watana and Devil Canyon)with reservoirs inundating 38,000 and 7,BOO acres,respectively,and powerhouses with an installed. capacity of 1,620 megawatts to provide electric power to most of the State of Alaska (Rail belt area). The Draft EIS evaluated several alternatives to the APA proposed project. Among them were hydroelectric development in several sites including the Susitna River Basin,coal "and natural gas generation,combinations of thermal and hydroelectric generation,and no-action.The Draft EIS recommendation (FERC staff recommendation)is three-tiered and ranked in order of preference.First,the Draft EIS concludes that a mixed thermal-based generation scenario,with selected non-Susitna hydropower projects added as needed,is the most effective approach to meeting the proj ected generati on requi rements.The next preference is hydroel ectri c development on theSusitna River and licensed construction in stages with the first stage being Watana I.This is a smaller version of the Watana Dam proposed by APA.It has an installed capacity of 900 megawatts and inundates 28,000 acres.The last preference is the Susitna Hydroelectric Project as proposed by APA.but with an increase in minimum flow releases during the salmon spawning season. The DE IS takes a commendable approach to structuring the decisions before the Commission.The decision is.in one sense,a system level choice; that is,what type of electrical power supply system would best meet the affected region1s needs over the long term.It is also an individual ---~-_._----~-_.------------------ . ..-.: .....,.P- .~ ....~'-~'~.'~..\.'. ..2 - -.,',~.:...',.'...........~.~,-'.'.~.._~..-::...'..-.--:' 2. project licensing choice in that FERC must decide what hydroelectric projects,if any,it should license as a part of the regional power supply system.With respect the coa1 ..fired power plants which would be part of mixed hydro-thennalsystems,the analysis must also detennine,at a screening level,whether the suggested plants would be licensable under applicable statutes such as the Clean Water Act and the Clean Air Act. Adequacy of the EIS: The Draft EIS provides a very unbalanced analysis of the alternative systems and the individual power plants included in them.Although it provides a relatively thorough evaluation of the impacts of the Susitna project,it gives only superficial treatment to other potential hydroelectric projects.Similarly,it ignores several potentially significant impacts related to the use of coa1 ..f1red power plants.The impacts reqUiring further analysis include,inter !!!!: 1.Fugitive dust emissions from increased coal mining at the Usibelli Mine and new mining at the Beluga coal fields and the effects of these emissions on the Denali National Park [A Class I area under the Clean Air Act's Prevention of Significant Deterioration (PSD)program]. Water quality impacts of coal mining at the sites noted above. 3.Noise impacts from expansion of the Usibe11i Mine on Denali National Park. 4.The impacts of bottom ash,fly ash,and scrubber sludge disposal from coal-fired power plants. The evaluation of the Susitna project also needs to be expanded to fully address some of the issues which it raises.For example,the analysis of water quality impacts indicates that the State water quality standard for temperature would be violated and that the standard for turbidity may be -violated by the project.Further analysis is necessary to: 1.Confirm the severity and duration of the potential standards violations. 2.Develop mitigation measures to reduce the magnitude and duration of the expected water quality changes. Finally,the economic analysis requires substantial reworking in order to provide an objective comparison of the alternatives. Environmental Impacts of the Alternatives: ~The DEIS indicates that each of the alternatives could result in significant environmental degradation.In addition to the water quality ,problems,noted above,the Susitna project could have serious adverse ".."-.;~,~,,~-."~,-.--~..:.--""---_. -.... "~ - 3 - - - - _. \ impacts on fisheries and recreation which are not yet adequately addressed in the Draft EIS.The other hydroelectric alternatives might present similar water quality problems (the analysis is not detailed enough to address this question)and some of them would result in major impacts to habitat.For example one of the alternative hydroelectric projects would significantly alter or inundate over 100,000 acres of terrestrial habitat. Conclusions: The absence of appropriate data and analyses leaves the FERC staff recommendations to the Commission essentially unsupported.We consider the flaws in the Draft EIS to be serious enough to merit the development of a Revised Draft EIS.A Revised Draft EIS would provide more detailed environmental setting data and increase the depth of the impact analysis for the alternatives so that all alternatives can be compared on an equitable basis.The impact analysis simply has not been developed to the point that a regional energy planning decision can be made which gives adequate consideration and weight to the environmental differences among the alternatives. This,when combined with the potential adverse environmental consequences noted above and in the enclosed Draft EIS Review Report,has led us to rate the Draft EIS ER-3 (ER:Environmental Reservations;3:Inadequate]in accordance with our responsibility under Section 309 of the Clean Air Act to detennine whether the environmental impacts of proposed Federal actions are acceptable in terms of public health,welfare,and environmental qual ity... The enclosed report is based on our review of both the Draft EIS and APA's responses to our license application scoping recommendations. We appreciate the opportunity to review this report.Should you want to discuss EPA's cOllll1ents please contact Richard R.Thiel t Environmental Evaluation Branch Chief,at FTS 399-1728. Sincerely, lsi Ernesta B.Barnes Regional Administrator Enclosure cc:Mark Robinson,FERC Ron Kreizenbeck,AOO Lenny Corin,F&WS-Anchorage ..'-....,..,.,.. (( ·--..'"..~:".~..".-'..- u.S.ENVIRONMENTAL PROTECTION AGENCY SUSlTNA HYDROELECTRIC PROJECT-FERC No.7114 APA SCOPING RESPONSE EVALUATION U.S.ENVIRONMENTAL PROTECTION AGENCY 1200 Sixth Avenue,MIS 443 Seattle,Washington 98101 July 30,1984 - - \.. ( APA SCOPING RESPONSE EVALUATION Table of Contents 1 PURPOSE AND NEED Z ECONOMIC EVALUATION 3 PROPOSED ACTION AND ALTERNATIVES 4 WATER QUALITY AND QUANnTY 5 FISHERIES AND AQUATIC HABITATS 6 WILDUFE RESOURCES 7 AIR QUALITY • SUSlTNA HYDROELECTRIC PROJECT ( U.S.EPA 1 Z 4 5 .9 10 10 FERC No.7114 -c APA SCOPING RESPONSE EVALUATION .INTRODUCTION ;.._----,-- ( U.S.EPA - .P- This report discusses the Alaska Power Authority's (APA)responses to EPA's seoping com ments on the Draft Environmental Impact Statement for the Susitna Hydroelectric Project.The scoping recommendations were based on EPA's review of APAts Application for License.The APA responses were contained in Section C of the APA report titled 'Susitna Hydroelectric Project.Project No.7114,Response of the Alaska Power Authority to Comments on the Alaska Power Authority's License Application.'dated January 19.1984.They were reviewed for their technical accuracy and responsiveness to EPA's recommendations. The APA report numbered each of the original EPA seoping comments.and. responded to them in numerical sequence (C.1 through·C.94).This numbering format has been retained for this report.In order to keep this report as brief as possible,responses which EPA deemed to be adequate,or which addressed an issue which we determined did not merit further attention,are ignored.Finally,we note that we did not expect any response from APA to our scoping recommemations. The burden for complying with the National Environmental Policy Act (NEPA)falls on Federal agencies such as the Commission.Thus.the objective of our seoping effort was to help insure that the FERC EIS would be a fully adequate decision making document. 1 PURPOSE AND NEED Comment C.4:The response states that an analysis of the cumulative effect of reasonable values for key variables other than the price of oil is not justified due to the 'dominant role played by world oil prices.'Although the importance of world oil prices as a determinant of likely economic conditions is recognized (based on the discussion in the referenced Section 5.3).the dominant role of world oil prices relative to other factors is not evident from the analysis.Moreover,from the information provided in Tables B.118-B.126.it appears that the percentage effect (20 percent)from assumed high and.low world oil price scenarios on projected households in the year 2000,(a key variable for estimating energy demands)is not dramatically different from the percentage effect (14.6 percent) from high and.low estimates of State mining employment.If the effects of other variables are included.the relative importance of world oil prices in determining future economic conditions and.energy demands is questionable.Our comments on the Draft EIS reflect this concern. SUSlTNA HYDROELECTRIC PROJECT - 1 - FERC No.7114 r. '.:._.-,"~~" (. APA SCOPING RESPONSE EVALUATION ..:.,...-":-.':-'~-'.-'..".:.'."':,'~."- U.S.EPA ..... Comments C.8-C.9:The response restates that future energy savings from conservation will occur primarily as·a result of market forces (i.e.,is priced-induced).Although this statement may be true,no additional data in terms of estimates of future energy savings from conservation (either program-induced or price-induced)are provided,as requested.Because of the imPortance of potential energy savings to development and analysis of feasible energy supply alternatives, reasonable estimates of energy savings from program-induced conservation should be provided in the EIS..This was noted in our com ments on the Draft EIS. Comment C.lO:The response adequately addresses the implications of cyclical growth in world oil prices on energy demand forecasts;however,it·should be recognized that certain insulating features of the RED model (e.g.,spending role and corporate income tax.component,P.A-lS)help to maintain the demand forecasts at a minimum level.If these features were not assumed.the need for the proposed project at the presently planned capacity would require reevaluation under a cyclical or declining oil }Xice scenario. 2 ECONOMIC EVALUATION Comment C.l2:The response misinterprets the com ments.as presented.First.the intent of the com ment was not to imply that the identification of relevant costs was incomplete (even though this was subsequently determined).but rather to identify the necessary conditions for the analytical framework used.Second. without further identification of project objectives.it must be presumed that the alternative which meets the energy demand requirements at the "least cost"is the prefened project.In this sense.benefits are measured only in terms of least cost. with all other factors effectively treated as being equal. Comment C.13:The response does not adequately address the request for data to substantiate an assertion regarding economic feasibility of the project under the -2 percent world oil price scenario.Because this scenario is not considered a likely development.however,and since it was not evaluated in the Draft EIS.the generation of additional data to evaluate the scenario does not appear to be warranted. Comment C.lS:The response cites Response C.S to justify not evaluating the effect of variable oil prices on other key economic factors.This response adequately addresses this specific concern.The need to evaluate the sensitivity of Susitna net benefits in terms of changes in the values of more than one factor from the table presented (C.lS.I).however,is not adequately addressed.If.for example,fuel prices decreased by 20 percent and Watana capital costs increased by 20 percent.it appears that the net benefits of Susitna would approach zero.The combination of these two events is entirely possible. SUSITNA HYDROELECTRIC PROJECT - 2 - FERC No.7114 - :.~_.._.~. APA SCOPING RESPONSE EVALUATION _.~.:. U.S.EPA - .... r"~~. Comment C.l6:The response attempts to justify the exclusion of opportunity costs for the State's equity investment in the Susitna Project based on the theoretical problems associated with selection of 'the'appropriate measure.Although numerous rationales exist as to which rate would be most appropriate,the need for some measure of opportunity cost is widely accepted.Clearly,the state could achieve some return on the equity invested in Susitna (e.g.,State Permanent Fund). and exclusion of this rate of return from the economic evaluation,however conservative,underestimates the full cost of the project. Comment C.l?:The response does not adequately address the stated concerns.The best thermal alten1ative,as evaluated in the Draft EIS,would consist of multiple thermal generating plants of sm·aller size,developed over an extended period.For example.the gas scenario would consist of eight 20o-MW combined-cycle units and two 7o-MW combustion-turbine units to be installed between 1993 and 2022.This staggered constroction period would not require the State equity investment needed to finance constroction of the more capital-intensive Susitna Hydroelectric facilities.As identified in the analyses of Comment C.16,the opportunity cost of using State funds on project financing,as measured by a reasonable rate of return on alternative investments,should be included in the cost evaluation.This is particularly necessary,given that (as noted in our comments on the Draft EIS)none of the discount rates used corresponds to the real rate of return being earned by the State's Permanent Fund. Comment C.IS:This response is generally adequate,although some misinterpretation is apparent.The intent of the comment presented was not to question the appropriateness of the life cycle method employed or of the assumed economic life of the project;rather,the concern was,and still is,that the relative costs to maintain the two types of plant systems over the final 30 years could.vary considerably from production costs in the year 2020.Although we recognize that this approach is not a standard practice in projecting production costs,it would provide information useful to more clearly assess project costs. Comment C.20:The response does not adequately address the issues,as presented. The implications of foreclosing future options as a result of commitments to centralized power generation at Susitna have not been discussed.The difference between the alternatives in terms of system reliability needs to be discussed and compared in the Revised Draft EIS,including the possible effects of sabotage.If the system reliability of the alternatives is comparable,this should be stated in the Alternatives Comparison Chapter. Comment C.2l:This response addresses the concerns expressed by dismissing the economic importance of lost user benefits.Although it may be tree that the economic value of lost recreational benefits pale when compared with other economic effects,the number of user days lost and some measure of the economic value of these lost benefits should be provided.Numerous studies have been prepared which estimate the economic value of recreational activities.nus analysis should be conducted prior to dismissing the economic importance of the lost recreational opportunities. SUSITNA HYDROELECTRIC PROJECT - 3 - FERC No.7114 ..~... ( APA SCOPING RESPONSE EVALUATION 3 PROPOSED ACTION AND ALTERNATIVES U.S.EPA .- '"'"' - \.. - Comment C.2Z:The response restates the objectives and procedures used to review and screen altel11ative energy systems.It is evident that a wide range of generating technologies were considered and evaluated in the referenced Railbelt Altel11atives Study.Our review and subsequent comments on alternatives evaluation were based on the sum mary information provided in the application.The level of detail presented in this summary was the source of concern.A detailed evaluation of alternatives in the application was limited to the economic assessment of the "best thermal"altel11ative.The statement regarding additional alternative evaluation was made to ensure that alternatives comparable to the Susitna Project in terms of project details would be assessed in the EIS.Our review of this EIS indicates that the information describing the altel11atives to the proposed project is not of equal depth,thereby precluding assessment of altel11atives at the same level of analysis.The response indicates that APA conducted a relatively thorough evaluation of altel11atives.The ErS must contain the results of FEROs independent review of APA's analyses.Additionally,given that the Commission staff has developed essentially new systems,these alternatives deserve a very thorough evaluation in the EIS.This is one of the reasons why we have recommended the development of a Revised Draft EIS. CommeDt C.23:As stated in the analysis of Comment C.22,the level of detail in describing the alternative scenarios in the EIS is not comparable to that for the Susitna Project.This makes assessment of the alternatives on an equal basis difficult.Additional information on project alternatives should be included (or developed.if unavailable)from previous studies.The description of altel11ative facilities should contain specific locations so that lam use,vegetation,am wildlife impacts can be adequately assessed.It should also provide enough detail on any liquid or solid waste discharges or gaseous emissions to allow an analysis of water quality and air quality impacts.The nature of the environment at altel11ative facilities locations should also be described in more detail to support a more thorough impact analysis.Habitat types,flow regimes and quality of any receiving waters,and general land use patterns should be identified.The alternatives should then be evaluated and compared in terms of stated project objectives.These issues were all addressed in our com ments on the Draft EIS. Comment C.25a The response ducks the conservation issue by saying that not much conservation is expected.As stated in the analysis of Comment C.8,reasonable estimates of energy savings from program-induced conservation should be included in the EIS.APA has not suggested inclusion of meaningful conservation scenarios. We see this as a particularly important omission.Conservation has been shown several times to be the least expensive means of matching future power loads with available power resources.Moreover,it general results in less severe and widespread adverse environmental impacts.Finally.a recent study conducted for SUSlTNA HYDROELECTRIC PROJECT -4 -FERC No.1114 ___________________________._M4'------------- ( APA SeOPING RESPONSE EVALUATION ( ~.~.- U.S.EPA ..... .... the Bonneville Power Administration found that conservation results in more net employment than the construction and operation of nuclear power plants.Although the study did not address other convention power generation systems,we suspect that the results would be similar for these systems•. Com meat C.l6:The response indicates that it was found noi economically justifiable to develop a hydroelectric scenario with the same capability as the Susitna Project.This ducks the issue of comparing equivalent projects from an environmental standpoint.The evaluation of non-Susitna hydroelectric facilities in the Draft EIS is inadequate due to the lack of project specific information and analysis. Comment C.l7:The response acknowledges that screening criteria changed twice during the screening process due to changing economic conditions.The response further indicates that each study iteration used internally consistent criteria. However,since some projects were eliminated by early screening while other projects were retained,our objections to this change in screening criteria remain. These objections could be resolved.if the rejected candidate projects were retested with the final screening criteria and economic assumptions. Comment C.l9:This comment ducks the issue by illustr'ating the "units"in the Watana and Devils Canyon alternatives.Each dam must be fully constructed in order to emplace its first unit.The impacts of the Susitna Project with only one unit cannot be fairly compared with a gas-or coal-fired unit of equal size; however,scenarios with production capability equivalent to the Susitna Project should be evaluated.The level of detail for comparable alternatives described in the EIS does not facilitate a fair comparison of environmental impacts~ Comment C.30:The APA reply is unresponsive to the comment.It only seems to highlight weaknesses in the models used to analyze generating capacity.The effect of licensing delays should be addressed in·more detail in the Revised Draft EIS. 4 WATER QUAUTY AND QUANTITY Comment C ..35:The information contained in the response should have been included.in the ElS.However,no specific discussion of this subject can be found in the Draft EIS.In general.the response given by APA is adequate.Information concerning sediment movement under the two scenarios,however,should be clarified.In the first scenario,the third paragraph of the response assumes that only the bedload fraction of the sediment load would be deposited.in the bOrTOW pits.In a river carrying a large sediment load,even a small reduction in velocity would allow the bedload and a significant portion of the suspended.load to be deposited.Reductions of sediment load are likely to be much larger than the three percent implied by the response. SUSlTNA HYDROELECTRIC PROJECT - 5 - FERC No.7114 c· --;:--;:;.---~.""--,..~._-~.....,-~ ( APA SCOPING RESPONSE EVALUATION U.S.EPA --i ,...." In the second scenario,the response deals only with the coarse fraction of the sediment"load.Although widening and deepening of the channel will reduce the overall canying capacity,large amounts of smaller sized particles may still be transported by the flow. Comment C.36:The response does not identify areas below borrow sites"E and I which would be subject to scour or deposition;therefore,it is not responsive to the original comment.The statement concerning degradation on the order of 0.1 to 0.6 feet should be clarified by identifying specific reaches of the river which would be most affected by degradation. The response also fails to discuss the morphological ~·consequences downstream of "the borrow sites if the Devil Canyon site is not developed.Morphological"changes are important indicators of impacts on aquatic biota. Comment C.37:Refer to the analysis of C.35 and C.36 above. Comment C.38:The response given by APA and the stream.morphology studies outlined should give a more complete understanding of possible impacts.at the Chulitna-Susitna confluence.The Revised Draft EIS should contain FER Os evaluation of the results of these studies. Comment C.47:Possible supersaturation of nitrogen downstream of the dams continues to be a concern.One reviewer suggested that samples collected at a prototype test of a cone valve outlet structure were not properly pressurized and did not reflect actual nitrogen levels.On the hasis of these "spurious"data,the applicant apparently concluded that cone valves could be used to control dissolved nitrogen levels.Therefore,a question has been raised in regard to the ability of the valves to control downstream nitrogen levels.On the other hand, supersaturation of nitrogen on the order of 115 percent has been observed at Devil Canyon under natural conditions during .high flows.These high flows would not exist under postproject conditions.The applicant response references an "attached report by Ecological Analysts"which was not attached and not a-vailable for review.The report apparently discusses prototype testing of the valves.The response also indicates that further analysis is now being conclucted.The results of this analysis should be reported in the Revised Draft EIS. Comment c.48:The response to Com ment C.48 references several pages of the License Application (pages E-2-96,E-2-135,E-2-172)which state that the leachate products associated with bottom soils of the impounded area will "be confined to a small layer of water immediately adjacent to the reservoir floor"(page E-2-135).This is not true since the lakes will be dimictic,and will therefore mix twice a year during spring and fall.This has obvious lake water quality implications. Comment C.51:The response to comment C.51 states that: "Reservoir limnological conditions should be oligotrophic and very resistant to trophic status or water quality changes to nutrient SUSITNA HYDROELECTRIC PROJECT - 6 - FERC No.7114 ( APA SCOPING RESPONSE EVALUATION concentrations from either significant anything but huge petroleum product reasonably expected to occur.' ( u.S.EPA amounts of wastewater or spills,neither of which is \ The first part of the statement is incon-ect since oUgotrophic systems are generally much more sensitive than eutrophic systems to increased nutrient loadings.Water quality conditions in the reservoir may be incorrectly analyzed in the EIS if this assumption were used. Comment C.S3:Intentions for clearing of vegetation in the impoundment areas of both Watana and Devil Canyon Reservoirs are cited in Volume SA,Exhibit E, Chapter 2 of the FERC License Application on pages E-2-67,E-2-70,E-2-91, E-2-94,E-2-144,and E-2-1S1.For to the Devil Canyon impoundment area,the following statement appears on page E-2-1S1:. IPrior to filling,all standing vegetation in the reservoir area will be cleared and burned,thereby eliminating much of the oxygen demand that would be caused by inundation and subSequent long-term decomposition of this vegetation.." The response to Comment C.S3 indicates that: INo plans exist nor are there any such plans included in the FERC License Application for clearing and burning of impoundment zone vegetation.I Since the response to Comment C.S3 contradicts the FERC License Application,the Revised Draft EIS should indicate which approach will be used.Also,nutrient loading from submerged vegetation should be considered in the water quality modeling efforts. Comment C.S7:The Vollenweider modeling approach is appropriate for estimating the long-term eutrophication potential of reservoirs when they are phosphorus limited.However,it does not provide any information on the seasonal dynamics of water quality constituents within the reservoir.Dynamic simulation models are required for the latter type of analysis.Also,the description of the nutrient modeling provided on pages E-2-133 to E-2-135 of the License Application indicates that some of the assumptions used in the analysis may be questionable.For example,the phosphorus loading rates were based on dissolved orthophosphate concentrations measured in the Susitna River during June.These concentrations were then used with the armual average flows to determine the armual loading.In addition,it was assumed that "phosphorus species other than dissolved orthophosphate are not converted to bie-available form·and IIno appreciable amount of bio-available phosphorus is released from the soil upon filling the reservoirs" (page E-2-134).These assumptions are not conservative and will tend to underestimate the actual phosphorus loading rate and resultant trophic status for the following reasons: 1.Loading rates should be based on total phosphoros rather than SUSITNA HYDROELECTRIC PROJECT - 7 - FERC No.7114 ~ I APA SeOPING RESPONSE EVALUATION U.S.EPA \.I orthophosphorus since all organic forms can decay to produce orthophosphate. 2.June may not be the best time to obtain representative values of phosphorus concentrations since (A)increased light will cause algal growth which removes available orthophosphate from the water,(B)June has the highest river flows so all constituents will terd to be diluted to low concentrations, and (C)silt concentrations are high in June,so some of the phosphorus may be adsorbed to silt and clay particles. 3.The assumption that "phosphoros species other than dissolved orthophosphate are not converted to a bio-available form"is not true and is not a conservative assumption since all organic forms can decay to produce orthophosphate. 4.The assumption that IIno appreciable amount of bio-available phosphoros is released from the soil upon filling the reservoirs·is also not true and is not . a conservative assumption since the decomposition of flooded vegetation and trees on the reservoir bottom will release substantial amounts of phosphoros which will mix throughout the lake during the spring and fall overturns. Also,page E-2-133 states that the Vollenweider analysis may overestimate the trophic'status since it is based on temperate lakes,and since the proposed lakes will have reduced light due to silt.nus is also inC01Tect,since high latitude lakes have more light and longer days during the growing season than temperate lakes, and may therefore be more prone to eutrophication problems than tern perate lakes.Also,turbidity may be much lower than CUlTent conditions due to particle settling in the reservoirs,so the epilimnion may be light limited. DYRESM is appropriate for simulating temperature distributions in reservoirs as long as the dominant temperature gradients are in the vertical direction.In long, nalTOW,deep reservoirs with high inflow and outflow rates,a two-dimensional model would provide more accurate information on the hydrothermal behavior of the reservoirs. The Peterson and Nichols (1982)report has again been cited as containing the details of the water quality studies.Since this report was not available for review, an assessment of the adequacy of these studies is not possible. Comment C.SS:The response notes that additional modeling was not considered necessary.Our review of the .Draft EIS indicates that water quality standards violations are a significant pos$ibility.Consequently,we have recommended the inclusion of more sophisticated water quality modeling in the Revised Draft EIS.The models recom mended in our October 31,1983 Seoping Report still appear to be appropriate. Comment C.6Z:The APA response refers to dam failure analyses conducted as part of the Watana Dam feasibility studies,but the results of the analyses are not reported in the response or in the Draft EIS.APA also indicates that downstream SUSlTNA HYDROELECTRIC PROJECT - 8 - FERC No.7114 -------------_...._-----------~-"""'!""---------------------- APA SeOPING RESPONSE EVALUATION u.S.EPA -safety plans would be prepared "after final design and prior to reservoir operation."The EIS should contain some description of the areal extent and severity of impact a dam failure would have on lands and people downstream from the project area.This is an important consideration to decision makers when weighing the less quantifiable effects of project alternatives. 5 FISHERIES AND AQUATIC HABITATS Comment C.63:The response lists a reference that provides quantitative information on fish impacts.This document was not available to EPA at the time --of the Application review or the current review of the Draft EIS.Furthermore, the lack of a quantitative impact analysis is a major drawback of the Draft ElS. ..... - Comment C.64:The response indicates that more quantitative fisheries data are being collected (e.g.,instream flow studies that correlate fish habitat with flow). The Draft EIS did not reflect this new information.It should be included in the Revised Draft EIS. The response also refers to difficulties in locating mainstem salmon spawners. Potential sampling e1Tors of great magnitude and importance to impact analysis should be reflected in the discussion.The Draft EIS impact assessment chapter did not describe the relative proportion of spawning salmon in the mainstem. Comment C.66:The response contradicts itself by stating that "The FERC License Application contains no worst-case scenario for any species"and that "the worst-case scenario developed in the License Application consists of an assumption that all habitat which is directly affected by the mainstem discharge might become unsuitable."The response also contains several inconsistencies or errors.First,an estimated ZZ.0-22.8 percent of the chinook,5.0-11.4 percent of the chum,and 0.9-3.6 percent of the sockeye salmon obsexved at Sunshine Station were observed at upriver locations (Application Fig.3.9)rather than the 6-7 percent chinook,5-7 percent chum,and less than 1 percent of the sockeye,as cited in the response. Second,the response states that "All chinook salmon which enter the reach (Devil Canyon to Talkeetna)spawn in tributaries which will not be affected by project-induced changes."This statement is inconsistent with Table E.2.27 which indicates possible restriction of fish access to Sherman Creek and Jack Long Creek because of stream mouth perching (see Fig.3.15 and 3.17 for fish COWltS).This table also lists fish access as a concern for numerous other tributaries in the reach.The fishery's impact analysis contained in the Draft EIS is suspect because of these inconsistencies. Comments C.67~.691 Reports referenced by APA as evaluations of sampling programs and techniques were not available to EPA and were not described in detail in the Draft ElS.Therefore,it is impossible to judge the effectiveness of the sampling programs and the accuracy of the fishery impact analysis. SUSlTNA HYDROELECTRIC PROJECT - 9 - FERC No.7114 ,"-'~.",' ( APA SCOPING RESPONSE EVALUATION U.S.EPA - Comment C.73:Although the Draft EIS mentions that water clarity will improve during the sum mer,it does not describe what effect this will have on predator-prey interactions of fish.This may not be a major impact,but it should be evaluated in the Revised Draft ErS.' Comment C.75:The response indicates II'hand calculationsII'will be made to determine whether erosion or deposition occurs in slough habitats.It does not indicate how these calculations will be made. 6 WILDLIFE RESOURCES Comment C.82:The APA response does not provide the requested information,nor is it presented in the Draft EIS.It is not possible·to fully evaluate the implications of the proposed project if mitigation measures are still being developed.The significant habitat loss that would occur as a result of the project requires some assurance that adequate mitigation is actually feasible before responsible decisions on the project can be made. Comment C.86:The data requested by this comment have not been provided in APA's response or in the FERC Draft EIS.Moose habitat data collection and model testing are still underway.It is difficult to assess the severity of project impacts on moose habitat without additional information,and impacts on moose should be adequately identified and mitigation planned before a decision is made on the project. 7 AIR QUALITY Comment C.91:The response treats this paragraph as an independent comment rather than as a lead-in to the addresses the issue of direct alternatives.This issue is the response to that com ment. paragraph labeled II'Comment C.92.11'The response air quality impacts of the project and its focus of Com ment C.94;see discussion of the \ ,.... I Comment C.92:The response fails to address the issue raised,implying that fuel use patterns are dependent primarily on (current)relative fuel prices.The nature of installed heating systems,rather than the relative price of different fuels,will dictate fuel use patterns.Even for new construction,fuel prices will not be the sole basis for selection of heating systems.The issue raised in the original comment is relevant to the evaluation of project alternatives.Will increased hydroelectric development alter electrical power costs sufficiently to affect heating SUSITNA HYDROELECTRIC PROJECT -10 -FERC No.7114 ,, .._.------,-.. APA SCOPING RESPONSE EVALUATION ':.'~:':""...~~-....-~.-:.:.. U.S.EPA systems chosen for new construction?Would fossil-fueled.generating plants affect future fuel supply or fuel prices sufficiently to alter the types of heating systems chosen for new construction?Would the project or its alternatives affect fuel prices sufficiently to result in increased use of wood for supplemental heating in both existing and new construction (recognizing that not all wood is obtained through commercial dealers)? .-.Changes in wood burning practices could influence attainment of air quality standards. Comment C.94:The response to this comment (combined with the response to Comment C.91)is inadequate.Compliance with emission limits set by air quality management agencies does not necessarily guarantee an absence of ambient air quality impacts.Screening level analyses are possible and feasible without precise site-specific topographic and meteorological data.The requested screening analyses have been provided in the Draft EIS.However,as noted.in our comments on the Draft ErS,they were flawed in several respects.Our recommendations for the Revised Draft EIS describe how these errors and omissions could be corrected.and will not be repeated here. (~r:, ~~:) ..... - \. SUSlTNA HYDROELECTRIC PROJECT -11 -FERC No.7114 ,~ r (- u.S.ENVIRONMENTAL PROTECTION AGENCY Table of Contents - Chapter 1 PURPOSE OF AND NEED FOR ACTION 1.1 NEED FOI.POWEI. 1.1.1 Kajor Concerns 1.1.2 Minor Comments 1.2 ALTERNATIVE ACT!ONS 1.2.1 Non-Hydroelectric Alternatives 1.2.2 Non-Structural Alternatives 1.3 SCENARIO DEVELOPMENT 1.3.1 Susitna Basin Development 1.3.2 Non-Susitna River Hydroelectric Development 1.3.3 Natural-Gas-Fired Generation Scenario 1.3.3.1 Scenario Evaluation 1.3.3.2 Fuel Use Act Exemption 1.3.4 Coal-Fired Generation Scena~io Evaluation 1.3.5 Scenario Comparison and Combined Scenarios Chapter 2 PROPOSED ACTION .AND ALTERNATIVES Chapter 3 AFFECTED ENVIRONMENT 3.1 PROPOSED PI.OJ'ECT 3.1.1 Water Quality and Quantity 3.1.2 Surface Water Quallty 3.2 NATtJlW,-GAS~FUEDGEBDATIONSCENAlUO 3.3 COHBINED HYDRo-nmmw.GENDA1'ION SCElWlIO Chapter 4 ENVIR06MENTAL IMPACT 4.1 PROPOSED PROJECT 4 4 4 6 6 6 7 7 7 Plans a a a 9 9 10 11 12 12 12 13 13 13 14 14 FEllC No.7114 DIAlT EIS REVIEW IEPOn ,.,.. .n"'t.", "li~ .... r I""" c.. u.S.ENVIRONMENTAL PROTECTION AGENCY .... - c.~, .... "..'" 4.1.1 Air Quality 4.1.2·Water Quantity aDd Qual1ty 4.1.2.1 Physical Habitat Availability 4.1.2.2 ChaDDel Stability and Sediment Transport 4.1.2.3 Suspended Solids 4.1.2.4 Gas Saturation 4.1.2.5 Nutrients 4.1.2.6 Temperature 4.1.2.7 Other Vater Quality Impacts 4.1.2.8 Ice Processes 4.1.3 GroUDdwater 4.1.4 Aquatic Communities 4.1.4.1 Plant Communities 4.1.4.2 Fish Communities 4.1.4.3 Mluor Comments 4.1.5 Terrestrial Communities 4.2 NA"l'U'RAL GAS-FIRED SCENARIO 4.3 COAL-FIRED SCENARIO 4.4 CO!!BlNED HYDRO-THElUW.GDDATION SCENARIO 4.4.1 Air Quality &Noise 4.4.2 Vater Quantity and Quality 4.4.3 Aquatic Communities 4.4.4 Terrestrial Communities 4.5 COMPARISON OF ALTERNATIVES 4.5.1 Water Quantity and Quality 4.5.2 Aquatic Communities 4.5.3 Terrestrial Communities Chapter S STAT!CONCLUSIONS 5.1 !ECOMKENDATIONS 5.1.1 Power Generation 5.1.2 Flow legalation 5.2 HITIGATIVE MEAStmES 5.2.1 Water Quantity and Quality 14 14 14 14 15 16 16 17 17 17 18 18 IS is 19 21 22 22 22 22 23 24 24 24 24 2S 2S 26 26 26 27 27 28 nac No.7114 DLU'T EIS IEV1EW REPORT ._------'-.~----.--,------ f'' r~ n ~....., (( ·.,~. u.S.ENVIRONMENTAL PROTECTION AGENCY 5.2.2 Laud Use and Ownership 28 5.2.3 .Aquatic Communities 28 5.2.4 Terrestrial Communities 29.... Chapter 6 EPA'S FINDINGS AND CONCLUSIONS 30 -6.1 DRAFT EIS ADEQUACY 30 6.2 ENVIRONMENTAL RESER.VATIONS 31 Appendix A APPENDIX COMMENTS 33 A.l Appendix G 33 A.2 Appendix H 34 - "..." If,~..:' \.. Rae No.7114 DRAFT lIS REVIEW UPOllT ,..,,, ,.., I~ ( ~n ~II • ((.. '. INTRODUCTION u.S.ENVIRONMENTAL PROTECTION AGENCY JaEconv&SUMlWlY ,.... This report presents the U.S.Environmental Protection Agency t s (EPA) comments on the Draft Environmental Impact Statement (Draft EIS &DEIS ,hereafter)for the Susitua HYfroelectric project sponsored by the Alaska Power Authority (APA hereafter).It discusses:. 1.Analytical problems with the EIS t evaluation of alternativ.es and how they should be corrected. 2.Serious omissions in the EIS t evaluation of environmental consequences and how they should be corrected. 3.'IbelERC staff conclusions and the problems whic.h EPA has with these conclusions. Report Organization: The report presents EPA's cOlllllents in the.ir order of appearance in the Draft EIS.Chapters,sections,and subsections carry titles which correspond to the titles used in the DEIS.Where appropriate,section numbers from the DEIS are referenced in boldface type. MAJOR FINDINGS &CONCLUSIONS Nature of the Action: The APA has submitted an application for license for a two dam hydroelectric -system,called the Susitua Project,to serve the long term electrical energy needs of Alaska's Bailbelt.The FEaC staff has treated the problem before it as being one of determining,to the best of its ability,what type of 1.This report was developed with the assistance of Jones &Stokes Associates,Inc.and Tetra Tech,Inc. FERC No.7114 1 - DRAFT EIS REVIEW REPOB.T (, .. u.S.ENVIRONMEN'l'AL PROTECTION AGENCY electric power supply system would best meet the needs of the Railbelt.Thus. the decisions to be made are,in part..,.sce.level decisions. Consequently.the DEIS BlUst e%Amine the differences among power supply systems.However.because nRC must also determine what specific hydroelectric projects.if any,to license at this time,the analysis DlUSt also focus.in some detail,on the environmental and economic consequences of individual projects. Review Criteria: Th1sdecision framework requires that the EIS serve several purposes. Consequently,EPA reviewed it within the context of four som.ewhat different sets of criteria: ..... 1.Bow vell does the document serve the intent of NEPA and the Council on EnviroOlllenta1 Quallty (CEQ)Regulations [40 cn·Part 15001 governing the implementation of NEPA? 2.Bow ve11 does it address the factors (primarily environmental standards compliance)vhich EPA uses in determining whether the environmental impacts of the proposed action,and its alternatives,are acceptable in terms of public health.welfare.and environmental quality pursuant to Section 309 of the Clean Air Act? Does it make an adequate contribution towards PERC's mandate.under Section 10 of the Federal Power Act,to optimize water resources development within the basin (or region of interest)l Does it provide the informat~on necessary for the Commission's decisions to be able to meet the -substantial evidence w test applied under the Administrative Procedures Act to decision .making procedures of this type t 3. ...... 4. ~ Findings &Conclusions: The major findings of our analysis are: - 'the Draft lIS provides a very unbalanced evaluation of alternative electrical power supply systems.Although it contains a relatively thorough analysis of the Susitna Project.its treatment of other systems and the individual projects within them is too superficial to provide a reasonable basis for well informed decision making. -The description of the Affected Environment (Chapter 3)for the various project alternatives is very unbalanced;there is generally insufficient environmental setting data to evaluate alternatives other than the proposed Susitna hydroelectric project. nRC No.7114 - 2 - DBAlT EIS UVIEW HEPORT r· /. ,""..(( .... u.S.ENVIB:0NMENTAL PROTECTION AGENCY The impact analysis as a whole (Chapter 4)is unbalanced because project alternatives have not been developed in sufficient detail;it is therefore difficult to accurately compare the enviroamental impacts of alternative actions. Insufficient information'is provided in both the Environmental Impact Chapter and the Comparison of Alternatives section to justify FERCts conclusions regarding the significance of the impacts of the various project alternatives. The PERC staff recommendation of a mixed thermal-based generation scenario (section 5.2.1)is based on questionable assumptious of future world oil prices and is not adequately supported by the impact analysis contained in the Draft EIS. Each of the alternative power supply systems has the potential to result in serious environmental degradation.Moreover,the evaluation of the Susitna project indicates that it could result in extended violations of State water quality standards. The discussion of mitigation measures is generally lacking;the fact that mitigation plans are being developed for loss of habitat is not an adequate basis for government agencies or the general public to determine if major project impacts can be mitigated.The magnitude of the potential impacts suggests that no action should be taken by the Comm:lssion until a thorough mitigation plan has been developed and reviewed by appropriate natural resource management agencies. These basic problems with the Draft EIS.as well as several other major problems in the analyses presented.lead EPA to conclude that a revised Draft EIS is necessary.A revised DEIS could contain a corrected and more balanced evaluation of the alternatives.Developing a revised DEIS,before the Final EIS,would provide for adequate review of these improved analyses by concerned agencies and the public before the Comm:lssion holds its hearings on the license application and begins making decisions.lie believe that it would be the most effective way of insuring that the dec.1sions made fully implement the public ts interest and achieve a reasonable balance among the goals of the various applicable Federal statutes. nR.C No.1114 - 3 - DRAlT EIS REVIEW REPORT r, {; 'i.';"':;,'",~,,~- ..--,'T ..' ",",(- U.S.ENVIRONMENTAL PROTECTION AGENCY Chapter 1 lU'IPOSB OP ABD RBED POK ACTIOR 1.1 HlmD lOll POWEll 1.1.1 Kajor Concerns In "Seed-on 1.2..4 (Load Growth Forecast),the central issue analyzed is the future price of world oil.As identified on page 1-9 of the Draft EIS, world 011 prices affect future power needs and the feasibility of generation technc)logies to meet those needs in several key ways. Becswle of the aportant influence of future oil prices on the price of fuel substitutes,especially natural gas,the oil price projections are critical to a'll~y subsequent economic analysis of alternatives,whether hydro-,or the1'lllllLl-based.The high degree of uncertainty associated with long-term. forecasts of oil prices reflects the multitude of economic factors which can influence price levels. - As diilcussed iD the Draft EIS,future world oil prices are forecssted based upon,fundamental assumptions regarding future economic forces and conditions.In the near term (1983-1988),it appears generally agreed upon that world oil prices will decline in real terms as current non-oPEC produc~tion levels increase aDd fuel switching and conservation efforts cont11l~ue.Huch uncertainty exists,however,over the long term.Al though there appears to be general agreement that prices will begin to rise sometime withilll the ,next decade,the key question is when and.how fast will prices escala,te thereafter. The Al~A world oil price forecasts.which are based upon the SHCA -No Supply Disruption-scenario.project that from 1989 to 2010 the real rate of price change 111 oU viII be 2.6 percent per year,resulting in a price of $50.39 (1983 dollars)in 2010.As identified '111 the Draft EIS.aD,important underlying assumption to this forecast is -that OPEC will contiDue operating as a·viable entity and will not limit production during the forecast period.Recent trends in economic growth in the UDited States aud the free mc No.7114 - 4 - ........,iF DRArr EIS BEVIEW BEPOIlT I' I ~4,: .:.~';..".-,'.. (.•;f\-. (..'....•..>.~ ..... - .... -- u.S.ENVIRONMENTAL PROTECTION AGENCY world will continue at reasonable rates.- The !'ERC forecast,in contrast,'projects a more significant and prolonged redu,ction in world oil prices in the near term,with a more modest growth in prices thereafter.The price of world oil in the year 2010 is projected to be $29 in 1983 dollars.The theoretical justification for this .scenario is au assumption that the strength of economic forces which currently are reducing oil prices (e.g.,fuel switching,conservation,and growth of nou-oPEC oU production)will continue to predominate over economic forces wbicll1 would inicrease oil prices,namely renewed world economic growth. Because the economic feasibility of the proposed Susitna project and altelt"Datives clepends upon which 011 price forecast is selected,the key question is which scenario more accurately describes probable future oil PUCI!conditions.Although both scenarios are reasonable if the underlying econ_mc conditions are accepted,it would appear·that,based on the forecasts identified in'Figure 1-5,more support ensts for the highf;!r UA forecasts.The FlRC forecast,although not included in Figure 1-5 (which is recosamended),would appear to be similar'to the State of Alaska DOR-Mean forec:ast.The forecasts which lend support to FERC's -lower growth- scenario are the three DOl.projections.Because two of these forecasts (50 perc.tnt and 30 percent)are used for budgetary and economic planning purposes,some -conservatism-may have been incorporated.Also,only one additional study,apparently prepared for FlRC,is cited as a reference for FERCts Draft EIS analysis of world oil prices. Thl!remaining forecasts in Figure 1-5,including two prepared by the Depal~tment of Energy,support a scenario of shorter (if any)periods of decljLue in prices and a higher rate of price increase thereaft·er.A review of recent forecasts of world oil prices prepared by the o.S.Energy Infol:'1118.tion Administration and published in the May 31 edition of Platt's Oilgram News,indicates a projected price of $50 (1983 dollars)in 1995.This COmp4lLreS with $22 per barrel (1983 dollars)in 1995 projected by FEB.C in the Drafl:EIS. Thus"FERC IS scenario of world oil prices,although based on sound economic reasClung and lr:echuica1 considerations,does not appear to be consistent with the 1I&jority of other forecasts.Because of the important implications of theset forecasts to evaluation of the project and alternatives,additional data are needed to substantiate FEllCls world oil price forecast. Spec:f.fically,the FEB.C staff should identify the factors which lead it to belltlVe that this lov price future is substantially more probable than a lIOdel~ate or high price future.Better yet,given the large spread among foreeasts of future world oil prices,it would be most appropriate for a Revilled Draft lIS to contain the results of a sensitivity analysis which shoved how the econocc ranking of the alternatives changed with oil price chanll;e•• FlRC No.7114 - 5 - DRAFT EIS IEVIEW UPOB.'l' .- - .- .'r ....~.. ( tJ.S.ENVIRONMENTAL PROTECTION AGENCY 1.1.~t Minor Comments The 11:'ate of chauge in projected world oil prices under the FERC scenario and the APA scenario should be presented in the same table.This will facilitate comparison of the forecasts. The lrERC oil price forecast should be included in Pigure 1-5 and A-2.The base year identified in Figure 1-5 for constant dollars should be 1983. The :l~rtance of 1:)il prices to energy demand forecasts,as determined by the HAP ,and RED model projections should be accurately identified.In other word"l,is there sufficient justification to select world oil prices as the single exogenous variable to bracket potential energy demands in the llailbelt?A review of the Draft XIS and supporting'information in A:PA's projelct application to PEllC indicates that high and low values assUDle.d for othe:z:'variables also may bave an iJaportant effect on energy and'demand forecasts.For example,froll the information provided in Tables B ..118 - B.126 (Volume 2A of the license application),it would appear that the percentage effect (20%)froll assumed high and low world oil price scenarios on pl~ojected households in the year 2000 (a key variable for estimating energy demand)is not dramatically different from the percentage effect (14.6%)from high and low estimates of State mining employment. 1.2 ALTERNATIVE ACTIONS 1.2.1 Non-Hydroelectric Alternatives This section,together with the supplemental information presented in Appendix B,provides a reasonable description of selective energy resources which may contribute to power generation for the Railbelt.The discussion of natural gas,in particular,fully addresses the issues important to future utilization of the resources. Two eluergy resources with potential for contributing to power generation in the Railbelt,which were not discussed,however,are w1ud energy and refuse-derived fuel.As stated in Exhibit D of APA's liceuse application, -several areas of excellent v1ud resource bave been identified in the Ia1lbelt.-The energy potential of and development opportuu.1ties for wind energy systeDl8.especially large conversion systems in the lailbe1t,should be djlscussed.S1m1larly,the energy potential from refuse-derived fuel plants,a resource considered in one of the llixed-thermal scenarios in me No.7114 - 6 - DIAn lIS BEVIEW REPOaT - - ... - c·· u.S.ENVIRONMENTAL PROTECTION AGENCY Section 1.4,should be described. The dliscussion of geothermal energy indicates that cost is a lllajor factor in limiting the development of geothermal resources in the lailbelt area. Examples of heat distribution piping costs are provided as indications of the high cost.Il~is unclear,bowever,whether generation of electricity from geothermal (which would not require heat distribution piping)would be similarly noncompetitive from a cost standpoint.This should be addressed in the Revised Praft EIS.. 1.2.2 Non-Structural Alternatives The dliscussion of the effects of conservation on electricity demand should include reasonable estimates of potential energy saVings from im.plementation of ct)118ervation programs in the J.ailbelt.Energy saVings from programs currently plalmed for implementation,as well as potential savings from a more aggressive approach to conservation on the part of the State,utilities, and municipalities,should be estimated.The data provided should be suff11~ient to analyze a feasible conservation program.as a component in an alte~~t1ve en~tgy resource development scenario. While the estimates lllay not have a high degree of accuracy at present,a more relialble data base could be developed for future considerations of energy c0118el~ation.Efforts should be lllade to record the effects of ongoing progr~ua-induced conservation so that future estimates of power demand could more accuratel.y reflect the influence of conservation.liso,the assU1llI~tions 1II&deregard1ng conservation in the energy demand forecasts for the 1a1lbelt should be identified. 1.3 SCENARIO DEVELOPMENT 1.3.1 Susitna Basin Development An assumption made in the production cost model.(OPCOST)to estimate least total.system COilts for Susitna Basin hydropower development was escal.ation of real fuel costs from 1993 to 2013 aDd constant real fuel costs from 2014 to 2042.this assumption is inconsistent with the escalation of fuel costs for the theniaJ.alteruatives,which increase to the year 2022 and are held ConStlLDt thereafter.The unequal treatment of future fuel costs biases the results in favor of systems with relatively large therlll&l components..The analyllis should be corrected so that it uses a consistent set of fuel.price aSSUDqltions across the development scenarios. -mc )(0.7114 - 7 - DUlT lIS IEVIEW 1EPOB.'l' ·. u.S.ENVIllONMEN'J;'AL PROTECTION AGENCY ,..... Cost estimates for the proposed project should reflect some increment for oPPOJ~tunity cOllts,as it is clear that the State could achieve some return on the equity invested in Susitna (e.g.,State Permanent Fund).Exclusion of this factor underestimates the full cost of the project.The discount rates used do not fully reflect this factor because they all appear to be below the real rate of return which the Permanent Fund could earn. The IDraft lIS states,on page 1-35,that OPCOST was run for each generation alteJ~tive using the staff's high,low,and medium load forecast.- AccOJ:ding to information on page 1-15,no load projections could be generated cons:.llstent with the low world oil price trajectory.Because world oil pricEls were identified as the single exogenous factor in generating alternate load forecasts D how were -low-load forecasts generated? ,.... 1.3.~~Non-Susitna liver Hydroelectric Development Plans The discussion of the non-Susitna River hydroelectric development plans should identify the amount of power generating capacity provided by thermal sourc~es and the reasons why the load requirements could not be met mostly or entiz'ely by non-Susitna River hydro projects.The environmental criteria used to eliminate the 86 other hydro sites through the 4-step iterative proce:ss should be identified'. The IDraft lIS states,on page 1-36,that the six alternative hydropower development plans were screened on the basis of relative cost,energy capability,and environmental acceptability.Additional discussion of the criteria used to determine -enviroumental acceptability·is needed. 1.3.3 Natural-Gas-Fired Generation Scenario 1.3.3.1 Scenario Evaluation ..... The estimation of annual operating costs for the gas scenario assumes real escalation of fuel costs from 1982 through 2022 and held conatant thereafter.l~e assumption of constant fuel coats is questionable based on other available forecasts and has the net econ01ll1c effect of favoring the thermal alternatives over the hydroelectric alternatives.Also,the assUJIption of coustant fuel costa appears inconsistent with projectious on Table 1-23,vb1ch show a continual escalation in real prices of natural gas. Although the aasumptiou that future escalation of natural gas prices will be closely linked to world oil prices is reasonable,the world oil price mc No.7114 8 - DRAFr EIS REVIEW ImPOla ------_._----,------------~,----------------------- ,...,. •r.'•'II u.S.ENVIRONMENTAL PROTECTION AGENCY projections which gas prices follow appear low,based on most forecasts currently available.FERC projects natural gas prices to increase to $3.44 and $4.09(19,82 dollars)in the year 2020 under the medium and high forecasts,respectively.The APA reference ease assumes gas prices at the wellbead to be $6.34 (1983 dollars)at the year 2020,or a mitlimum of 58 perce1l1t higher than FERC's.In its analysis,PERC should state whether the projected natural gas prices are wellhead prices or delivered prices. The discount rates assumed for the analysis are 3.5 percent,5.2 percent and 7.0 I.ercent.Because of the importance of these assumed rates to the economic assessment,a discussion of these rates,including the theoretical justification for use of each rate,should be presented.The rate considered most appropriate by the FER.C staff should be identified and the reaSOllS for se.le'cting this rate should be clearly stated.It should be noted that the assumed discount rate used by APA in its license application to FrRC was 3.0 percent.Use of this rate,with the forecast of high fuel cost escalation,would result in levelized total power costs approximately equiv~llent for 'the natural gas scenario and the Susitna project. 1.3.3 ..2 Fuel Use Act Exemption The a,ssumption that an exemption would be approved to allow for use of natur~ll gas as a fuel for base-load power generation should be further discu'Jsed and supported.The reasons for exempting the proposed scenario from provisions of the Act should be identified. 1.3.4 Coal-Fired Generation Scenario Evaluation The Draft EIS states,on page 1-42,that -Fuel costs were escalated from 1982-~~022 and held constant thereafter.-Table 1-23 shows escalation of coal I)rices only under the high forecast and shows the esca1.ation continuing to thEl year 2050.If coal prices are assumed to be held constant after 2022, this Ilhould be indicated in Table 1-23. The clliscount rates assumed for the analysis should be discussed and justif~ied• The assumed real coal price escalation rate appears low compared with projec:ted rates in studies cited by A'2A in its License Application (Appendix D-l).PERC project.co~prices to increase to between $1.55 and $1.70 (1982 dollax'.)by the year 2010,whereas APA assumes a year 2010 price of $2.80 to $3.41. PERC No.7114 - 9 - DRAFT EIS REVIEW REPORT I' ~i C.-- ""'" .. ( u.S.ENVIRONMENTAL PROTECTION AGENCY 1.3.S Scenario Comparison and Combined Scenarios The EIS needs to state what the basis 1&for comparing the scenarios. Criteria other than least cost such as system reliability and flexib111tYt should be 1de'at1f1ed as factors to be considered in the evaluation of alteJ:~t1ve sCleuar1os.Also.any differential effects from financing the alternative scenarios should be identified in the cost comparison.The sce1Ul,r1os should be compared in tli!rmB of all project objectives. The lD1xed scenario evaluated should lnclude analysis of a wider range of potellltial ener,gy sources.Energy sources such as peat.geo~hermal.and conseinat1on discussed in Section 1.3 and other potential sources such as wind energy sbould be included in an analysis of alternative sources of electricity supply_ F!l.C No.7114 -10 -DRAFT EIS REVIEW REPORT ,' ·.''".'(. u.S.ENVIRONMENTAL PROTECTION AGENCY Chapter 2 PBOPOSED ACrIOII ARD ALDIHA1'IVES ere .... Cbapte,r 2 of .the Draft EIS provides a thorough description of the proposed action,which g:Lves the reader substantial assistance in understanding the potential enviroumencal impacts of the Susitna project.However,the other alterD,ative regional power supply systems are not .given nearly as much attention.This superficial treatment seriously limits the readers'ability to ass:ess the slcale or significance of the impacts of the alternatives;The chapter needs to be revised and expanded so that it provides thorough descriptions of each project included in an alternative generation scenario.Although specific design information is generally not available, IIlOre comprehensive descriptions could be developed based upon conventional power plant designs.This discussion should give special attention to the various waste streams produced by thermal power plants and their ultimate fates. Additionally,g:Lven that the PERC staff is recommending an access plan which essentially el1111inates the license applicant's recreation plan,this chapter needs to contai.n anew recreation plan which is consistent with the staff recommended access plan.Also,this chapter,in accordance with the CEQ regulations,must contain a summary comparison of the environmental impacts of the alternatives based on the revised impact analyses recommended later in this report. Finally,we not,!that this chapter,at page 2-8,provides estimates of gross storage volume,live storage,and minimum reservoir level for Watana Dam which differ fr,om those presented in the swmaary,at page J:d.The maJdmum water surface elevation for Devil canyon reservoir is listed as being three feet ~L1gher than the dam's crest elevation.[page nil.These.apparent errors should be corrected. FlRC No.7114 -11 DllAF'l'EIS 1lEV1EW IEPORT .-.~'~~,.._.~""--,-,"'- ( \ ..<..".:'",.'_.•";-~_._'-~- ( .. The fi.lure is text or figure aDd reference - .... ..... u.S.ENVIRONMENTAL PROTECTION AGENCY Chapter 3 ARECDD ERVIKONHKBr The Affected Environment Chapter and supporting EIS appendices were reviewed in conjunction 'with the analysis of the Environmental Impact "Chapter.The principal thrust of this review was to determine whether existing environment descriptions were sufficient to conduct the impact ~lysis and support the conelulilions of the impact analysis contained in the Draft EIS. In general the Affected Environment descriptions for the proposed Susitna Hydroelectric Project (Secti.oa.s 3.1.3-3.1.6)are sufficient to support the analyses.Where background environment data were found to be lacking,it was noted in the comments on the Environmental Impact Chapter.Affected EnvirollSent descriptions for the project alternatives (Sections 3.2-3.5), howevel~.were found to be too brief and too general to support an equal comparlson of impacts of all alternatives.Specific:locations for altenuLtive facilities should be identified and data on habitat types,flow regimes and quality of any receiving waters,and general land use patterns should be described so that impacts on land use,vegetation,and wildlife can be adequately assessed. We did find several additional minor technical problems with the Affected EnvirotlSent Chapter.These are discussed,briefly,below. 3.1 PROPOSED PROJECT ~•.~...;~,?r~::"~'t..:';Z';"and Quanti ty.''.;1 .The s1J~hab:1.fat types listed in figure 3-4 are not described. iDadeqt'£&te to differentiate between the habitat types.The should contain a brief description of each habitat type Append:b:H for more detailed information. InforDulLtion concerning the sediment input of the Talkeetna River should be me No.7114 12 -Dun XIS REVIEW REPORT •,..,. "... u.S.ENVIRONMENTAL PROTECTION AGENCY presel1.ted in the Revised Draft EIS.If this river carries a sediment load similar to the Chulitna B.i ver.morphological changes at the Talkeetna-Susitna conflu.ence may occur.This information is necessary because aquatic resources in side sloughs and channels downstream of the Talkeetna-Susitna conflu,ence may be affected by altered sediment movement patterns. The re:ference to Exhibit E.vol.SA.Chapter 2.Table E.2.29 does not contain flood frequency information as stated in the text.Figure E.2.29 does give this information.This reference error should be corrected. 3.1.2 Surface Water Quality Water quality information for Susitna River tributaries should be presented.'!'he Draft EIS states that turbidity in the Susitna mainstem decreases with movement downstream due in part to dilution from clear water .tributaries.This type of general statement yields little information concerning the specific water quality issues of these biologically important water bodies.Although tributaries may not be drastically affected by the project.some impacts are inevitable..'!'he scope of these impacts can not be understood without knowledge of existing conditions. 3.2 NATURAL-GAS-FIUD GENERATION SCENARIO The statement that water quality is not an issue because water use is zero is mslealUng.In Chapter 2 of the DEIS.the description of this alternative states that a complete water supply system.road system.camp facilities. sewage and waste treatment facilities.airstrip and transmission facilities would be constructed.Construction on this scale would undoubtedly affect water lluality in the area. 3.3 COMBINED HYDRO-THERMAL GENERATION SCENARIO A general descr:lption of the expected water quality of the Snow River and other surface waters likely to be affected by this alternative should be presen1:ed.If quantitative information is unavailable.the Revised Draft EIS sbould stat.e whether these surface waters are influenced chiefly by glaciaJL activity or snowmelt. FERC No.7114 13 -DRAFT EIS REVIEW REPORT at least for NOxtonper low as ·..- - .\, u.S.ENVIRONMENTAL PROTECTION AGENCY Chapter 4 4.1 PRIOPOSED PROJECT 4.1.1 .Ur Qualit,y The diesel geneeator emissions estimates appear to be incorrect for nitrogen oxides and carbon monoxide.We estimate 1581 tons per year and 412 tons per year for CO.Both of these estimates exceed the 250 year t:hreshold for PSD.Also,for the S02 emissions to be as indicated,the sulfur cOntent of the diesel fuel can not exceed 0.1%. 4.1.2 Water Quantity and Quality 4.1.2.1 Physical Habitat Availability The description of habitat availability is fairly complete,but some attempt should be made :to quantitatively describe slough substrate changes that may occur 41S a result of flow alteration.This type of information is necessary becauS4~the availability of sloughs would be a moot point if substrate conditions wereunsu1table for salmonid species. The D1:'aft lIS fails to explain why side channel habitats would be less affected by the project than side sloughs or tributary mouths.This could be a~leviated by first describing these habitats and then presenting cross-fl,ecti011s of side channels which show their decreased vulnerability to flow alteration. 4.1.2.~!Channel Stability and Sediment Transport The Draft EIS should consider the possibility that the Devil Canyon site may not be developed.The Draft EIS assumes that borrow sites below the Watana FEllC No.7114 14 - T·... DRAFT EIS REVIEW REPORT .. " ~.~..:,.:--~. I ( u.S.ENVIRONMENTAL PROTECTION AGENCY \,. Dam wi.ll be inll1ndated by the Devil Canyon Reservoir.It is possible that construction delays,economic or environmental issues,or decreased power demandll may delay or prevent construction of Devil Canyon Dam.In light of this,the sediment transport implications of.a ·Watana only·project should be fully addressed in the Revised Draft EIS. The Draft EIS states that there would be an increase in the occurrence of high flows capable of initiating gravel bed movement.The Draft EIS, hOWeVelL",never defines the range of flows capable of transporting bedload and should therefore.not predict frequency increases for these flows. 4.1.2.:3 Suspended Solids The Draft EIS fails to show that operation of Devil Canyon Dam would reduce the cc)ncentration of suspended solids compared to,operation of Watana alone.Solids released from Watana would be small enough to have remained in suspension for over 600 days and would not settle out in the 58 days they would remain in the Devil Canyon Reservoir.Therefore,all particles released from Watana would also be released from Devil Canyon.Addi tional particles resulting from bank failures along the edges of the Devil Canyon Reservoir may also be released.The release from Devil Canyon Dam would,therefore, contain at leant as 1IlUch,if not more,suspended solids than that from Watana. The s1upended solids discussion fails to address the impact that ice forma t:Lon in the Va tana Reservoir might have on suspended solids levels both in the!reservoir and downstream in the river.If 5-6 feet of ice is expectt!d to form in the river,it seems likely that a greater thickness might form o'ver the reservoir.With the drawdoWtl schedule planned for the winter (Figure 2-10 in the Draft EIS),some scouring of reservoir shoreline and bottom should occur.The Revised Draft EIS should discuss the likelihood of this seouring and make some judgment as to its significance.It should also address whether similar scouring would occur at Devil Canyon Reservoir.While the d]~awdown schedule in Figure 2-10 indicates Devil Canyon would not fluctlULte,statements on page 4-48 suggest it would be drawn down as much as 50 feet in August and September.This inconsistency should be rectified in the Revised Draft EIS and the water qlULlity implications of any drawdown should be preseD.ted. The AlIA license application contaiDs an analysis of project effects on turbidjlty (in terms of NTUs),but this information has not been brought forward into the EIS.It would be helpful to summarize this turbidity infOrlUltion in the Revised Draft EIS or at least reference the data in Exhibi1:E so that the project-related changes in turbidity can be compared to State standards..The project is expected to reduce,rather than increase, turbidlty in th4!Susitna River during the summer,but winter discharges are FERC No.7114 15 -DRAFT EIS REVIEW ImPORT ·,'-.';-':-;. (.-.. .. "" expectll!d to increase turbidity.If Vatana Dam discharges are in the 10-20 NTU range,this could exceed State requirements for protection of secondary recreation and propagation of fish. The DI~aft EIS .does not state assumptions and data used to calculate the predicl~ed summer suspended sediment increases during construction.It should reference Appendix H (page H-45),which does contain this informlltion.IQuantification of impacts is useful,but the results are meaninl~less unless the assumptions and methodology employed are clearly stated or referenced. The Draft EIS states that large or long-term increases in suspended solids resulting from vegetation clearing and construction are not expected.Large increases in sedime~t production are possible on small watersheds where even limited construction can alter hydrologic processes.The value of the dOCumel1t could be increased if qualifying statements"w~re included concerning the relative importance of this type of impact. The Dt~aft EIS considers changes in only the average suspended sediment concent:ratious.Consideration should also be given to changes in peak sediment levels,which are often more detrimental to stream organisms. 4.1.2.4 Gas Saturation This section provides a discussion of the problem of supersaturation of nitrogE~n downstream of the dams.It asserts that if the cone valve outlet structtLre works as designed,supersaturation of nitrogen below Devil Canyon Dam will be reduced.APA has indicated that the outlet structures have been subjected to prototype testing,and t"hat further testing is now underway. The re!lults of this testing and any other substantiation of the effectiveness of the structures at controlling nitrogen saturation should be reported in the Re,rised Draft ElS.This information is critical to a clear understanding of the project's water quality impacts.If the cone valve outlet structures do not reduce nitrogen supersaturation as expected,nitrogen levels could .....exceed the State standard of 110 percent. 4.1.2.5i Nutrient~1 This se!ction contains a very brief review of nutrients in the lakes,which indicat:es that nutrients are not a II&jor concern.Review of APA license applics,tion data and APA responses to EPA scoping c01l!1llents that are backgrc1und to the nutrient analysis,however,indicates some significant incons1,stencies ~lnd data gaps in the analysis.First,it is unclear whether there SLre plans to clear and burn all vegetation in the reservoir inundation \areas p~rior to.filling of the reservoirs.There are conflicts in the intent FERC No.7114 16 -DRAFT EIS REVIEW REPORT ~"..""---:":::. .. -'--.-'._.. ( ..... - .- - .~ \. ..... o.S.ENVIRONMENTAL PROTECTION AGENCY as desicribed in the license application and the Draft EIS.The assumption used in the Draft EIS impact analysis should be clearly stated in the Revised Draft lUS. Second,the Vollenweider modeling approach used to predict nutrient condit;l.ons in the reservoirs is appropriate for estimating long-term eutrophication potential of reservoirs when they are phosphorus-limited,but it is not useful for predicting seasonal variations in water quality paramelters.Some of the phosphorus loading assumptions used in the model are also questionable.We recommend,therefore,that a ol1e-dimensional model (such as CE-QUAL-RI)be used to indicate potential problems in reservoir nutrient loads.This would aid in the analysis of different reservoir development scenarios. 4.1.2.6 Temperature The Draft EIS predicts that water temperatures below Devil Canyon Dam would be increased -by 40 C for late fall and early winter.It also predicts that temperatures would be reduced by 20 C for mid-summer conditions.The State water quality standards sgecify that -weekly average temperatures shall not increalle by more than 1 C.-This suggests that the State water quality standal~ds would be violated by the project.The Revised Draft EIS must contail:l a more sophisticated evaluation of these water quality changes to determ:Lne the magnitude and duration of the potential standards violation. It sholl11d also 4:ontain a thorough evaluation of possible mitigation measures to redluce the project induced temperature changes to levels that are in compliance with the standards. 4.1.2.:7 Other Water Quality Impacts The Dr'llft EIS does not identify which surface waters would receive wastewater dischal~ges during the project construction phase.While the water quality impact of these discharges is expected to be small,the reader cannot assess the v8,lidity of this assumption nthout monng the anticipated discharge point(s). 4.1.2.8 Ice Processes This brief section states that -ice breakup has a profound influence on the morphology of the Susitn&River.-It also states that -after the filling of Watana c01llDlenced,the effect of ice breakup on river morphology would be signif:Lcantly reduced.-The l.evised Draft EIS should describe how the morphology nIl be affected,with appropria.te references (no references are currently provi,ded)._Also,it should describe how the sloughs will be FEltC No.7114 -17 -DRAFT EIS REVIEW REPORT '.. """ ((. - 11, ,~~ - - ..... u.S.ENVIRONMENTAL PROTECTION AGENCY affected. 4.1.3 Groundwater This brief one paragraph discussion of groundwater should be ezpanded in the Revised Draft EIS and appropriate references should be included to support the st.atement that "the proposed dams have no impact on groundwater." 4.1.4 Aquatic Communities The Draft EIS iu generally deficient i~its fishery resource impact analysis» due in part toa lack of data on the existing fishery in the Susitna River. Without a quantitative assessment of fishery impacts 'it is difficult to fully evalual~e the proposed project. 4.1.4.1 Plant Communities The Draft EIS states that "reductions in summertime turbidity and stabilization of flows • • •could significantly increase genetic .aquatic plant and invertebrate productivity and thus food availability for fish." It sholuld state in this paragraph that this may be possible only above the Chulitlla River conflueuce. The Dll:'aft EIS s~ates that -Increased benthic algae and invertebrate produc1:ion on the submerged river bed would occur concurrently with a decreafile in wetted surface area due to reduced summer flows.-This stateDM~nt is misleading.Generally.a decrease in wettetli surface area is equated with reduced total production.We agree that improved water clarity may favor lower trophic level production;however»other factors such as changefll in water temperature and greater turbidity levels in winter (turbidity may damage overwintering invertebrates)should be considered. Also the Appendiz (p.1-62)concludes that ·summer temperature reduction may be sufficiently severe to retard growth of benthic food organisms"during operat:lon of both dams. 4 .1 .4 •~t Fish C01DllllUUi ties The Drllft EIS states that juvenile salmon growth from June-September could be neglig~.ble above the Talkeetna River confluence and reduced by 50-60 percent in dOWDstream reaches during reservoir filling (p.4-26).Reduced growth would be caused by lower water temperatures.The Draft EIS should discuss the I1W1lber or percentage of the salmon populations that might be affected. This discussion would require a detailed analysis of data that may already P'EllC No.7114 -18 -DRAFT EIS REVIEW ImPORT ...... .__.•._•..,:L ,;.,.•... (.(. - - u.S.ENVIRONMENTAL PROTECTION AGENCY exist or is being collected at this time.The discussion should also address the effect of reduced'growth on timing of juvenile outmigration and subsequent survival to the adult stage. The DI~aft EIS also states that early spawning pink and chum salmon would produce offspring that would emerge prematurely and would not survive the winter (Watana Operations only).A detailed analysis is'needed to determine the number or percentage of pink and chum salmon that would not survive and the effect this mortality may have on adult returns.Also,the discussion should expand 011 the statement that "later spawning salmon would be affected only slightly."'To what extent would sockeye,cobo,and chinook salmon be affected?Would the emergence period be shifted for embryos in slough babitall:s as well?What effect would early emergence have on 1)the ability of juveniles to feed in the river;2)juvenile outmigration timing;3)the abilit~,of juve:niles to feed in the estuary and ocean environment;and 4) overaLl survival? The Draft EIS states that changes in mainstem water temperature related to operatlon of both dams could have "important implications for the survival of the emigrating juvenile salmon."''l'his discussion should be extended to includtt the potlential number and/or percentage of each salmon species that may be significantly affected.Considering the magnitude of this impact, the Afj~ected Environment Chapter does not adequately address juvenile rearing in the Susitna River.Also,how will mainstem temperature changes affect reariDtt fish in slough habitats? The Druft EIS states that "'no combination of impacts has been projected that would reduce by as much as 50 percent any of the five salmon populations spawniIllg in the Susitna River and tributaries above its confluence with the Talkeetna and Chulitna rivers •••'l'his statement should be based on detailed analysis showing how the figure of 50 percent was derived. Estimates of mortality should be shown for each life stage that is affected.Also,the reach below the Talkeetna River confluence should be includ~d in the analysis,as juvenile growth in this reach could be reduced 50-60 ~Iercent. Although APA suggested that the Draft EIS evaluate the effects of high water flows ()n fish,the Draft EIS did not contain this analysis.Winter flows are explected to 'be approximately three times the present flolr level after dam. operation begins.Changes in fish habitat and possible effects on overwintering resident and anadromous fish should be evaluated. 4.1.4.3 Minor COZllDllents ,r-Results of the lower trophic level production analysis should be interpreted ~carefully when addressing fish production.Paragraph six,page 4-30 lERC No.7114 -19 -DRA.FT EIS REVIEW REPORT ,.... ••(.( ""'" o.S.ENVIRONMENTAL PROTECTION AGENCY -suggests that ..juvenile salmon production should increase"because of increalsed food production.Statements such as this are misleading because many other factors also contribute to juvenile salmon production. The Draft EIS states that ·Accessibility of tributaries to'adult salmon is not likely to ble a problem during June-September • •••This statement is incons:lstent with license application Table E.2.27,which indicates possible restriction of :fish access to Sherman and Jack Long Creeks.The Application also lists other creeks where fish access is a concern because of perching. ..... ,.... \: The Driaft EIS states that "some redd dewatering might occur in winter above Sherman during reservoir operations due to reduced ice staging...During project operation.winter flows are expected to be twice the present flow levels (see Draft EIS Fig.4-2).and it would seem reasonable that these high flows might counter the effects of ice staging.This should be clarified. The Drllft EIS states that flow stabilization (due to project operation)would reduce stranding of fry caused by freshet flows in summer.Normal freshet flows and runoff do not always cause significant stranding because flow attentULtion is often slow enough to prevent it..Gradual reductions in flow after a summer storm would ultimately depend on the permeability and absorptive capacity of the soils in the drainage. The discussion of thermal effects on egg incubation during operation of both dams is confusing and incomplete.The discU:8sion incorrectly leads the reader to believe that warmer water in the fall will enhance incubation success where it is likely that the newly emerged fry will starve during the winter.,Again I'a thorough analysis is needed.Also.the EIS should discuss,the effect of temperature changes in the mainstem on temperature in sloughs and the resultant effect on salmon survival. The DrlLft EIS'discussion on sedimentation of redds during dam operations is weak.The disc'ussion should focus on sediment transportation and deposition during turbid winter flows and how this might affect embryo and alevin survival in the mainstem.side channel.and sloughs.The analogy to the glacial lake is not necessarily evidence that alevin survival will not be affected by turbjld winter flows. The D~&ft lIS mentions a concern for successful reproduction in the reservoir.The discussion should be expanded to include those species that would 'l~e affected and to what extent water drawdown might affect future populations.The mitigation chapter (section 5.3.4)should address this problem when clliscussing a plan to introduce resident fish in the' reservoirs. The Dra,ft EIS cannot assume that adverse effects to salmon would be reduced because adult salmon might avoid the cooler Susitna River water and migrate FERC No.7114 20 -DRAFT lIS ltEVIEW REPORT r '.. (.. .. u.S.ENVIRONMENTAL PROTECTION AGENCY up the talkeetna River.First,there is no sound evidence that salmon will avoid the cooler water.Second,if salmon do avoid the cooler water and spawn in the Talkeetna or Chulitna Rivers,there is no evidence that salmon production in these rivers would improve.Numerous density-dependent factors could limit the survival of progeny from the straying salmon. The Aplpendix of the Draft EIS (p.1-64)discusses the potential for an increalle of mercury in fish inhabiting newly flooded reservoirs.It was concluded that mercury levels in fish would likely increase and could possibly reach the Food and·Drug Adminis tra tion ' s •action level·of 1.0 ppm (ug/g)mercury in the edible portion of the fish.This discussion should be undert.sLken in the main body of the EIS.Also,a mercury motti toring program was deemed necessary.A discussion of this program should be included in the mi t:iga tion section.. Finall,r,the Draft EIS states that increased fishing pressure is expected to be the major impact to fish inhabiting tributary streams and that ·Cooperative regulation of fishing activities or fish removal.• .might mitigat:e these impacts.·Fish removal may eliminate fishing pressure,but we would not call it a mitigation measure. 4 .1.5 'I'erres trial Communi ties The disicussions in this section are a condensation of material in Appendix K. While it seems proper to rely on an Appendix document to supplement F"descriptions of existing conditions.such an approach is not warranted for the impact discussion.An EIS should thoroughly discuss project impacts. Methodologies aDid background data are ideal candidates for presentation in ""'"appendices.but impact analyses belong'in the main text.The material in this section has been condensed to the point that the biological implications of project impacts are not always apparent • ..... The imp,act discu,ssions currently presented in Appendix K provide a generally adequate analysis of construction and operational impacts of various project features.These discussions give a better perspective on the magnitude of impacts than do the discussions in the Draft EIS text.Construction period impacts and impacts of increased access are much more thoroughly addressed in Appendi:x K than in the main EIS text. - Both Allpendix It and the Draft EIS text treat the issue of poaching very lightly.This impact warrants additional discussion in the R.evised Draft EIS,given the extended period of project construction with about 5.000 people living in the construction camps. The Draft EIS does not contain the results of A2A's moose habitat modeling efforts.If the model has been completed and checked for accuracy,the nRC No.7114 -21 -DRAFT EIS REVIEW REPORT (i ~ ! ·'.( U.S.ENVIRONMENTAL PROTECTION AGENCY Final :EIS should contain some quantitative assessment of project impacts on moose.The mile wide mudflats around Watana reservoir would have more than visual impacts.There would be permanent impacts to terrestrial communities as well.These impacts should be identified in the EIS. 4.2 NATURAL GAS-FIRED SCENARIO Our experience modeling gas turbines has indicated that the plumes may be subject to building-wake induced downwasb.The use of the EPA 1SC Model (EPA-450/4-79-o30 and 031)has therefore been required.PTPLU does not simulate building-wake induced'downwash.Also,PTPLU does not compute concentration as a function of distance.Therefore,.the model could not have been used as was indicated for predicting maximum concentrations at specific:locations.' CS,~4.3 COAt,-FIRED SCl~NARIO .- 4.4 COMBJCtmD HYDRO-THERMAL GENERATION SCENARIO 4.4.1 Air Quality &Noise .r- \." One of the sources of potentially major air quality impacts not fully considere.d in the Draft EIS is the expansion of the Usibelli Coal Mine.Each of the alternatives that includes coal-fired generation should incorporate an evaluation of this impact.Increased coal production at the.mine may lead to a significant increase in fugitive particulate matter emissions. Emissions should be considered as a function of activity,(e.g.,blasting, loading,transport,ation,etc.),and meteorology (wind speed,precipitation, etc.).Particle size distribution and deposition should be considered in· FERC No.1114 -22 -DRAFT EIS REVIEW REPORT ... ( U.S.ENVIRONMENTAL PROTECTION AGENCY determj~ning th~effects of these emissions on ambient total suspended particulate levels and visibility in the area.These potential impacts are especi.s~lly criti.cal in light of the close proximity of the mine to a PSD Class I area;t:he mine is approximately ten kilometers northeast of the Denali National Park.Additionally,if the Beluga Coal Field could be develo}:,ed as a fuel source for any of the coal-fired power plants,its air qualit"impacts should receive the same type of evaluation. Other air quality impacts not fully considered in this portion of the alterna,tives analysis are the potential effects of sulfur dioxide (502 ) em1ssiolns.Environmental effects,such as 'damage to lichens,due to SO , may occur at ambient concentrations which are lower than the air quality s.tandaJ:'ds.Since coal-fired power plant emissions (primarily 502 and NO ) are known precursors to acid precipitation,the potential for acfd precip1,tation and its associated environmental effects must be evaluated. At leaot screening estimates of acid deposition should be developed and the sensiti,vity (buffering capacity)of potential receptor areas should be discussed. Additionally,expanded development of the Usibelli Mine could have adverse noise eiffects from increased blasting and truck movement.The Revised Draft EIS should use available screening techniques to develop a worst case estimate of the extent and magni.tude of this potential impact on Denali National Park. 4.4.2 Water Quantity and Quality The Dra,ft EIS does not contain enough background information concerning flow and water qualjlty to accurately assess the potential impacts of this alternative.For example,information concerning the water quality of the Snow lU,ver and reservoir hydrology of the other non-Susitna hydropower sites is inStlfficient to forecast impacts.More complete knowledge of existing conditions is necessary prior to assessment of impacts. Each of:the project alternatives that would rely on coal-fired power plants could have significant impacts on water quality at the coal mining site. This is a major omission from the EIS'analysis.While the impact would be difficult to quantitatively assess without knowing the exact location of mining activity,the Revised Draft EIS should indicate,in a qualitative sense,that significant water quality impacts can be associated with coal mining.Addi tionally ,the evaluation of the power plants t direct water quality impacts suffers from some serious omissions.It does not currently address the potential water quality problems which could result from the need to displose of fly ash,bottom ash,and scrubber sludges.Absent specific data,a worst case analysis would also be appropriate here. nRC No.7114 -23 -DRAFT EIS REVIEW REPORT . ""'" ...~". .,- .--._·0. ("::-',.c ," .- ..... u.S.INVIRONMENTAL PROTECTION AGENCY 4.4.3 Aquatic.Communities Although the Draft EIS attempts to address the relative impacts of this alternative (hydropower portion only).it is obvious that additional information is needed.How many adult salmon spawn in areas above and below each dam site?Where are important rearing habitats located?What are the expected changes in water quality and salmon hAbitat?The Draft EIS states that s.s,lmon migration blockages could result in salmon losses greater than those from the proposed project.The EIS should base this statement on a few fal:ts.The Draft lIS did not discuss impacts related to thermal project:..The levised Draft EIS should do so for a legitimate comparison of alternatives. 4.4.4 Terrestrial.Communities The dililcussion :In this section is too generalized to allow more than a superfi,dal comparison with impacts of the proposed Susitna project.The Draft l~IS notes (page 2-41)that fairly detailed site information is available for thE~Chakachamna site.Additional detail on impacts associated with tbat site would be useful as a point of comparison with the Susitna area. 4.5 COKl~.ARISON OF ALTERNATIVES 4.5.1 Water Quantity and Quality The information presented on impacts of project alternatives is inadequate to allow meaningful comparison of alternatives.The assumption that total impacts would be a function of project size may not be accurate.Page 4-71 of the Draft lIS states that the Watana I-Reregulating Dam alternative (the -smallest-alternative)may have a greater impact on suspended solid concentrations than the proposed project.yet this alternative is rated as having the least vater-related impact.The lIS should present specific impact analyses for each alternative and a table which allows direct coaaparioon rather than ranking alternatives solely by the nUDlber of river miles affected.Without this type of analysis.the lIS simply does not provide a clear environmental basis for the Staff's second tier .recommendation on Vatana I in Chapter S. ·lE1tC No"7114 -24 - . 'DRAFT lIS REVIEW REPORT r - £1'\..;( "' \, ". ( u.S.ENVIRONMENTAL PROTECTION AGENCY 4.5.2 Aquatic Communities Additional infoJ:~tion is needed before the XIS can conclude that the non-Susitna River hydropower alternatives would have less impact on aquatic co1lllllUJ:lities than the proposed project or alternate versions of the Watana and Devil lC&uyon Dams.The XIS should make some attempt at quantifying the combined effects of the non-Susitna hydropower alternatives and comparing them to the Susitna project to support this conclusion. 4.5.3 Terrestrial Communities Given the lack of detail in the information available about alternative projects,this section is generally adequate.It would have .been useful, however,to have had a basis for comparing wildlife impacts using a measure other l:han gross acres affected by project construction.It is unclear whether enough information was available to perform a screening-level analysis using the U.S.Fish and Wildlife Service Habitat Evaluation Procedures (REP)model for such a comparison. nRC No.7114 -25 -DRAFT EIS REVIEW REPOR~l::....--_ .. .".'II (, -,-...~...- c' 5.1 RECOMMENDATIONS u.S.ENVIRONMENTAL PROTECTION AGENCY Cbapter.S ST.AFF CONCLUSIONS ..... 5.1.1 Plower Generation The FElRC staff bas recommended a mixed thermal-based generation scenario based cln considerations of engineering feasibility,economic characteristics, and en"4 rironmental effects.This conclusion is not supportable based on the analyses provided in the Draft EIS. Engineering feasibility was addressed ouly incidentally,with no co.parison of the alternatives.With the exception of a brief analysis on the Susitna Project,potential impacts of the alternatives on the operation and reliability of the existing generation and distribution system in the Railbelt are no It:discussed.Also,the statement that "such an approach (mixed thermal-based generation scenario)would provide flexibility in systems planning and efficient fuel u'se to cope with the uncertainties of population growth and generation require.ents"is not supported by any discussion in the Draft EIS.While we agree that a staged project would provide extra :flexibi11ty,the body of the EIS should provide Sa.8 description of this flexibility and its effect on the planning of future power supply to support the statement in the staff conclusions. The ecc)nomic characteristics cited in support of the recommended mixed thermal-based scenario are based on highly uncertain economic conditions and quest.iola.able assumptions regarding future price behavior of oil and other fuels.The maj10rity of forecasts available suggest that the price of oil and related fuels will increase at a considerably higher rate than the rate assumed in the !ERC analysis.Inclusion of the higher rates would dramatically alter the results of !ERC's economic comparison of alternatives.Moreover,the statement that "thermal generation costs for .the 1IIedium load forecast are approximately 7S percent of the costs of the proposed Susitna develop1llent on a levelized,total annual cost basis"is _aningless unless the assumed discount rate and fuel escalation rate are lEllC No,.7114 -26 -DRAFT EIS REVIEW REPOllT -~.. ..... - 4 4'...-..' ,~.( u.S.ENVIRONMENTAL PROTECTION AGENCY .... stated..The s1l1bsequent statement regarding the impact on consumer energy costs Jtrom development of several plants versus the large capital commitment needed for the Susitna project,although important,is not supported with any analysls in the Draft EIS. Regardlng environmental effects,the conclusion that the alternative hydro and tbermal scenarios would result in generally fewer adverse impacts than the Su.sitna project appears to reflect more the degree of site-spec1fic information available for analysis of the Susitna project than the results of a cODqJarable assessment of project alternatives.Little site-specific envirollDlental setting data or impact discussion are provided for thermal or non-Su,dtna basin hydro power plant sites.This makes the FERC.contention that'the dispersed impact of a number of smaller facilities would be less than the full Susitna development generally unsupported by the Draft EIS.The cumulative impact of a number of independent power projects could be considE!rable,depending on location and nature of the developments. FERC sltaff further recommends that ·should any hydroelectric development be authod.zed in the Sus1tna Basin,it should be licensed and constructed in stages • • •The first stage of this development in the Susitna Basin would be the!Watana I alternative ••••The Draft XIS does not contain a discusllion of the rationale for selecting Watana I as the best choice for a first phase project.It is not clear whether this option was chosen for its econom.:J~c,environmental,or power generation advantages.The Revised Draft XIS should provide the rationale for this staff recommendation. 5.1.2 Flow Regulation The nRC staff flow regulation rec01lliD.endations appear to be appropriate. The ac1:ual effect of the minimum flows and proposed spiking flows on spawning activity in the main river and side sloughs will not be determined,however, until the facilities are in place and operational.We recommend that A2A develol'a monitoring program for postproject spawning in side sloughs. Spawning counts should be performed and compared to records of past spawning activity.It will be important to determine whether the 12,000 cfs minimum flow and 20,000 cfs spiking flow are successful in keeping side sloughs available to spawning salmon. 5.2 M!'l:IGATIVE MEASURES The Draft XIS'discussion of mitigation measures is generally lacking in terms of specific proposals and indications of the effectiveness of the FERC NCl.7114 -27 -DRAFT XIS REVIElJ REPORT ..- - - - ..- ; ..- \ .., U.S.ENVIRONMENTAL PROTECTION AGENCY proposals.At sever~l points,the EIS describes ongoing efforts to develop mitigation programs.It is difficult to judge the effectiveness of mitigal~ion measures that are still in the formative stage.We recommend that 8.detailed mitigation plan for all of the proposed projects'adverse impactJI be incl!oded with the Revised Draft EIS.Agencies or organizations with plr:imary responsibility for implementation should be identified with each mit1ga1=ion measure.Accountability should be established if implementation of these measures is to be ensured. 5.2.1 Water Quantity and Quality Several mitigation measures are discussed briefly.References should be provided for more detailed discussions of these measures.Considerable attentlon is devoted to implementing a -spike flow-release schedule during salmon spawning.No discussion is provided regarding prevention of possible drownings .of sport fishermen or others during these releases.Even with elaborate wamiJlg programs,deaths can occur from sudden releases from dams.This factor must be considered,since this measure may therefore not .be prac:tical. 5.2.2 t.and Use and Ownership Chaptez~4 describes the adverse secondary impacts that could occur as a result of the Susitna project.We support the PEllC staff recommendation that all access plan with site access only from Gold Creek be approved,if a license:is granted for the project.However,the Draft EIS indicates that even wj~th appropriate land management practices,secondary development would still Clccur.This suggests that in-lUnd replacement or restorat:1on of lost habitats should be evaluated as an additional mitigation measure in the Revised Draft EIS. 5.2.3 Aquatic Communities APA's r'esponse to EPA's scoping recommendation C.63 is that -there will be no net 10S8 of fisheries resources as a result of this project.-In support of this statement,several mitigation measures have been developed to minimize and!or rectify lmpacts to the fish resources.However,as the Draft EIS 8tates:-the long-term effectiveness of mitigation measures ~emains unclear.-Several problems affect the reliability of the mitigation measures.First.,there does not appear to be adequate information to assess present populatilon sizes,yearly fluctua1~ions,and use of specific habitats by sablon and other species.Second;.such information is generally beyond the scope of any construction impact statement.Third,assessment of resource losses caused by the project would also be difficult,if not PERC No.7114 -28 --DRAFT EIS REVIEW REPORT ..(. - r i ! - -(- - - - u.S.ENVIRONMENTAL PROTECTION AGENCY imposs:Jlble,to quantify accurately.Therefore,careful interpretation of any mOldtoril1g d,ata must occur during project construction and operation. QualitJr control of such projects is essential.Several agencies and/or neutral consultants should review the monitoring programs and results in detail..Quarterly or annual reports should be prepared to assess the adequae:y of the mitigation measures.AD essential element of the mitigation should be establishment of minimum flows in the river for purposes of protecting the fish resource.Identification of these minimum flows is necess~~y to assess the overall impact of the project on anadromous fish. Althoue:h avoidance,minimization,and rectification of impacts is preferred, it is lprobable that compensation for the impact may be needed.For example the DrllLft EIS states:-there are no specific plans to mitigate losses in fish growth due to low temperatures in summer or to rectify or compensate for loss of Ye.lllrs.•Similarly,there is no mitigation ~easure suggested to compensate for loss of juveniles due to premature emergence during winter or due to loss of habitat created by woody debris that normally originates from above c~m sources,or from streams that perch.These factors suggest that artific:ial prop'!lgation or habitat enhancement should be evaluated as mi tiga t,ion meaSUlt"es. 5.2.4 'I'errestrial Communities The DrllLft EIS has identified significant impacts of the Susitna project on area wildlife.The mitigation discussion indicates simply that mitigation programs are being developed.An essential part of the environmental analysis in an E:IS is its analysis of possible mitigation measures in terms of their potential effectiveness and ·costs.Consequently,the mitigation program.being developed by APA needs to be described in detail (in an appendix if necessary),including details of the moose habitat carrying capacity model being developed. Discussions in the Draft EIS and Appendix It make it appear that the U.S. Fish al1d Wildlij~e Service HEP model will be used or perhaps modified to provide some of the analyses of mitigation 1D.e.lIlsure effectiveness.The BEP procedure is a very useful tool,but the internal mathematics of the model have the potential for producing biased results if the model is not used carefu~ly.The EIS should document any HEP analyses that are being done. If REP analyses are not being used,then the procedures being used must be thorouglbly explained so that results of the mitigationprogralll can be properl:,evaluated. FERC No.7114 -29 DRAFT EIS REVIEW REPORT •••""'" - - ..... ..... ..c· U.S.ENVIRONMENTAL PROTECTION AGENCY Chapter 6 EPA'S FIBDIRGS AIm COBCLUSIORS 6.1 DRAFT gIS ADEqUACY We haVEI concluded that the Draft EIS is inadequate;that is,it fails to meet the basic requirements of the National Environmental Policy Act of 1969 CHEPA)and the Council on Environmental Quality's (CEQ)regulations governing the implementati10n of NEPA.[40 CFR Part 1500].The Draft EIS simply does not provide an analysis of alternatives which is thorough enough to resolve the issues which are ripe for decision at this time.Consequently J we believe that a Revised Draft EIS must be prepared before a Final EIS is developed for submission to the Commission.The omissions in the Draft EI5 are so serious that we bel1evethat this approach is the ouly one fully capable of resulting in a F:Lua1 EISwhich can serve as an effective basis for the Commission's hearings on the merits of the project and the alternatives.The major errors and omissions which must be addressed with a Revised Draft EIS include: 1.Tbe economic analysis of alternatives 1IlUSt be revised so that consistent fuel price assumptions are used to evaluate each alternative.The analysis should include a sensitivity analysis which sillows how the results change as predicted fuel prices increase.FlRC sltaff DlUst provide thorough support for its recommendations regarding wlaich forecast or range of forecasts should be used for decision making pll1rposes • 1:Lna11y,the economic aua1ysis should be revised so that it reflects tbe full cost of complying with environmeuta1 standards. SJ~ecifically,the analysis of coal-fired power plants assumes a much lower level of air pollution control than EPA has ever approved for a cc)al-fired power plant in the Pacific Northwest or Alaska.The ana1ysi8 should assume that 90%continuous removal of 502 would be required and should include scrubber sludge disposal costs. 2.The chapter on the proposed project and alternatives needs to provide me No.,7114 -30 -DRAFT IUS REVIEW llEPORT -------~.. .....-.,. ,-,----i -• u.S.ENVIRONMENTAL PROTECTION AGENCY- more deta:lled descriptions of the alternatives so that more specific estimates of their potential environmental impacts can be developed for the Environmental Impacts Chapter.Additionally,given that the FERC staff is recommending an access plan which essentially eliminates the license applicant's recreation plan,this chapter needs to contain a new recre.ation plan which is consistent with the staff recommended access plan.Finally,this chapter,in accordance with the CEQ It''egulatioD.s,must contain a summary comparison of the environmental :Lmpacts of the alternatives based on the revised impact analyses. - ""'" 3.The Affected Environment Chapter must be revised so that it provides more infol~tion about the potential sites of the alternative projects lihich make up the alternative regional electric energy supply systems.Specific locations for alternatives should be identified. Data on habitat types,flow regimes,the quality of receiving waters, and general land use patterns should be provided.This information is ~~Bsential if the EIS is to provide .a meaningful framework for ~~valuating the significance of the impacts of the alternatives. 4.The Environmental Impacts Chapter needs to be revised to correct the several errors and serious omissions noted,in detail,in this I~eport.These revisions must address the potential water quality standards violations we have noted.They must also address in 1=lotentia11y serious impacts of coal mining and coal-fired power plant tlTaste disp,osal. 5.1he Staff findings and recommendations chapter should be revised to reflect the revised analyses.At a minimum,it needs to be reworked 8:0 that it is fully consistent with the environmental analysis results t,o date. 6.2 ENVIRONMENTAL RESERVATIONS EPA is required by Section 309 of the Clean Air Act to determine whether the environmental impacts of proposed major Federal actions are satisfactory from the standpoint of public health,welfare,and environmental quality. Although the Draft EIS'analyses are too incomplete to support a firm or final determinat:Lon on this question,we have concluded that we have serious environmental reservations a~ut virtually all of the alternatives evaluated. The Draft EIS suggests that'the Susitna project could result in significant water 4~uality standards violations,major adverse effects on anadromous FERC No.7114 -31 -DRAFT EIS REVIEtJ REPORT c ......'"_,.( o.S.ENVIRONMENTAL PROTECTION AGENCY - ...... .-. I ,.... fisheries,and serious consequences for terrestrial wildlife.Additionally, it could result in major losses of wetlands habitat.The other alternatives appear to have a significant potential for serious adverse impacts on air qualit)r,water quality,and fisheries.EPA will not be able to make a final determination until we have received and reviewed a fully adequate Pinal EIS • PERC No.7114 -32 -DRAFT EIS REVIEW REPORT -' ...."II I..,\~'.. ,\..,.((. -- A.l Appendix G u.S.ENVIRONMENTAL PROTECTION AGENCY Appeudix A APPlHDIX COHHEH'tS .- ~ I ,..... I - Page G-'12,G-l3,G-l4,and G-29:The correct name for the first author of the User's Guide for the ISC Model is ·Bowers·,not ·Bowles·. Page G-·1S andelsewbere:It is implied that ·one day's meteorological data" was input to the PTPLU Model.PTPLU uses a wide variety of assumed meteorological data to estimate worst-case conditions as a screening technique.Actual meteorological data for a given day can not be input to predict a maxiDreml impact. Page G-'17,G-l9,and G-l8,Table G-S:The emissions from the gas turbines is described in the text as being ·very hot",while Table G-S lists theo0temperatureas3:50 F (450 ItJ.This is relatively cool for a gas turbine;gas temperatures of 800 to 1000 It are not uncommon.The proposed turbines must have some sort of heat recovery.The'high buoyancy of the turbine plumes is due in part to the large volumes of gas. Page G-20:It is stated that PTPLU was used to model three sources. However,PTPLU can only simulate the emissions from a single source.Were all of the emissions from the three sources assumed to be emitted from one of the 8t~lCka?To accomplish a more detailed analysis of complex terrain impacts the appll:'opriate model for use is COMPLEX I,not VALLEY.Hourly on-site meteorological data can be used in COMPLEX I. Table G-8:The estimated Good Engineering Practice (GEP)stack height of the proposed coal-fired unit i8 472 feet (the building height plus 1.5 times the height or width,whichever is less).Since the proposed stack height is less than the GEP height,the potential for building-wake induced downwash must be considered (that is,the ISC Kodel must be used). FD.C No.o 7114 -33 -DRAFT EIS IEVIml REPORT • ((... \ - - u.S.ENVIRONMENTAL PROTECTION AGENCY A.2 Appendix B H.l.2 Habitat Types The listing and definitions of the habitat types are inconsistent and incomplete.The text lists seven habitat types,but Figure H.1-3 lists only six.The text also describes only three of these seven habitat types.No explanation is given as to why the other habitat types are n"t described. In order to accurately assess potential habitat alteration,a clear understanding and description of the resource are needed. H.2 Flow Reg±mes H.2.1 Preproject Flows The caption for Figure H-2-3 indicates that curves for the Gold Creek and Sunshine gaging stations are shown.However,the legend in the figure indicates that the Susitna and Gold Creeks are shown.Either the legend or caption should be corrected. H.2.2 Postproject Flows Companion figures and tables are provided for postproject conditions for comparison with figures and tables given in Section H.2.1 for preproject conditions.Some comparative discussiol18 should also be provided to the sparse one paragraph text of this section.For example,a brief discussion of the order of magnitude of flow changes would be useful. H.3 Habitat Alteration The methodology employed in this section appears to adequately address the question of slough habitat alteration.The appenc:lix should,however,also include a discussion of the alteration of other habitat types.In addition, there should be a SUDllll8ry sectlon indicating how the results obtained from the sampled sloughs relate to those sloughs not sampled.Some discussion of potential substrate alteration would a180 be useful in assessing overall habitat changes. me No.7114 -34 -DRAFT EIS REVIEW REPORT ------_......"""""......_.._------ '.:-,:,,~,-.'----~.,' ,.•J A f~"-' ~...),\,:,"- c...'.",,. u.S.ENVIRONMENTAL PROTECTION AGENCY B.4 Temperature No discussion of the results,findings or conclusions of the temperature modeling for either preproject or postproject conditions is presented in this section.As a minimum,a reference to discussion of temperature effects in the EIS or License Application should be provided. B.S Surface Water Quality B.S.1 Salinity A brief one paragraph description (plus two figures)is presented to describe salinity in Cook Inlet.Some mention of postproject salinitY conditions should also be 1IIB,.de. B.S.2 Suspended Solids - Table B.S-1.should include the assumption that the DEPOSITES model does not include sediment contributions from reservoir bank failures.the same approach utilized in this section should be applied to the Devil Canyon Reservoir so that overall impacts can be addressed. B.S.3 Nitrogen Gas Saturation This section provides a realistic discussion of the possible supersaturation of nitrogen due to air entrainment in the Watana outlet works.This discussion suggests that the Alaska Department of Environmental Conservation (ADEC)standard of 110 percent saturation is likely to be exceeded during excess flow conditions,even with the'installation of the fixed cone valve outlet structures.This section does not include a discussion of the data, which show that this standard is exceeded under natural conditions during high flows,nor does it mention the effects of the Devil Canyon Dam. H.S.4 Nutrients A brief (two paragraph)review of the nutrient levels in the reservoirs in support of the applicant's modeling results is presented.The statement that the lakes will have turbidity (and correspondingly low phytoplankton production)is not well supported.Suspended sediment size distributions (Figure 1.2.80)indicate 80 percent to 85 percent of the suspended load is silt and sand which should quickly settle in the reservoirs. FE1lC No.7114 -35 -DRAFT EIS llEVIEW REPORT ----------.....,;.¥........------------------_.------------------ .( .- - July 20.1984 (-0 u.S.ENVIRONMENTAL PROTECTION AGENCY SUSlDA IIIDROELXcmIC PKOJEC% :FEIC PKOJEC%HO.7114 DRAFt DVIKORIm!iTAL IHPACr STA'I"EMEH'r UVIEW UPOItT -, .. ~.,-------_........_~-------------------'~ r ", t:*'. I ":I 1-1 \,ll.i _ .---- ~.......; ,.. Iitr.tIa"J.tobin,oa '.de~al lue~&1 taaulltoty Co.aiaaLoc W.al1L~t~,DC 2'0246 Dur lIf'.lobLlltoo.:· RECEI\lED SE:P 12 1984 Pi1fsbu'Y,Madison &Sutro .... ("'1-,r~~~..~...... ~.--,.I-.r '.() c.'_t '..Z:.t •.- ~ (.:...Q:t ..' i, The C~~ctl hi'receiYed a copy of the ~.f~Ecvi~oam4nt.l tapaCot S~&t ...n: (~tS)011 the su,tta.a '!1droclectri.~l'roject (me Projec.t !to.7114-Aluu); I ca writlna to offer our ca.-ent.on this 4oc~nt.thete ca.=ent.Ihoule uot ~.c~fga.4 wlth the co.aeatl of tbl Couc~il that FtAC .~.t r.~~.lt ~~....t to Section 105 of the Klttonet KLltorLC P~~.e~V&~LQ~Act .~d O~r r~l.tLoa.(36 Cr!Part ~OO).We are.however.pre~red to c~n,u~t pf'oaptl,with FIle Ind the Al ••~&S~.te at,tori,Pre ••rvacion OffL_er a. aOCla a.ft~illitLaCel the revtew proc..s called foC'by o...r rCi.lh~ioJ.\i" ,.'you "1 kaow,O"Per the t~.t two year.ve h.....easasee l.n tl:1!orul cOf'coet,oodeacI "lttt P'!_e.the Aluka POWe:'A~~hortt1,~he Atu'u S:.a:e llL.tQ~lc Pr....natLoll O!fi.~e~'-'1~O)u,d o~"ers resudi.c&t::he S~.~tn& projecti our .pe<ttLc .rel of concern b••been the ,o~lider~:loQ'o! \iltor\c pcoopertt •••with Ipeci.l reference to ~be yer1 hlab CQ.t~th.t k",."'Ie coeported ta c:oaDe~t1oa "ith the haadlLD.i ;;,!~rc;.c':'~Q,~_&l •~r:u tn cbe S~ltca p~oj.ct.We are plea.ed to aee that &c~~r ~~~~r CODc:e~are a4d~.t'14 In tbe DIIS,~rticul&r11 ic Appeadiz O.fJe are ,te&.Md to tMC""ft that effortl b.lYe be.a u:ie to focus &rcb.&otolic&~.~rv.Y GO .r...tb4t ~••a p~ob&bilit1 of cont.ini~biatoric prQpert~e••th&~ FedLed..-at l't tltodc property diler i.but toa b.ne beea cieveloped &:l.:i ~lioed •••d t~t \tatoric propertie.tbat .re aot &(cbeo1oz1e&t lite.bAve -etC _a ip«.4 to the estlat 'lI&&esr:ed by earlier 4oclAen:•• ~DCIS ia.Lcat••clearly th.e a coc.i4er,bt.au.~r of hiihly .ii~ifi~&Qt .re~eolO1icat .tt••witl be aff.cc.~by t~e S~.it~Pteject if t:pro~ee4s ••pre•••el,plaD.eel.Of ap6cial iaportl\ace it ttle fact that lIola.y of Che stte.coccaLft ict.:st~atirLed cultur&l 4epostCI aa~4epoai~.of ?QLC&CLC t.~r.or a.olL4c cl'90.1t.~aa~i~detailed &Ie deterat~tioQ po ••L~le. ~•.t OD ,relect .o<~oct4lion it appear.tha~the .eaeral Approacb to la~ct-=itt:.tlo~propocad --~lY.&e .z=&v&tlo~of .ites lubjeet to -oat dl:eet project ,tfecta.aAd proeeetLOQ ia-~t.ce aad .oottort~~ho.e ...bl'c.'0 aor.lul.....!fa•••-h .......bla.~~ ~'Io riO 0375 ~-------------~~-------~----_._-_._- - / ,-. "--'.~ 1'-~ r . - • ·r 2 'k ~ebftt:i.ftft to !'\aye coacet"I'U abellt th.&HrOach..lMlo.&tauc AM "f'e~.~,~t'.n.u COftc.t't'tI ::t~..:rat 1:fall La.tQ two c.t~i1a,: e~~~~••~t -~r\itl·••tola:-Ot'"ao~.t~a.ILv •••r~b.Ql~l;at WQr~ ~ft i,-.c.s••~••~~OGcerftl .~ue th,potltbil1t1 thAt cartA~c ~.e4re••~~'OQrc••alue!wtll ~l:n~.~~r ~~~;t.la..~trlc1Aa.~ C ...l~t'4t\.0I1.• . r.:ta ~r n.tilv of .f.rU.r 40clllents en the prQj~~t '"wer.<:1J11l:ern.d .'bOllt :btp\teat lO1'lI tl\at laO ~re.t\t of ilver,land sur face I\,l,bj IC~to IQ)'kLtld °~ .H.'Ct W'O ..l.d \e lubjected to pl\ysica't tnapeel:tou for htltQrt,propul:tu l ~.rdte,s of the lt~etthood that an,thLnl would be !Q~n~.rhi D~!S =akl. i~cl.eat'th.!~thl,.ot"t of over\L1.l it not occurrlQ.&.S\lrvey tl 11Je 1a~ C'C'Ilpl..te,bQllreTet',anc!c&re ahoatd be t&~en tQ enlu.r&that t c con r:l.nl.Lal co ~I~i~ed by t"e.ponstble prediectve ~odets or hi.torie ~roperty clillt~t"tiO\1" It att-t-t-IeC1"to be anttdpace""4-tbat:all arcbealQit:d s~:eI .u~j~·.;~:'..J .i~et blpacts vll1 be luhjected to archeoloateal .~lv~ae ex~ava:iQ~(Sec.5.'.').Ue atroclt,rec~end thac this el~ct.tion be re-.Ya1~:.J. U~;~e.tioaab11 the tittt aubjeet to ispact eon!tttu:e an i=p~~t.nt r~'earch rut'ftce.and should be treaced a!such»bu:i.r does no:nec:eu~r~ti !\JLt.). t~.t ..eh Ic4 e.er1 o~e .hould be eX:lv&ted.etther wholly jr in P&~~. ~.t t.l1eeded,and whIt haa yet to be provided.ts a 'YI=e~ttc:. coa't'e~enll.e re.earch propolal that seek.:0 o~:Jt~~~xt,~ule!~:~ca r:o addre ••d~ft.tr.bl1 ,iiOifielut r~.e&rch q~e.tionl thr~u.ih ~e o!:he .t~.1 that "ttt be lOlt.to ~ar expedenee it is unu.ll.l.al ~jr llol.:h a releareb project to requtre ~xc4vation of .11 aices,Ie any ey~r.c,ic ahoald not be I ••~.d at the outlet that all ,ital lubjac:to dir~~t ~~fe~t wilt be n:c&..ate:4i to""extent and tuture of U::IV.C tor.i~.,J~:';b~~~::.er~~i~e~ by tll.reqIJlre..ntl ot the ruelr:h delli.g:1... v.allo quutton V'hether it ahoutd be auto....c tCllly IISu:le1 :'"~the Ii ~:'H ~.,;"ject to ~let.Ct '01 road.lad tro&alstllion !tne.cae buc bit pc.)cec:r:ed throach I.,ol.daace &nd .00 tcortU&(Sec:,5.3.9),Par ~i.c~larly wi:h ~latL..t1 I~tt,QQcaapltc4ted titea,Ivoidance may ~e mere ~xpea~t~e ~~i~ l!:Iu l"'ec~et'1.ad wtle:'e I i.te.vi ttl aubltact ill sl,Irface cepoa i.:i &:'e ill'Pot ••d ••"ol4atlce by construct Lon ma,Qal1 leave the s ttllS o~e::l to .'I1lda1t ...V."Hen that flexibility IhQ~td.b4!lI.i~nt4i.n.c!ta de:~t!ia& bow to treat Itt••lubject to .web effect.as thol.o!road con.tru:tt~n 11lld tl'aa••tlllLoa.Un••,eo that d,,:a.recovery (an oe emplQyed where ."ropr\&t•• !!In,ffteie1l'cl,.eou tdend ruourcu Fil'lc.it .hou14 be aoted t~at .u~y.y i~not yee comp:.:e on certain .:L.eo.tl ot t~.project;th1.l1 .oae o~the Haurel itven ia Seccion 5.3.9 .~.certatftly noe co~r.et and should be e~~ecte~~o rise.!~.bo~ld no:be .Z~~t.~l tor eza-pt.,that only 11 .~cheolo!~~at and h~ltQrLC sLtes ~tll ;.I~~j.cc tQ effect b,the cr.n••t ••ion linea (5.3.9).liace 0011 p~tt.tQ.r,work hal beec do~e on lose co~rtd~rt and ~~r.~ork i. appar.ctly ~t.rva,CApp«ndtx 0,Se~.0.I.l.5.!). ..- (t..c:O'ftd,"l1!"e e~eerced a'eJo ...t.t""fact t"'.t w ..l:l .~el..&&tto=of L&lN,tl i. ~~t~t'Qi!l,1Mt,.t":~eeta::tet.t ut,,~..fue4.~h .~ad &.",o~4.a.~c..At •.)fuea.td ,u ~i~.QUe t,",,_ar"".O~n7 .~C'Oj)rut.optLou for ~tQJo)Q~tl..of .~te::{f:.l .~tC'Qn.t~,.ares nat c~cuu,r!II ...;~r-~pt'14tA tQ~ ~f't{••'Of ...oci.t\O"',t,ll"cbittct ..rd.~hnrtQ4.or c.lt~.~ ~~..-ee."••~tt'"ft ••r-alocatto~,.'la nCQrT!s':tCln &ra·"Q~.th4 -..1:.1.(Heet""opt(01lt t"at _,.b.&~rO,rl6t.tor .~b profMrt.L&I.tt.o~& ee..{~.r.ttoa '~OQla ~eiY'la ~o Qttl:ltto~o9tton.&lP:09rL&t.!or ~b. ~..~ttoe or BOft-.reheolocLcat blltorlc y&L~'t l,..ci~lc&ll1 laclw4i~ :&ftlti.t..etoCf'at."hto~i.c,t.noll l(nt....i.Dertc&Q ~~l;loLr&1.vdla&.• ~lr.,..ar••orr1 to lee a l.c~of coordiaatioQ lo th ..OIt$bl~w..~ coatlot.rltiOC'of -.oe:LO'lCOn04LC:r4e tor,"aud "c~ltl,&rd rtlo\l:,ctl."·\It a.ot. wtt't~tere.t.for ex..ple.that ·non-~~ttyC r ••idtQCI vll~th.LIQlACtd. nral .ettla.;......ot th.It'ea .Ill!thlt ......c~HIolrat cOfiflict••stlt Ln cbe S ...it".'-atn ar.a -on.:thol.1ft\O chl••••1\\La.tLl\&Ind n,htQ.&fot't'Iolu1 c,.ta.aed t~.d\tt~ll uses ••••others compe:Lna fc~tbe I~e h~rve,:••lod ;'O'"f'a.e"t _:eael..;.•"(Sec.3.1.8.1).Dc the ..vd~d i.lollted rual ••tttas~O~trw••th ~tch t'f'lditlonal or cu.Caaary .ubli.:~n~t .~:tv~cte. ta'ce place \c.,..~htod.ca1 depth!Are lOtt.e of th.e=~et"hlp,elLltblt !or: lIdo'LOti 1.t:1 the WttLoul ~e:tlr:U'of llt.to~tc ?l&cea beCI'.lIC Qf thetr •••oeiation with luch .etti~s or u~e,?S~ectrL;Itcentt~~.hQ~ld be ,tyee to the po'lible ht.eorle eh&ra~ter of the trels lad values that.~n t~e =.15,a"C()G'Lderecl oat1 with refeuace to ,od,aeconcal.:concer",..IE th.y cre of hlstol:'ic yd\W.the,..uet be cons tde red ~ndH Se;c ton 1.06 of ebe ••tto~l·!ilto'f'i.c ?relel:'VICton Act.The re~.Qt report ~f ehe ~~taeut of the Interto~4Qd the Aae~t'la Folkli!e C~n:~r ertt~~led ~ltaf'al Coe ..natioD (Liburj"of Cocl:-e ..1~a3).ho~lc!be rllvte ....d tn cU. 'C"'IIe-'t'.l • ...... ?<l'af'th."tt"u.p.ct to the 41"c:h&01QI)".we are d.i.uppotnte<i wtCh :ne al'JlCrea.t p4't'clpttaa th.at the pda.ar1 vdue of the litu r:o be lubje~teJ to,,) aat"re ".....reb ..,Ut lie La their potenttat ~aQ.tdb~tton co :h~ co".tractLoll of.·p~.l\i.ltortc cultuul chroClolav"(l:f.5.\0.v.~.l.l.l). !l!tM a,"ea..of I "...arch delil~ir:ia di.fficlJH to b4 cer;.~u war:th~1 t~.aaQ••'at too oft.~in AaericaQ archeolQI1 it ha.~e&Qt r:he .ere d lo~t o~cb1"oaotolt~&l .equeacel of at'ti.!a~t or EeltlJre r:1PC~.or th~ d e~iifiOQ 'c!c'hroaolo:lcdt!arianaed n.eed ph.aIU without la_~tl~to;..:."""eo_tO fOT dUfer.Qcu ot'1t.:athl"tties -0C1.l thea.If chi.i.d1 Chat i • .aoe.whtltb4 MIll f ..~1,.La~Of't.aQt &l:'cbeo1.os tc:&l re'Q~r:c:e.of r:~~s~.i:'1l&....."...",pcooJ..ct·.r.i.~·"·!liportaetopp0fo·tuaLty "ill hive beea toat to ~OQtr tbl.lte ....,.. .to ·a.t.ilkJI .=dworld a~cheoloa1.Ve caQQet overea.phu t~e the aced Ear « ,~...,....····ttlorO'C~~·bilbt1.cpbl.ticated.t~11y justifted re.e&:,ch de.~io to &uide '.taL.uta f'.~=O'Y..r,.~b.&t h prepou4 at Sua ltal.Such I ruut'ch du iiD t • ., ".....".•...'-'eet ••••e 'llave ariu.ed pt'e.,io~.1.11 to en.lJu ~h~c ceatl are k.pt u:ldlll:" CoC'trel'aa4 are tully jalcttte4,bur:it t.1110 ~eed.d to eQ.~re chae the ~..;iirf:"IIUd ttl I&l"cee reaeucc'pl:'oducu a ••x ~1Jlll ,.:i.1IS11:i.H e p.ayQ!:' "l,tap;..ara·'fie:-Appea4iz 0 -tb.at t~.r.L.1'1 Laportaa.t poteQttll at Sl.l.i.:a.& ..",eo'.ted1 t~l.''''''Ol'U~Qe12Cl!l of t.ate Wiacoe.L=-Roloceae env troQ.lWnr:&l c~.U:••~£1n:both dir.ct paleocaviroaaental dAta and the le••direct blolt ~i:b11 iD~)rt&nt corrobor.tt~.d~t~obtainable fro.the .r:~c~l~~i~~l ~.card of ~ua.Q ••tt!GD.a.t ••ubtL'tea,.,and deaoll:"aphlc ~£tr:erQl"There "1 'be othllr iApcr~ant rue&rch toptc:.thac ate oot a.o~vtQ~'fr.:n che 4oc~ctl provid.d.v.ree~ecd ~tole 4tCeccton co Q~h~dbaQ'. I !.- .~ - - ..... ·"r' 4 t"r...~t 6£!~f"e'el~ol ,ted h~r tu •••,.t;t ..tt,~P4Cl.eH<a.A celli ~.in ~9lllt~'':'a ~U1 tq;-ert'-t.ita,~rob 1"'·..·crLcu.to~r.~04rcl\(U4~;,..0 ~~a .. th 'I'r-oc:;>oOe-d ~ti t II 't'tlc o.ar7 '0 t ~~t t l'l a • --vill 1~fo~.r4 to e~.u!~iOl wlth pt~c .~~t~.ll••k&S!lO to e.-c:l-te S~ttOfl l~",.t."ot tbll ,raJoct at n~c·.u.rn.it cOClvecll"'. '(·~~r/'~;F~\ n.....:'P.Ua, Di~cto~.Offie.of C~ttur.t I ••olare.'r..u"I'.~left :..~-~&¥~@~~~~~~~ OFFI(:E OF THE GOVERNOR OFFICE OF MANAGEMENT AND BUDGET DIVISION OF GOVERNMENTAL COORDINA TlON / / BIU5HEFFIELD,GOVERNOR CENTRAL OFFICE POUCHAW JUNEAU.ALASKA 99811.0165 PHONE:(907)465-3562 SOUTHEAST REGIONAL OFFICE 431 NORTH FRANKUN POUCH A W.SUITE 101 JUNEAU,ALASKA 99811·mes PHONE:(907)465-3562 SOUTHCENTRAL REGIONAL OFFICE 2600 OENAU STREET SUITE 700 ANCHORAGE,ALASKA 99503-2798 PHONE:(907)274-1581 NORTHERN REGIONAL OFFICE 675 SEVENTH A VENUE STATION H FAIRBANKS.ALASKA 99701-4596 PHONE:(907)456-3084 September 4,1984 REceIveD Mr.Kenneth F.Plumb Secret.ary Federal Energy Regulatory Commission 825 North Capitol Street,NE Washington,DC 20426 Dear Mr.Plumb: SUBJECT:FERC NO.7114 SEP 6 1984 ALASKA POWER AUTHORITf' - - 01·A35LH The State of 1~laska has completed its review of the Susitna Hydroelectric Project,Draft Environmental Impact Statement. Attached for ~{our consideration in the development of the FEIS are our comments. Wi thin the ne:lCt two weeks,the Alaska Power Authority will be forwarding to you copies of all of the materials which have been referenced in our comments. Thank you for providing us with this opportunity to review and comment on this important project.If I may be of any further assistance,o:r if you have any questions,please feel free to contact me at (907)465-3562 or our Regional Coordinator,Jack Heesch in Anchorage at 274-1581. Sincerely, Robert L.Grogan Assistant D.~.'rect..~/'.",/ ,~£//l Jack"t'~~S~h Regional Coordinator Enclosure XC.3:~1 Mr.Kenneth F.Plumb FERC No.7114 -2-September 4,1984 .... cc:Esther Wunnicke,Commissioner Department of Natural Resources Don Collinsworth,Commissioner D1epartment of Fish and Game Richard A,.Neve',Commissioner Oepartmen,t of Environmental Conservation Larry Cra~ford,Director Alaska Power Authority - ,. Division of Governmental Coordination Office of Management and Budget State of Alaska Comments on Federal Energy Regulatory Commission Office of Electric Power Regulation Draft Environmental Impact Statement Susitna Hydroelectric Project FERC No.7114 -Alaska of May 1984 The Alaska Department of Fish and Game (DF&G)and the Department of Natural Resources (DNR)have reviewed the Susitna Hydroelectric Project,Draft Environmental Impact Statement (DEI5)-prepared by the Federal Energy Regulatory Commission (FERe).Their reviews were based on an assessment of the adequacy of the identification and quantification of resources affected by the proje:ct and alternatives,the determination of impacts to those resources att:ributable to the projects and the specific mitigation options proposed to offset those impacts.Their separate comments have been combined into this document which represents state agency review of FERC's DE1S. The FERC DEIS does not adequately address many issues that must be considered b~r state regulatory agencies when processing permit applications. If the commEmts presented in this review are adequately addressed in the FEI5,state regulatory agencies should be able to perform many of their adjudicative functions without disruptive delays. Tne DEIS doe:s not contain sufficient information on instream flows or fish and wildlife:data on whicn to base decisions regarding the project.The major areas requiring more thorougn consideration before an adequate assessment lof the project's environmental impac ts can be made are as follows: 28513 840904 1 1. 2. A mOIre comprehensive assessment of stream flow,water quality,and fish and wildlife resources of the Susitna River is needed dowulstream from Talkeetna.The anticipated impacts on downstream resources and on resource users which are attributable to the proj.ect need to be identified and quantified.Analyses should includ.e the effects of changes in river stage,water quality and temp,erature,on re4ring and overwintering fishes.Analyses should address riparian vegetation,wildlife (including moose)and the recreational fishery. There is a need to identify stream flow requirements necessary to main.tain instream resources (water supply,fish,wildlife, recreation and navigation)downstream from the proposed impolundments.Operational flow scenarios need to be developed that consider the requirements of all life cycle stages of fishes. Instream flow information should include target fish species, manaLgement objectives,habitat units associated with alternative flow scenarios,and the minimum and maximum flows necessary to maintain target populations during all seasons of the year. 3.The DEIS has not resolved the issue of an acceptable flow regime to protect fishery resources during project filling or operation. An effective release schedule capable of minimizing impacts is a necl:!ssary component in developing an acceptable mitigation plan and must be incorporated into the license.The FEIS should ide1ntify those habitats potentially affected by altered flows,the res,ources utilizing these habitats during all stages of"their life-cycle,the processes which could affect these resources,and methods to sufficiently m~tigate the impacts identified.The DEIS does not predict with any degree of confidence the project IS effects on downstream water temperatures,turbidity,ice conditions,and groundwater upwellings.An understanding of these relationships is necessary to determine the project I s effect on fish'habi tat and dependent fish populations.Information in the 28513 840904 2 "-.."~'.;.".-•....-_.:.,. - ..- ..... DEIS is inadequate to detemine whether the minimum summer flows or maximum winter flows will have positive or negative effects on anadlromous or resident fishes. 4.The PElS should discuss the full range of important impacts to fish .and wildlife resources and should identify mechanisms for detE!rmining appropriate mitigation of these impacts.The mitigation plan should be based.upon a quantified assessment of anticipated impacts to £isn and wildlife populations and their habitat,and should include a process for agreeing on the magnitude of impacts.and a mechanism for the formulation of a comprehensive fish and wildlife mitigation policy and plan. 5.The impacts to fistl and wildlife resources caused by the several alternative access routes to the project area must be more fully evaluated.These impacts include the effects of access to the 'project area for project construction and operation as well as the affects caused by increased access to surrounding lands by the get1leral public and adjacent land owners. 6.Soc:io-economic impacts on commercial,recreational and subsistence USE~of affected resources and supporting industries require furtl:1er assessment.This stlould include the identification of reliources used;the quantification of use levels;the description of use patterns,including seasonality.its context within local c~nmunities,and descriptions of geographi~areas of use. 7.Mi t igation planning.as mentioned above,must be further de''1eloped.This is probably tRe most important remaining issue. This cannot be acl:1ieved until the impacts to fish and wildlife are better identified.The FEIS should includ~a discuss ion of how impacts to fish and wildlife resources will be mitigated through project design,operation or through compensatory measures.A comprehensive evaluation of impacts and applicable mitigation 28513 :--_84.0904 3 8. alternatives needs to be conducted to evaluate environmental costs,the feasibility of mitigation,and the trade-offs of fish and wildlife resources and habitat. The Alaska Power Authority (Applicant).ie consultation with other stal~e and federal agencies bas developed a comprehensive listing of impact issues.(Please refer to issues listed in the March 6, 1984+letter from Jon Ferguson (APA)to Don Collinsworth (DF&G), the May 8.1984 state response to the list from Robert Grogan of the Division of Governmental Coordination to Jon Ferguson,and the Jul:1 23,1984 response from Mr.Jon S.Ferguson to Mr.Robert Groigan.References 1,2 and 3).A process has been initiated for addressing project issues,evaluating the significance of each, and arriving at resolution.The FERC should review the impact issues as developed by the State of Alaska.An analysis of the impact issues,significant impacts and recommended plan to mitigate should be included in the FEIS. 9.FERC should be a participant ~n, prE!sentations and discussions of Prc>ject,Issues Settlement Workshops. or take advantage of,the the Susitna Hydroelectric .- 10.Information presented regarding the environmental impacts of the alt.ernative hydroelectric projects is not sufficiently detailed to permit a reasonable comparison of these projects with the proposed action.While there is relatively little quantifiable information av.ailable for some of the alternative sites,we believe the di:scussion on alternative hydroelectric sites could be better supported by information available from the DF&G,DNR and other agencies. 11.The level of information contained in the DElS does not reflect the amount of project-specific information that is currently av'ailable to the FERC from the Applicant,state agencies and other 28513 840904 4 .-...:.........:...'.'--.."-. sources.Further,impac ts that cannot be quanti fied need to be identified.Effective mitigation is based on the accurate prediction and quantitative evaluation of the impacts of a pro~losed action on resources and the incorporation of this kno,.,ledge into the planning process. 12.It is a requirement of the Federal l~ish and Wildlife Coordination Act".(48 Stat.401,as amended,16 USC 661 et.seg.)that the cost of mitigaiton must be incorporated in the benefit-cost assessment rel'lting to project feasibility.The state recommends that fulfillment of this requirement be reflected in the FElS for both the proposed project and the alternatives. 13.If mitigation planning for the SusitIia Hydroelectric Project is adequately addressed in the FEIS,the state agencies can readily idelCltify stipulations which may be necessary under state laws or regl:1lations.This would insure that stipulations are no more con:servative than necessary,and that the regulatory process is minimal and efficient. 14.Mechanisms which will incorporate information arising from ongoing studies and other sources into the impact assessment and mitigation planning process are not clearly identified. 15.A Dluch more expeditious review could have been performed if (1) ~the DEIS included a topical index allowing cross references between volumes and (2)topics were adequately discussed,thereby saving the time required for researching points of concern. 28513 840904 5 .... r Specific Comments 16.Section 1.4.5.3,Page 1-43,Economic Analyses The DElS states:. !fA conclusion from these analyses is that,wi th the high construction costs of the larger hydroelectric projects and current uncertainties regarding Beluga coal development,the most prudent Rai1belt generation expansion plan would be a mix of non-Susitna hydroelectric resources with a combination of gas-fired combined cycle generation in the Cook Inlet area and coal-fired generation in the Nenana area.The use of smaller,lower cost hydroelectric resources in such a plan would reduce thermal generation requirements and fuel demands through the study period." Furtnermore,Section 1.4.5.2 states:IITne analyses in Sections 1.4.3 and i.4.4 indicates that the coal and gas scenarios would meet the Railbelt power requirell11ents at lower cost than the proposed Susitna Project." The apparent superiority of coal and gas or SOme combina tion of the two is maintained over a range of price assumptions and real interest rates.This llsuperioritylt is the result of two factors.First,the FERC load growth forecast is slightly lower than the.Applicants,thus slightly reducing annual benefits regardless of assumed oil,natural gas,and coal prices. Secondly,the Susitna Project's capital intensiveness generates a significant annual debt burden at real interest rates as low as 3.5 percent. A major problem with evaluating a project like Susitna is the long project life.Tne estimated benefits and costs are evaluated over a fifty year period.Eccmomic forecasting is,at best,a minor art form and is.not a scientific endeavor.The methodology of long run forecasting is as much philosophy alS substance.Projections may.not be accurate over so long a period,but they can be methodologically conservative and financially r:28513 840904 6 .- prudent.Conservatism could manifest itself in the use of high discount rates for project analysis.thereby attaching less importance to forecasted events as thE!y occur in more distant time periods.These are the periods for which we know the least. The FEIS s~ou14 present an objective analysis of the impact on the economics of the project and alternatives that would result from a broad range of projected real discount rates and provide a discussion of the risks involved with the discount rate assumptions. 17.Section,2.1.6.Page 2-11.Construction Monitoring The DEIS does not contain adequ,ate information on construction monitoring. No mention i!l made of a plan for continuous inspections and measurements of the fill plac:ement or grouting during construction.Detailed and consistent inspections llIlUSt be made to insure the accurate placement of the Watana impervious c()re.A discussion of the type and location of instrumentation is missing.The DEIS should discuss in detail the monitoring schedule and procedures t,aken during initial filling of the reservoir.Routine visual inspections are essential.It is unclear what measures would be taken in the event of piping.sloughing or misalignment observations. Assuming worst-case scenarios.discoloration of the drainage system discharge would indicate piping of core materials -not leaChing as stated by the DEIS.Piping would indicate severe inadequac ies in the inner core which could only escalate.It may not be possible to simply locate and grout the pr10blem area. 18.Section 2.1.6.Page 2-11.Dam Safety Dam safety is an important aspect of overall project design.No mention ~s made of any emergency plan in case of the dam r s failure.Under DNR r s Dam 28513 840904 7 ....:•... - Safety Program,administered by the Division of Land and Water Management (DLWM),routine project inspections are mandatory.In particular,U.S. Army Corps of Engineers,Recommended Guidelines for Safety Inspection of Dams,(Reference 4),should be discussed as a basis for inspection on this project.These ins pections are intended to be made jointly with the FERC inspections.D*R requires copies of all FERC inspection reports. The final designs of the project plans and approval by DNR and DF&G under 11 AAC 93. submitted,but any further processing is held of detailed d~lm designs and specifications. at least sixty (60)days. specifications will require These applications have been in abeyance pending submittal Review and approval will take 'P""" 19.Section 2.1.9,Page 2-13,State Approval of Plans and Specifications Alaska StatutE~s 16.05.840 and .870 require that an applicant must have plans and specifications approved by DF&G before constructing a dam on a river that is important to anadromous fish.If these plans and specifications are not sufficietllt in the view of DF&G,approval may either be denied or conditioned with those measures which must be met to protect fish resources before construction of the project may begin.If mitigation planning for the Susitna aydroelectric Project is adequately addressed in the EIS,state agencies can readily identify stipulations which may be necessary under either of the above mentioned authorities.This would insure that stipulations are no more conservative than necessary,and that the regulatory time frame is minimized. 20.Section.2.1.9,Page 2-13,Consistency Determination The FEIS snould consider wnether the proposed project,or its alternatives, are consistent witn tne standards and guidelines of the Alaska Coastal Management Plan or approved coastal community management plans. 28513 840904 8 -- .>'••''.'-".-_".:..-;:....;;••.:.~.......-:.:.:.:.')•_.••••'". 21.Section 2.1.12,Page 2-21,Mitigation Planning The,mitigation plan needs to contain contingency elements that can be inco,rporated .lS additional information is collected and anticipated impacts are better quantified.Mechanisms for modifying the mi tigation plan as impact aSSeSSlllents are refined and as actual operating experience is gained sheuld be outlined.Plans for habitat modification,as proposed for sloughs,should be provided and should include engineering designs, consltruction,operation,and maintenance plans and a detailed cost analysis. WitClout these,mitigation proposals cannot be evaluated nor developed with any assurance~of success.This is necessary to ensure that appropriate mitigation occurs and the mitigation actions are in harmony with the overall development and conservation of the resources in the area. 22.Section 2.1.12.3,Page 2-24,Mitigation Planning Tne State does not support or propose regulations to solve problems that ~re more appropriately dealt with througn the development of an effective mitigation plan.Mitigation plans should indicate that a particular impact might requir1e changes in fish and game regulations but they should not attempt to slpecify what those changes will be.Management options and mitigation options should be dealt with separately.The DEIS addresses management options as part of the mitigative process for the Deadman Creek drainage (p.2-24).Regulatory restrictions are the responsibility of the Boards of Fis,heries and Game.This does.not apply to res tric tions placed on individuals brought into the area to engage in construction activities.It applies only'to regulations affecting the general public.It may be appropriate to have project stipulations,rather than regulations of the Boa,rds to limi t project personnel from engaging in certain activities,as construction projects can create unusual concentrations of people brought into the are,i by means not avai lable to the general public. 28513 840904 9 - .... 23.Section 2.1.12.4,Page 2-25,Mitigation,Habitat Enhancement Mitigation for wildlife habitat loss resulting from development of the project should be in the-form of compensation.Compensation may include enhancement of the productivity of wildlife habitat and acquisiticn of replacement lands 1n order to obtain habitat quality commensurate with that lose from project development.The applicant's proposed plan is designed to enhance wildlife carl."ying capacity outside the project area to compensate for habitat l,oss resulting from the project.The feasibility and specifics of the plan are still being studied.The benefits to wildlife that will be derived from the proposed enhancement techniques are difficult to assess at this time.To assure adequate protection of the state's valuable fish and wildlife reSI)UrCeS,an effective mitigation policy should address both habitat enhancement and replacement lands.Considering both habitat ennancement and acquisition of replacement plans is necessary to reasonably address biological requirements of the populations affected and to compensate fCtr the loss of habitats of certain populations that cannot be mi tiga ted through enhancement alone. 24.Section 2.1.12.3,Page 2-25,Mitigation,Fish Losses of resident fish species and habitats within the impoundments can only be mitigated through compensatory habitat replacement or enhancement elsewhere.Resolution of this issue must be accomplished jointly between the applicant and the resource agencies in the context of presently feasible propagation technology and the benefits to the resource and user groups of artificially stocking waters in the project area.Therefore,it is not appropriate to make a decision on this tradeoff such as the artificial stocking of Kokanee in the Watana impoundment,until a process for addressing t:he overall mitigation plan is implemented.The compensating measures proposed to mitiaate loss of Arctic grayling habitat in reservoir zones (p.2-'25)are not necessarily desirable options.Until the resource agencies discuss compensation measures,the options listed (research on grayling propagation,hatchery facilities for grayling,and introduction of 28513 840904 10 --....-_..._-_...-..._------------------------------_.----- """ ,.. -."':""..- rainbow trout into the Devil Canyon reservoir),should be considered only as options propolled by the applicant as they have not been endorsed by any agency. 25.Section 2.1.12.6,Page 2-28,Recreation Plan Volume 6 of the DEIS addressing Recreation Resources and Visual Resources appears to be a credible document. Phase five of the applicant's proposed recreation plan (Table L-IO,page L- 37)for the Stephan Lake 40 acre site and development should be considered as a higher priori ty.This site will be the only public site on Stephan Lake and it will be a major access point to float the Talkeetna River.All other lands surrounding Stephan Lake have been or will be conveyed to native Corporations pursuant to ANCS·A. -26.Section 2.1.12.8,Page 2-29,Visual Resources The features of the applic~ntf s proposed visual resource plan appear to be adequate if fl::lllowed as specified in the DEIS. 27.Section 2.2.2,Page 2-29,Access Road The FEIS should provide a comprehensive assessment of the secondary impac ts of providing public road access into the middle Susitna basin.This assessment must address the impacts of increased opportunity for the use of federal public lands north of the project area as well as facilitating development of private native lands both north and south of the project area.These native lands are currently not open to public use nor would they necessarily be open to public use if road access were available. In its discuission of secondary impacts of improved access,the FEIS should address impac:ts to ungulate populations,vegetation,and brown bear use at Prairie Cree~~.Prairie Creek attracts brown bear from an area of 7900 Km 2 28513 840904 11 '".'~"~".....: - (not 5700 Km 2 , p K-17 of DEIS).Only brown bear make seasonal movements to Prairie Creek during salmon runs,not black bears as reported on page K-82. 28.Section 2.2.2,Page 2-30,Access Road Although public .access may be restricted during construction,long term use by the public:must be anticipated since state funds will be used to construct the access road.The road must be designed to Department or Transportation and Public Facilities (DOT/PF)and Matanuska-Susitna Boroush road standards!.There should be some discussion on designing recreational amenities,SUl::n as pullouts or viewing areas consistent with the area's future recreational uses. 29.Section 3.1.1.1,Page 3-1,Geology Tne introductory statement on seismicity is poorly written."Thrusting ll is a form of i'faulting"j "Shearing"is what happens along faults.All of these items mayor may not be the result of "plutonism"and are definitely not the resu.lt of "regional me tamorphism"as stated but rather the otner way around.The third period of deformation,for example the Castle Mountain Fault Zone,.1!ISsuredly extends through the Quaternary.Northwest drifting continental blocks of the Cretaceous is a theory under considerable debate and not accepted widely enough to be quoted without a qualification in the DElS.Rationale for using this theory should be further discussed. A clear statement is needed on subduction zone faults.Although a surface rupture hazard to the sites may not be significant,the ground acceleration hazard from these sources should be discussed in greater detail. The surficial geology within the region needs to be defined.The discussion in the DElS is inadequate for evaluating the area. Construction activities will modify the character of sediments overlying permafrost,t'esulting in thaw of permafrosts with resultant:thermokarst and 28513 840904 12 .... erosion.Discontinuous permafrost has been encountered in scattered locations in the lowlands and should be considered within the entire project area. 30.Section 3.1.1.2,Page 3-1,Land Management The FERC application briefly discusses the complex land -ownersbip pattern in the project ,area.The DEIS assessment does not accurately portray this complexity.Land ownership for the entire project should be clearly delinea ted Otll large scale maps in the FEIS,including the transmission corridors and alternative project sites.The land ownership maps sbould show all the competing land selections and their selection date.·DNR is assisting the Applicant in the development of a land acquisition program for the Susitna Project. FERC should not presume future state ownership of lands currently selected by both the.state and native corporations.The OEIS is written as if the project land were state owned or could be acquired by state selection.The state will pl:,obably have to wai t until the Bureau of Land Management (BLM) has adjudicalted all the competing land selection applications.BLM has suspanded adjudication of the state's selections until the native selections are adjudical:ed.The potential time delays for resolving these competing selections c()uld have a significant impact in the overall project schedule and cost and should be discussed in detail. 31.Sec tiOtl 3.1.3.1,Page 3-5,St reamflows In many sections of the DEIS,various flows of the Susitna River are mentioned.However,a better unders-tanding of measured streamflows would be reached if gaging stations were identified by name and location.I t is critical to clearly identify wnere measurements are recorded to provide useful and accurate data for fiSheries habitat,economic,and safety planning. 28513 840904 13 4 ••":,;.'••_-...0:.,''.,:.~.....'...._.-'_~_-.' - .... 32.Section 3.1.5.1,Page 3-25,Timber Resources The DEIS provides extensive,generally descriptive information on forest conditions in the project area.The descriptions are ecological in nature rather than economic.Volumes and values of wood involved are not disC'ussed.Ttlie forest resources of the area are economic resources only in the personal-use context at the present time.Consequently,our concerns center on making any wood felled or "cleared"on state land available to the public in so far as is practical. Prior to developing clearing schedules for state owned land,the applicant would be requ1ested t.o consult with DNR IS Mat-Su Area Forester to determine the feasibility of selling merchantable timber.In areas where public access may exist (along the transmission corridors)felled wood may'be made available for pick up by the public for use as fuel • 33.Section 3.1.5.2,Page 3-31,Caribou Major herd clt'ossings of the impoundment area have usually occurred when population levels were relatively high.It appears likely that the proba- bility of major crossings of the impoundment area and increased use of the northwestern portion of the range will increase if herd size increases.The peak size or the herd was recorded in 1962 when 65.000-70.000 animals were coullted,not 40.000 animals in 1955 (p.K-12). 34.Section 3.5.4,Page 3-66,Talkeetna Fisheries Results of DF&G studies indicate the Talkeetna River supports large runs of chwn salmon.possibly exceeding 200,000 fish.The .FERC staff expects that losses to sal.mon production in the Susitna River above Talkeetna during the filling opercltion of the reservoir would be partially offset by increased production in the Talkeetna River (p.4-32).The FERC staff assumes that fish Which nc)rmally would migrate up the Susitna River would select for the warmer water'of the Talkeetna River.Even so,any displacement of 28513 840904 14 """- additional fiish into the Talkeetna River system may lead to increased competition and overcrowding of spawning and rearing areas.The possibility of lost produ(:tion in the Susitna River being compensated for by increased production on the Talkeetna River is highly speculative.(See comments on Keetna Project,page 34). 35.Section 4.1.1.1,Page 4-1,Geology,Seepage The OEIS indicates there is a potential for seepage through the Watana relict channell at Tsusena Creek during the filling operations.The location of seepage is not identified.The OEIS recommends monitoring during filling.however,further provision may be necessary to control unforseen seepage.It is unclear wnether the relict channel will need to'be excavated,thlen grouted.The procedures used to reduce seepage throu-gh the ~elict channel should be ~learly stated. 36.Section 4.1.11,Page 4-1,Geology,~orrow Sites Information on material sources and borrow site locations is not readily referenced in the OEIS.Material sources,such as local sources of building material,and availability should be more thoroughly discussed.It is unclear how much material is available at the various borrow and quarry site locations.A large amount of material will be essential to construct the project.Tnere should be some discussion of the full extent the material can be excavated from a particular borrow site before the impac t becomes excessive,in,order to assess associated environmental effects. Surface and subsurface ownership of these sites is unclear.This information c:ould be critical to future management and planning efforts. 37.Section "4.1.1.1,Page 4-1,Geology Geology and Appendix E, DEIS. 28513 840904 soils are fundamental issues of the DEIS and the subject of but are covered less adequately than are other parts of the 15 ----------,-_..-------------------------------------- ..... ..... ..... ..... ,[liiIlliIiJlI! Several types of mass movement are mentioned in the DEIS.Clarification with more detail on the potential impact of landslides into the reservoirs. is necessary.The DEIS does not adequately discuss prehistoric landslides located near the proposed Devil Canyon dam site.There is no mention made of the potential hazard and environmental effects resulting from giant waves produced whelil !andslides enter the reservoir.No mention is made of the future headward (upslope)extension of these slides.Only shallow surface slides are discussed.Tl1ere should be some discussion of major bedrock slides due to pore pressure buildup along pre-existing planes. 38.Section,4.1.1.2,Page 4-2,Land Use,Transmission Corridor The proposed transmission corridor may affect some existing and proposed state agricultural disposal areas.The DEIS discussed placement of the towers along existing rigb.ts-of-way and stressed using single pole towers or IIR n figure towers instead of the "XII figure towers to lessen this impact. These statements imply the area beneath the powerlines can continue to be used as agric:ultural land.There should be some discussion of the allowable uses of the l.and beneath the power lines and the safety precautions necessary around the bases of the towers.This discussion should include an assessment of the cost/benefit ratio related to use of towers requiring considerably more expensive foundations than the proposed structures. 39"Section 4.1.1.2,Page 4-4,Land Use,Transmission Corridor The DEIS contains a statement wnich implies that there will be an access road along the entire length of the transmission corridor.It is our understanding that the applicant has not proposed a continuous access road along the triansmission corridor J but rather plans to utilize existing access and winter construction to the extent practical.In other areas it may be necessary to,restrict ground access and utilize helicopter access.There should be further discussion of this issue. 28513 840904 16 ---------- ,.,.,.. ..- ..- -- " 40.Section 4.1.1.2,Page 4-2,Land Use,Transmission Corridor DNR is conce:rned the transmission corridor may act to bisect state agricultural dlis posals if there are restrictions on the type of access that can be granted across or from the corridor.Tbe extent of allowable public use along the.transmission corridor is unclear.DNR,the state land managing agency requests further discussion on the type of access the state may grant acrloss and along ~he transmission corridor.It is not clear who will manage and maintain completed transmission lines,and what access restrictions could ultimately be imposed • 41.Section 4.1.2,Page 4-4,Air Quality,Fugitive Dust During construction,fugitive dust emissions from road dust and wind blown dust could probably be controlled by frequent road watering and would require a Temporary Water Use Permits (TWUP)from DNR. 42.Section 4.1.2,Page 4-4,Climate Conditions The environmental impacts of the proposed project run about 16 pages and yet: climatic effects are treated in only 4 1/2 lines,essentially saying no significant lI11icroclimate change will occur.The possibility of climatic coolings of the environs by reservoir evaporation and the higher ambient atmospheric Illoisture content (resulting in more condensation/precipitation downwind)should be discussed. 43.SectiOIll 4.1.3.1.1,Page 4-7,Spillway Capacity The Watana d~lm is designed to discharge 156,000 cubic feet per second (cfs), the estimated 10,000 year flood.Reference to an emergency spillway and fuse plug indicates allowance for additional capacity to permit discnarge of the Probable~Maximum Flood (PMF).Projected PMF flows and the dam1s capability of passing 100%of thePMF without overtopping need to be clarified • 28513 840904 17 --------- ..... - .... ..... .' Tne FEIS should discuss wnether the Devil Canyon Dam would be able to withstand or control a flood surge caused by the overtopping or failure of Watana Dam.Further discussion of Devil Canyon's ability to withstand an overtopping without failing is necessary.The PMF has not been specified for the Devil Canyon area. 44.Section 4~1.3.1.2,Page 4-9,Flow Regime The discussion on surface water resources is well done.However figures given for mean annual stream flows at the Watana and Devil Canyon dam sites are misleading due to the flow variations throughout the year.Mean month ly stream flows shown in Figure 4-2 are more accurate and should be used throughout the FElS for consistency.The FElS should discuss the instream flow methods used to determine the impacts of maximum and minimum flow scenarios on fisn and wildlife habitat,fish life cycles,water quality, recreation,navigation,and transportation.Many sections mention probable effects on ~he fiSheries but fail 'to mention what the effects are,or hbw they were .assessed.This information is essential to evaluate the effectiveness of the mitigation measures • The Applicant asserts that the project 10,000 cfs winter flow will not overtop the sloughs more frequently than under natural conditions. The FE!S sholil1d determine the impacts of increasing winter flows to 10,000 cfs from not1l1a1 flows of 1,000 to 2,000 cfs J in particular t determining under what conditions and at what frequency sloughs would be overtopped. The state hliS not established a position on 12 t OOO cfs required summer flows,to dat~e no negotiations on minimum flows have taken place. 45.Section 4.1.4.2.1,Page 4-26,Downstream Temperature Effects Table 4-2 shows significant temperature changes 1.n the Talkeetna to Cook Inlet reach of the river during both reservoir filling and project operation.On page 4-26,the DEIS states that downstream of the confluence 28513 840904 18 .,.. of the Chulitna and the Talkeetna Rivers,growth rates of juvenile salmon and resident sipecies would be suppressed by cool temperatures.The FERC staff estimated a reduction in accumulated June-September growth in this reacn by about 50 to 60 percent compared to potential growth at pre-project temperatures.These values contradict previous statements (p.4-23)that only minor teDlperature differences are expected downstream of the Chulitna confluence.The FEIS should reassess temperature effects of the project. 46.Section 4.1.4.2.1,Page 4-26,Downstream Habitat Effects The Stat'e reccl1umends a more thorough analysis of the fisheries and aquatic habitats downsltream from Talkeetna.The impacts of the altered flows in this reach may be more significant than those upstream. Below its confluence with the Chulitna River,the Susitna River is broad and relatively shallow.Therefore,an altered flow regime may affect relatively more aquatic habitat downstream than upstream.The state recommends that; additional emphasis be directed toward the assessment of impacts downstream of the Talkeet~na River. 47.Section 4.1.4.2.1,Page 4-30,Downstream Temperature Effects If the growth reductions stated in the DEIS are realistic for the lower reac:h of the Susitna River,they could have major impacts on juvenile salmon utilizing this reach.This reach supports a major portion o·f the Susitna River salmon population.The significance of the potential impact on lower rea(:h juveniles caused by reduced growth are not discussed in this DEIS and cerl:ainly should be further evaluated.There are virtually millions of emigrating ju'venile salmon in the lower reach.Adult salmon enumerations on tributaries have been conducted for many years and would provide some rationale for estimating numbers of emigrating juveniles in the lower reacn. Unfortunately,little information is available on the timing of juvenile salmon emigraltions out of the Susitna River.If the majority of juveniles 28513 840904 19 - .- - .... have emigrated prior to the period of projected temperature changes,impacts may be minimal.The FEIS should discuss timing of juvenile emigration in the lower Susitna River. 48.Section j~.1.4.2.l,Page 4-33,Downstream Impacts on Fisheries The DElS states that "It is not possible to quantify the direct impact of the project OIlI the commercial,sport,or subsistence fisheries,except that all other fac:tors being equal,changes incatcn would be approximately proportional to increases or decreases in the size of the spawning stocksl! (p.4-33)•For the sport fishery,this conclusion suggests a lack of familiarilt;r ll1i th factors affecting the ~port fishing effort and harvest. To understand the potential impac ts of the project on the recreational fishery that occurs downstream from Talkeetna,it is necessary to understand how these fisheries function.Although this information was presented in OMB's comment:s on the license application (November 18,1983,Reference 6) we will repec:lt it for consideration in future environmental analysis and mitigation planning. On the SusitIla River from Talkeetna downstream to its confluence with the Yentna River,there are nine tributaries flowing into the east side of the Susitna and one flowing in from the west that contain significant fish populations.Most of these streams support major salmon runs and jointly support up tel 100,000 man-days of fishing effort each year.Access plays a major role i10.limiting growth of the recreational fisheries that occur on these stream::!.Much of the land adjacent to these streams is in private ownership and public land that is available is relatively undeveloped or inaccessible.Other than in the Talkeetna area,there are no public boat launcnes that allow anglers access to the Susitna River.There is a commercial ac:cess point at the mouth of the Kaskwitna River.The state has rec.ognized the problem and has spent approximate ly $500,000 to purcnase lands at the mouths of Montana and Sheep Creeks.The state has also initiated a road construction project that will provide access directly to the Susitna River at the mouth of Willow Creek. 28513 840904 20 P •••- •_"-:-:"_.'• - An important upect of the recreational fisheries is that they are located primarily at confluences of tributaries to the Susitna River.Recreational activity in these confluence areas is directly related to the large number of sialmon that are present at these sites.As five salmon species migrate up the Susitna River they tend to congregate at the mouths of all tribu- taries flowing into the Susitna River.During the open water season the areals around the mouths of tributaries provide ideal resting or staging areas for adults of all fish species as well as rearing areas for juvenile fistt.The extl!nt to which these areas are used 1S dependent on the depth and velocity of the water at the tributary mouths which in turn is sensitive to changes in mllinstem flow.At high flows,the mainstem creates backwater areas at the tributary mouths,thus increasing water depth.At low mainstem flows,the backwater areas are eliminated,resulting in shallower water and increased flc)w veloci ties at the mouth.When these"backwater areas are "eliminated,their attractiveness to fish is significantly reduced and fish will be displaced to other areas more suitable.They could be displaced from tributary mouths that are easily accessible to anglers.In the Susitna River,natural low water conditions which affect recreational fisheries do occasionally occur.When they do,it occurs primarily during May and June at the time elf chinook salmon migration. Chinook salmon are the most highly prized sport fish in Alaska and as such they attract large numbers of anglers to the limited areas that are opened for fishing.The Susitna River chinook salmon is a limited resource that has been intensively managed and has a long history of allocation conflicts between various user groups.Sport fishing for cninook salmon is allowed on only five Susitna River tributaries in the Talkeetna to Cook Inlet reach ll1itn the eXI::eption of the Yentna and Talkeetna River drainages whicn are also open 1:0 chinook salmon fishing.Three of these streams,Willow, Caswell,and Montana Creeks are road accessible east side tributaries that are open to chinook salmon fishing only on ll1eekends wnile the other two,tne Desbka Rivel:'and Alexander Creek wnicn flow in from the west side,are open to cbinook salmon fishing 7 days per week.The weekend-only fishing streams 28513 840904 21 .:-:'.,--:-:. - .... .... receive extremely neavy fishing pressure during the chinook salmon fishery. Since the are,as that-are opened for chinook salmon fishing are extremely limited,any plhys ical changes in backwater areas on these streams which may reduce holdinl~areas for chinooks could be particularly damaging to the recreational fisnery. It is also important to note that salmon utilizing tributary confluence areas are not necessarily migrating into those tributaries.All five salmon speC1es migrating to the upper Susitna,Chulitna,and Talkeetna Rivers enter,in varying degrees,the sport fisheries that occur at the confluence area,s of the lower Susitna tributary streams.Any impact that occurs to salmon species that utilize the Susitna River in the Devil Canyon to Talkeetna reach has the potential to impact the recreational sport fishery which harvestl;these·fish in downstream confluence areas. Flow reduc tions under tne proposed filling scnedule may al ter the phys ical characteristil::s of the tributary mouths in the upper portion of the Talkeetna to Cook Inlet reaco.These are the areas where the major fisheries occur.During toe open-water season,induced mains tem diSCharge reductions of 34 percent in June and 28 percent in July may reduce the areal extent of these backwaters.Water depths in these areas will also be reduced.Th;!!Susitna River below Talkeetna is moderately to extensively braided,with the river channels wide and shallow.Therefore,this reach is more sensitive to flow reductions than deeper more incised channels,which occur further upstream.Reductions in discharge during and after filling of the reservoir could result in substantial changes in the habitat at tributary mouths whicn may seriously impact existing recreational fisheries. Since the tributaries flow into a variety of habitat types,the impacts of reduced flows will vary. The FEIS should quantify adult salmon escapement in the Susitna River below Talkeetna.It is very possible that adult salmon escapement in this port ion of the Susitna River exceeds those estimates available for the river above Talkeetna.This would mean that the reach below Talkeetna is especially 28513 840904 22 .... important to rearing juveniles.Here again,there is very little quantitative information presented in the DEIS.Information is needed on juvenile rearing in the reach below Talkeetna.Large numbers of juvenile chinook salmon and adult resident species are migrating out of numerous east side Susitna tributaries in the reach below Talkeetna.They are dependent OD over-wintering habitat in the Susitna River.There are no quantitative data presented that indicate their abundance or which habitats·they are dependent upon.There is almost certainly going to be an impact on juvenile fish rearing in this reach with post-project winter flows changing by over 200 percent.The FEIS should show how winter habitat will change with the dramatic increase in flow and wha t impact this would have upon overwintering juvenile salmon. It appears that the transmission line corridor-will be crossing in the immediate area of the Burma Road I s intersection with the Little Susitna River.The Little Susitna River is designated as a recreational corridor in the willow Sub-Basin Area Plan,from the Parks Highway downstream to where it enter s the.Sus i tna F la ts S ta te Game Refuge.In the Area Plan the management intent is to protect recreational values and provide for visual and sound buffers in the corridor.Recreational use of the Little Susitna River is increasing at an extremely rapid rate,primarily due to upgrading of the 6urm~~9a(t:,which-accesses the lower Little Susitna River.In 1983 angling effort reached 35,000 man-days which resulted in this fishery becoming the second largest freshwater sport fishery in Alaska.This is an area of extremly hign use and future plans include the development of a campground and boat launching facilities. 49.Sec tions 4.1.4 and 4.1.5,Pages 4-25 and 4-33,Fish and Wildlife Impacts -Impactsa,re u:suaLly stated in terms of the current populations,current ">".•=----··r··<.• habitat conditions and current management goals.In some cases,they focus only on the fate of currently living individuals rather.than populations. Tais approaCh may be adequate for short-term impacts assessment.'.It is not 28513 840904 23 -------~~---------_._-------=-=---------------------------------- adequate when the duration of an impact is likley to span a period during which populations,habitats,management goals,and/or regulations may change significantly.Management objectives,populations,and regulations will change over the long period of the project life.Since these changes are well within the time frame of many of the impacts of the project,the FEIS should discuss impacts and.mitigation that·are responsive to a range of possible population levels and management objectives. The results of cumulative impacts are not emphasized enough.While individual impact mecnanisms may not be significant when viewed independently,cumulative impacts,resulting from a combination of lesser events,may have more severe effects on wildlife populations.The combination of events,SUCh as increased human access,habitat loss, disturbance,disruption of migratory pathways,and changes in predator-prey ratios,may have impacts when acting together that exceed the sum of the impacts from the individual activities. A large number of issues seem to be set aside simply because they cannot be precisely quantified.Clearly it is not possible to precisely quantify all of the impacts.However,it is difficult to see how reasonable and responsible mitigation decisions can be made unless there is some indication of the magnitude of the impact.Many of these issues can at least be narrowed to an order of magnitude.They should be thoughtfully examined and outer bounds placed on tne problem.For example,a maximum possible level of habitat loss and alteration adjacent to the impoundment and downstream can certainly be determined.These estimates can be narrowed by developing more logical scenarios.The effects of several of the scenarios on a wildlife population can be examined to identify a worst case situation.If this worst case shows an unacceptably hign impact,further studies can be designed to narrow the range of possibilities.The DEIS states that "In the reach from Talkeetna to the Yentna River,it is impossible to predict post project c'hanges in vegetation with any certainty."Downstream vegetation cnanges could greatly affect wildlife populations over time and.the possible range of impacts in this area needs to be discussed.There are presently 28513 ~.411Q04 24 available 1U0re recent studies for moose.bears,wolverines,caribou and sheep.These should be incorporated in the FEI5. A good analysis of the amount of.habitat lost by the project,for·all species,will not be available until the development of su.itable habitat maps,cu.rrently.in progress,is completed. 50.Section 4.1.5.2,Page 4-37,Wildlife Impacts Cnanges brought about by the project may have widely di fferent effects on different population sizes or under different environmental conditions. Mortality induced by the project mignt be insignificant at high population levels.In some instances,the project might permit c~ntinued existence of a population of the current size,but preclude growth to its current potential.In other cases pre-and post-project populations might be the same size,but the post-project population might have less capacity to sustain hunter harves t and predation or to recover from·per iodi c environmental perturbations,such as severe winters.While the DEIS .occasionally alludes to changes in productivity,it tends to focus on maintaning current population level.A range of possible population levels should be addressed in the FEIS. 51.Section 4.1.5.2,Page 4-37,Significance of Impacts Tne FEIS snould rank impacts within and among species to aid in identifying further study needs and to determine the importance of specific mitigation measures.Ranking impacts helps determine where the major efforts of the mitigation plan should be directed.In ranking impacts,certain questions need to be addressed.Tnese include:what percentage of the available habitat,for each type within the r~gion,will be affected?Is the acreage lost witnin a specific habitat type significant?~How.much similar habitat has been lost in nearby accessible areas?What species of wildlife use these habitat types?What factors limit the population growth of the species?How will cumulative impacts in the region affec t these wildlife 28513 840904 25 populations?How will these habitat types cbange over tbe life of the project?By answering similar questions for the various types of project related alterations to lands and waters,the potential scope of a problem can be determined even when precise quantification is impossible.The FEIS should more realistically weight impacts so that the oeed for further study or specific mitigation measures can be assessed. 52.Section 4.5.1.2.Page 4-37,Caribou An important consideration for the Nelchina caribou herd~not addressed by the DEIS is long-term management and the dynamic nature of caribou populations.The DEIS states that the DF&G's goal is to maintain the population at 20.000 animals.This information is outdated.The DF&G's goal is to increase the size of the herd and maintain it at 30,000 adult caribou (36,000 including animals less than l year old).Tbe FEIS should address the effect of the reservoir and access road on a herd of this size because the Watana reservoir intersects a major historical migratory route of the Nelchina herd. 53.Section 4.1.5.2,Page 4-37,Dall Sheep Tbe assessment of impacts to Dall sheep in the DEIS contains several omissions and inaccuracies.The FEIS should incorporate DF&Gstudies on Dall sheep published in 1984.Most important are the predicted impacts.to sheep.As-all of tbe heavily used lick sites at the Jay Creek mineral lick area are about 2200 feet in elevation,they will not be inundated by the impoundment and mineral leacbing will not occur.Only a few lick areas that receive relativetly little use by sheep will be inundated.The greatest impact to Dall sheep may result from the Watana impoundment blocking or impeding sbeep from crossing jay Creek and limiting use of important lick sites on the east side of the creek.Lick sites on the east side of Jay Creek are heavily used by sheep which arrive from the northwest.As ment ioned in the DEIS.the ef fec ts of cons truc t ion ac ti vi tes and disturbances from recreational boaters and low-flying aircraft,may also 2~513 840904 26 '------,..--------".-.------------------------------------- - - ·~-._',. have signiticant impacts.Erosion at some lick sites could result from seasonal fluctuations in water levels in the reservoir.reducing the already limited escape habitat adjacent to the lick area. 54.Section 4.1.5.2,Page 4-37,Black Bear The approach used in the DEIS to quantify impacts to black bears results in an inaccurate assessment of the impacts.To more accurately assess impacts, the study area needs to be divided into three distinct areas:Watana impoundment,Devil Canyon impoundment"and downstream of Devil Canyon.In the former ,a very high percentage of forested black bear habitat (70-90 percent)will be inundated.This includes nearly all the important deciduous forest habitats.In the second and third areas,a lI1Uch smaller acreage of forested habitats will be disturbed.Combining all three areas masks the effect of habitat destruction in the area o~the Watana impoundment.Habitat destruction in the Watana impoundment will essentially eliminate the resident black bear population in this area,while the impacts in the Devil Canyon area will be much ,less. 55.Section 4.1.5.2,Page 4-37,Moose The DEIS states a 11 •••loss of about 10%of,the major wintering and spring calving habitat within 10 miles of the impoundment area (p.4-38).11 How this figure of 10%was arrived at is unclear.In 'addition,it can be misleading by itself.A small percentage of available habitat may support a large number of moose,especially during the winter.If high quality habitat is inundated or disturbed by construction activities the consequences to the moose population would be more severe than if low quality habitat was disturbed.Therefore,the type and quality of lost habi tat and its value to moose needs to be assessed.not just the areal extent.In the spring of 1983 over 60U moose \Jere counted just in the Watana impoundment area and approximately.2800 moose range in the area of the Devil Canyon and W'atana impoundments.The same problem previously described for assessing impact of lost habitat to bears applies for moose. -28513 840904 27 :......~.'-'.'- ~."', With better habitat maps,this assessment sllould be improved.In addition, displaced moose will be subject to much higher levels of mortality due to predation and higher concentrations of moose on reduced winter range. 56.Section 4.1.5.2,Page 4-43,Wolverine and Wolves The impacts projected for wolverines and wolves (p.4-43)are incorrect.At least 35 wolverines could be affected by the impoundment.Up to six wolf packs have terri tories over lapping the proposed impoundments,and all six could be disrupted.tn addition,access roads,project facilities, construction activites,and transmission corridors would likely reduce additional habitat for wolves and wolverines or cause disturbance and increased mortality. 57.Section 4.1.7,page 40-47,Navigation Further discussion is warranted on navigational impacts for each portion of the river.As indicated,recreational navigation is increasing;however a discussion of the tlistorial use of the river is needed to support this statement.Commercial navigation should be given more consideration. Studies by the applicant should have been used to evaluate the probable impacts.Additional studies are required to evaluate tile nagivational limitations,if any,which may occur at the various flows proposed. 11 AAC 93.141(2)and (3)further define navigational flow requirements for recreation and transportation. 58.Section 4.1.8.Page 4-49,Fish and Wildlife Users The subsistence section has several errors or has presented very vague discussion on local resource uses.Some of this has undoubtedly resulted from fai lure to use primary sources 0'£information when discussing subsistence issues.The Subsistence Division of DF&G has prepared several reports and maps with valuable information on subsistence uses within this region.This information should have been included in the FEIS. 28513 840904 28 --............_""""-""""'------~~~...,---------~~._------_._- The limi ted information on specific subsistence use patterns for the area was not used.The DElS states that "Subsistence user statistics are not distinguishable in harvest statistics for game species,wi th the exception of caribou.1l The Board of Game established a subsistence moose hunt in Game Management Unit 13 in 1983.This Game Management Unit encompasses the Upper Susitna River.Also,narvest estimates for all game species for a 12- month period in 1982-83 are available for Cantwell (DF&G,Subsistence Division,Reference 7). In tne discussion of socioeconomic impacts (Section 4.1.8)of the proposed project,no effort is made to quantify the number of subsistence users -affected or the degree to which subsistence activites will be affected by the project. Z8513 840904 29 ·.-,~.". 59.Section 5.3.3,Page 5-9,Downstream Flows An estimated 50%of side slough habitat will face acute access limitation under proposed summer flow release scenarios of 12,000 cfs.There i.s no mention how spiking with an additional 20,000 cfs to mitigate access limitations at these sloughs will be scheduled.It is unclear what the total spiked flow for three (3)continuous days will be.Plans for observation and prevention of overtopping of upstream slough berms are not discussed.The effect on the fisheries from these proposed spiking flows is unclear. 60.Section 5.3.5,Page 5-11,Mitigation Planning Tbe DEIS states that the "•••h.ck of definitiveness is due,in large part, to a lack of sufficient information as to the feasibility of mitigation proposals"(p.5-11).Another major factor for the poorly defined mitigation plan is the lack of supporting information to develop mitigation proposals.The vegetation mapping and moose carrying capacity model being developed by the applicant are two important elements for input into the mitigation plan.Previous vegetation studies have concentrated on describing "vegetation types"rather than "habi tat types.II "Habitat type"maps ar.e essential for analyzing the amount of habitat lost for all species due to the proposed project.Habitat mapping has been undertaken by DF&G for the project area.While preliminary information will be available this year, complete maps are not expected until spring 1986. The FEIS Should assess the feasibility of enhancement for meeting the goals of wildlife mitigation,as well as otber mitigation measures for loss of wildlife habitat (for all species)including replacement lands.Procedures for per iodically reassess ing the effectiveness of mi tigation measures,and 28513 840904 30 ~----------_......-,--------......_------------- .. .. procedures for implementing "mid-course"corrections should be discussed in the FEIS.Additionally.before altering habitats for the benefit of moose. the ultimate fmpacts of these changes on present wildlife inhabitants must be assessed. 61.Section 5.4.5,Page 5-15.Future Studies DF&G supports the recommended and ongoing studies 1 isted in section 5.4.5. Research conducted by the Subsistence Division should be used as a basis for designing future studies. 62.Section 5.4.5,Page 5-15,Subsistence The DEIS is incorrect in stating that tI •••subsistence activities are protected by law for a particular population of Alaskans •••11 State and federal laws protect subsistence uses.which are not restricted to any specified group of people.It is also incorrect to imply that subsistence activities are important only to "rural native communities,"since communities that are largely non-native (e.g.Skwentna)may rely greatly on subsistence uses of fish and game. 63.Appendix N,Page N-IO,Ahtna Neither the Copper River Native Association nor Ahtna Inc.are in "the regional corporation Cook Inlet Native Association,Inc.(p.N-IO).tI 28513 840904 31 "-.;:.' ~... Specific Comments on Alternatives 64.Section 3.5.1.2,Page 3-65,Alternatives,Land Management and Ownership - ..... As with the Susitna Project,the Keetna Project could be subject to delays related to unadjudicated competing state and native selections for federal land in the project area. 65.Section 3.5.4,page 3-66,Alternatives,Keetna Project The potential for fisneries impacts with the development of the Keetna alternative hydro site appears to exceed any otner individual site discussed in the DEIS.The Talkeetna River is a major producer of salmon with rapidly increasing levels of recreational use.The DEIS implies that little is known about the size "and composition of fish migration up the Talkeetna River.As mentioned in comment on Section 3.5.4,the Talkeetna River supports large runs of chum salmon,possibly exceeding 200,000 fisn.The DF&G regularly monitors chinook and sockeye salmon escapement on several major clearwater tributaries of the Talkeetna River.Prairie Creek,above the Keetna site,has the highest density of spawning chinook salmon per stream mile of any stream within the Matanuska-Susitna Borough.Chinook salmon escapement in Prairie Creek generally range between 3,000 to 5,000 fish,but in 1976 it was as high as 6,513 fish.Equally important is the fact that these salmon support the highest concentration of brown bears during July and August of any known location within the Susitna basin. Nearly 40 bears are attrac ted to Prairie Creek to feed on chinook salmon. Prairie Creek also contains sockeye and coho salmon,but numbers are not well quantified. Disappointment Creek,located at the Keetna site has a chinook salmon escapement of 200-300 fish,and is also popular for rainbow trout and Dolly Varden fishing which occurs at its confluence with the Talkeetna River. 28513 840904 32 ._----- --'.-<:f"".-~..".~..._:... • .~...'-.--~,,:,.,:....:. .F- - Chuni Ina Creek (some times called Clear Creek),downs tream of the Kee tna site,is a major salmon producer and a major sport fishery occurs at its confluence with the Talkeetna River.On even years,pink salmon escapement often exceeds 250,000 fish.Cninook salmon escapements have been as high as 2,000 fish.Sockeye escapement into Fish Creek (a tributary to Cbunilna Creek)range fr,?m 5,000 to 10,000 fish.Up to 2,500 cobo salmon and 7,500 chum salmon have been estimated in this creek.Sport fishing on Chunilna Creek averaged 4,260 user-days annually of fishing effort between 1977 and 1981. Tne potential impact of the Keetna dam on salmon resources is greater than that which would occur with the Susitna development,because the Talkeetna River salmon populations greatly exceed those in the Susitna River above its coniluence with the Chulitna River.The size,composition and behavior of fish runs above and ·below the Browne and Johnson sites are less well known and the magnitude of impacts are difficult to compare with the Susitna. 66.Section 3.5.8,page 3-71,Alternative,Johnson Project In discussing the Johnson alternative hydro site (p.3-71),there is no reference to the Subsistence Division I s major-paper on Dot Lake (Tecnnical Paper 119 by Gayle Martin,reference 8).The community of Dot Lake would be flooded by this project.The Subsistnece Division has also supported res~arch in Nenana (Technical Paper 191 by Shinkwin and Case,reference 9), and this would be useful in the-analysis of impacts at the Browne alternative hydro site. 67.Section 4.1.8,Page 4-49,Alternatives,Impacts on Subsistence Local resource use is an integrated part of community life and local econo- mics.The extent to wnicn subsistence use may be impacted will continue to depend upon resource availabili ty,habitat protec tion,and management practices.It must be stressed that the improvement of wage opportunities ..... 28513 840904 33 ~-_.'0.->..-.--.~,..-........:--: - - - ".., - in local communities will not re~uce the impact on the local resource user of either increased competition with other hunters or with lots of target populations. 68.Section 4.3.8,Page 4-79,Alternatives,Impacts on Subsistence The DEIS,when discussing socioeconomic factors affecting the village of Tyonek for the Natural-Cas-Fired Generation Scenario (4.3.8)states that "A construction camp to house workers near the site would reduce (impacts on subsistence ac tivities)cons iderably."The past experience with workers at the timber mill south of Tyonek is an example of an industrial project bringing a new population to the area.The hunting and fishing activities of the new work force competed with Tyonek residents for fish and game resources,primarly moose.Therefore,regardless of how a new work force is housed,they will have an impact on customary uses of the resource.It should also be emphasized that regardless of the limits on the acitivites of the workforce,the construction of support facilities (airstrips"roads', etc.)impro'le access to the local area,hence increasing competition for local resources if the native corporations tolerate or encourage access into their lands. 69.Section 4.5,page 4-86,Alternative Dam Site The alternative dam sites suggested by FERC have not been thoroughly analyzed.There are significant impacts associated with the alternative dam sites that reduce their feasibility.The sites cannot truly be considered as alternatives until an accurate assessment of their environmental impacts has been completed. 70.Section 4.5.8,page 4-89,Alternatives,Tyonek/Beluga Area Information available fromDF&G has not been utilized 1n developing the discussion of the Susitna development alternatives in the Tyonek area.The 213513 840904 34 • ,.. .,~:.. Subsistence Division has prepared numerous technical reports on resource uses in the Beluga/Tyonek,Chakachatna areas. ,....71.Section 4.7,page 4-91,Alternatives ..~ There is insufficient information avai lable to compare the effects of the alternative hydroelectric.project with the proposed project.Comparisons of alternatives with the proposed project need to be based on the amount, availability,and suitability of habitat types affected and the manner in which habitat changes would impact the wildlife species and populations dependent upon them.Total acreage comparisons above are inadequate • 28513 840904 35 ..- •.J -......-...-.'~..-, References OMB Comments on FERC DEIS Susitna Hydroelectric Project 1.Issues list March 6,1984 Susitna Hydroelectric Project Alaska Power Authority 2.Mr.Robert L.Grogan,Associate Director Division of Governmental Coordination Office of Management and Budget Letter of May 8,1984 to: Mr.Jon S.Ferguson,Project Manager Susitna.Hydroe1ectric Project Alaska Power Authority Topic:Comment on Susitna Hydroelectric Project Issues List. ·3.Mr.Jon S.Ferguson,Project Manager Susitna Hydroelectric Project Alaska Power Authority Letter of July 23,1984 to: Mr4 Robert Grogan,Associate Director Division of Governmental Coordination Office of Management and Budget Topic:Responses to OMBls Comments on The Susitna Hydroelectric Project Issues List. 28513 840904 36 #. I.• I~e .."'., References Cont I d I~ 4. 5. 6. 7. Department of the Army,Office of the Chief of Engineers Document ER 1110-2-106 Appendix 0 Recommended Guidelines for Safety Inspection of Dams Alaska Department of Natural Resources et al., June 1984,Susitna Area Plan,Public Review Draft Mr.Robert L.Grogan,Associate Director Division of Governmental Coordination Office of Management and Budget November 18,1983 Letter to: Mr.Larry Crawford,Executive Director Alaska Power Authority Review and Comment upon Application for License Susitna Hydroelectric Project (In:Responses to Agency Comments -January 19,1984) Alaska Department of Fish and Game,1984 Cantwell Technical Paper 8.Alaska Department of Fish and Game,June 1983 Use of Natural Resources by Residents of Dot Lake,Alaska Technical Paper No.19,Gayle Martin,Division of Subsistence 9.Alaska Department of Fish and Game.February 1984. Modern Foragers:Wild Resource Use in Nenana Village,Alaska. Technical Paper No.91,Anne Shinkwin and Martha Case, Division of Subsistence 2aS13 840904 37 - - - - ·~,MEMORANDUM State of Alaska TELEPHONE NO: r- i TO: FROM: Jack Heesch,Project Coordinator DATE: OMS/Division of Governmental Coordination Anchorage FILE NO: 0;fi~~Y;- Carl M.Yanagawa,Regional SupervisOYSUBJECT: Department of Fish and Game Habitat Division Anchorage 344-0541 Susitna Hydroelectric Project (FERC #7114)DEIS (....'"..; .....,:.... -. The Alaska Department of Fish and Game (ADF&G)has reviewed the Susitna Hydroelectric Project,Draft Environmental Impact Statement (DEIS)prepared by the Federal Energy Regulatory Commission (FERC).Our review is based on the adequacy of identification and quantification of fish and wildlife resources affected by the project and alternatives,the impacts to those resources attributable to the project,and the specific mitigation options proposed to offset these impacts. Based on our review of the DEIS,the document does not contain sufficient fish and wildlife data on which to base decisions regarding the project. The major areas requiring more thorough consideration before an adequate assessment of the project1s environmental impacts can be made are as follows: 1.There is need for a more comprehensive assessment of the fish and wildlife resources of the Susitna River downstream from Talkeetna. The anticipated impacts to these downstream resources and users which are attributable to the project need to be identified and quantified.Analyses should include the effects of changes in river stage and water quality on rearing and overwintering fishes. They should also address riparian vegetation,wildlife (including moose)and the recreational fishery. 2.There is a need to identify instream flows necessary to maintain fishery resources downstream from the proposed impoundments. Operational flow scenarios need to be developed that consider the requirements of all life cycle stages of fishes.Instream flow information should include target fish species,habitat units associated with alternative flow scenarios,fish population objectives,and the minimum and maximum flows necessary to maintain target populations during all seasons of the year. 3.The identification of the full range of important impacts to fish and wildlife and the establishment of mechanisms for approaching mitigation of these impacts must be achieved.This should include a more quantifiable assessment of anticipated impacts to fish and wildlife populations and their habitats,a process for agreeing on the magnitude of impacts,and the formulation of a comprehensive fish and wildlife mitigation policy and plan. ·.Jack Heesch -2- '.'~.y, 4.The impacts to fish and wildlife resources caused by access to the project area must be more fully evaluated.These include the effects of access to the project area for project construction and operation as well as increases in accessibility of surrounding lands to the general public. 5.Socia-economic impacts on commercial,recreational and subsistence use of affected resources and supporting industries require further assessment.This should include the identification of resources used;the quantification of use levels;the description of use patterns,including seasonality and its context within local communities;and descriptions of geographic areas of use. 6.Mitigation planning,as mentioned above,must be further developed.This is probably the most important issue.This cannot be achieved until the impacts to fish and wildlife are better identified.Then,the EIS should include a discussion of how impacts to fish and wildlife resources will be mitigated through project design and/or through compensatory measures.A comprehensive evaluation of impacts and applicable mitigation alternatives needs to be conducted to evaluate environmental costs,the feasibility of mitigation,and the trade-offs of fish and wildlife resources and habitat involved. The Alaska Power Authority (APA)in consultation with other state and federal agencies (including the ADF&G)has developed a comprehensive listing of impact issues.(Please refer to issues listed in the March 6,1984 letter from Jon Ferguson (APA)to Don Collinsworth (ADF&G)and the May 8,1984 State response to the list from Robert Grogan of the Division of Governmental Coordination to Jon Ferguson.)A process has been initiated for addressing these issues,evaluating the significance of each,and arriving at resolution.The FERC should review the impact issues as developed by the State of Alaska.An analysis of the impact issues,subsequent identification of significant impacts and recollJIlended plan to mitigate those significant impacts should be included in the ElS. The FERC should also be made aware of the presentations and discussions of the Susitna Hydroelectric Issues Settlement Workshops.The mechanism by which FERC plans to incorporate this and subsequently prepared information into the licensing process should be identified. 7.Information presented regarding the environmental impacts of the alternative hydroelectric projects is not sufficiently detailed to facilitate a reasonable comparison of these with the proposed action.While there is relatively little quantifiable information available for some of the alternative sites,we believe the discussion on alternative hydroelectric sites could be better supported by information available from the ADF&G and other agencies. Jack Heesch .'.-•~:":-_~"4 '.:••":~.'--..~-,,,;;'---_. -3- _. These are the same concerns we expressed in our comments on the APAls application for licensing of the project.We found no significant improvements in the'way that the DEIS addresses our concerns.We recognize that all impacts cannot be quantified at this time.However,the level of information contained in the DEIS does not reflect the amount of project- specific information that is currently available to the FERC from the APA, this department and other sources.Further,impacts that cannot be quantified need to be identified.Effective mitigation is predicated on the accurate prediction and quantitative evaluation of the impacts of a proposed action on fish and wildlife resources and the incorporation of this knowledge into the planning process. It is a requirement of the Federal "Fish and Wildlife Coordination Act ll (48 Stat.401,as amended,16 USC 661 et.seg.)that the cost of mitigation must be incorporated in the benefit-cost assessment relating to project feasibility.We recommend that fulfillment of this requirement be reflected in the FEIS. Alaska Statutes 16.05.840 and .870 require that an applicant must have plans and specifications approved by the department before constructing a dam on a river that is important to anadromous fish.If these plans and specifications are not sufficient in the view of this department,approval may either be denied or conditioned with those measures which must be met to protect fish resources before construction of the project may begin.If mitigation planning for the Susitna Hydroelectric Project is adequately addressed in the EIS,the department can readily identify stipulations which may be necessary under either of the above mentioned authorities.This would insure that stipulations are no more conservative than necessary,and that the regulatory time fram~is minimized. The ADF&G does not believe that the information regarding the impacts of the proposed project on fish and wildlife resources is sufficiently complete. The document does not provide a comprehensive analysis of impacts,nor does it contain an acceptable mitigation plan.Information contained in the DEIS does not reflect the level of information available regarding the project. Not clearly identified are the mechanisms which will incorporate information arising from ongoing studies and other sources into the impact assessment and mitigation planning process.The ADF&G strongly recommends that the EIS be modified to accommodate the concerns expressed in this letter. Our more detailed comments on the DEIS are enclosed.We hope these comments are useful in modifying the EIS to a point where it can be useful in making decisions on the feasibility of the project.If you have any questions regarding these comments please contact Mr.Norman Cohen in Juneau at (907) 465-4100. Enclosure cc:Commissioner Richard Lyon,Chairman,Alaska Power Authority Board Commissioner Esther Wunnicke,ADNR Commissioner Richard Nevel,ADEC Larry Crawford,Executive Director,APA r.', ..- I t,,.~/ ~._,'_.-,.'-'.':..' Enclosure:A'laska Department of Fish and GameConments on the Susitna ~~droelectric Project DEIS,prepared by the Federal Energy Rlegulatory Corrmi ssion FISHERIES Impact Assessment The DEIS has not resolved the issue of an acceptable flow regime to protect fishery resources during project operation.An effective release schedule capable of minimizing impacts is a necessary component for determining an acceptable mitigation plan and must be incorporated into the license.The DEIS should identify those habitats potentially affected by altered flows, the resources utilizing these habitats during all stages of their life- cycle,the processes which could affect these resources,and methods to sufficiently mitigate the impacts identified.The DEIS does not predict with any degree of confidence the project1s effects on downstream water temperatures,turbidity,ice conditions,and groundwater upwellings.An understanding of these relationships is necessary to determine the project's effect on fish habitat and dependent fish populations.Infonmation in the DElS is inadequate to determine whether the minimum summer flows or maximum winter flows will have a positive or negative effect on anadromous or resident fishes. Table 4-2 shclws significant temperature changes in the Talkeetna to Cook Inlet reach of the river during both reservoir filling and project operation.On page 4-26,the DEIS states that"downstream of the confluence of the Chulitna and Talkeetna Rivers,growth rates of juvenile salmon and resident species would be suppressed by cool temperatures.The FERC staff estimated a Y'eduction in accumulated June-September growth in this reach by about 50 to 60 percent compared to potential growth at pre-project temperatures"These values contradict previous statements (p.4-23)that only minor temperature differences are expected downstream of the Chulitna confluence. If these gro~ith reductions are realistic for the lower reach of the Susitna River,they could have major impacts on juvenile salmon utilizing this reach.This reach supports a major portion of the Susitna River salmon population.The significance of the potential impact on lower reach juveniles caused by reduced growth are not discussed in this DEIS and certainly shc)uld be further evaluated.There are virtually mill ions of emigrating juvenile salmon in the lower reach.Adult salmon enumerations on tributaries have been conducted for many years and would provide some rationale for estimating emigrating juvenile numbers in the lower reach. Unfortunately,little information is available on the timing of juvenile salmon emigrations out of the Susitna River.If the majority of juveniles have emigratl~d prior to the period of projected temperature changes,impacts may be minimal.Expanded effort should be directed toward determining juvenile emigration timing in the lower Susitna River reach. The ADF&G has repeatedly recommended a more thorough analysis of the fisheries and aquatic habitats downstream from Talkeetna.The impacts of the altered flows in this reach may be more significant than those upstream. ·---'.-~.-: I""'" t'.. - Below its confluence with the Chulitna River,the Susitna River is broad and relatively shallow.Therefore,an alter~d flow regime may affect relatively more aquatic habitat downstream than upstream.We again recommend that additional emphasis be directed toward study of the resources and potential impacts downstream of the Talkeetna River. The DEIS sta.tes that lilt is not poss ib1e to quanti fy the di rect impact of the project on the cOJm1ercial,sport,or subsistence fisheries,except that all other fa:ctors being equal,changes in catch would be approximately proportional to increases or decreases in the size of the spawning stocks" (p.4-33).For the sport fishery,this conclusion suggests a lack of famil iarity with factors affecting the sport fishing effort and harvest.To understand the potential impacts of the project on the recreational fishery that occurs downstream from Talkeetna,it is necessary to understand how these fisher'ies function.Although this information was presented in ADF&G's comments on the license application,we will repeat it for consideration in future environmental analysis and mitigation planning. ,. On the Susitna River from Talkeetna downstream to its confluence with the Yentna Rivel~,there are nine tributaries flowing into the cast side of the Susitna and one flowing in from the west that contain significant fish populations..Most of these streams support major salmon runs and jointly support up to 100,000 man-days of fishing effort each year.Access plays a major role 'in limiting growth of the recreational fisheries that occur on these streams.Much of the land adjacent to these streams is in private ownership and public land that is available is relatively undeveloped or inaccessibll2.Other than in the Talkeetna area,there are no public boat launches thiat allow anglers access to the Susitna River.The state has recognized the problem and has spent approximately $500,000 to purchase 1ands at thle mouths of Montana and Sheep Creeks.The state has also initiated a road construction project that will provide access directly to the Susitna River at the mouth of Willow Creek.This project is expected to exceed $5 million and result in a substantial increase in angler access to the Susitna River and Willow Creek. An important aspect of the recreational fisheries is that they are located primarily at confluences of tributaries to the Susitna River.Recreational activity in these confluence areas is directly related to the large number of salmon that are present at these sites.As all five salmon species migrate up the Susitna River they tend to congregate at the mouths of virtually all of the clear water tributaries flowing into the Susitna River. During the open water season the areas around the mouths of tributaries provide ideal resting,or staging areas for all adult fish species as well as rearing areas for juvenile fish.The extent to which these areas are used is dependent on the depth of the water at the tributary mouths which in turn is sensitive to changes in mainstem flow.At high flaws,the mainstem creates backwater areas at the tributary mouths,thus increasing water depth.At low mainstemflows,the backwater areas are eliminated,resulting in shallower water and increased flow velocities at the mouth.When these backwater a:reas are eliminated,their attractiveness to flsh is significantly reduced and fish will be displaced to other areas more suitable.This could have significant effects on a recreational fishery since the fish may be displaced from a tributary mouth that is easily accessible to anglers.In the Susitna River,natural low water conditions -2- ·."'. - - ..... which affect recreational fisheries do occasionally occur.When they do,it is primarily during May and June during the chinook salmon migration. Chinook salmon are the most highly prized sport fish in Alaska and as such they attract large numbers of anglers to the limited areas that are opened for fishing.The Susitna River chinook salmon is a limited resource that has been intensively managed and has a long history of allocation conflicts between various user groups.Sport fishing for chinook salmon is allowed on only five Susitna River tributaries in the Talkeetna to Cook Inlet reach with the exception of the Yentna and Talkeetna River drainages which are also open to chinook salmon fishing.Three of these streams,Willow, Caswell,and Montana Creeks,are east side tributaries that are open to chinook sa1mcln fishing only on weekends while the other two,the Oeshka River and Ale!xander Creek which flow in from the west side,are open to chinook salmon fishing 7 days per week.The weekend-only fishing streams receive extrE!mely heavy fishing pressure during the chinook salmon fishery. Since those clreas that are opened for chinook salmon fishing are extremely limited,any physical changes in backwater areas on these streams which may reduce holding areas for chinooks could be particularly dama9.~ng to the recreational fishery. It is also important to note that salmon utilizing tributary confluence areas are not necessarily migrating into those tributaries.All five salmon species migrating to the upper Susitna,Chulitna,and Talkeetna Rivers enter,in va1rying degrees,the sport fisheries that occur at the confluence areas of the lower Susitna tributary streams.Any impact that occurs to salmon speciles that utilize the Susitna River in the Devil Canyon to Talkeetna reach has the potential to impact the recreational sport fishery which harvests these fish in downstream confluence areas • Flow reductions under the proposed filling schedule may alter the physical characteristics of the tributary mouths in the upper portion of the Talkeetna to Cook Inlet reach.These are the areas where the major fisheries occur.Ouring the open-water season,induced mainstem aischarge reductions of 34 percent in June and 28 percent in July may reduce the areal extent of these backwaters.Water depths in these areas will also be reduced.The Susitna River below Talkeetna is moderately to extensively braided,with the river channels wide and shallow.Therefore,this reach is more sensitive to flow reductions than deeper more incised channels,which occur further upstream.Reductions in discharge during and after filling of the reservoir could result in substantial changes in the habitat at tributary mCluths which may seriously impact eXisting recreational fisheries. Since the tributaries flow into a variety of habitat types,the impacts of reduced flo\l/s wi 11 vary. There has bE!en minimum effort,especially in tributaries,to quantify adult salmon escapement in the Susitna River below Talkeetna.It is very possible that adult salmon escapement in this portion of the Susitna River exceeds those estimates available for the river above Talkeetna.This would mean that the reclch below Talkeetna is especially important to rearing juveniles. Here again,there is very little quantitative information.Information is needed on juvenile rearing in the reach below Talkeetna.Large numbers of juvenile ch"inook salmon and adult resident species are migrating out of numerous east side Susitna tributaries in the reach below Talkeetna.They -3- ,. c· .. are dependent on 'over-wintering habitat in the Susitna River.There are no quantitative data presented that indicate their abundance or which habitats they a.re dependent upon.There is almost cert.ainly going to be an impact on juvenile fish rearing in this reach with post-project winter flows changing by OVE!r 200 percent.There are no data which show how winter habitat will changE!with the dramatic increase in flow. It appears that the transmission line corridor will be crossing in the illlllediate area of the Burma Road's intersection with the Little Susitna River"The Little Susitna River is designated as a recreational corridor in the Willlow Sub-Basin Area Plan,from the Parks Highway downstream to where it enters the Susitna Flats State Game Refuge.In the Area Plan the management intent is to protect recreational values and provide for visual and sound buffers in the corridor.Recreational use on the Little Susitna River is increasing at an extremely rapid rate,primarily due to upgrading of thl~Burma Road which accesses the lower Little Susitna River.In 1983 angling effort reached 35,000 man-days which resulted in this fishery becom'ing the second largest freshwater sport fishery in Alaska.This is an area IJf extremely high use 'and future plans include the development of a campglround and boat launching facilities. Mitigation Planning The mitigation plan needs to contain contingency elements that can be incorporated as additional information is collected and anticipated impacts are better quantified.Plans for habitat modification,as proposed for sloughs,should be provided and should include engineering designs, construction,operation,and maintenance plans and a detailed cost analysis. Without these,mitigation proposals cannot be evaluated nor developed with any assurance of success.This is necessary to ensure that mitigation occurs and the mitigation actions are in harmony with the overall development and conservation of the resources in the area. "Losses of resident fish species and habitats within the impoundments can only be mitigated through compensatory habitat replacement or enhancement elsewhere.Resolution of this issue must be accomplished jointly between the applicant and the resource agencies in the context of presently feasible propalgation technology and the benefits to the resource and user groups of artificially stocking waters in the project area.Therefore,it is not apprClpriate to make a decision on this tradeoff such as the artificial stocking of Kokanee in the Watana impoundment,until a process for addrE!Ssing the overall mitigation plan 1.s implemented.The compensating measures proposed to mitigate loss of Arctic grayling habitat in reservoir zones (p.2-25)are not necessarily desirable options.Until the resource agencies discuss compensation measures,the options listed (research on graylling propagation,hatchery facilities for grayling,and introduction of rainbow trout into the Devil Canyon reservoir),should be considered only as options proposed by the applicant as they have not been endorsed by any agency. The ADF&G does not support or propose regulations to solve problems that are more appropriately dealt with through the development of an effective miti~}ation plan.Mitigation plans should indicate'that a particular impact -4- - """ .... - li.:~ L_.' .... .... .i- I I might requirle changes in fish and game regulations but they should not attempt to specify what those changes will be.Management options and mitigation options should be dealt with separately.The DEIS addresses management options as part of the mitigative process for the Deadman Creek drainage (p.2-24).Regulatory restrictions are the responsibility of the Boards of Fisheries and Game.This does not apply to restrictions placed on individuals brought into the area to engage in construction activities.It applies only to regulations affecting the general public.It may be appropriate to have stipulations,rather than regulations of the Boards,to limit project personnel from engaging in certain activities,as construction projects can create unusual concentrations of people brought into the area by means not available to the general pUblic.- Results of ADF&G studies indicate the Talkeetna River supports large runs of chum salmon,possibly exceeding 200,000 fish.The FERC staff expects that losses to salmon production in the Susitna River above Talkeetna during the fi 11 ing oper'ation of the reservoi r woul d be partially offset by increased production in the Talkeetna River (p.4-32).The FERC staff assumes that fish which normally would migrate up the Susitna River would select for the warmer water'of the Talkeetna River.Even so,any displacement of additional fish into the Talkeetna River system may lead to increased competition and overcrowding for spawning and rearing.The possibility of lost production in the Susitna River being compensated for by increased production on the Talkeetna River is highly speculative. Alternatives The potential for fisheries impacts with the development of the Keetna alternative hydro site appears to exceed any individual site discussed in the DEIS.The Talkeetna River is a major producer of salmon with rapidly increasing -levels of recreational use.The DElS implies that little is known about the size and composition of fish migration up the Talkeetna River.The ADF&G regularly monitors chinook and sockeye salmon escapement on several major cleanlater tributaries of the Talkeetna River.Prairie Creek,abov1e the Keetna site,has the highest density of spawning chinook salmon per stream mile of any stream within the Matanuska-Susitna Borough. Chi nook salmon escapement in Prai ri e Creek genera l1y range between 3,000 to 5,000 fish,but in 1976 it was as high as 6,513 fish.Equally important is the fact that these salmon support the highest concentration of brown bears during July and August of any known location within the Susitna basin. Nearly 40 brown bears are attracted to Prairie Creek to feed on chinook salmon.The ADF&G has recommended that this stream and its adjoining uplands be protected from incompatible land uses.Prairie Creek also contains sockeye and coho salmon,but numbers are not well quantified. Disappointment Creek,located at the Keetna site has a chinook salmon escapement of 200-300 fish,and is also popular for rainbow trout and Dolly Varden fishing which occurs at its confluence with the Talkeetna River • Chunilna Creek,downstream of the Keetna site,is a major salmon producer and a major'sport fishery occurs at its confluence with the Tal keetna River. On even yeairs,pink salmon escapement often exceeds 250,000 fish.Chinook salmon escapements have been as high as 2,000 fish.Sockeye escapement into -5- _........:...... .... r (..•..",Xi ... .....: .- - I" ! Fish Creek (a tributary to Chunilna Creek)range from 5,000 to 10,000 fish. Up to 2,500 coho salmon and 7,500 chum salmon have been estimated in this creek.Sport fishing on Chunilna Creek averaged 4,260 user-days annually of fishing effort between 1977 and 1981. The potential impact of the Keetna dam on salmon resources is greater than what would occur with the Susitna development because the Talkeetna River salmon populations greatly exceed those in the Susitna River above its confluence with the Chulitna River.The size,composition and behavior of fish runs above and below the Browne and Johnson site are less well known and the magnitude of impacts are difficult to compare with the Susitna. TERRESTRIAL Impact Assessment If public rOcld access to lands adjacent to the project is provided,it should be clE~arly specified in the DEIS.This will enable assessment of impacts attriibuted to any increased access.These impacts can then be accounted fOl~in the mitigation plans.Specifically,if vehicle access is allowed to the south side of the Susitna River via the Watana dam,this will initiate a h()st of secondary development and subsequent impacts directly related to the project that will require mitigation.With access to the south side of the Watana dam,ungulate populations ~ill be affected by increased hunting and disturbance.In addition,ORV and ATV traffic will disturb vegetation.Brown bear use of Prairie Creek (see Fisheries section) can be expected to decline with increased access and development south of the Watana dam.This impact is recognized in the discussion of alternative access routes (p.4-79),and the same impacts would occur if access to the south side of the river is prov~ded.Prairie ~reek attracts brown bears from a minimum area of 7,900 km (not 5,700 km ,p.k-17).Only brown bears make seasonal movements to Prairie Creek during salmon runs,not black bears as reported on page k-82. Impacts are usually stated in terms of the current populations,current habitat conditions and current management goals.In some cases,they focus only on the fate of currently living individuals rather than populations. This approach may be adequate for short-term impacts.It is not adequate when the dur'ation of an impact is likely to span a period during which populations,habitats or management goals or regulations may change significantly.Management regulations may change every 2 or 3 years, populations can certainly change significantly over a decade and habitat over 2 or 3 decades.These changes are well within the life of many of the impacts of the project. Changes brought about by the project may have widely different effects on different population sizes or under different environmental conditions. Mortality induced by the project might be insignificant at high population levels.In some instances,the project might permit contfnued existence of a population of the current size but preclude growth to its current potential.In other cases pre-and post-project populations might be the same size,but the post-project population might have less capacity to sustain hunter harvest and predation or to recover from periodic -6- ._••~_:'••••••••••••~'-40"~'._~.-_••';.;..:.__~.~••~•.';-~-'.~,.,.:·..2:.;;.·_">-.~_._:..:-..__ - ,.... - .,... environmental perturbations,such as severe winters.While the DEIS occasionally alludes to changes in productivity,it tends to focus on whether the current population level can be maintained. The results of cumulative impacts are not emphasized enough.While individual iTnpact mechanisms may not be significant when viewed independently,cumulative impacts,resulting from a combination of lesser events,may have more severe effects on wildlife populations.The combination of events,such as increased human access,habitat loss, disturbance,disruption of migratory pathways,and changes in predator-prey ratios,may have impacts when acting together that exceed the sum of the impacts from the individual activities. A large numbE~r of issues seem to be set aside simply because they cannot be precisely quantified.Clearly it is not possible to precisely quantify all of the impacts.However,it is difficult to see how reasonable and responsible mitigation decisions can be made unless·there is some indication of the magnitude of the impact.Many of these issues can at least be narrowed to eln order of magnitude.They should be thoughtfully examined and outer bounds placed on the problem.For example,a maximum possible level of habitat lc)ss and alteration adjacent to the impoundment and downstream can certainly be determined.These estimates can be narrowed by developing more logical scenarios.The effects of several of the scenarios on a wildlife population can be examined to identify a worst case situation.If this worst case shows an unacceptably high impact,further studies can be designed to narrow the range of possibilities.The DEIS states that "In the reach from Talkeetna to the Yentna River,it is impossible to predict post project changes in vegetation with any certainty."Downstream vegetation changes could greatly affect wildlife'populations over time and the possible range of impacts in this area needs to be 'discussed.There are presently available more recent studies for moose,bears,wolverines,caribou and sheep.These should be incorporated in the DEIS. Some attempt at the ranking of impacts within and among species shou.1d be made to aid in identifying further study needs and determining the importance of specific mitigation'measures.Ranking impacts helps detennine where the rna,jor efforts of the mitigation plan should be directed.In ranking impacts,certain questions need to be addressed.These include: what percentage of the available habitat,for each type within the region, will be affected?Is the acreage lost within a specific habitat type significant?How much similar habitat has been lost in nearby accessible areas?What species of wildlife use these habitat types?What factors limit the population growth of these species?How will cumulative impacts in the region affect these wildlife populations?How will these habitat types change over the life of the project?By answering similar questions for the various types of project related alterations to lands and waters, the potential scope of a problem can be determined even when precise quantification is impossible.At the very least,impacts can be more realistically weighted so that the need for further study or specific mitigation measures can be assessed. An important consideration for the Nelchina caribou herd,not addressed by the DElS is long-term management and the dynamic nature of populations.The DEIS states that the ADF&G's goal is to maintain the population at 20,000 -7- ·-~.•..':.:--:!:-".;~...':-._._~,.•:......-_·.-.r .:.,._.'_.'........... t.:"-...,-" animals.This information is outdated.The ADF&G1s goal is to increase the size of the herd and maintain it at 30,000 adult caribou (36,000 including animals less,than 1 year old).The effect of the reservoir and access road on a herd of this size may be significantly different than the effect on the current population because the Watana reservoir would intersect a major historical migratory route of the Nelchina herd. Major herd crossings of the impoundment area have usually occurred when population llevels were relatively high.It appears likely that the probabi,l ity of major crossings of the impoundment area and increased use of the northwestern portion of the range will increase if herd size increases. The peak si~~e of the herd was recorded in 1962 when 65,000-70,000 animals were counted,not 40,000 animals in 1955 (p.k-12). The assessment of impacts to Dan sheep in the DEIS contains several omissions and inaccuracies.These include ADF&G studies on Dall sheep published in 1984.Most important are the predicted impacts to sheep.As a11 of the heavi ly used 1i ck si tes at the Jay Creek mi nera 1 1i ck area are above 2200 feet in elevation,they will not be inundated by the impoundment and mineral leaching will not occur.Only a few lick areas that receive relatively 'little use by sheep will be inundated.The greatest impact to Dall sheep may result from the Watana impoundment blocking or impeding sheep from crossing Jay Creek and limiting use of important lick sites on the east side of the creek.Lick sites on the east side of Jay Creek are heavily used by she1ep which arrive from the northwest.As mentioned in the DEIS, the effects of construction activities and disturbance from recreational boaters and low-flying aircraft,may also have significant impacts.Erosion at some lick sites could result from seasonal fluctuations in water levels in the reservoir,reducing the already limited escape habitat adjacent to the li ck area. The approach used in the DEIS to quantify impacts to black bears results in an inaccurate assessment of the impacts.To more accurately assess impacts, the study area needs to be divided into three distinct areas:Watana impoundment,Devil Canyon impoundment,and downstream of Devil Canyon.In the former,a very high percentage of forested black bear habitat (70-90 percent)will be inundated.This includes nearly all the important deciduous forest habitats.In the second and third areas,a much smaller acreage of forested habitats will be disturbed.Combining all three areas masks the e~ffect of habitat destruction in the area of the Watana impoundment.Habitat destruction in the Watana impoundment will essentially eliminate the resident black bear population in this area,while the impacts in the Devil Canyon area will be much less. A good analysis of the amount of habitat lost by the project,for all species,will not be available until the development of suitable habitat maps,currently in progress,is completed. The DEIS states a "•••los s of about 10%of the major wintering and spring calving habitat within 10 miles of the impoundment area (p.4-38).11 How this figure of 10%was arrived at is unclear.In addition,it can be misleading by itself.A small percentage of available habitat may support a large number of moose,especially during the winter.If high quality habitat is inundated or disturbed by construction activities the -8- I"'"" I"'"" .... - ..... consequences t()the moose population would be more severe than if low qua lity habi tat was di sturbed.Therefore,the type and quality of lost habitat and its value to moose needs to be assessed,not just the areal extent.In thl!spring of 1983 over 600 moose were counted just in the Watana impoundlnent area and approximately 2800 moose range in the area of the Devil Canyl:,"and Watana impoundments.The same problem previously described for iilssessing impact of lost habitat to bears appl ies for moose. With better habitat maps,this assessment should be improved.In addition, displaced moosle will be subject to much higher levels of mortality due to predation and higher concentrations of moose on reduced winter range. The impacts projected for wolverines and wolves (p.4-43)are incorrect.At least 35 wolverines could be affected by the impoundment alone.Up to six wolf packs have territories overlapping the proposed impoundments,and all six could be disrupted.In addition,access roads,project facilities, construction activities,and transmission corridors would likely reduce additional habitat for wolves and wolverines or cause disturbance and increased mortality. Mitigation Planning The DElS states that the 1I •••l ac k of definitiveness is due,in large part, to a lack of sufficient information as to the feasibility of mitigation proposals"(p.5-11).While we agree with this statement,another major factor for thE!poorly defined mitigation plan is the lack of supporting information to develop mitigation proposals.The vegetation mapping and moose carryin~l capacity model being developed are two important elements for input into thE~mitigation plan.Previous vegetation studies have concentrated on describing "vegetation types ll rather than "habitat types.1I "Habitat type"maps are essential for analyzing the amount of habitat lost for all speci~!s due to the proposed project. The DEIS expresses our concerns (p.5-11)about the feasibility and specifics of habitat enhancement measures.ADF&G agrees with the FERCls analysis that II •••the Applicant has not documented the likelihood of success for its rehabilitation and enhancement proposals,nor documented the amount of compensation that could be attributed to the enhancement efforts •••"and the "•••impacts to wildlife would not be compensated for by enhancement t1echniques ll as currently proposed by the Appl icant.Along with studies on thle feasibil i ty of enhancement for meeting the goals of wildl ife mitigation,other mitigation measures for lost wildlife habitat (for all species)including replacement lands,and contingency plans,if experimental measures are not beneficial,need to be discussed.Additionally,before altering habitats for the benefit of moose,we must assess the ultimate impacts of these changes on its present wildlife inhabitants . Alternatives There is insufficient information available to compare the effects of the alternative hydroelectric project with the proposed project.Comparisons of alternatives with the proposed project need to be based on the amount, availability,and suitability of habitat types affected and the manner in -9- ·-_...~-'.' .. -_..';'':''::::~-,'.-_.-. - .~ ')... I I - which habitat changes would impact the wildlife species and populations dependent upon them.Total acreage comparisons above are inadequate. SOCIOECONOMIC FACTORS Impact Assessment The subsistence section has several errors or has presented very vague discussions em local resource uses.Some of this has undoubtedly resulted from failure to use primary sources of information when discussing subsistence issues.The Subsistence Division of the ADF&G has prepared several repof'ts and maps with valuable infonnation on subsistence uses within this f'egion.This infonnation should have been included in the DEIS. The limited iinformation on specific subsistence use patterns for the area was not used"The OEIS states that "Subsistence user statistics are not distinguishable in harvest statistics for game species,with the exception of caribou.1I The Board of Game established a subsistence moose hunt in Game Management Unit 13 in 1983.This Game Management Unit encompasses the Upper Susitna River·.Also,harvest estimates for all game species for a 12-month period in 1982-83 are available for Cantwell (ADF&G,Subsistence Division). In the discussion of socioeconomic impacts (Section 4.1.8)of the proposed project,no E!ffort is made to quantify the number of subsistence users affected or the degree to which subsistence activities will be affected by the project. ADF&G concurs with the DEIS analysis that subsistence users would be the resource user group most severely affected by project development.Local resource uses are integrated into and support cOlTlTlunity life and local economies.The extent to which this can occur and be maintained depends on resource ava'i1abil ity and habitat protection.It must be stressed that the improvement lJf wage opportunities in local communities will not reduce the impact on thle local resource user. ADF&G supports the recorrmended and ongoing studies listed in section 5.4.5. However,reslearch conducted by the Subsistence Division should be used as a basis for designing future studies. The DEIS is incorrect in stating that 1I •••su bsistence activities are protected by law for a particular population of Alaskans •••11 State and federal laws protect subsistence uses,which are not restricted to any specified group of people.It is also incorrect to imply that subsistence activities are important only to II rura 1 Native q)mmunities,1I since communities that are largely non-Native (e.g.Skwentna)may rely greatly on subsistence uses of fish and game. Neither the Copper River Native Association nor Ahtna Inc.are in lithe regional corporation Cook Inlet Native Association,Inc.(p.N-lO)." -10- ..,", ..~......--":~.-,....'...;..'--'-...---- Alternatives ...-.,,.-,""...-,-..~ C·.. .'f ~. !'~~ Infonnationavailable from ADF&G has not been utilized in developing the discussion of the Susitna development alternatives in the Tyonek area.The Subsistence Division has prepared numerous technical reports on resource uses in the Beluga/Tyonek/Chakachatna areas. In discussing the Johnson alternative hydro site (p.3-71),there is no reference to the Subsistence Divisionis major paper on Dot Lake (Technical Paper #19 by Gayle Martin).The community of Dot Lake would be flooded by this project.The Subsistence Division has also supported research in Nenana (Technical Paper #91 by Shinkwin and Case),and this would be useful in the analysis of impacts at the Browne alternative hydro site. The DEIS,when discussing socioeconomic factors affecting the Village of Tyonek from the Natural-Gas-Fired Generation Scenario (4.3.8)states that "A construction camp to house workers near the site would reduce (impacts on subsistence activities)considerably.1I The past experience with workers at the timber mill south of Tyonek is an example of an industrial project bringing a new population to the area.The hunting and fishing activities of this new work force competed with Tyonek residents for fish and game resources,primarily moose.Therefore,regardless of how a new work force is housed,they will have an impact on customary uses of the resource.It should also be emphasized that regardless of the limits on the activities of the workforc:e,the construction of support facilities (airstrips,roads, etc.)improve access to the local area,hence increasing competition for local resouY'ces. -11- ,'",.MEMORANDUM State of Alaska DATE:August 8,19~{f E eEl VE D .... .... DEPARTMENT OF NATURAL RESOURCES,OFFICE OF THE COMMISSIONER TO:Robert L.Grogan,Associate Director Division of Governmental coordin~t~ Office of Management and BUdge~,r FILE NO:620.6 AUG 1 t,1984 . .~/TELEPHONE NO'465-2400 1.1.1'.2:;._.-~:mHOflfTY FROM:Esth:r ~.wunnick'l~SUBJECT:Susitna Hydroelectric Comm~ss1oner ~-t Project The Alaska Department of Natural Resources (DNR)appreciates the opporturnity to comment on the draft Environmental Impact Statement (DEIS)for the Susitna Hydroelectric Project,Federal Energy Regulatory Commission (FERC)Number 7114.My staff has reviewed the DEIS and provides the following comments. We are concerned that the document generally did not provide sufficient information to allow this agency to properly assess the project's potential impacts upon area resources.The following comments include requests for additional inf,ormation needed by ONR for a meaningful project analysis •. € WATEFt MANAGE~NT Flow Regime The discussion on surface water resources is well done.However figures given for mean annual stream flows at the Watanaand Devil Canyon dam sites are misleading due to the flow variations throughout the year.Mean monthly stream flows shown in figure 4-2 are more accurate and should be used thro~ghout the DEIS for consistency.A discussion of instream flow methods used to determine those minimum flow requirement scenarios which could impact fish and wildlife habitats,fish life cycles,water qUality,recreation, navigation,and transportation should be included.Also many sections mention probable effects on the fisheries but fail to mention what the effects are,or how they were assessed.This information is essential to evaluate the effectiveness lJf the mitigation measures.The Alaska Power Authority (APA) asserts that 10,000 cfs winter flow will not overtop the sloughs more frequently with the project than under natural conditions.Additional studies r are needed to show that increasing winter flows to 10,000 cfs from normal :flows of 1,000 to 2,000 cfs will not overtop the sloughs.Also,there are no '.comments on 12:,000 cfs as the required summer flows.To date no negotiations on minimum flows have taken place. In many sectirnls of the DEIS,various flows of the Susitna River are mentioned.However,a better understanding of measured streamflows would be reached if 9au9in9 stations were identified by name and location.It is critical to clE:arly identify where measurements are recorded to provide useful and accurate data for fisheries habitat,economic,and safety planning. An estimated 50%of side slough habitat will face acute access limitation under proposed summer flow release scenarios of 12,000 cfs.There is no mention how spiking with an additional 20,000 cfs to mitigate access limitations at these sloughs will be scheduled.It is unclear what the total spiked flow for three (3)continuous days will be.Plans for observation and prevention of overtopping of upstream slough berms are not discussed.The effects on the fisheries from these proposed spiking flows are unclear. 02·001A (Rev.10/791 ,. "."-...;_t.:....:.·;_·..--:_•....'" Spillway Capacity The Watana daITI is designed to discharge 156,000 cubic feet per second (cfs), the estimated 10,000 year flood.Reference to an emergency spillway and fuse plug indicates allowance for additional capacity to permit discharge of the Probable Maximum Flood (PW).Projected PW flows and the dam's capability of passing 100%Clf the PtvF without overtopping need to be clarified. The DEIS indicates there is a potential for seepage through the Watana relict channel at TSUIsena Creek during the filling operations.The location of seepage is not identified.DEIS staff recommends monitoring during filling; however,further provision may be necessary to control unforseen seepage.It is unclear whe!ther the relict channel will need to be excavated,then grouted.The procedures used to reduce seepage through the relict channel should be clealrly stated. If the Watana dam overtops or fails it is not certain the Devil Canyon dam would be able to withstand a flood surge.Further discussion of Devil Canyon's ability to withstand an overtopping without failing is necessary. The PMF has not been specified for the Devil Canyon area. Although questions about design and spec~fications are not answered in the DEIS,11 AAC 93.150 through .200 requires'that an application to construct or modify a dam must be submitted with detailed designs to this department for approval before construction.These applications have been sUbmitted,but any further processing is held in abeyance pending submittal of detailed dam designs and specifications. Monitoring ProlQram The DEIS does not contain adequate information on the construction process. No mention is made of a plan for continuous inspections and measurements of· the fill placement or grouting during construction.Detailed and consistent inspections must be made to insure the accurate placement of the impervious core.A disclilssion of the type and location of instrumentation is missing. Also,routine visual inspections are essential.It is unclear what measures would be taken in the event of piping,sloughing or misalignment observations. Assuming worst-case scenarios,discoloration of the drainage system discharge would indicate~piping of core materials -not leaching as stated by the DEIS. Piping would indicate severe inadequacies in the inner core which could only escalate.It may not be possible to simply locate and grout the problem area. Dam Safety Dam safety is an important aspect of overall project design.No mention is made of any emergency plan in case of the dam's failure.Under DNR 's Dam Safety Program,administered by our Division of Land and Water Management (DLWM),routine project inspections are mandatory.These inspections are intended to be made jointly with the Federal Energy Regulatory Commission (FERC)inspections.We also require copies of all FERC inspection reports. The final designs of the project plans and specifications will require approval by the department under 11 AAC 93.This will take at least sixty (60)days. Page 2 r pei-. ~._.~.-.: The DEIS should discuss in detail the monitoring schedule and procedures taken during initial filling of the reservoir.In particular,the United States Committee on L.arge Dams (USCOUJ)gUidelines must be closely observed. Permit appliccltions to construct or modify a dam require detailed engineering designs and monitoring scenarios acceptable to the department.This review will also require at least 60 days. Navigation Further discussion is warranted on navigational impacts for each portion of the river.As indicated,recreational navigation is increasing;however a discussion of the historical use of the river is needed to support this statement.Convnercial navigation should be given more consideration.Studies by Harza-Ebasc:o and R&M Consultants should have been used to evaluate the probable impac:ts.Additional studies are required to evaluate the navigational limitations,if any,which may occur at the various flows proposed.11 AAC 93.141(2)and (3)further define navigational flow reqLlirements for recreation and transportation. Climate,Air Gluality,Noise During constrLlction,fugitive dust emissions from road dust and wind blown dust could prclbably be controlled by frequent road watering.A road watering operation would require a Temporary Water Use Permit (TWUP)from DL&WM • ..~. i,.>LAN)MANAG£~NT _Ownership The FERC appli.cation briefly discusses the complex land ownership pattern in the project area.The DEIS assessment does not accurately portray this -compleXity.The land ownership for the entire project should be clearly delineated on large scale maps in the DEIS,inclUding the transmission corridors and alternative project sites.The land ownership maps should show all the competing land selections and their selection date.DNR is currently assisting APA with its land related research.. Decisions on project feasibility should not presume future State ownership of lands currently selected by both the State and Native corporations.The DEIS is written as if the project land were state owned or could be acquired by the State.The State will probably have to wait until the Bureau of Land Management (BL.M)has adjudicated all the competing land selection applications.BLM has suspended adjudication of the State's selections until the Native selections are adjudicated.The potential time delays for resolving these competing selections could have a significant impact in the overall projec:t schedule and cost and should be discussed in detail. Habitat Mitigation The applicant's proposed habitat enhancement plan is designed to improve wildlife carrying capacity outside the project area to compensate for habitat lost resulting from the project.Other state agencies are concerned about the feasibility arid specifics of the habitat enhancement plan.The applicant is pursuing studi.es to address their concerns.The FERC staff assumed in its Page 3 ..:.:..~....:~.:...~ •..'~,.,.-':..<.,.....;:.:,-.-. ....' - - - - analysis that enhancement techniques would not compensate for impacts to wildlife.This judgment was premature.The department would urge FERC to reevaluate its assessment following the studies in progress • The Susitna Arl:a Plan was prepared by this department,DF&G and the Matanuska Susitna Borough in cooperation with DOT/PF,the Kenai Peninsula Borough,USDA and BLM.The ,area plans classify state land for various purposes as required by AS 38.04.06;5.and AS 38.05.300.The lands encompassing much of the Susitna Hydroelectric Project have been categorized as private land to reflect Native selections.The remaining lands have been designated pUblic recreation, wildlife habit,at,forestry with some grazing and remote cabin areas.These designations ~:re a result of agency compromises during plan development. Since the projl:ct lands are classified private in the plan,they should not be considered as an additional loss of designated wildlife habitat as a result of the project. According to the DElS,the Office of Management and Budget favored habitat compensation with replacement land.This department cannot recommend additional habitat replacement lands be established beyond the current level of lands with wildlife habitat classification.The State cannot control the development of federal lands selected by Natives.Habitat which could be lost to private use was considered in the development of the Susitna Area Plan. Additional state land is not availa\;lle to compensate for the Susitna Hydroelectric Project through a replacement land program.To adopt a replacement land program would entail changing land designations from other primary purposl:s to wildlife habitat.Sufficient state land is not available for large scali:reclassifica tion.The applicant's proposal to enhance existing wildlife habitat to mitigate the loss of habitat carrying capacity in the project arl:a is an acceptable solution. Access Historically,this department has agreed with the FERC staff conclusions favoring access from Gold Creek and recommended railroad access from Gold Creek to Devil Canyon with a road from Devil Canyon to Watana.The department has reevaluatelj its position and now favors the applicant's proposed road access south f:r:om the Denali Highway to the Watana dam sitE;!,along with a connecting road to the Devil Canyon dam site and a rail link from Gold Creek to Devil Canyon. Although public access may be restricted during construction,long term use by the public should be considered since state funds will be used to construct the access roalj.There should be some discussion on designing a lower speed road which in the long term may be more consistent with the area's recreational uses. F Transmission Corridor The proposed transmission corridor may affect some existing and proposed State agricultural disposal areas.The DElS discussed placement of the towers along existing rights-of-way and stressed using single pole towers or "H"figure towers instead of the "X"figure towers to lessen this impact.These statements imply the area beneath the power lines can continue to be used as\r agricultural l;and.There should be some discussion of the allowable uses of the land beneath the powerlines and the safety precautions necessary around the bases of the towers. Page 4 ------~-------_.,----------------------- ·-..'. ~_.',......,~:-.,.......'" I""" ~ (1_) .- The DEIS contains a statement which implies that there will be an access road along the entire length of the transmission corridor.This may not be possible in environmentally sensitive areas.It may be necessary in certain areas to restrict the ground access and require helicopter only access.There should be further discussion on this issue. This department is concerned the transmission corridor may act to bisect its lands if there-are restrictions on the type of access that can be granted across or front the corridor.The extent of allowable public use along the transmission corridor is unclear.DNR would like further discussion on the type of access;the State will be allowed to grant across and along the transmission corridor.It is not clear who will manage and maintain completed transmission lines,and what access restrictions will ultimately be made. Borrow Sites Information on material sources and borrow site locations is not readily referenced ,in the DEIS.Material sources,such as local sources of building material,and availability should be more thoroughly discussed.It is unclear how much material is available at the various borrow and quarry site locations.A large amount of material w~ll be essential to construct the project.There should be some discussion'of the full extent the material can .be excavated from a particular borr.ow site before the impact becomes excessive,in order to assess associated environmental effects. Surface and subsurface ownership of these sites is unclear.This information could be critical to future management and planning efforts. Alternative Dam Sites The alternative dam sites suggested by PERC have not been thoroughly analyzed.There are significant impacts associated with the alternative dam sites that reduce their feasibility.The sites cannot truly be considered as alternatives until an accurate assessment of their environmental impacts has been completed. OTHER RESOURCE ISSUES Geology and Soils Geology and so:ils are fundamental issues of the DEIS and the subject of Appendix E,but are covered less adequately than are other parts of the DEIS. Several types of mass movement are mentioned in the OEIS.Clarification with more detail on the potential impact of landslides into the reservoirs,is necessary.The OEIS does not adequately discuss prehistoric landslides located near the proposed Devil Canyon dam site.There is no me~tion made of the potential hazard and environmental effects resulting from giant waves produced when landslides enter the reservoir.No mention is made of the future headwarej (upslope)extension of these slides.Only shallow surface slides are discussed.There should be some discussion of major bedrock slides due to pore pressure buildup along pre-existing planes. The introductol~y statement on seismicity is poorly written."Thrusting"is a form of tifaulting";"shearing"is what happens along faults.All of these Page 5 _ -------_.----- -~."-.-.,.-.-.'.'.'"'. .-;-:...."".~.-.:~.:..:....:~:-- -~ ..... items mayor may not be the result of "plutonism"and are definitely not the resllit of "re~lional metamorphism"as stated but rather the other way around. The third period of deformation,for example the Castle Mountain Fault Zone, assuredly extends through the Quaternary.Northwest drifting continental blocks of the cretaceous is a theory under considerable debate and not accepted widely enough to be quoted without qualification in the DEIS. Rationale for using this theory should be further discussed. A clear statement is needed on subduction zone faults.Although a surface rupture hazard to the sites may not be significant,the ground acceleration hazard from these sources should be discussed in greater detail. The surficial geology within the region needs to be defined.The discussion in the DEIS is inadequate for evaluating the area. Construction activities-will modify the character of sediments overlying permafrost,resulting in thaw of permafrosts with resultant thermokarst and erosion.Disc:ontinuous permafrost has been encountered in scattered locations in the lowlancls and should be considered within the entire project area. Climatic Condi.tions The environmental impacts of the proposed project run about 16 pages and yet climatic effects are treated in only 4 1/2 lines,essentially saying no significant mi.croclimate change will occur.Concerns such as climatic coolings of the environs by reservoir evaporation and the higher ambient atmospheric mCiisture content (resulting in more condensation/precipitation downwind)shoUld at least be mentioned. Timber Resources The DEIS provi.des extensive,generally descriptive information on forest conditions in the project area.The descriptions are ecological in nature rather than ec:onomic.Volumes and values of wood involved are not discussed. The forest res,ources of the area are economic resources only in the personal-use context at the present time.Consequently,our concerns center on making any wood felled or "cleared"on state land available to the public in so far as is practical. Prior to the development of clearing schedules,the Mat-Su Area Forester should be consulted.Houselogs and sawlogs should not be cut up into shorter lengths,specifically,spruce trees over 12 inches in diameter at the stump. All felled wood on state land should be available for pickup by the pUblic without charge unless there is sufficient interest in sale of the wood. Opportunity for sale of wood to fuelwood dealers and houselog and lumber producers should be provided via the Mat-Su Area Forester • Recreation Plan Although access from the Denali Highway may not be the optimum choice,the recreational plan proposed by the applicant is acceptable. ~-Volume 6 of the OEIS addressing Recreation Resources and Visual Resources appears to be a credible document. Page 6 '..'''':''<' ,. ,, ~T ••"•~<,~_. -~.•~..;.:~....,..;'..~---.'.-';_..~_...-.-..'~'".:..,•...:....,:.:._. ..... - ,.... , .- - .- - Phase Five of the applicantts proposed recreation plan (Table L-lO,page L-37) for the Stephan Lake 40 acre site and development should be considered,as a higher priority.This site will be the only public site on Stephan Lake and it will be a major access point to float the Talkeetna River.The features of the applicantts proposed visual resource plan appear to be adequate if followed as specified in the DEIS. Economics A petroleum economist with the Division of Oil and Gas reviewed the DEIS economic analysis and offered the following comments. Section 1.4.5.3 states in part: "A conclusion from these analyses is that,with the high construction costs of the larger hydroelectric projects and current uncertainties regarding Beluga coal development,the most prudent Railbelt generation expansion plan would be a mix of non-Susitna hydroelectric resources with a combination of gas-fired combined cycle generation in the Cook Inlet area and l:oal-fired generation in the Nenana area.The use of smaller, lower cost hydroelectric resources in such a plan would reduce thermal generation requirements and fuel demands through the study period." Furthermore,Section 1.4.5.2 states:"The analyses in Sections 1.4.3 and 1.4.4 indicates that the coal and gas scenarios would meet the Railbelt power requirements at lower cost than the proposed Susitna project.1t The apparent superiority of coal and gas or some combination of the two is maintained 'ov~:!r a range of price assumptions and real interest rates.This "superiority"is the result of 'two factors.First,the FERC load growth forecast is slightly lower than APAts,thus slightly reducing annual benefits regardless of assumed oil,natural gas,and coal prices.Secondly,debt burden at real interest rates as low as 3.5 percent.(The real interest rate is currently about 8 percent.) The major protllem with evaluating a project like Susitna is the long project life.The estimated benefits and costs are evaluated over a fifty year period.Economic forecasting is,at best,a minor art form and is not a scientific endeavor.The methodology of long run forecasting is as much philosophy as substance.Projections cannot be accurate over so long a period,but they can be methodologically conservative and financially prudent.This conservatism would normally manifest itself in the use of high discount rates for project analysis,thereby attaching less importance to forecasted eVE!nts as they occur in more distant time periods.These are the periods for which we know the least. The APAts Financial Update (Feb.1984)admitted that the Project has significant fi.nancial risks.Even with relatively bullish oil price and coal price projecti.ons the Project only has a real rate of return of around 5 percent.Given the magnitude of the potential state investment this rate of return is much too low to consider the Project as a prudent use of state funds. The OEIS may present a more objective analysis of the economic tradeoffs involved in trle Susitna project. Page 7 .. "..., ~... '. _::,_0".,"-.. r' -- II;'~.-;.; - *** The FERC DEIS does not adequately address many issues necessary for processing future project applications submitted to the Alaska Department of Natural Resources.If the questions addressed in this review are adequately answered in the final EIS the department should be able to perform its adjudicative functions without disruptive delays. This department could have performed a much more expeditious review if (1)the DEIS included a topical index allowing cross references between volumes and (2)topics were adequately discussed,thereby saving the time required for researching points of concern.. cc:Jon S.Ferguson,APA APA Project Manager Page 8 - - .,,- ,... ~V&V[®w &~~~~~ DEPARTMENT OF TRANSPORTATION and PUBLIC FACILITIES DEPUTY COMMISSIONER -CENTRAL REGION JUly 23,1984 Bill Sheffield,Governor 41fT AVIATION AVENUE,POUCH 6900 ANCHORAGE 99502 (TELEX 25-185) PHONE:266-1441 RECEIVED RE: JUL 261984 ~.Lr.sK.·,rOWER AUTHORITY Susltna Hydroelectric Project Federal Energy Regulatory Commission May"1984 Draft Environmental Impact Statement - Mr.Jon S.Ferguson Project Manager Alaska Power Authority 334 West,Flfth Avenue Anchorage,AI askzl 99501 Dear Mr'.Fergusorl: • The Alaska Power Authority has sent us several documents concernIng the Draft Environmental Impact Statement for the proposed Susltna Hydroelectric Project and alternatlve!s,and requested our prelimInary assessment of potentIal .Impacts.We have!used the Draft Environmental Statement and your letter of JUly 3,1984,wIth attached maps"on whIch to base our comments.AccordIng to your latest notIce"the comment perIod h~s been extended from July 9,1984 to August 15,1984. The fol lowtng cc)mments refer to hydroelectrIc alternatIves to the Susltna Project and flnally to the Susltna Project Impacts.As thIs Is a prelImInary assessment only,we request contInued coordInation as more InformatIon becomes ava I I ab Ie.We note that the Johnson,Browne and Keetna projects wou Id be connected either dlrectly or by al Ink to the Anchorage-te-Falrbanks Intertle. -The Snow and Chakachamna projects would requIre transmIssion lInes of significant length. Browne Dam and Reseryolr;Nenana River,100 Megawatts Speclflc comment·s on the Johnson,Browne,Keetna,Chakachamna,Snow and Susttna projects l~re listed below: -o Ttl I s pro j e<:t req u I res the re Iocat Ion of over eIeven mIIes of the AIaska RaIlroad and approximately seven miles of the George Parks HIghway.The relocatIon of the raIlroad wll I requIre traversIng over hll Is and possIbly cut-and-flll procedures to allow suItable gradIng.The re located road wI I I be moved f rom the va IIey center to the per Imeter , and may also requIre cut-and-fili.Protection of the roadway from dam failure and sIgnIfIcant emergency spIt lage would have to be addressed. -----,----........-~=..==============~~==~ f Letter Jon S.Ferguson -2-July 23-,1984 ...,....... - Johnson Dam and Beseryolr;T~nana RIver,210 Megawatts o 'TheproJe<:t entails relocating over twenty-five miles of the'Alask~ IHghway,a HIghway maIntenance statIon and the rebu II ding of a br I dge (for the B I ghway)be I ow the dIscharge sIte.Dam safety and splll"age Impacts mentIoned above would also have to be addressed.The brIdge and the exten~ilve construction requIred to relocate the road would be very costly,eSI)eclally as the area Is geotechnlcally unstable.Several Department of Transportation gravel pits also exist In the vicinIty.In addItIon,the site InfrInges upon a corridor desIgnated for a proposed Fa I rbanks··to-Canada/Lower 48 ra II road and poss'bI Y the TransA laska Natural G~m PIpelIne. Keetno Dam ond R1MeryoIr:"Talkeetna River,100 Megowatts o The project does not appear to Impact Department of Transportation fac IIltles.. Snow oam:Snow FHver,100 Megawatts o The projec:t Is located near the Seward HIghway and the Alaska RaIlroad. It does not,however,appear to Impact eIther facilIty sIgnificantly. Chok8chmno oam and Reseryo'r;Chakachanna RIver,330 Megawatts o The projec:t does not appear to Impact any Department of TransportatIon facilities. Susltoo project Dams and Reseryolrs;Susltna River (DevIl Canyon Dam and Watana Dam),Various scenarios for generatIon output o This project does not appear to Impact any Department of TransportatIon f ac II I ties. The potential projects mentioned above could Impact Deportment of TransportatIon facIlities both directly and Indirectly.Because of the constructIon and access needs,railroad spurs and access roads might be constructed (e.g.to the Susltna Hydroele<:frlc Project site).The IndIrect I mpacts of extrll-tr.'af f Ic feed I ng off and on to Department of Transportation facll 11'Ies could be sIgnIficant.(You may want to request specifIc comments from the Northern RegIon office concerning the Johnson Project as It Is lo<:ated withIn theIr region.) '''':'-':,.";"''i!,~i': :-:"~. ./ Letter Jon S.Ferguson -3-July 23,1984 ~We appreciate the opportunIty to comment upon these plans and look forward to further coordInation with you.If you have other questions or comments, please contect me. Sincerely,C~Haugen Deputy Commissioner Central Region ....cc:Jay Bergstrand--Systems and Program Planner,Central Region John Burkholder,P.E.--Reoonnalssance and Location EngIneer,Central Region R.J.Knapp--Commlssloner,Department of rransportatlon and Public FacilIties Keith Morberg,P.E.--oeslgn Chief,Central Region John B.Olson,P.E.--Actlng DIrector,Design and Construction,Central RegIon Merlyn L.Palne--Reglonal Environmental Coordinator,Central RegIon James J.Rhode,P.E.--Chlef of TechnIcal ServIces,Central Region - , ~Il'~~"'__lo '\ ;,..-\ ,,- ......-_.,-...! '".,~/..~}'~·l'. ../~..;:-+>,~r';:: .~~..::-~~-:..,.... '.':~'.-.~.:,:".'; '.,. .;--."'.~".~ ~..~-.,-:;,-...'......., ,',:\:f~i.{·:2;"?~~ir";<, f"" Tony Knowles. Mayor Municipal Light 8l.Po'Wer 1200 EAST FIRST AVENUE -ANCHORAGE,ALASKA 99501-1685· TELEPHONE (907)279-7671 RECEIVED ~- August 9,1984 Susitna Hydroelectric Project No.7114-----7 Mr.Kenneth Plumb,Secretary Federal Energy Regulatory Commission Office of Electric Power Regulation 825 North capitol St.N.E. Washington,D.C.20426 Dear Mr.Plumb: SEP281984 ALASKA POWER AUTHORITY -- The attached document is in response to the Federal Energy Regulatory Commission (FERC)Staff Draft Environmental Impact Statement on the Susitna Project (ElS)-Project Number 7114. The document provides comments on various portions of the draft report.Particular emphasis is given to the alternative sce- narios developed within the Draft EIS. The comments provided are intended to give some insight into those areas which we believe are deficient in the draft EIS.In this respect,it is hoped you will evaluate each for merit,and where appropriate,incorporate your findings into the Final ElS, published on this project. Thank you very much for the opportunity to respond.Meanwhile, should you have any questions regarding our comments,or our data which supports these comments,please contact me at your convenience. Sincerely, 'q~Municipal Light &Power GT/1b Attachment PROVIDE FOR TOMORROW,SAVE ENERGY TODA Y. .... -Tony Knowles. Mayor Municipal Light 81..Po'Wer 1200 EAST FIRST AVENUE -ANCHORAGE.ALASKA 99501-1685 TELEPHONE (907)279-7671 UNITED STATES OF AMERICA BEFORE.THE FEDERAL ENERGY REGULATORY COMMISSION In the Matter of Alaska Power Authori~y Application of a License for the Susitna Hydorelectric Project )'")project No."7114 ) ) ) rI . MUNICIPAL LIGHT &POWER COMMENTS TO PERC DRAFT EIS Given a satisfactory agreement on the purchase of bulk power the The Municipality of Anchorage will be a major user of power generated by the Susitna Hydroelectric Project (FERC No.7114)should the project be approved and constructed.As such,Anchorage Municipal Light and Power (AML&P)is extremely interested in the development of this pro~ ject,or any suitable alternative which may provide a long-term stable,and cost effective,energy base.In this respect,if alter~ natives to the Susitna project exist which do not pose adverse effects in terms of air quality,does not cause unacceptable visual impairment or excessive damage to the state's largest renewable resource industry (the commercial and sport fisheries)and are of lower life cycle cost, then they must be considered and developed. AML&P believes,however,that any alternative considered must be real, available,and be subject to the same rigorous scrutiny and study as the proposed project.In this regard,this response will center on' the alternatives and the areas of these alternatives viewed as weak and requires more comprehensive evaluation and/or study to determine feasibility. GAS"FIRED GENERATION SCENARIO: FERC Staff states in the Draft EIS that gas price projections and the i development of this alternative is based on the assumption that suf- ficient volumes of gas will be discovered in the Cook Inlet region of the state,and that local utilities will be able to obtain contracts for this gas.ML&P staff believes that the basic assumption which drives this scenario is invalid,or at least suspect.Best estimates - provided by the Alaska Power Authority and the Alaska Department of Natural Resources strongly indicates that with no change in the PROVIDE FOR TOMORROW,SAVE ENERGY TODAY. .- .... i' ..- general gas consumption pa.ttern of the railbelt region,the following reserves are most probable: •proven Cook Inlet reserves (3.7 TCFl will be exhausted by 1998 • •unproven Cook Inlet reserves (2.04 TCFl will be exhausted by 2007. ML&P staff believes that because long-term gas reserves are questionable,the doctrine of highest and best use should govern the use of this resource. The best use doctrine is clearly the Goal in the "Power Plant and Industrial Fuel Use Act",a component of the "National Energy Act"of 1978.The purpose of this act,and the subsequent regulation by the Department of Energy's Economic Regulatory Administration is threefold.These objectives are: reduce oil consumption to a minimum severely restrict industrial and utility use of natural gas encourage the use of alternative fuels (Hydro prime con- sideration). Based on FERC staff's assumption,it appears that the developed natural gas scenario is contradictory to prudent use of a limited natural resource,and to the principles of the Fuel Use Act.This situation creates a dilemma in which one agency of the Department of .Energy advertises that natural gas is a viable alternative to the Susitna Hydroelectric Project while another arm is directed by law to severely restrict the use of natural gas for generating electric power.ML&P staff believes that PERC staff must address this conflict. It appears reasonable that if the gas supply question and fuel use restrictions cannot be answered satisfactorily,then the viability of this alternative becomes questionable. COAL FIRED GENERATION SCENARIO: To develop this scenario FERC staff analyzes a number of different scenarios using five 200 MWe coal plants at two locations near existing coal sources.These analyses showed that an acceptable sce- nario locates ·2-200 MWe coal plants at Nenana,Alaska and 3-200 MWe coal plants at the Willow,Alaska site.ML&P staff notes that the FERC contractor used simple EPA approved screening models to make this determination. ML&P staff believes that through local and .regional Alaskan experience,sufficient data exists which indicates that these models -- are not adequate to produce true air qua,lity impact estimates of the various coal plant scenarios.ML&P staff further believes that if - 2 - ..- more sophisticated modeling,which uses actual m~x~ng height &cloud cover for each plant placement,is undertaken,the results would be .vastly different.In this respect,if meterological extremes which are commonly experienced at Nenana and Willow during the winter are taken into more realistic consideration (including site specific information)the probability is high that one coal plant,much less two coal plants,could not pass the PSD or the state standards acid test at Nenana without the employment of some very complex air quality control technology.This suspicion is evidenced by Golden Valley Electric Association1s recent PSD experience in contemplating the construction of a smaller coal fired generation facility at Healy, Alaska.The plans were tabled after an economic analysis of the cos~ of required air pollution control equipment was assessed and found to - be prohibitive...... These factors raise the question of validity of an economic analysis which does not take into consideration the potential costs__for more _complex air pollution control equipment.In turn,these costs cannot be established unless more sophisticated modeling is accomplished to determine just what level of control is necessary to meet all appli- cable standards,including PSD increments. ML&P staff concludes that the questionable results from the simple air quality screening models,which are not site specific,does not accurately reflect the air quality impact potential of this al ter- native.ML&P staff further believes that to draw more proper conclu- sions,further analysis is required which uses models which accurately reflect expectant~onditions.Only then can this alternative be pro- perly put forward.These factors must be sharply focused because,if this alternative is found to ultimately not permittable,or if the cost of complex pollution controls are C'OSt prohibitive,then the alternative cannot be considered viable. COMBINED HYDRO-THERMAL SCENARIO: - FERC Staff considers a number of scenarios which involve the combined use of'Thermal and non-Susitna hydropower facilities,and evaluates each as an alternative to the primary project.ML&P staff comments in this section will be confined to the selected hydro alternatives as generation development using the gas and coal alternative are addressed above. ML&P staff agrees that if Hydro alternatives exist which are poten- tially more economical and environmentally attractive,they must be considered.To reiterate,however,ML&P staff believes that such alternatives must be subject to the same rigorous scrutiny as the pro- posed project.Such appears not to be the case as evidenced in FERC staff1s recommendation as t~most effective approach to meeting future power demand within the railbelt region. FERC staff recommends a mixed thermal-based generation scenario, supplemented with selected non-Susitna basin hydropower facilities which would be developed after independent evaluation and deter- mination of merit from an economic and environmental viewpoint.To evaluate the term Ilreal potential'·of these various combinations,ML&P - 3 - -- ..... r - ~- staff has analyzed these scenarios in great detail.ML&P staff's pri- mary conclusion is that the stated potential for the development of an acceptable mixed generation scenario is based on an unsound foun- dation.On the validity of the thermal portion of mixed generation scenario,the major questions of gas supply,Fuel Use Act and coal burning air quality degradation potential must be comprehensively studied to determine impacts.Independent of cost and other economic benefits,if these facilities cannot be permitted,the approach fails. On the hydro side of this scenario,ML&P staff believes that the -reality potential W of the various sites evaluated by FERC staff also presents niajor problems.In this"arena,ML&P staff questions the prudence of recommending a mixed thermal--hydro scenario which could have accumulative economic and environmental impacts far in excess of the proposed project.This conclusion is drawn based on factors,such as cost of each project (1982 dollars),total potential flood plain area inundation,and the potential for adverse impact on natural resources. Individually,all hydropower projects identified in the FERC DEIS as non-Susi tna hydro alternatives hold potential for major problems in terms of environmental and economic impacts.A number of these poten- tial impacts are high risk and could be devastating in terms of resource loss,or increasing the seriousness of an existing hazard. As such,ML&P staff provides the following comments toward areas which would require extensive study before a selected project could be con- sidered a candidate for the combined hydro alternative to the proposed Susitna Project."These impacts should also be measured in terms of a revised economic analysis to determine feasibility and ultimate repla- cement potential to the primary project. CHAKACHAMNA PROJECT: Comprehensive study has already been completed on the Chakachamna hydro alternative.Just recently this project was the subject of an extensive study by the State of Alaska through its contractor,Bechtel Corporation.The study identified seven exceptional risks associated with this project.They are:. 1.A natural barrier glacier forms an ice dam which con- tains the lake. 2.An active seismic fault is located approximately one mile from the proposed powerhouse location. 3.A recently active volcano vent is located four miles from the natural ice dam. 4.Much of the proposed tunnel site is covered with high glacier and icefields which creates a real probability that adequate rock may not exist along all portions of the proposed tunnel alignment. 5.Extensive geological investigation is necessary to determine if machine boring of the proposed tunnel is feasible. - 4 -".- ..- 6.Significant Salmon runs (over 100,000)exist in both the Chakachamna and McArther Rivers. 7.The probability is high that the proposed fish passa- geways may not function properly with a proposed 19% flow release. These exceptional risks seriously jeopardize this project in terms of risk'aod the ultimate"viability as a real alternative.In ML&P staff's assessment,these conclusions render the project an unlikely 'candidate for any type of revenue bond :funding,which certainly can- cels any hope of ever constructing the fa.cili ty. JOHNSON PROJECT: 1 This project,although not studied as comprehensively as the Chakachamna Project,also has been found to carry several e~qeptional risks •.These risks are: 1.The reservoir will inundate an area at least twice the size of the Susitna Project and only develop approxima- tely 1/5 the installed generation capacity. 2.Reservoir will inundate: (a)the village of Dot Lake,as well as other small settlements. (b)approximately 25 miles of the Alaska Highway,the primary transportation corridor within interior Alaska.Corridor will be difficult to reroute. (c)approximately 25 miles of gasline corridor. 3.Geotechnical problems are suspected at the dam site which could significantly increase the cost of the pro- ject. 4.Significant King and Chum Salmon migrate through the dam site location. Additionally,there is a significant amount of river traffic (subsistence and recreation uses)which will be impeded by this pro- ject. Finally,ML&P staff is in severe disagreement on FERC staff's cost estimate of the project.FERC staff estimates the cost of this pro- ject (in 1982 dollars)at $310,000,000.Based on earlier data (1967) provided in a study by the Federal Power Commission (1969),ML&P staff has estimated that a realistic cost of this project should be approxi- mately 2 billion dollars. Part of the estimate incongruence may be explained by the FERC staff statement that the dam would have a maximum height of approximately 140 feet (43 m)and a reservoir maximum water surface of 1,470 feet - 5 - -----,---_._---------@----,....,..-..--,------------------ ,. msl.Both topographical charts and the previously cited study indi- cate tail water elevation at 1,290 feet msl making th~difference in water level on the two sides of the dam approximately 180 feet. Obviously,a real dam must have freeboard and extend below the downstream water by a depth of the water plus the depth to suitable foundation base.The Federal Power Commission cost estimate was.based on a dam height of 210 feet.Considering a crest length at least .6,400 feet,not counting diking of approximately one half mile in length required elsewhere,it appears that the cost estimate used for the 1969 study is more reasonable.This value projected in terms of 1982 dollars indicates the cost to be on the order of $1.95 billion. BROWN PROJECT: The Brown Project is another projeci;.which is associated with several exceptional risks.These risks are: - 1.The inundation of approximately one third the--surface area of the Susitna Project with only one.tenth the installed generation capacity. 2.The flood plain will inundate: (a)Approximately 6 miles of the George Parks Highway which is the primary route from Anchorage to the interior portion of the state.Siting a new route will be difficult. (b)Approximately 10 miles of Alaska Railroad right-of- way.New route will also be difficult to site. ....(c)Approximately 6 miles transmisson line. of primary electrical (d)Some coal and gold resources. 3.Possible large Salmon impacts as several species of Salmon have been documented both above and below the dam site. Additionally,this project will also impede navigation of the river to· large numbers of subsistence and recreational uses.Further,there will be probable impacts on the state land disposal program in the area as the program offers a number of tracts in the area to the public for settlement. Finally,this project will require a dam over a mile in length and must be higher than indicated by FERC staff if it is to hold water. -Early estimates of the Bureau of Reclamation set the cost of this pro- ject at $436,000,000.Using the same escalation rate as employed in the Johnson Project,the cost indicated would be closer to $2.6 billion rather than the $681 million estimated by FERC staff. - 6 - - ..... .... SNOW PROJECT: This project has one exceptional risk that makes the project poten- tially hazardous if considered for construction.The potential is very high that a glacial lake,which is located in the drainage above the proposed reservoir,dumps per iodically on a two to three year cycle.The unnamed lake,with its well known dumping characteristic, is well documented and creates an extreme flood hazard on the Snow River lowlands,and moderate flood hazards on the Kenai River. Placing a dam at this location would certainly create a high probabi- lity that the lake generated would periodicallY overtop the dam in an uncontrolled condition.In turn,such an event creates the potential for disaster in terms of dam washout,severe flooding of -downstream·- facilities and unexpected life threating situations. Additionally,the Kanai River syst~and its tributaries (the Snow River)is a favored recreational area of a large majority of the population of Anchorage.The political climate and acceptance of constructing such a dam in this area leaves questions concerning local attitudes,how these attitudes would effect the eventual realization of the project • The fisheries question concerning this project certainly must be con- sidered in more detail,especially the Sockeye Salmon which have been documented in -lower Paradise Lake,a lake which will be inundated by the reservoir. KEETNA PROJECT: The Keetna Project selection presents special problems because the river reach both above and below the dam site is clearly more impor- tant in terms of fish,recreation and subsistence use than the effected portions of the Susitna River.The famous Talkeetna River is a major source of recreation which would be severely impacted by dam construction.ML&P staff estimates that its construction will destroy,or adversely effect,significantly more species and numbers of fish than the total Susitna Project.Of prime importance will be the King and Chum species of Salmon.Any high dam in this location would create significant problems in passage for these fish and seriously decrease the recreation and subsistence value of the area. Politically,local attitudes are estimated to be at a very high degree of unacceptability as the recreational,subsistence and rural lifestyle is substantial.This uncertainty must be fully explored because it, along with the fisheries question,could render the project unaccep- table in terms of total impact. SUMMARY: In summary,ML&P staff analyses indicate that the FERC staff recom- mended approach to Southcentral Alaska power needs precipitates more uncertainty in terms of accumulated impacts than the proposed Susitna Project.On an individual basis,impacts of certain selected hydro -- components are judged to have high potential to exceed those total projected impacts,and have higher overall costs (projected at greater - 7 - .- than 7.2 billion in 1982 dollars)than those of the Susitna Project. This conclusion is of deep concern to ML&P staff,as the alternative approach and various derivatives suggested are not based on one substantial fact,but speculative issues which mayor may not prove to be valid.In light of this uncertainty,ML&P staff also concludes that the alternatives proposed byFERC,as the most cost effective and environmentally acceptable approach to future railbel t power needs, are proposals without foundation and cannot be relied upon as viable alternatives to Susitna.ML&P staff further concludes that because FERC staff has not made a convincing argument that the mixed thermal- hydro approach is more economical·and environmentally .sound,FERC should either engage in more extensive study to;(1)provide the fact~_ required which removes the uncertainty of their position,(2)develop - other alternatives which prove to be economical and environmentally sound,(3)or allow the Susitna project to go gorward and be licensed for construction.. Respectfully submitted, ~LL-ry C.Tucker Attorney for Anchorage Municipal Light &Power 1200 East First Avenue Anchorage,Alaska 99501 (907)264-4545 GCT/lb - 8 - ) ;\:/a .... " l.~.."..(~ ...' l:::!'u~I""'a F:lo #v w til I '-' - .'.n.~~?111".' / RECEIVED Pillsbury,Madison &SlJttV • r-r'.8135r SCi$.,.-,~. ",... ..-, ,~ Whl1...an in 1:&.1.0 ~reellent wt.th P;:;,RC Statr oonolu.1o"'l in ':t·ho tcIo-that eta tha.t the f)ropoa.d .A.l'A p1'fJjeet 11 tal"~M OOQtly 1ft both tltm.notal an:!em1ro!'l:lenta.l tOr""..lC tho.n a a1.'t or locs Dal!l1 va • deeentra11:od alt.r~t1TQ~-neTerthelesnthere are ea~orrl~w!1n the cu.r~nt ons th.::lt uo bel teve 1)reelu~e c.eart1 ngrul an!l.l:rs 1.Und.er ltE:PJ.. Th-ese tla.vo o.o.n 11"J)4rt be lucr1bed to th~appl1.eantiJ 1nsis";enoe on r4=~-t~e~lng or th1a 11oens1ngproces~wh11e eon!1stently r~rug1~ to ~roTlde the cort or re:eareh and analys1s neceasorr for a full con;lde~tlon or the proJeot •1ts i~aetot and alt~rn&t1ves. AoDoog the data gap.)and aralys1 s we belleve r.eCe!~ar7)are I 1)l!ek of l~rtant fisheries data-A~the National Marine F1!he~1eeS~OO bQE not04.core det~lled and 8ucatant1Ye inrormat1o~1s r.ee~ed 1n thllJ &reA 'oet"ore an lnto1"l!ed decision can Ol!IlIl1de.iieeearch on the r1Ter &ftd t1aherT dovnatrea~~~IalkeetnA &nd ~lbutAr1 strea:s 'both Abo?and beloy hl::eetn=.1s lc.eking. - 2).AJ..t~rat velll ar~or _~r.r 1;~7 And.tl. ~~t.~tAl rla~c 1n th1a ~oounent.Wh11e it 18 true thac 801ar-generata eleetrlo1tT 10 ~.t &bund~nt in the sUmmer.the use of batterle3, &vArlety or other generat1ng sourees,and other tores of .to~e makQ~.olar 00115 an lmpertant eleaent in ra1lbelt eleett1f1catlon. In the pa_t 1t!1JlJ.r a7 hOlle ha.s ~eeelved all It.l1ghting and radi.o power rroa &aol&r p4nel.Only 1n the ~1ddle or wlnter was it neeessa~~ to ~p18uent the solar enera1 w1th 12-gallons of gaso11ne in a &A::IIll gSMrator.Others itt thls area are able to 1"orego QTl,1 therz:al bao~~ualng larger solar arrays and batter1 bar~8.Solar electr1c1ty 10 ~ooa1~the rule rather than the e%oept1on 1nmany areas o!bush Ala:::lnol~1ng the ra11belt.Thls trend must be reeogn1.zed.and DQ4e a part or any ne~tor power and alternatives considerat1on. Pl.a••aee attaehsent for further deta11e~on low-h~d hydro alt~rnattves-. ~_...:-.~__........_....,;.......s-.-.-;._--:-.....____ J:.: ..... .-:.,3s:st9~eO.m.P\\k t.;s,f\ct!at"t99 p!!rro"'x aralvse?\-~.::!S CO!\~1.~~"t;1c!"Qr 8'Oe1.o~on«l10 lJ.Jpoct:J are rl:lte~t.o tnos'!eO~lIun1t1e.and Clrea.s wh\~~v111 r.e~t.~the eoet d1r~et 1~~et=,r!~~s~~t~ f""'"OoeU2't'lt It 'I.n:!.er ).6 Soc.\o~e'O~ll!le -3~"!'I1"~-r1 I~~'Je.:!tt,...)s t'h'O ·~ettT cf Alaska State to s~port t~e ~roJeet ~n~tQ eo~t\~~1t! wuppert ["or COQ -untt7 si!t'!""'V1."'es •••8nti ita ?"IUb~T"~\11 ~l"'Or.r:a"at .on wtlleh a larve port1on or its e1tizel"ls r-el,y for ~~;lloyfl"l~?'tt•.• On~ortunat~lx_the_O!tS has not a~11=~~thta key ~~~u,.~it: ~D1.r1oat~on=.In th ..lt~ht o~recent htotory .~~r~~!~1~~'publ\~~!"OJeet!l,.~oQ .a nuolear pla!'!t!jhA"'~l)rof!\1e~('se"'''!!'e eeO!lo~t~~l".,""Ii ".!I ....we bre~lf),'.the OEIS faust &dd'r~s~bot1'l tnt!dtr~et err.e~~or th11 project aMd the lndt~et 1~~teta t~ell resl~e~t!o~Ala!~• .... 5)!1Ltlm\\\on tcad:gu.""te -Thro~hout the O::IS WlI!erll!tl"')11 1"klit ."~A propoaQ4 to a1t~at.flsherles.sOQ1oeeo~o~te.and var10ul other ~iQP&ota w1.th seneral,ret unrormulat~4 pla~••Cl~e~APAt s h\.to~1 I of fal1llZ"'O to follow 1)rev1oIJ11,.-prc:o:lsed gu1rt'!11ne!!in e07"!st'Jotto!"'J ot cho Anoho~e-~1r01nk.Intertle,we strenou~11 obteet to proee.~1r~ any 110ense fo'r tl'lts Al'r't ...ant 1'''''!I'~leated o!"'!vaque.~e'Meral l'ro~1~•• for reduelng or mltteat1~1~pacts. On~.thea.defect.are cured 1~r.~w D~IS O~!upple~e~t.we hope to DAke aore detal1ed COQ~e~ts on \doeu~ent wh1eh w111 bett~r allo~~O~ An informed chelae 07 the pUbl1e a~~~eo1!1o~~akers. ,~ - Paul Bratton .. ..... - - r- i !.1141~-I••&.g••_---------_ -~dr l{llt<ll ..\l<lSki\ ( :()Ill111l111 i·t \.•0\(.t i (')11 I}r()g r(1111.111 (.. i~ ,~ ,.. :August 22,1984 ltECEr"rED SE.fol ~1S~4 . PUl1buryt M:Jd~"..~q~; .....t:".•.--.-.... -17114 Susitna Hydroelec'tric Projec't: aDra t Environmental Impact St.a'tement ~enneth Plumb.Secre'tary Federal Energy Requlatory Commdssion 825 N.(:Spitol,N.E. washington,D.C.20426- Dear Hr.Plumb: ~comments filed on the DEIS in this proceeding by the Rara~Alaska Community Action Program and t:he Alaska Regional Energy .Association contained errors izl 1:he ~le.which may lead to confusion and omittea references to sources.. C\o'lv-~J~h'~J~~eltzinP Chair Alaska Beqional Energy Association - Please accept the enclosed correC'ted copies as the tables to accompany oar coldlDents. 'f'bank you. SiDcerely, t.""/7!;,1.t-l'J'"tW ~ Jlaethev Zencey EDergy Dire~r ltDral Alaska CoauWli1:y Ac1:ioD PZOg'ram 0-1-; .. PillsbuTY,Madi~an &Sutro SEP 12 "1984 RECEIVED . ':'- ~€NTS Ot' """"J \,:"..~(JItAL tl.USkA ~UNlTY ACTIO";P~OG~:\)Il (~lJri\t.CAPI ".'~,1 ."~ANO . I ."._"'1 ~oU ~E'GIOHAL tt'i£'RCY ASSOCt"ttON (Altt").·""r "i\~1.~....:'..,,::.-,',:"'t ~ ..'"\~.:"\'~'.'"".•,FiRe ~;.7lJ4 &wa1tna H)'dt'cel:ctr1e 'r-ejeett ~,laa~a L>c'a ft Snvit'Ol'lMl'ltal ·l!1\p!etSt!t~_~t. ~\I'iiu.t L9!4 .!.:..tNT~OCJC'rIOH t Ttl.Rural Alaska c:ol'lul\u:\ity Act ion Pro;;zra!"l (~iJrr\L CAP)"e~d th.~Al ••kA R.~ional t~er~y Alloelatlo~(A~!A)a~. org&ni:ot1wna eoncerned with the affo'l:'dabl11ty and rell«b1.11ty ot.er"er9Y supplies 1n.,.r-ural Alaslita.RurAL CAP oper.tto••tate·a:'ld federally-fu:"lded e~ergy pr09t'ams "i:"l the are.c of w.atherizatio~f co~sumer education,co~u~ity tre1n1~and teeh:'l1cal assista:'lee,and advocacy.AREA is an un1ncorporated asso~latio~of 13 ~o~-~rofit Native a ••ociatio~.and the North Slope Borou;h.AR!A is cupported by the member orQan1%at1o~s !~d by kurAL CA~. RurAL CAP and AREA have h~d lori~stend1n;co~cern about ~h. 1~act of the SUlitna project O~the ability of the State to r ••po~d to more uroe~t enerQY needs in rural area8 of the Stat•• - Tn.Sua1tna project will have e w1de-ra~;in.g 1~paet o~the entire J=ita~.of AlasKa,1:'1cl\J~i:'l9 ri.Jral Alsska.The impact will 1ncludo diroct effects of projf:ct-induc&d popul.tio:l inc~~.o.a~d 1nd1~eet efteets O~tMe rest of tne Sta~e, ~h1ch d~penda heavily O~state spendin~for eco~omi~ growth,(~e.u.e tt,e State will f i~anee a sub.ta~t i.!'\1 portion of the project's e~ormous cost).In spite of ite finding that the alter~atives are superior to the proposed prcject"the D£I5'1I analysis of both the direct and indirect .ocioeeo~omic impacts of the project is i~oqu.t..The eelS's ecnclus1o~s reQardi~g the eeo"o~ie and environJle:\tal superiority of the project alternatives need ~o be.treno~hened to reflect the l~s!er socioeeo~omie 1ap~et of the alte~natives. Th.D£IS offee's the follovtnQ find1MQs of socioeeo:'lo:nic impact.: ·~ub.tantial population growth from project-i~duced 1n-.i~r.tion 1n·prese:ltly small eommu:'lities would ~c~r to some deQree u~~er all see~arios.This gro~th would cayse 9ho~ta;&s i:'l all commu~ity =ervicea,chan~ea in lifestyles,4Md dis~uptio~of .~bsi~te~ce activities.Tne combined hydro- tner=al scenario wi~h CMakaeha"~a a~d all the -1- """i ..- I - - . S~.itn.8aSln d~velop~~t~r\nel~dl~9 th~prO~2@d proje<t)~ld have th~Qreat~~t =octoeec~l~ ltIpwActa.The coaL-flt'e~\ie:'\'!r~tto:'\"Ie'O:'\arl~~ld h.~cor@ subatantlal impact=thQ~tn.~etv~.l QA~·f1rod =~~~ar10.byt 1e:o than th~oth~~-. alter:\atlve:..•(p.H-"].) The OtIS .1ao eaneludedt : •....froa ~n envlron~ental sta~dPQint o~ly,the t,herlWl &lterl"l4t1vl!S (natural g!la and co.l-f1!"~d ;_ner&tlnQ facLl1ties)vould have th~l.au~••vo~. cO:'l.e·~\,le:'\ce:.Add1tio:'lallyp baa.-d on ccnaiaerationa of el"lQi~e.ri~Q '~aa1b11tty, econoaic characte~i8t1cs,a~d .~v1ro"~"tal ir;ap.Acta.the Staff concluded that a ~1xe~ the~l-bA~en g~~erat1on scenario,vith selected non-5'~A1tna hydropower projects added as :'lee~ed, appe'ln to be the most etfective ap.~roac:h to IM-et1,n~the projected ge:'ler~tio:t requ1re!!'!e:tts of the Ra,1lbelt area.-'(p.xxvi.) Th •••findinQ8 need to be stre~9the~ed for two rea!o~!. Fir_e,the a~alysia of the direct soc1oeco:tomlc l~p~~t. f.ai.l.to properly aC::C::O\J:'tt for "roject-i!"lduc~~~opulatio:'\ aigl'.tio:,to the State.The socioeconom1c:1~p!c:~of the :,"to:,,-Sua1tn&basin alternatives woulr::be moore dispersed,but it ~~ld allo be Itretched out over a lo~qer period.The phy.ic~l extent of the direct 1mp~cts of the Me~-S~sitna ba~in .It.rM~t1ves would be wider,byt the 1m~!et i:t a:ty one ,plAce and the C:1,JI1~lative impact 0:'1 the st.!tels eeo:"lof'!\i' a.a Whole would be lesa severe. Second,non-Sulitna basin alter:tatLves wOwlc re~~4re iess_ (if any)state fln3:tc1al support.This ~eans that che altern4tlvea would have less impact o:t the rest of the ,StAto by drawing away less state speMding from their local econoci••than laroe-scale Susit~~oasi:t hydroelect~i~ develop~nt would. !!.:.'efIS SOC;:.;:t_o_£_C_O;;,;,NO~M;.;:I:.;;.C ANAt.'i::i IS. To auaD4rlze briefly,the OEIS conC3ucts the sccioeeo:'\omic analyai.aa follows: Th.analyais defines the impact area of ~ne p~oject cased on phyaical proximi~?to the aite.The key to defining the 1:paet area is vnere workers O~the proj~ct vill live. Since 1t ia assumed they wLll live within reaso:'\able co=Q~tinQ distan~e by autQ~obile (if not ~ctually in a co:'\mtruetio~camp),the impact area is limited'to tne a~ea pny~ieally close to the site.Thus ~he ~ajor impact area -2-. -.,,. - - - ..'. t.the northcentr~l .~d ~orth~~·M.t-Su 8QrouQ~a~~th~ ~.~t~ll area of -The Yu~o~-~oy~ku~~~~h·(~1c"1~~~ •bo~gh at .ll .nd whlch th~~IS chould rtfa~te 4~~~Q ·Y~~~-~o~~k~~c.~~~.Oistr1ct 1~th~U~o~A"1~O~. 90t"'C)t"I~•)~ tn ...~d ~jor at~p in th~.O~1ceeo~omic a~alY811 il to ••l.ct baa.lin.pop~1.t1o~p~J~etle~.for t~iMpaet .rot. 1~••n.lyDlc foc~.o:MA1~ly on t~e Mat-Su eo~u~~ana ~latton proj.etlon~R'Ioade by !Seve ra 1 part hJ1:fOE"thl1t: Are..Th.ct.ff hat ••1ecteO the lo~~t of the projoetlc~G (done by ~SEk)••th.lower bou~d estt~~te.The ~naly~tc choae thia ••t1 ••te because po~ulatio~Orovth wtatowld. ahoYld t.~r cff 68 tn~l~flat1o~-Qdju.t.d value cf .tete apending doc11n••with fallL~Q oil pric••a~d felliMg .~at. r.Y.nu.~f~M Prudhoe Bay (u~l~!s ler~~-seal~projects sucn ••Su:ttn&Ar •.b~11t with subst~~tlal ~o~-state r9ve~uesJ. for .n upper bbu~d estimate,the aMaly~i~uses the Ma~-Su 8orough'a hi~her populatio~p~ojeetions•. The analysis then eo~s1ders what rate of growth iM pop~l.tion.attributable to the project,should be a~~ed to the ~=e11ne to be~1n assess1n~1mpsct.T~e a~alyaia add. tbe applicant'.project~lnduced populatio~proj~ctlo~.too.••li~prOject1Q~.in staff's revised definitiQ~ot the iapac:t are ..(ex"anded to include Paxso~,Healy,!I~d Ner\&na).. This procedure yields an upper bou~d aMC lower bou~d ••ti~t.of total pQpulatio~in co~unitie!of the i~paet.ro..80th eati~tes -indicate substa~~ial populatlo~ growth i~the small co~u~ities ~ear the project 81te~·The .AAlyaia YAel theae populatlo~esti~!tes to assess the i~et of the project O~q~alify of life,the eco~~y a~d eaplO)'1M:"tt,houailt9,e01Mlu!'\ity services,fiscal status and tr.napcrtation,for.both the Wata~a a~d ~v11 Canyo!'\phases of tho Sua1tn&project.The OElS briefly discusses impae~e in ~~ehorag.and Fairba~ks and geMerally dismisses them as ainor. After c~rlno the impact of project-induced populatio~ growth on the affected communities with tne 1~paet of the altern4tive.,the OEIS co~eludes that the natural gas .c.~ario has the least im~act,fcllow~d by the coal scenari.o.The eomblned hydro-themal sce:'!.!rio and the propoaed project (e~d ~usitna basin alter~ativesJ will nave .rouQhly .q~1vale~t i~paet.aeeordi~Q to the DEIS. III.IMPROVE~tNTS N£~O£D IN THE DEIS's ~UCIOECQNO~IC ANALYS!~.-- Th.-'Qcioeconomie impaet-.!~alysis in the OEIS is i~adeq~ate -for ••verei reasons 5Md should offer a !tro~~e~co~clu~io~ -~- r I .- I - ... ttlat the non-~\Js1.t:\a ~a1n ~tt~"',at lv~~C'l!'"l!'s\Jp~~tor'1:.0 th", p~'!"d_pt'Clji:ct.t 2 !!l!.~defiMa ~5t'iF,ifI.C~:"It lftlDect ~~~e!"t'O'W1Vt Q~~Qll~QLV.~the h1~tory ct la~-5eele ~c~rwet1o~ Pt'Ojoct4 on t.hi2 :,tate aa ~"hol@ !~~1"l~"e~~Q'(5 .LtiO.tl~,.tr4te~y of ~rra~~t~o air tr~~s?Or~at1o~to t~att.fr08 A~ehora~e .~~~elrba~ks• ~e propo••d project L~volves spend1~~up to $15 b1111o" \l'I .ct\l<l.1.dollars over a 15-20 year period,eQuivllertt to th.cont1nu...t1on of recent year~'one-bil11on-doll.r &n~~~l c4p1tal apend1~Q for 15 to 20 year:.S~en .pending VQ~ld be a tre~e~dow~eeonomte .tl~Ylwa to t~8 State'.eeo:'lOfl\Y. Ttl.propo••d ,pt"oject is a world c 1 as!co~st t"uet 10:'1 project,.eeo~d only in Alaska's history to the Trans-Alaska 011 Pipeline,a~d by it~sheer ma9~itude w111 directly affect at least the e:"\t i r-e Ra 11 ~l t • Tbe project'.impact on the Railbelt centers of ~~ehorage an~Fairbanks ~ill ~e greater than the OEIS a~t1c1pat.5. 7h.CiIS'a e~ti~.te that AnchoraQe po~ulat1o~will 1ncre~ae by 649 ••«result of the project 1s shoek1n~ly love T"l~· ••ti~t.ia even more off base if the OtIS's recoMme~rled ait1gAt1on .trate~y is followe~.The OEIS ~eeomme~d! :low-eoat tra:'llportat1on to the site from Ancht>raQe to 'airbank..The OElS did :tot analyze impacts 1:"1 A!H:horage and r.trb-.nko arillil'\O froft'l this m1t1~atlo~!tt'~te~y. Such a atrate;y might also increase in-mi;ratio~of job •••kera to Ala:ka.Job seekers wOwl~be ~re likely to r.locate to •larger population center as therewlll De a gr.ater n~r of other jobs available in the event they cannot g.t jobs on the p~oject. ~!h!DEIS raises !!~issue ~does ~a~~lyze !h! .1~~lie~tlo~G of projeet-related misratio~to the State as u~lo¥oa voriera tram else~here ~ve to AlaSka to aee~ vocE on EH.project or in project-l~aUCed joSs.The OEIS _nt1ona in passi:l9 that \J:'lemployme:'lt may 1:tc:rease (as haa happened in the past)as in-mi~ratio:'l to Alas~a .xp.n~a the labor force.However,the OEIS does no f~r~h.r analysis.This effect is erucial to a:'l accurate projection of project-induced po~ulat1o~groyth a~d analyaie of the re.~ltin~impac~.The C£I~must a:'lalyze in-mi;raeion to AlaSKa i~more detail. 2.!b.!.OE1S ra tees!.!.!!l issue ~E.!.!~.!:'lalyze ~ 1~~liC4~io~e ot the fre=ue~t i~accu~aeies in la~ge =roj3c~~1 ~~tr;ar;u of the size of the oe!~work force--~-..--.-.----.--- -4- - ,~ • r ...... ~.~ti.tng 21 ~~.T~~~IS elt~a a 1~!2 It~dy of 1~~~-cc41e eon~true~to~~rojeetD by t~o Con~~ ~••4~eh Inctlt~te Whtch :ho~·t~eetual ttQl~O~ a.1(3~1tuo.of eon:t.!'fJct1o:'\Qt;\,lOY~;H\t diffl!"d.-~.~ Q~bata~tl.1ly f~tho eetl~~oa ~e.~rlor to ~~M~t of tho projoct."(~IS ~\1-39.~~o a~Jn ctwd1 f~nd htgher tha~o~~oet.d tur~over in t~.p~ojoet work fQ~.ThG CClS off~r~~8e~~itiY1ty .~alytt~of th.ce faetara O~t~o ovar~ll Impaet of the projeet • ~of th•••raetora 1s consi~er@d in eo~part~~the 1~.ct of tho alter~at1vea with th.p~opeo.d proj~et. AlL of th.no~-Sua!t~a alternatives involve "~~rc~= ...ller projeet:which are more ~preAd out ov.~t1~.~d .p.ce.~.r.for.the pea~e~plcy~nt at a~y Qiv.~t1~ u~~~_~~y of the alternative!11 much lo~er.Th@ bocx:a-bUlSt ch.ra .:ter of -a'll the no:'\-S~s l.t~a bas i:'l .1torn.tiv~.15 therefore much less.As the OEIS ~cte., Wthe otabi11ty of the pop~latio~A:'\d the pe~e~~ta~e of the peaK which remains in the area d@ternn:,,\@s (eie)the 5eYeri~y of tbo~-cwst'impacts...'Boo~-bust'phe~o~~a are .eire d~fflcw.lt to plan for tl'\a:'\oradual ~:-owth.· (H-45.)Therefore alternat1ves wlth less cO:"lc@~t~ated pe.lit eaployme.,t arid less boom-bust'character will t'l.ave le.&aoc1oeco:"lomic 1~pact.However,the O€IS fails to fully r.cognize the superiority of the alternatives' l ••••r socioeconomic impact • 2 !h!2£l!~:"Itio:"l.~fails l2 a:"lalyze ~impact ~ proje~~oule ~2n ~res~~~State ~'hifci~C ~t.atQ ~p:o:'\dll'\g l!2!those areas,wnose eco:,\Otues cet,;,e:"lc h04Vilt ~~tato ~oe~dl~g,12.~e~o,ec~. The OilS ree~~iles that ·Em~loyme~t a:"ld i~com@ 1M ~a:'lY r~1Qn~of Alaska are hiQhly depe~de~t O~State gov.rnDe~t aourees •••on ~n individual level,the State government ~eeou~ta for about 45\to 50\of personal wage-and-salary ineo~in rural commu~itie!.end a .tat.wide .veraQ@ of 31\.-@ N-13. Howeyer,the DEIS tails to a~alyz@ the im~act 0:tne &uaitna projeet &:'\<1 the alternatives with res~ec:t to tM • •ff.~t they will have on local eeo~o~ies cy C:Ma~9in9 the ~.oor.ph1c distribution of state spend1nq. The baaic eoncern is that the State appro~rlatio~s r.Q~1r.d to make Susitn~feasible must come at the ex~n••of state s~ndin~in other areas of ~he State. Thoro 1.no other possibility,~ive:!the h\Jge SUlll'lS rOQuirec1 from t.he :::;tat.e (et le~st :2 to 3 billio:!i~1983 dollaral,and the 1Mevitable deeli~e in state reve~ues as .",or1'd oil prices fall and producclo:,,\tt"'om Prudhoe Cl!ly, -5- , r- i I - . ,;. . e t~l.rg@at oil field in U.S.htctorYt be~1~'its stoady Mell~irl l'9SS. Thent LS no dO\lbt S\,Isttna vLll t'equ1r-e Bublt.tl"lt,111 !I~at@ .~~\ture.(~qulty a~~/o~~a~o ~t~btl11~~lo~t.AO t~o ~p~'~Seo~te ~Ft~a~elal ~~t~~~~8t -All fin.nc1~q optio~~which hav~se~M@d t •••ible O~pO.ltaly feaSible ever the eeu~. of the OftQoln~~vlQV Or Suaitrla have i~YolY.d 1.r9.laYQ13 of state asslat&nc~.t~IS e!••~ th.t su~ltna 'ILl!have to be O:"le ot ~h4!!Sta'=eta h1gh.At capltaL fu~diM9 prlorltle~In o~dor to ftc~i.~therequ1red equ1ty ec~tr1~utlo~.· ,7-5. ReqYlred state appropriations ~ould ~~nge fro~a low of $1,91'0 .11110:,\n01!:!inal dollars (.xcludi:'l~tiJture interest ••rno,al under the tax-1!xempt Reve:"lOJe SO:'ld pla!"l with state .q~lty and rate s~abilizatio~paid up-fro~t to 53,58e Di.lli.on nOllinal dollars u:'1der the pra~featuri~t;a mix of tax-exeapt revenue bonds a~d REA loa~s with ~dedicated oource of atate fy~ds for eQ~lty a~d rate !tabilizatio~. Aa the tables in Attachme~~1 s~ow,the contrib~tio~a to ~Y.1tn•.,111 eonaU1lte a major portio:"!of the State's c4p1eal b~d;et--betwee~58 and ~l'over the lite ot the prcjltct,••I)w:dng that growth in the oper~t t:'lQ budget .ta~ilil••a&reYe~uea decli~e (see Ta~le.I-Ill). The 58-61'.hare of the capital b~d~et co~!ume~by Su.~tn.oyer the l1fe of the projeet is .i~~ifieaMtly higher th.~the Suaitna service are!'s e:'\tire s~are of the ~tlt.capital bUd~et over t~e l~st five years--4~.4' (0...Table IV).--"-- In e'"ery year betwee:'\f''''t'aa a:'1d F't 1999 except O:"le, Susitn4 'a share of the capital bUdget ~ill be substantially gre~ter tha~the hignest snare ~ obt.ined by the S~8itna service area from the State CApital bUdget. Aa the Mit.itself admits,the State fU:'lding cO:Mlitment to Suaitna will have a major impaet O~the priorities i~ (~nd therefore the ~eograph1e di.tributio~of}the State capi.tal bUd~et. In the p~at,~ural area~of the State have depe~ded mere h.av11y·o~the capital budQet tnaM O~the opera~iMg bUdQet fo~eeo~omic stimulus.As State fU~di~g for ~~4itna re.ha~es the distributlo~of ~he S~ate·.capital bUdget,it will hav.a serio~a 1mpaet o~the rest of tne -6- -,,!""r----...-,.........._...-......:.......:--: - 5tetll!.1e.~i;i.lly rut's 1 C04Irll"HJ~'t lee,bee~use t~."!I ~o~ the St~t.dope~~=0 h~avtly O~atat.~~n~t~~to ;~~~~t t~.lOC:A 1 .co~~_ tn 1,a~••atudy of the NAMA re~1on fo~:'I~ : r • ...... - - -at«ta ~ev.~uel to .d~eltl~~,co~struetto~, aoctal ••rv1~o.e~d co O~alone .uppo~t 50\of the totol l~eo~earned throuQ~outtn.NAHA r_glon.-(oarby~h1r.'~:uee1.t••• ~ECO~09Y'19~2t A~chora;e.Alaa~a.) A 1980 .tuoy of Bethel found -state reve~uel d1r@etty cr iftdirec:t1.y account for 34\(of total loeal iMe~rPPe~,· (o.~bysh1r.,A••oeiates r The Bethel tee~~y,PreB~Mt And Future 1980,Anehora99,AK.1 The peree~ta~0: lOCAl l.ncOM devende:\t on state spe:"\d1n~i:'l Bethel is :'IOV DUchh1;hlir after several years of fedet"al s~:"!dirHJ eutB and lnerea ••d state spe:'ldinq fueled by the oil ~ri~ r1aes in ~he early 1980 1 s, The Susitn.project will have a great eco:'lo~ie i~pact o~ other .reas of the State because the proj~ct relies 80 hoAvily on .tate fU~di~~at a time when revenue5 are ineYit.~ly d8elinin~a~d because the e~tire ~tate, eApeclally rural areas,are so depe~de:'\t 0:"1 ~t.ate .pending to support ~he1r local eeo:'lom1es. I~coap&rin;alternatives,tne OtIS fails to ~:'Itio~that .11 non-Sua1tna alternatives have less 8ocioeeo:'lomie i~ct bee.u ••they do not rely a8 heavily Cif at all}on.t.t..f\.lndi1"l;. IV.CONCLUSION.--- In conclusion,the OEIS's fi:'ldin~s that the alter~at!ve!to li~.itn.a are enviro:une1"ltally more beni9:'l 4:"10 eeo:'lo1'l'lically DOre effective need ~o be strengthe:'led to reflect the l ••••r .ocioeeo:to~ie impact of the alter:"latives 1:'1 two nap.ctsa 1.The alternatives are mere ~ispersed'i~space a:'\d more screeched out ever time,lessening their eu~~lative -booa-bust-impact on the State, 4.The .lternative.depe~d less,if at all,O~s~ate f1nAfteial suppor<,so their indirect eco~omie effect on the re8t of the State,especially ru~al a~eas, will be less. -- -7- ".!•i±. t'AOtJ:t t.,... bt~!'t 11M!nt:,2!.~venlJ1! J\:no 'O~-...l,i=n~..)e<.:.·..,;t .1J1l b)'hU.onn l r :.:General ru~A",.11abl..-_.-...... :"'trol.UM Total !State F'i:'\4 l'Opoe~a t in-g-·fer t ...:-!ttt y~t'l "oUt:)R.W~\J9!o !ud't!C t C~l")t~.l .- POt".2,'OC 3,181 (,,2,124 15 2,622 3,085 (?)2,2'3 7'13 86 2,5;6 3,040 2,4'5 ~'!I!"""87 2,0.45 3,3~7 2,673 6'4 II 2.'50 3,23S 2,98'7 348e,2,'87 3,~79 2,951 ~328-90 2,'50 3,235 2,911 323 '1 2,139 3.105 2,794 310 92 2.768 3,256 2,930 325-93 2,811 3,307 2.976 J30 9.2,7S9 3,2-46 2,921 325 95 2,645 3,112 2,801 Jll ~9fi 2,"59 2,893 2,604 2eJ9 9"2,295 2,700 2,430 270'3 2.185 2.571 2.314 25' 99 4,055 2,4l7 2.175 24~aoon 1,942 2.285 2,056 229 ·AaR~.the cyrrent ratio bet~een P.troleu~R.ve~ues end total .~rQvenu ••(85\)continues • ··ep.rat1n;BuCQ_t assumed to Q~o~at e,per year u~ti'i.~ =~.ch ••90\of total reve:'lues. i""'", -8- - t1.~t.t II. S~.ttn.U9t\on ~(nc ~ J...Ul iJ 11.\1~..n~'.).- Av.11llble Dedicated P'erC"lnt of h~r tor Ca,olsal ~..von ....o 161o!!'\e~O'oerat in9 Il.ldeet. .-rtlcs "3 177 &16 22\ 1S6 S'S 196 369 35\.,"4 210 454 31\ 88 3.8 227 121 65\ 89 Jl8 2.7 tsl 75\ '0 323 2Ui 77 76\ 91 310 238 72 ii' 92 326 237 89 73\ '31 330 239 III 72' g~32S 233 92 72\ ,~311 150 161 48\ g~289 2!)6 33 89' 91 270 277 (7)103\ '1!-25'~2-17 10 96\,';24:2 214 28 tsS\ 2000 221~L9 210 8\ - 5.9~O 3,413 2,507 5~' The Dedicated R.v.n~e scenario was chose~for analysi!. bee&u••l,a.l.gialative pro?Csals focused O~this sl:ra~e;y and boc&u ••it botter represents the opportu~ity cest ~t th~~~=1tn.project for the State throu~h ti~• .- -------------_._------------- 't~~II I, S~~\t~~Y'traOn !l7't-Al ~ .\....ll.bl.Dedicated S\,l:t.tl"ll P@r'ce:ott or Y••t'f.oe.-ed.t')1tal ~yen\Je 9~1~,,~~rat1no ~ee.t r rl'"713 1"~'C 25\ ~,SfJS 220 345 3g\ C1 674 2J6 "38 35' 8e 348 254 94 13\;,328 216 52 a.e\ to 323 216 ~7 15\ ,.....91 310 266 44 ."'2 326 265 61 t52\ '3 330 268 62 81\ 94 3ZS 261 64 80\is 311 179 132 sa, 96 289 200 89 69\ "270 253 17 94\-If!257 228 29 89' 99 2~2 198 44 82\ 2000 229 9 220 4'r-- 5,920 3,Sa8 61\ "'"Tn.n.dic.ted RAv.n~.acenario was chose~for analysis beca~o.1984 11.~1.1It1v.proposals focused en this ett>ateQY And boleause it bott.r ~.presenta the opportu;,i ty COlt of the Su~i~~&prcjeet tor the ~tate throu~h time. _._.... -10- -.. "..... TA.!U..!:1V. ".,.. ! .- S.t'Ylc~A~eeo•tiL _ (C:loct~lOl\ D1G~r1~t')rY"o Ii 12 83 S.rv1e.A"& (~U i::1Qct t.o~ Cl;tr1ctQ}I." ,.... ti '-12 J.3 20 2.56 44.90 .50 15.36 44.68 221.45 35.97 '73.02 52.09 308.68 !i2.3! lS7.~4 14 ..47 1.8.fJl 16.2' 52.88 ! 6 7-1!l 16 18-21 lS.2G 39.50 331.77 67.56 107.94 61.4 1'ct«l for S\,l41tna SoeM1c. Aroa Total Alloc:at.-d t.O Specific Dl.trlct~le ••e, 375.12 SeO.59 231.6 860.76 1,395.00 417.29 563.03 1,811.'4 925.18 3,'<43.12 .... hrcent s~.s, .. -11- - .1ll!IIfIIIII , : Al••ka Power ~uthor1ty Appl1cation for License for Major Proj e<:t.... ) ) ) l ,-,-...;..-_._---------) Project.So •."7U(. (SUui tna}.RECEl\/ED SEP 12 1984 PilJsbury,1.1iJJiscn &Stltro - 1.'I'he Alaska ConsW'rI'et Advocacy Program (ACAP)is a project o~ the Al.ska.Public.Int.erest Research Group (A1<PIRG).AC~r Js a non-profit orqanization,based in Anchorage,that represents r-Illdential utility consumers'interests before state ar.d federal-_..._~~. re,gulatQry bodies. ACAP submits these co~ents in the interest of addre!sinq specific fin4inqs contained in the Draft Enviror~er.tal Impact Statement (OEIS).ACAP is coneerned that the OE!S misses some critical points in it!approach. Ac'tual 10&4 <;rovthwill depend (among other thin9s)0:'1 tl".e .'-ieee ••of non-atruc:tural alternatives in curbing or re-o;~!"1.1ctu.:-inq electricity usaqe.The OEIS deals with non-structural alternatives only in &cur.ory,short-term fashion.This treatment is inconsist~r vith the lon9-~erm nature of the Susitna project's productive lif..In general,we believe the OEIS must reflect that the I~eci.ion whether t:o proeeed with the project is being made u."\cer great uncertainty abou~suchfaetors as future load qro.....th,oil price.,a.n~st.ate revenues available for financinc;.Alaska is r ffOfJtJO()5~l-oJ7nC_W:=~ ,AUG 2·~.~/:- ~.--- ·, - - part~c~l&rly aenaltlve to oil prices eh&n~e!--a ~ey 1n~x e.ro,1.n<1 vhi~h Qthor determinant.evolve.We ~U.e~·eha~ ~&~ion.l ~~1.1on ~.~in9 {and it~correlative preparatory analysil} r-••uat take into account this.19vere uncertainty. The v.ry -.11 or nothin9~nature of a project of this- ..... aaqnitwe flies in the face of the need for fl&xi'o11ity that ...11,1 likely b.-nec.••ary to meet ehanq1nq condi tions.A plan tha.t il incremel'\ta1 in nature.would spread the c:os'ts and avoid creatinq larqe amounts of excess generating capacity . ~ft DElS should ad4ress this aspect of rational energy planning in a.ae ••ing the various generation scenarios advaneed to date. 2.AVAILABLE GEh~RAT!NG CAPACITY - - r IQ YOl~1 of the Oraft Environmental Impact Statement (UEIS),~he main text,.se<:tion 1.2.3."Future 'Enerqy ~esources" include.~&bl.1.5.This sehedule of planned ~tility a~ditions consist.of two projeets,Braaley Lake and Crar.t La~~.These project.are hydroelectric with a total capacity of 97HW, .v~il&bl.in 1988.The schedule does not include a unit bein~ QeveloP44-in So14otna,-den~ted REA Soldotna ~l,which is a gas- fired 9.n.ra~or of approximately 30MW·.The schedule also fails to 1nclud.the proposed l2SMW mine mou~h eoal-fired unit currently beinq examined ~y Matanusk&Electric Assoeiation, Inc.,(MEA).The Alaska 1eqis1ature appropriated funds to Itudy this proposal 1n1984;it is a longer-term projeci:.bu~ could be built by 1993.S?ldotna n~er on is scheduled to be on line by winter 1985. -2- : .r'.- ......., - tn .ec~Lon 1.2.5 ·Gen~ratiQn-Local ~el.t1on!~1e!o! g7 +297 -16 1,115 818 1,131 1,034 Net Peak load (as qenerated) Mar9'il'\ ~.t1nq and Pl.nn~R.i1belt Syst~."(p.1-15)at p.l-1!, r~~l.1-12 (Syacem Generation C4pabl11ty -Selected Years'. ~rovid.1 for 1913z Exiatinq qeneratinq capacity (1992)(MW) Planned additions (1988)(MW) Av~ilab1.capacity (1992)(MW) Ret1rMlenta (~) .- .- Co:naiderinq the above mentioned units,however,the sehedule ahould more properly read: Exiatinq generatinq capacity (1992)(MW) Planned additions (198S(MW) Planned adOitions (1992)(MW) Ava.il.able capacity (1992)(MW) Retir.ements (MW) 1,034 127 125 1,386 -16 .... Net Peakloa4 (as qenerated) Maro;in 1,370 818 452 3.Non-atxuetural Alt!rna.tives Volume 1,main text of the OElS (as expanded slightly in Appendix C)notes three categories of non-structural alternatives~ -3- - .... -- ;...,. 1,~.rv&~ion 2..Rat;.d••1qn 3.toad ~an.~nt,. J'h1l lM.Ln text,1.3.'.1 anc!1.3.4.2,essentially discount.tho potantial contributions of these factors tow~rd eont:ol11~; e'herqy require=ents. In light of ehe lon9 teem nature 0:the perioc of in~erest in the OEIS,thia discounting is inappro?:iate.tver.a cr.e- fourth of one percent reduction in the forecast rate of growth "IOuld greatly affect the overa.ll requirements throuqr. 2010.More important,this pessimism regardi~g the above factors taila to take into account 1)Al~ska state policy of JPromotinq conservation through Alaska Public ~tilities Coeai~sion (APUC)rate setting ~ctivity Qeline~ted in 1980 (A.S.42.05.141(7)(e)and 2)the recent decision of the APUC in t1-S3-47 (Investigation into Regulations l:st~:Olis::':"l;;f..:.licy in PrePAration of !tate Design Proposals).In t:-83-41 (March 29, 19S4)the 'Co=miaaion determined in Order ~o.6 to "(I]ncrease ~e conaideration qiven to conservation as a separate Clb;jective."•••The conservation objective is a prir.'lary pricing objective and tlat rates were set forth as the standArd r'l.te form.Moreover,in Order No.13,the Commiss ion aet October 1,1984 as :-eporting date fo~each electric utility to propo•.e a specific date fo:'"submittal of a plan to im?le:'!'lent icnovative and experimental ra~es.While the ne~ness 0:these .J~•••in t,he country in gener!11,and 1'.1 a sl<a in particular,r.'lay -4- -.: ,.- t 1 • ,~ - ~-.., - - - .- reaylt in ~hi.tory of suceeas,th.absence Q!•auttielent te!t per.iod ia no re&aon for eonclu4inq as done in seetlo~1.3.4.2 th4t.WIt 1.do~tful th&~in ~h.nQar futu~rate desiq~ar.~ r .1~k4 ~n&9~nt will invalidate the need for additional generation.- The planning horiKon for the Susitna project is longer than the wnear :future."Even if non-structural al ternati vea do not ·inv.lid&~ew the need for additional generation,they may well effect the tia\in~~nd amount of need.'I'iminq rr3j'""'ell be cri tiea 1, given the effects that excess capacity over long periods of ti~e would.have on the overall economic viability of the project. Gi.ven the emphasis recently placed on these nO:1-structural ••'Lt.ra....:ti.ve.L at the state le\7~~_r_the eElS r.\ust a.na lyze the pctertti.=.~ for meetinq the needs served by the proposed p:oject.Se~sitivi~y anAlysis i.require~to ascertain the results if"non-struet~ral alternative.are effeetive.The burden of provinq the ~roject i.upon the Ala.ka Power Authority and the Fe~~ral ~~prgy Regulato~/ Co ..i ••ion.C1smissinq non-structural alterr.atives out of haMd fails to meet the burden. 4.Lo44 Gr~h Forecasting: A vAri.~of forecasts for iaentifyinq the wnecessary· aDOUnt of electricity qeneration for the Railbelt area have beer. pre~d.The Alaska Power Authority sent fou:co~puter oodel forec&.t~to FERC for ~na1ysis:1)Department or Revenue (OOR)~. 2)H&n-in-the-~r~~ic Program (~~P)-Institute of Social anc Economic Research (ISER);3)~ailbelt Electric Oernand (~O)- Batt.ell1!ll and.4)Optimi%ed Generation Planning (0::31')-t;eneral Electri.c Company • -5- ..... I i - ,.. The APA svttled on the followinq fiqures,denorninsted 1983- 2~808 (GWh) 580 (!9I)pea.k 1990- 3,737 2000- 4,5"'2 2010- S,!SS 1,200 (~) Correspondinq averaqe annuA'growth rate •2.8\. The APA expre8:.ed some comfort with this forecast level in part d~e to comparison with utility sponsored dema~d forecasts that were significantly higher.One exa~?le,however, thAt the APA specifically referenced was 'the 1993 9ut'~s a='\d McDonnell Power Requirements Study done for Chugach Electrie Association,Inc.,(etA).Since CEA supplies power not only to ita own 60,000 c~nBumers but to Matanuske Electric ~ssociation. Inc.,(MEA)and Ramer Electrio ~ssoeiaeion,Ir.o.,(H£A)~~d the Ci 1=Y of SewArd,C!A'.needs are the greatest sir.qle part of over- 4.L.l Railbe:Lt req1.lirements.In APtJC !'ocl<et 0-82-47 (~ai'19 a 4) testimony ••tab11shed that current demand throug~out CEA'S system 18 less th,a.n that postulated by Burns and ~cDonnellls "Lol,ol" scenario.The cu:rent.requirement-s of eEA's systerr.are bein; reeVAlUAted,both by CEA anQ by an independent joint effort by M&A and HE:A to separate their requirernentsfrol':l those of C1:A. FERC should ta.ke these new efforts into consideration,even thouqh FERC Staff has proposed load qrowth scenarios for analysis -6- '1"'-._...............'.....__.,;.,'-,...............J which are l~r than ~e AlasK&Po~r ~uthority reference ease. I~ted thi.~d&Y of Auqu.~l~!~at Ane~orage.Alaaka. r •..... : Respectfully s~mittedf r ...... ,- -7- ~&kL AlasXa.Cc'l5l.:!er ~Cj ~ar.I Post O!fice Sox 103111 Arx::h:a;e,Alaska 99510 (907)272-63551 278-3663 :--'-'''"'P''..................._:...-__._.'_....._.-.ioM.............._'...........-.•_......_ .' -/' UNttED STATES or ~~~ICA BSF.OP.£-rat FEDERAt ENERGY IU:CULATO~Y COK!"tSSION '~&.ka.~~_A..ut.hority }-f--- Application for License for ) Major Proj ect ) ,------------, Prcjeet Ho.7114 (Susi t.na) .-, Certificate of Service -_;;..;";;;;.;;.;~;",;.,;;.....;;.",;;.,.-..,;;;.,;;,,.,o__..;;. thereby cert.ify that I have this ~ay servee the forEtqoing dc>cument upon each person c!es iqna ted C~the offici61 service list compiled by the Secretary in this r,:.proc:eeainq.J..., Dated at Anehoraqe,A:asxa,this~day of August, 198,•• .- ...... - - - In t'M ....tnr of. l~Itt'O stATES C'F A~ER!C.~ ~t E''tRC'f R~t'UroRY CO~ISS!~ RECEIViD SEP 1 219S4 .,......,"I'""0 ....... ~,~.. .: Alaska ~t'Author\.ty ",~l.,,')btt!son t Slt~ S\Ml~na HYdrooteetrt.e ~Jeet ~M)JreT !'lO.7114 A~tle4tlOft tor lleenae' : ""....\ .~.~............ A.an lntervenor I ~lsh to eomNent on eh~Or3rt Env1roiMental I-pact State~ent relevant to ~ojeet 7114 (Su.c1.tna).I v1.11 confine lIy eonments to Volu:w.e 7,A.Qpet".d1.x N.Soc1.oeeonoaics.These comment!are as rolto~sf 1.The-Federal Energy-Regulatory COMlLsston ts to be h1.«,hly CCN ended for its overall 1n.s1.ghr::an.d ~~~~ti.on wt th ~1:0 the .octal and env1.roMental value!!este~ed "'y the nllidonta vho l.nh&b1.t the ooten.t1:ally 1m~c:ted c:01mftu..,1t1es and an.-•• 2.A~1x N 'requen~ly quotes the soe101ogte~1 stu~y authc~.~Y.$~ephen ~raund and commissioned by the At~s~a ~ower .~U1Chor.lty •..,~11.Lml'Ort:ant 1nfomat1on su:!aced 1.n.the report, It ahould not be f~used on to the exclusion of other data -..ther~by the F.E.R.e.For lnstanee,on June 21.1983,! ,~ ..~T~.~ke:e;n.a.Tral)perCreek area.It 15 d1seurb1ng that:no re!- erenee 1 •.ade In ehe ~.!.S.to this ~rt1cularly tmporeane hoerinA.A~~roxiBatety seventy ~oQle at:~ended.forcy people tCl:t1!led orally.a~~rox!.mately thirty five a'dd1tional written to.ti~n1es were submitted,in add1tton ~o the su~1!ston of nevtQaoer doe~entat1.on and other written e~ib1ts. --.., e' testl~y and d~t4 of the June 21.19a3.hearing (in the t.U;~~.,t't·..;)oe~C~4t"e4)an~l.nelude 4 s\Jbata~t1.~l "~~~!"Y t 't:'1.71!r.rl'·iti~i.~:it,:.i ,.:.•,j;::·'~·"'.;:;i;;.;.;'~I,;·~;; of t:ht~he4rtnc In the tl'\v\.ror=ental.~~et State!l~~. 3.It la ~C"etrut that the '''I.R.C.Tl'Ust rely on 'th& ..,',~~~'~~,~~~~.Iln~o~S~y ~e~rt~commts!tone~.~y .the Ataska0'.·),~.rt;,.rlll,I.·.,.ll ••r .•"ll~I'I.tll'.~I••·t"'l I'~':i.~i!fl.i:i~:i.i·i!i:~~.': :.~r.".\l~r~.~y,.~t.\~,I~,~~~t~,~y..Frat;'k .~~.th..&~t~~O,~~~.~~~.,!~~~.,."':" "...I or II ~!~,~y~,f~~1.NS ~.n.~tene1.~l'ty 1nlp.aeted c~u.~1tt.e~A!"'.d .·f".j~;'JI.···'l'1 •.I ••'tt.l~i.I'I'i,;.,\:,.tt·".lt·.··~';I:~.tl'&i.·.:':"~;:~ .......,.nN••exh1btt &rave de!1eteneies.Pleaa-e rind attaehed a ee~y ••t.I,.IIIII'L.,.~t'.··••\"~'I~.E"'~··'·"1 ••_••.•••,.'I.::••••:.~,:'''''.' ••I't"I""~~I'~fF:-Y;~~1~~"e,~~~.C!f>\.,t;~.~u..~h:!~.~~~.t.~s~.s.~.~7,~~~~e~..1.~..... ""'" .I."",~t.ch the ~Y'were conducted and ;>oints out s~e basic:•~:.,.i , • .I ~,• •,I ~.I •r . •,I ••••••••••••I ••. dof1.c1.ene\.es • ..,bY-t.~1$!J'r,1sm1 "Ihat the F.E.R.C.CO'nll)are the Household Sut"V.ey •F"'...,••••I.,,~~,,,.~~.•~.f .•.~~~~9 .•..~b1.~c hearin.g test1.mon1..es for ereh i I ~t-""."1"~~~"111~I~~'~~'~~~r.,~~~~~.~.~,o::~.t~~.~.~~.~~~y.~!:~~~~~\i~.. •'I'~1=,~lent tnt.rt.~e.laborers anc1 employees,el05t o!whore are:l i !.I I I'.Ii r •I t ~~•~•;•I .I .i.i.;.,r r !,~.!~.....I ~•,I ~'"~t ,;f r Ii,I I r • :!•I:I r ...:t •I ;.;I ,f :...I t I •I •I •;••1 • II~11"1 II"~',.~l ,~~1~1 ;I,~,~t,,~~.,~~~;~.e .~e~~.l~.te!t~r.tt?2!Y.~neeted 1 ill i'III.i It i i ;~\1~~~1 i~l~A~~:;Jjl!ai l~:~~~~:~~~,~+~'~~,'~r-~,~~~lr;e~~,r~~rt~7:'ltt~.." .~~I~';<;:~~ii~~~,~~~'l~'/~~e,~':Z~,~,Lr:..~~e.~y~r~~,~r:t~.~~.mpcet Seat-.nt. - -.dated AUl5\,l:§t 20,198'+• Roberti SJ"leldon,'!'alke-etna.Ala ska - .- i~ Transcription of Handwritten Letter August 6,1984 Dear Secretary Kenneth Plumb, This is in reference to the Alaska Power Authority application for the Susitna Hydroelectric Project (FERC No.7114 -Alaska). I believe in FERC's draft Environmental Impact Statement found that the Susitna Project would be too costly and too environmentally detrimental to provide for the needs of the Railbelt community ..It recommends smaller hydroelectric projects.I am writing to say that I agree with this wholeheartedly.I feel that this is a "white elephant"'project, totally gone out of control in its planning.It has never been proven to me exactly how it will be financed.I certainly don't want public monies paying for this monster. For the past few years,I've written my feelings on this project to my Legislators,Governor,and of course the Alaska Power Authority.The Power Authority seems to be wi 11 ing to go to any 1engths to get thi s project started.They may make a lot of money off it,along with all the agencies involved in studying it and building it.But it will hurt the public interest and probably leave the public with huge cost overruns. I also want to mention the socio-economic impacts to Talkeetna and Trapper Creek.Our community is not set up to handle the rapid growth such a project would bring to the area.Yes,our area is growing,but not that fast.Right now,my family and I can't drink the water in town because we get sick. This letter is a plea to turn down the APA's application.APA will give you more and more statistics to support their program.They'll say those are more accurate facts.That is only because they want this project regardless of the negative impacts. Thank you for your time. Becky Long Box 344 Talkeetna,Alaska 99676 5767/136 F1 ..,! ....- :f:.,.......,:~•• ,~.,~.~..":'"~:.:.. .'..'~>:...'" ....... ""'". .('...~..'.'..':~';......--_.,...........~... '..- ....,,~/-. ..... - Transcription of Handwritten Letter August 13,1984 Dear Mr.Plumb: This le~~er concerns the draft environmental findings by FERC on the proposed Susitna Hydroelectric Project. First and foremost,I would like to say that I agree with the Commis- sion's conclusion that the project would be environmentally unwise and that there may be less harmful ways of providing power for this part of Alaska.This position is exactly what many in this area (Southcentral Alaska)have been saying for years.The potential and probable damage to habitat would affect salmon,black and grizzly bear,moose,and caribou,not to mention the many small animals,birds,other fish species,and -lets not forget the river itself,the finest and most beautiful this side of the Yukon. The latest update I have seen from the APA came out at a Talkeetna meeting late in the winter of this year.The main theme of the report was that most fish that came up the Su branch off to the Yentna, Talkeetna,and Chulitna Rivers.The Yentna intersects the Su downstream from Talkeetna,and the other two flow in right near the town.Only a few thousand salmon continue up the Susitna and spawn in sloughs and small creeks adjacent to the big river itself."A few thousand ll seems to be an insignificant amount to the APA,but it is definitely not to the people who live north of Talkeetna or boat in to fish.Many people of both groups really do obtain a significant amount of their yearly meat by salmon fishing in those waters. Also,I believe that the fisheries on the aforementioned tributaries will be affected more than APA leads one to believe.Remember the Susitna has been freezing over,and following the laws of nature for more years than I can imagine -at least -thousands,maybe more. Sudden changes in this water quality -temperature,nitrogen content and salt content -are life and death for the salmon in all the rivers,and they are all interrelated. 5767/136 F1 .",.,..__!!f,*,,~ But 1 1 m getting long-winded.Hopefully,you will stick to your guns, and not be swayed by the APA's over zea10us plan.Besides,I think they are just in it for the money. Yours Truly, Dennis Ransur Box 344 Talkeetna,Alaska 5767/136 F1 f . ..- ""1-.. •".......r D f ..ok ,....?em . r I I - ;.-.... -j!il!lIIllII . Ii' ,-i - - '!""'--------'=~.~.--------.......--...._-----_...._,........__......-------:-r;";:.~'..'i CO~r.:::~.s i :.\I.,!/I l:"llp.).•.•"\""N ""..~tj~,I~••'(..~_fl f (';...;..~,j ~ '?1l l .f f -,-."... .- t,4..ronee I,An~"f:on D1toctot.Offieo of Iltetrle ~~t ~latt~ ro4et~l In~~nY ~.gul.tory CQB~1.11Qn all ~rth c~ttol :trQot,N.R. ~Q~lhttoa,n.c.2Q4~G- RECE1VEt") SEP 1 2 'i9~1 Pinsbuq.Ma~i~n &SlStro !,.n 'n 21~'!.,·rr-.~...... .'..., -fhe .ttache4 eoeaenta on th~draft SIS tor tht propo!e~ '~ai~n~lydrooloctr1c Pro~~et It@ Bub~1tt'~IS pub11c com~~nt o~ behalf of Joff ~ltI1n.It 1s hoped that 1nl1~nt of the timing of tb~P~tC lIS eOQDOnt ~:io~durin9 the busy,but short Ala!xan a~r,~b4t thota eo:aQnts ~ill still b@ alloY~d to 1nelu~ed as ~tt of.~h~~oeota ~n~that staff and commission m~mbers give f~ll eo~.1aor.t1on these eomm~nts. (~-;.... -_.-..- !!ttJ?.$CfJ6/ ---------- """-, ~ *'- ._----- If,'~I ,-2~.....2,C" ... ••I'.........\ r ce.~~~01 J:tf r W:tT:Itt ,.". ... ft,:c.\a!)IOO TU:~~~tM.\?'~rns o;t 'F~". P~::I)nc~t~~.tr~:~~!C FItOJ3C'T,.,.....:: """,' -- - . tb.a.~c~nt.~r ••ub.i~t.d on behalf of Jeff Weltlin as publie ."j.I',•I I ;~.r I 1 C • •t .,I ~;I.t •I .,.".t ,•• •,,I l ~, : • •'t .''"I •r •t •.":..;;;',I :;,:•:.:~: C~A~"...';'P.~,~~~.~.r .•~.r~n.~e~~~,~.~~en,~a~.reV.1..ew.,~,~.h~~!!!.~1\d .. offer th.follovln9 co~ntl. Gen.r~l Co~ents Tbe c~~ct.offered in the following ~ext !pea~to the issue of .AhanceD4nt potential of the Opper Sus1tna River ~ra1nage i~ &C ••ace of the propo8e~hy~roelectr1c project on the Sus!tna. 1).v.lopeeQ~potential of the upper bas i n (above Deve ls .Canyon) for ~a••a ••laon h&o1tat ehoulO be aOdressed in much ~ore depth toen rxac ataff have discussed in th~OE!S.The star!assess~ent .tat••that, ~~.concl~~ion wa.c.4ched by the Alaska Department of FlSh ~ud G4Q0,t1~hor1e4 Rehabilitation Enhaneem.nt an~ ..Z>ev.l~ntI)1v1.ion,that upriver expa.nsion ot ana~ro!l'!ous aalaoc pop~1~t1ons to areas above Devil Canyon vas not P:.1ct~c.a=lo.1n tho absence of the Susitna project.'!'he Qt.ff .,tbu.,couclud••that loss of upriver salmon'potential ,...wou14 ..110~,.~,.~..Iignificant project impact.(t'EIS,p.4-27). .....".~~•.•~:~:f~.'.•,...~o~c+u..aio.n ~,s.stated above takes gross liberty in-,.i.,ta .,c5.t.r.in~~10.n ~f not significant impact by rel ieinq soley on ..~.~•.~r~r.t.~8tatment the Alaska Dept.of P'ish and Game,FRED. w!tbout 1nveatiqating the overall upriver enhancmeen:~otentia.l ia ir.ater detail.While Alaska Dept.of Pish an~Came,FR!~tas tho only re~onnaisance level st~d¥'of the upper S~41tn4 rlv.:.~lmon potential,the st~dy effo~t has be~n greatly cr1t1c1104 Dy oth.r AO?&G ate!!assigned to the SU!1tna hydro ---~--------, salmon - flebeC'y ,t~dtea,.bl ~f'.(i bLol~i;at~&a.19n~~to t~.eoO'~:tnl.,t .•t.,••~••~jl:i~,I'1 l~.':·'·;ri~:·.:l::~~::j "':·lt~.!;:!~."I'..!.' ,'.t :~~:;,.:';.4 ~~~,~~..~1~~a~~,_te6~fo~.allm~n ~fthane'~t~~tn~trom ~~tYQ~e !.Jj I 0'~•••,rl.'11 .::"t·!,.:~!t!~:r~;~i!{;~t':":~r:!;f~;.::t~:;:~l:~!;f!!;~;;:; Cook.,l~.~.•1'.4 .ql,1ae\ll~ut'Qrg~T11tD,t1enr&.~el.er1 tlet12!1'\~01 . '':-'.'t '.I I I I ~.:.~•~,••:1 ;I •~t t •I I :;: I ;~r ,••J ~;f •i i ~;:';.;i ~;~!i ;;~~l I •:r .,•I :~";~~I .;: : ::;r ";~~ Qtbe.r ..,~~ClI.IOV1.t.~itb1n A~r.G bear 8eriou~qut!tiol'l:1.3 te tl'l'O. .•.'.*•I •r • •..•••{,.;;,,;....I ••L •".',....;,..1 •:,• • ,,• I • •~,• reli.bil~tl ..~f ..t~~..~n:i a&au~tion!I\a~~by A01'llC,p~t~1 n petfor..n~~~f~·t~,~~tu~y an~ar@ public r~eer~tor U!~by ,!~C ~Stalf in .Y~luAtinv ~~.potential of up~r Susitna .~ee.4nt.Copl..of eelevent memorandum have bee~attaehe~....'..,..;:.:. ~for .tafl and coaaiasion members consideration. ~LDdLc.te4 froe th.attached memOtan~um,determination ot ~he • . • •.'l •".','••••••" I .,,. v.lue of the pot.ntlal enhance~ent thro~gh ~xpan!ion ot the (... ".;...~.itD"anadrollCua .tacks to !-he upper Sua 1 tna dra 1nage is •unless fYrth~r investigation is petfortned. ..~~.A.l~..~.Pew:Authot1ty has failed to .address this issue and cbould be req~e.t.d by P!RC to provide additional field dat~~nd !.A.V ••~19..tion 1norder to =ake a rational det~rtnination of the .-pc.opQae4 byd~o.1.ctr1c project's impact on the enhaneeme~t potential of the upper Suaitna. \. - - l.-\lrl~to ~9Ct ~IU~:=c=n=rn:.ntJ c.'\,~=1~-r.I i~ I~~,OQ 'tl:3 hO ~PJ:t G4 tltQ~t ot Cbo U~::'Wo.il;.,,;Ld.vc:: ~:M::;;=~.. . ~~'o..&AC'Q ~,.t .xJ tb:2 fZl.r.:~\t O::lort:in:'l"o"1:0r ~X!r ~k !ril£lt: ~J:.t1.CtcJ.~t.'Pl'.rt Of \:ti ~ut1os iu t1~1~~c:awcj,~i'r;~l:g.~~.;a!.,;\; ~-c,:)lr~r.r:t.:.s;~tl~co..~rc:1a..r ~'i~~i~l·\O~~\;o.",\:.i\"':':(,·a ~~ce::::~t>~-.1i.ng ar:ao'Q ·~o:c:JJ:::.n c.:.r&~~M.t ~jll.am'4If;~.u.. ~teC~n.:mocl'~OQrel:~n':'c.ooorcU,fl.:ltoe tQ tlC't (]to.",:.1l.. :':~tten,%~w.o~.fo:twa ~rti C.w ~~J:O~'~,Utl s~U:,fJrc S't::.:.:1ng c::c:1~UJ:1-t1tl SU tIyaro l-"U:twri~~~d.~;j,r.:t\1~v1w r.;l:Q~. %k ~I =.YQ:Y :o:d.11~r"1l1t..~tho'~lJ l:ycJ:O jI,cj=e'~4n(~t~l,~ i 4str:rtea 1"t tlis!lt ~.'. ONe tbo ;.cr1~ot tho l,J,~t t\JO WCO~;Ll,I law"{.)Qt:n ~:.ltc~.;.~cific c,;~:ltions ~l,)Qut the :ellOQrt tolc.:l:icc.i ·u~'::t(,)ur L~viL;i';'l.tlC: uoc-;,)QL~~•.!COJl~110:J:OJ.i ....J.i ~it)W 1 t~1:0.;~'"'::t::~~~ccuJ.~I l1:~a~"lG 'tIiio n.o.~.I I~Qo A r'-K~wL.'::'"r~~. oft1(O t=ou,.n at:n1e l\op:;:.~1re l'Or n .c:o~~'~tl'.-=:c:.crl.:.~~.V;:'':'';'t.,o';', r:IJl ~oqt:Q~~U'OtllrJ be p:ua:o<l Dolon;to Oob :tUrr;i#i;~3il\~~i:I •• cHst"'1OJH.c=.'(QJS ~lWl e:::1t:ol. OIl Ka:cQ ~,%VU fJiven a.o:t'l ~t."':o ~t.:yuro ilC.11JCtie ~tl.~·':.'0:1.-:,:'~ lrtdC''C ~.Of!~~rt:..DecaU:Q ~'1e ~nli'si~t.lACoe Sr.cCi4.11.:1~3Sl~ 'GC1 ~~:t=n.fa:a..c::a:=t::t~docs~,I ecX..•for .:u-.d \2.5 ~ve.f'l ~ J.c::::;==0 CJW ~tb:l ~-t:1rl,t.hc W.QJ l~9iona.l ~i;~iCQ {~·.o c;:lj ~~toM Anc:h=~c:ff1c:a).I ~~ivw'O it on ~:.ut.l~'l\';~:\:..~O; . .~~=-'"1c:c Ct'~.toct :t:"~rt \~D:ot.:oc ~il:.A.oQon o~.r.:.~i~\" ftt:S:l)DLvL=J,oa,GO I ~enly a.ble 'Co rcr,fiw t.:.hc .t·a~r'C tQ~~~:.s;;,n ~...~%b:2UeYt:'l'al ':..~at11:group U:2.U wro ti.Ja.'\Il l<i;~.i.'1.:110 i t c::i~eX:t1~cl>o~. I aCjlUn oalle<1 Y04Jr oftiC.)And ~!..l::c;":'turl.i.:I:c.:J.:c~...l.y ~or ~~V.!oJ: t::1:I ~IX)%CQI"d <J.!.Ye it a t:.horoo;."l reviQ'ti ~"':r.J ~z vt.;:y ~)j,;;'in.l~· told ~t t 'coulti-=J/ith I11j tQ<!UO:':~1 ~I c:mn~t ~~~..;J..J?'i c;,. ~.:c...r=-""'t to n::::t'l:U'to 6~iti =,1·11 ke-o p my qt.l(!stior..:.\m a t..'Or t: ~":C.l.~1"":I :s.. . ' . .... 1)mty 1s M c:f1cic:ll Fr'J:O nQ~rt (tJo...Series N'!::cir.(j "itl~')e.l ... f..---c4 iI~vicic::ul reviCM ~J at;=cvJl troo ~t,.;t.l:"::~~~l: (~~0dJ aur}.;ot1.;c.llri.~J tQlo1~c.:1ll 3/24/Uj)7..-....-... -~------------_--..:- I.;'i / '"'" ".-'.. - 1),~~,~=~&on tM~ul:on ~b'I U.~l'S'J:1t1'4! I ~~~~"V,<="4 ~,~:r=-4 at tho ~''Plu:o~ott~':ic'",_ ...cetQ'.:~~~1:L.~..rc.:.~,~~·!nlcrt 1::.t="Ob::~~~---e . ~,"1."':4 ~o:t,f1::"~ry !J'\~Q !t~t:Q ~nt!~~:Q by I .,...., ,., ,. ,,,G~t~~.~~~:~to ~~~foe thQ vUd ce~5 i~t1 ~1~ateei<.:~r~~'~tcliQr.i'rotu..-tu%'~'~~.:..-d,'",.,.<,••."••,<.,.<'••', •.••..I.I I.••... 4)~__ono of the 4UthO:O cl the Aport net 9iwrt a ch.!~0!!!:o .~~~2~.~afe,,tct=Qrt bcfot.a it.s rele!.se,esped.~lly •rf ..."fl'lrll"'",r'l~bo'~i~,~no~1:0 h--ve.his ~"l'e at'2~to thct_~?.I .••.••,If.r ..~•"t •t;;,••I ,,,I r.r ,I •~•I ,.~.'>.'.~...~..."•..l·'·.·..::··(·.·....'l ~A ueotbor C1JOltiOll.l ccneerning hoi tha betl:!fit cost calculations .~.to ~t;'1.."W ,Jr:Oj,~;Q~~l:)11itl w-are =~!:lut sinee I am told .~coe ~QtJ.~:wer~p:cvioW:ly rl!l~e~by !!CD!of you:~~iel'\ll.c=:e:~.~~l~o:Q~,Ifll nQ~bcther p=sin;Q~.In a~di~1o:'t, .•~..,..:, ,at:4~t=~,~the .c:raft ~~port eo..oo:eerr't.1!'l9'g':'!yli.":~eult:.."':'-e are in .r',1Q=.~tic.,~.the of~ic:1;ll oaiZrtn!nt~l resporlsein the t"eV'i~ ,F-:~..t,•I • , •,.,f ••c:.~.~~~Exhibit'.s.~rU:onse,t;y the wav,ms drafted =-1 th~~.~;',.,,.,~-.'. 1 bal1ave the :.lNae c:~re~rt without O!!=Br~nta.l reviev is a g-r0.a.:2 error 1n ptqtoeol if not in p:o!es!1ona.l1~by yo-\.!:,senior ~~ctc.U.It e::crta.!.nlv ~s l.ittle to er:..!r.oe t ....:e O!ar~ent's~~,.,~~in timos of elcse perusal by the ~s~slaeu~e e~d ;'1"]i.e 1n ~~~.I •' Ie LI ~~yg••tion as a protessional biologist and request ~s ~ ~SC3C~~,0!thO Suay~ro F1~eries ~~t.iqation 9rou~and cepa~~Mt ..".."'.~t9ct.o tM COox Inlet ~e9iQ:'1!.1 Plar:'ling'~th~t::~drU?; "'"'"""'"...,.doQ~:nt,=.~'''04 .fran pbl1c 41l~t.e9islative distribut:ior.a:tc!a 1"-',I ••,••••••,••••.fom~'f ~pa.~~n~:rwlev 'P:OO!SB initiated.I elso believe a revi~-." .iii I I I I I J t I I I [Itt i ~,~.~~th11I ~~:es:ihapp!ne~wcull5 be hel¢ul to all o~":.-=~..t.I I ..J •I [i t 1.1,.,.I,• I t ~••>.., • ;••••"'!"t •';...~••;I ~I • . . •;••••I .•~•••1 I • • . -,.I"••:,.f 'f'I ••~~~.l~;,.}:clu4aaeither peQ~e or ~e.'rlbers cf c:::::'!\ittees l!t:c. .1.n ::::r=•. ,- \. cc::Cc=iBa1o.-:er enn ~:b I n1.=~-aa:lL~nc.r ~P:.:4iQt ~ulr.:a...~ Bom1C1 J',Qpcl-J..ra ~l SoI.r:ic:!c L::rry &~~t Stave :er..~oyer Jch:2 Clark At Ki.~"Y Dave Daisy Gee:9!c...-.-'Li.ngha."n Bob BIJ.r!<e~t. Tau ':re."\: ..,._. " •t:::)e::~ ~~~~~~)~ •~"1l 1 ~:~n=-"""" t.:2"~'.l ~.~'Uf~)fe:~;~"'~~3 i:~"'r..~lC:l ~::* ~~~ ~~1~of~:. ~tn!~V'Qt SU-1'!'On c..Wo~:"nt St~ (. ~..... ..... ..... t ..~~01Jllo for ba1.nr;late 'lit.'"th1I 1'aY1...,of the dra!t reEX't't. Al ~~4 th:t ~~nt end 9&YQ it a p.D.rtial revie'loi,Chwcl< .~CC~-A ~~~to l~(It 1t e.:o to ot..~r =ere ptessing pc:io:ities ~:a t L~~h:.:r1r.;;~1c..~r1e=o.nd rY8S bu4~tG o~e\JP"/j,ns ~.'i ti~e:.:'t:=~~.c:::4.1ld ~,bo:t.La •br1e~:.viw of tho r_port trom Al !(ir.9sbucy anc ~.~.cfO'Jr ap::e1fie ~=haw 4lroc.dy been coveted by 70::'i 1t=~'., I boll.".the uin point we want to get a01'OS8 1s the bias eowad •batc=or1ce wh1Ch~raet.~i%aa the entire report.No realis~ic ban'as:t :ataz,eon:lidar4~1on for tho typt_or loa:io..,of exist:in; !iCbo~1&3q c:poeont1al for nQW :1~'.r1Qn are discussed Qr ev~~ CC~:~l~1n"'th'Q roport:.Sl.lppo:ein~reference r..Ate:ial in sc.~e ll-,'7 1:S O.t:h=a.1 ft..:ing cr wry In:9inal.Po~ial ne~ti...e .~m~cts !:c ~1ntroC.letien.o!l\:l.tchaty ::toe:k.s en oxistinc;wUd stocks (as ,~~to I.::1.~st::odl:t1r..")oty)arC!not discussed.~~ee':lno:::i.;:': UM\r..J.:J CltCtlonvould require much mote 1:ime tha.n i8 4vailat1.e bue t:::.:J ~~not :ofleet tm:I variability or uncertainty in basic ;::==1=~tA (1.Q.a ~iQncra·interval)•... ••At~a:o ~fw 1IpIC1t1=.'%he review ...as not fOt'tolarded to Ser.ato:nc=='.c~1=.0:::Jurw.MJ.l B:2 viU ~SCI if ~ag::::opciat.e • -..'-~I"" .'# ' " I:. . •'>0'" 1.~~1,l~''''~~-lt1 •only ~~~~~O (~)aa {")are .~~in arrt ~~~.:C:L"~~.:t.• •2.r ~~H3.6.1.1 ~~COleon •Q\=!a~1.on the &sa=ption of ~r :Qt?;\~t ......=o ~1.'\~t.l.!:::J\t='C~..icn to ~t ~~~~'I':'\Qra '.Q:O 11~c:G.:)~to.U';Q 1~l091e:l C~.!M h:oOct "tic~= Q1=Lea 1.0 Q.fl(t t...-cJ.~ftt .of ~1'1:'b11ity t:Q~~rl tlM C:Q~M .t\j'Ct;C':==1a colt:~lon c.~Il.CNlt tQturn ~r &c:o~Cu.m~o of ~o.:dt ~~w=uld o~~"t.~~(Ptl~11)~~c Qrtly ~~~c:=r~~c2 ·~t k=-"'C'::"-=1c:."\f r=':U:.'"t~t,.).AO.It ~lS ntl: c:e:i:~,.~~~t ~~rJ fort Q....-o ctOdt:o~1n '%\J:It~or qiV'Cl A..i'j ~~Ql ot 11':.1'11Ol~1~~:C'·..~~n tor ~rc:~:eo dret h1scr ~e:' Q:A c::=elu:1~.~~of-~tru:1t e:;)a Doppcoa.eh to pertiner.-:.&:.a ~~.tb:~tho :;;:eeio.:1 Cl1=;o:=:1am erd tha rest of tn.report. PS.91·33~·'O!-No~our.it con!ctaqging or radio tagging is mH,r.t; Odt=~~~t.1r:StJJdiea 1.rtve:t1~t10lUJ haw l:he'Wn there ia li~..i:ed QiIX :;~:t c:~mi~(ch1~~)art:nUTtlors are sr..:.ll ~d a:=,i1:~.=~,,~'~Co 1~to ta';anc!track 4Cul t c.Umon. 4.Pave 3~,-~.acenar10 discussing differential harvest rates Eo= •~~wild (f1stMly)u.JJrcn hAa already been cHacusseo.The ~wcW.4 ccr=:~to ~b.Coc~Inlet o::mn"rc:i!l fia."'e:y \It'hiC.'15 a (-;:;'03£aJ.:""d .::teC:X ~i::±wtry.Ohc!3r no o:mc1itiOl".s =!JlQ these stOCK_S boe ~~At t:=o 95\~oit.ation tate <tJ:!to the ~tent.i!.l ove:ha:ves: .::~vUd~.~:=inaJ:sport harve2t ~i~:ies a:e prooaoly no: :fet..-.4 hl'0 • /""'1 7. ., ~Q. r~ - 5. ,. 'Ilbe ~t.u.~"&'.%DeS that greater production will oCt.:l..!co £:01: ~&=a b:l.tehory p::ogr!C.C!.rtYing cap!city (rearing t:et.en:ia.l)~s 1:01:.c!1~f:e=thC2 t:01nt that qiven e1"01J9h naw:&l sp:t.wner:s,the n:fnn ~I C:.ClOlt c:oc.1ld t:3 ~0!I'd from wild stccU IJti1 iz ing a ·ff ¢:":::i." ':be ~j,QS ~tDu.aped.ea &K:ti.ons aiscussed in Tan'Trent's rev i~ C'Q &4;;0=.=. PI9t .a,-5.2.1.2 IhoW.d be 5.1.1.2. ~.0,!be'mt:.ir-c:tU.noo.k er.ha.na!ment IX09rmn 4SS1.m!S snolt'proC~::icn hC:1 b:;,t~fitl.~rl1n9 pl:.nt~Which are untried or unproven.':'he bioc:ri=1.:a r:a.f~~~tor Table 5-G ~rt.ain rrostly to other s?!cies no': ~.~only rQlA~rl!f~~~1$the ~Directive '3 frO!'!1 the ut-~o;f tbo ntm t)ivir-lcn Reor~::!.t!.on z.'ani.1al.' 1IaCJ=57,5.1.1.5 {2}~"'«is re!ere.11Ce c1t~.Also,needs disC'...~sio:-:o~ u:==:tul s...Jron run:J nat~~:t'oecu.:rirtg ir.hi~gas O::lr.Qentra':io~,s• Page 81 ,85 •COntractor costa =ep:esent only a portion of ~=ojec,: CQ{~~~~~ma1nter~noe eosts~ope!!.t1ng costs sh~~lc ~a 1r-.cl~. ~0"... •.'.... - r-10 .. u. u. !""" f - ~./13. ..-10&. 15. h~'0 •Cult4bJ..~ftOr otoc=~t bo e1oarod ~t;OMtlesa.nd :.:;..~\c;:J,'~~~~~-t.!.,..""r ~'\:O ~e-:c:v.~M.f})~to ~~Qr ~&jo:t:;:c.t~:'9 10 ~~i-:e--:;;.~~~:eJ a ~r-v ~J.t::)~'\-~..."t.'"rQ cc}ot~:;).,\lcC-~;:J r..:g C ~~r:1t~~~~.t1\~iUQl\,C\U~ru U~CV:';D r;::.:J t ·'<E-:c::.:~t:~~~~(:;;a::A:~f~Wr~~ b::l ee'~~~c:;~~C-:"~:J\~~~~=t o~n in .Cce!.t~t::.~4\~.~_~t:;:..~.a ri:i~~~~.:s.If t\,V\t1A~ f'~-x."-:l ~.c.~c::t:l:l ~:-~-a.(~.::u~;-:.:ta ~9'"'~at th1~i~ ~Q=1.0.t::1l~~CO"fO c:hi.r.ook ha~Ib~l~:~t1:l\i.~;u e:ook~dc::=:.;(:ae:~)~tho "G'Clmr.:1 PJ.vc~~~~Itoc~VQYld ~:Q ~~~~talct ~t l~bFo v;~1=10:to ~~rcU.J.c~rJ.n~. ~C:X:::t't ~::J~to =.c::c:h ~1t in tM:!. lQ.oa 103.~toc:D -M par ne:nt'a ClC:ti1liQint.l,these st~s are are ~.at;:C'JC1Q.tQ ~~~1:OarCQII ....,. ~~·lC4.SOckeye broo~=tocks from the Culkana ~iver are not &k.=~l.Ato fm'~~=-...3.~in f\t::nbIr 9. Pa.9't ·105 •.~CCt.~'tMt s::><:kcyt'jlJY!n1.les at the Gulk4N ha:ch~:y ~r=t teen ~-c-...x by mN viN::to otc La 1.ncoz:;ec:t.The CiYlka.na. &c.!.l1t:(~~:.n epi..-ootie in 0t'Q 1nc::=tar tMis spring. •~9D 10'.%)iud.vlJ\ta98s of stocking 8r.\olt.~t ue tne refe:ences tb.:1~~~trQt:::m::mt 01 on ~res~? Pa~~ll~.%bay.·to aS8~the cost construction estiea:es are aQC4..Jato,but F"'~t)1v1aion.h4a a h11tory ot bUilding par t.:.all J' cc;~ot~or :enlc4 ~hnt~cr1Q:due to increased costs,so 1 ~et1ctl 1:3.4 Df111:n ~.o'l,C'~ia :uftic:ient to build a r..atc::,~~y. JII.~124-l4.1._ec:cncalc AMlysi$-~t being An eeonanist I can',:s~!.1< vita Ut:i ~~.-~en the tren:f1t/c:o=ealOJlation but on ~9i 136 I (Cl. ~....:TC::.'"t 1:1 the ~~:SU=1tr.a lUwr -~re is no o:xr:re:cial fir~1D t!=di:;;a:~t....PJ.~J:O the Cllc:ulations using c~rcial c:c.JtQ UQ =t "t1114.Al=t if ~'Wet (i!itarc:iAl c:atQ t=eroenta~s c=~.IQ !==c:t'!Q,c:tn:a·and c:cho Uld 5'for No:thern Cook Inlet =~UO =:-0 q:;;;::opciAta. JaQl 138 -It 1,r:y t:n&tratan~1ng a ~at 3\is ext.remely oP'=L~is:ic a=S ttut."te "lzs ju.=t ••vAJ.14.~ge 139-142,the cost Analysis c::::==tb:u edT';"la::t.1c,0:)I a.cJc:::l.Cl ~fX and te<:eiV'ed a.03py of the c..:a:~ of.JC::e.u~'a li:hery and E~1<:As=~pt:ious for lSS2FR20 ~QC;=cnt ;.nd ~"I.h~11tz!.ticn S.i=Jl&ti~."hic:h discussed benefit o:s-: c:::J.~t.1Q:\:J.~L~S-O~OO:;ts includc!!:ueh things as ~piT;al ~-:.o of cn3=cn fi::..lotin9 and vilri~ble CC2::of fiShing among ot..'"le=s. t!Xl:JQ.4.:.not l.nc:lud..in~t.~Q SiC eq\1!.t.ions u::ed for the p::c?Osec. ~=Otr.J.h.:.t.chary.. Part.o1!tho por=it :equite!:lent tor thll!~p £klu:na hatche:v ","'.3.5 :'0 1n~~t.."'lQ eo~:.of ~car~~nd rr.lcove:y p:ogr4C.to deterr::lne :.r.e ~t.~cry contrib~t1on to tho cixed ~toe~tishe~y.This ~as a r~~~~of the ooneocn &14rse hat~~ery r~~u:~the S~~e I' 'I' - • ..... - • - ...,.""ft.- " '. .~. --------""""""'~====~.........------------ ·..eATt:"Jb r¢"'2~,,te3 Ot-.1!·7·~10 Z'74·7sa.3 Aa ...i~01 "[0 ~~.,. S\.t~ftM ~H\HJ'"$.A'~ Enh4"et~"t Stydy (ON,t) lI'aJ1 tOe: .~MO: .... t..... -- ,, ,',At~tl u.o Alaska"oep.artwnt or .",h '"fJ ea=•Su H~ro review, er1~ri17:~'b1 ON:Q .C!.Mi2tt·cnd'Q)'ul\'01 'Uta su~jtr;t report by F~EO.r~h ,~t,=~I ~:t=-4 by SQ'Mtor Vie Fhch-tr'.effiee and he asked "'i~ t-......j ~T'Q'YfQf ~~hstont'r ColHnsworth with a carbon c:opy to hi s 0'\'11=. eafortuM~'"t.'Mt lettt'"fT'Oftl S'enetor FhcMr wu 'cst d"lring the 1n~crn!l ~~~.tat.-a believe &1 I ~tt.r of protoco1 the letter should go to s..."."tl:l't"F1scMr'Cl1rvetly froa AOFIG h~Adqu&rt~rs rather th4n from AnFf1~/S~ Jt1dro. ".,,,"1..is urcfy and was due Mlrdt 21.After dhcussions with Richa!"d Loou.~RdttU11cn,1M OQnnh r.~lso at the Soard :o.eet1ng here in Anchorage CR ~Z3nS,it wa.doei~thlt I should sand the review to )OU.Ke1so 1=!ir..atlt:!M would e:al1 Sen~tQr Fisc:her's o(fi eo and 1M ke arrangements ",;:r.U~t.~COtSs1d'1rat1on cf OU~rev1aw and a ru~"se to Senator Fhcrer. ec: .' - -. .. - .. ""'" It specifically statts i~Seetfon 5.1.1 that report sections 5.1.i.1 -..., 4 ,,111 ,rovfde 'Ir\evah.lation of the .up~er Susitna F.iver waters!"·:':---_...-.~ '.... C".. •'.,i - productfon potanth1 for sockeye.chum ~coho and en f r:ook sa 1r'"'J 1"\. ~t1ons 5.1.1.'-4 presented &,reasonably clear ~ef1r,itfor.of t~,e stre&aS or lakes s~stem from w~~ch prQduet~on cou,~be expeete~L~: beyond this,the eva.1uation 1$biased,fn our opinion.and bas::c~ .fMc:curate data presentation and 1nterpretation.C.,page 3:b;':or. paragraphs a~bued en data ,presented tn Tab'e 5·2 which is ~ccr~ glQa'le1"ate aiR =hmatc:hed information.For examiJle.the rec"lo:it.:':"~r: r!!JzrCers "reslnted f n Tab i e 5-Z for the two a1 te rna t,yes ....d i,,~,C:C~ 1dent1c.&1 to one anClther if the e;q to siiiol t survi va 1 in fact ;s fifteen tiQls.·greater under hatchery conditions than r.a~I..J~1 production!Add1t1on4"t,if the survival rates on naturai procu:cic~ presentad in Tab'e 5-2 Are accurate And there is a 1:1 male fe~aje se~ r~t10 and f~C'Undity is 3000 e9gs,recruitment cannot be cCr.ipu:.ed as three fhh per spawner ~ut rathe,..1.S fish per spawr:er.Also.':he reference to "brood surviva1"in Table 5·2 is unclear.Wr:at'1 ife phases all"!specifically covered by the terTiI "broed".and why is presente<1 'liihe."egg to smelt SlJrviv~l has already been quantifie:? 1"'...."-c::....I _ -- ...-.. t - ...'.•o.Jsz::is f $' ,'.. ..~.. ~,. " t1'N9Qrt st'Ctfon 5.1.1.'•4~'W!~\le$t{Qn tht aeeuraey 0'the r ..cr'l~t· -..t AU '"'01'\tN 11'Tab"s S-!,$.4,'.6 and 5-8;''SO~k eye. CtltftOOt"eono,.and c:~"llmoll l)~Je.f'tturnl at high!r I"ate~than ~~tI4,It l ..'t tft Cool tnltt.~or example,seekeyt sa'~n pre~uc· tfOft tft .the SUlttn&River ....nSlt beMe",2.9 an-d 5.3 'iSh Ptl"Spl..~t,. (T.rbo~.et.",19$2).I~thQ Ktn~f and K!~i'Qf rivert,~!e~1tm!n~ ....'bebiPlUn 12.1 tnd '.2 fish per 1p.~tr.In Tabl e 5-2.tMe.,' recrvit:=rlt ~Ir p"sented is for a spawning pair (l':la;e/fema1!).tf r-a4j"Ited.for fndiv'dull s~awnerSt the number wou1d be 1.5 tfsh/s~r.Th'1 is markedly below th!2.9-5.3 f1sM/s?awr.e r reported for the Sus1tna Rfver (TarbQA,e~.&i.,1982).Therefore.the non-MtcMry Neru1bnent (natlJt"al ~rodut:t1on)!st1mate~!re l.l"l!"ul. fst1ca11y low,in our opfn1on.Tab'e 5-8 referenced a 2.75 f1sn per : f : ;. spaiwning ehv=Silmon p4~r or 1.4 l"ecruft~"t/spa~Mer.A mo!'"e r&llf~ti~esti=4tt wovld be 2.4 recnuitment/sp!~n!~(Ba~k!l!.19~C). The '~_J)re11l1in.a ry Upper Cook In1 et cotmtercia 1 chum sa 1l'lon 1'\a,.....est_._.. ..,1.4 .111ton ftsh.The Susftna R~ver produces conservatively.75 percent of the Opper Cook [nlet chum salmon eateh.ihe 1982 Susit~! Rhe,..em.,.1110"escapement was Ipprc:dmate1r 0.5 r.dll fon fish an~ tt'&e appot'tionld Cltch at 1.1 million fish.On th1s bas1s.it car-be IIS~the recruitment per paren':year spawner was in the I"'ange of. 3.2 fish.provided also,ft i~a~sumed the 1geZ return wa~~anaged or.,- I MSY bisis.Whether the recT"'lJ~trnent ffgtJre is 2.4 cr 3.2 f;$~P~I'" Spl~".r or the mean of tnese two "um~!rs,the esti~ate of 1.4 (is'~e~ I,p."".r used in the this draft re,o.rt is too 10w in our Qpi~l~cr..t~~ beU.ve the economic ana1ys1s on c:hu!'!'l sa 1r.'\Ol"l w~s bHec c~ ...'~ .- ?• the 1.4 fish "'f'W1tMnt nvri;)er,l",d thlt the ana'11h s""ow'd be rKllcvlltA-d for o~ct~d nturn~ul1n~the 2,4 flSh'recI'"i.itr'!..t n....f'f)tf'SPAWft'~. t ..-. ...: r i i c·- ~. I 2.5.1.1.1 Sock~$.1-0" p«ge 3!/plr'l.t The report .tI~.that wth.nu~er of ad~it sockeye salnon available _...to the f.bhlr1Is__de~"ds on whether a 'fhhway enhancer.:ent prog"a~0"a hatcJ\.tT')'enh&ncecnent program is used.-The report gees c:,,:to S":!~! thlt ·with I hatchery (no fhh....a,ys)more salmon car.be harveste~..." These SUtelMnts tend to exe:\pl !~y the tone of the repor:.The t·..·: enhlnC8ltnt methodsshou1d be eva~uated individually ~n sep~ra:e s~t1cns and then "ompared in a sins'!section 1r.an e'....a'~atio~c.& .1ttrnathes.The 1=pression is given in the report fror.'t tr.e u:::;c: thlt I hatch4r,y is the enhancement answer.The facts sh~uid ~~~3<~or ~.ly.,IS to which alternative is the most favorable. I' - ..... \- ,."., 3.5.1.1.5 Potential !lrr1er to Juvenile Salmon Emfsratic:i Ind Adult Salmon Immigration This entire sectJon is pre$ente(!without 4 reference SC~ice.',..'ha: infCT"'lA&t1on 1$there ava11ab1e that supersaturated gases ~n.Oe.·~1 Ca~on exist at levels which can cause mortality? --- thit 'hypothesized oltgopsy pOW!r were to ~su't 1M ~ner!11ed @~o~~~~c rent ~tth ~QtS1 in th~t~rre"t anllys1!.OM"~d2m4nd c~rve5 ferfnd1v~d~~1 p~::c~eould not 01 pQrf~et~l'y alastte 1 (~~o~gh they ~ld still t\IVQ 4.Mg~Qhst~e1ty).~I'ld two:eons1d~rable e~:!ss •C~~t1t1 ~~l~htYe to .x~st '"thQ 1n~Jstry (esp!c{a11y in those y~a~s.nQ"prlQl l'baing used as a wea~oft tft l eom~et1tive stru;;le wl:~~Me rother ~n of the tndustf"1 lftd ~t!nt1a'entrants)•.-.- ThcuVh t~.It~Q of th~s rent to processors may be s1gnfffcant.w!r.av! conlQ~tt1vcll assfgned no value to it in the.1982 economic ar.a1ysis. ~fnal Cost of Ffshino Effort For C~re1a'ly Harvested Sa'~c~: -In the fort'gc)in;dhcunfon .....e ha.ve acc01Jnted 1'01"J:!?"'fvate r"'argin!i revQnut and tot~'rtven~e of the enhaneement production.We will ~OW turn to .st1~tfn9·the private marginal cost ar.d te~!l eo~t of h:l"Vestfl"lg the tnhancedstoc~.The thr-ee eor.-pol"lents discussed oel.:w ar'e of prt::4T)'importanc!in estimating the va'ue the resC'Jr'C!S f~regc!"!i r: the process of harvesttn;the enh~neement produced s~l~n. A.Capital Costs of Sa1men Ffsh~n9: ( \ """" - .... The Alaslan salmon f1eet.as wet'as other Pacific sal~cn f~s~;~c fleets,hal"been characterized as b~'n9 lar-gely overcao1tal1Z!d- {CI~tehffald and PonteccrYo,1969 Pierce Commfss1on Re~crtt Pierce 1981}.In short,the balance of literature on this suoject coir.~s o~: tnlt $iT=o~-ffsher1es ha~e grea~'y exp!nd!d f1sh1~q ~o~er ~n reco~~ ye4rs.aut.because the c;uarttlty of fish is esse!':~1a11y fixec.l.~~~.::: for a""ual fluctuations).new ea~1t!l1nvestr.'e!"lts in vessels,;ea'"a":: Id'vanc:ed t.r.hnolosy added to the 'fleets have ceen li!!"Sel v w~<l'.QO.C~e "~ns.quc.ne.of overc:a;l1talizatfon has been an established a:~'it)'O·t ..~ fleet to hlrv~st ..en beyond the 1978 to 1982 rive-year average ra r',eS ':. The 1981 harvest of 125 million sa1mcn c'ea~ly re~~esents tne C"!!i~:e~ to twenty year upper-yea.r bound for combine~harvest of wna~dej S~OC~S and·the output Iran plolbHc ar.d private hatcheries wl'licM ca.n be e;l:cectec to be produe~at the writing of this text.It has been assu~e~in ~~e a"llys1s that,dospite government efforts to lfm1t nu~oers of fi~~er-e~ irl the flelt.tho general response of fishe1""l'!'len to 1ncreased success as I resu1t of enhancement harvested salmon will be !~as~l'"~ele,b~t nt1ative'1 s~Tl scale,refnvestment 1n f1~hfng C!O~cfty.Tr~s,averag~ cost (totA!cost)of capital 1nvestment 1n the 1982 S1~~1!t1o~s is ~(pected to var,y with enh~ncement procuced cateh at a rate of ;ive percent of the average revenue (to~a1 reYen~e).In?Hed in this cSS~.;'7.:­ t1an 1s the expectatio"t~t some current rent disSip!t~~~1~ce~~i~es, such as the law market interest r!tes ~vait!b'e for s~1~~~f1sre~~~~, wi11 not extst beyond the late 1980's. ,Perfectly elastic refers to !~e~a~d curve wft~a~elas:i:i:j :- inf1r.ity (Ed-.) ....',..'"._,.. 't'.'b"'-:..... .,.~,•_,1...• L L ·fI- i L ·1~ ... 8.Variable Costs!of r1shin~: The 'Hrhb1e cost$of catching tht tnhancerr:ert produced salr.-c'"1r'b:e pr1~r1'y the labor resources l~loe1lted wft~the increased fishi~; effort.OthQr cQ~onent'of f1,h1ng effort cos~s lre fcac,fuel I ~c~t and 9t.r ~inttnanet.bift Ind i(e.Estfmates for tnese costs fro~ vlrfO\lsstud1cs range 'fro.on 0 (Orth t 'lSa~)1"his est 1mHe for the eCQnomfc:f~iS1b1'it.)'of a prfvate nonprofft hatcher)'in V!~dez.to d rang!of 15 percQnt from an 1ndeJ:lencen.t const.:ltant·proc~ctd tst1r-He (.;.:. tM Clnadhn $~la::mfd enhancelOOnt program (a~rc 1!y and Morl ey I 1;i7). In theory.SN"1ncreases (less than 10 percent)in the harYest;~le stoc~of AlaskAA sa1mon will probab1y resu1t in no perceptible ¢~ar;e in varhblo fhhfnq costs,as an increase fn the denstty of the stc:~ir't Iny gfven "Qt.ffshe~harvest ZOMe wf1'si~p1y 'resu1t in a hi;~er c=~c~ per ~n1t effort as opposed to 10nser fishins per1ods.Larser ?rciec~~~ 1ncreccntal 1ncreases in harvesting which are anticip!t!c curi~g the 'ate 19801s Ind elr'~1990's th~ugh the proposeG ~rogra~a~e e~~!ct~c to r-au1re s~l'additions to total 1aoor.For the purposes of this study:an estimated fraction of 10 percent of the lan~ec Ya~~e ~i11 ce used fOl-estimatfng the enhancement assoc14ted average variabTe f~s~~:; cost ovctr tho 20-.Year projected 1ife of the program. C.Socia'Cost of.Fishing Effort: Total labor eost est1mates shou1d not be confused with s~~ia1 lab~~ costs Ul;Ul1iy developed for efnciency estfr.:ates of this t)'~'e (Shaffer,1977).Social labor costs would be approxi~ately eQ~!1 t: total ~csts only in a full employment econo~y.Due to cord~tic~s of pervasive unemploynent 1n many Alaskan fishing communities.r.e~e~~~ar:£ to the :ne1at1ve1y sma'1 enhance~~nt assoc1atec labor resources rec~~~:c can 1argely be expected to come from the pool of une~~loyed.Jse 0; total labor costs in this analysis will c1early result in ~r,o"ares- t1mate of variable costs of fishing. Public Costs from State Treasury: The ben,ef1t eost frameworl<demands an acco1.lntir.g of al'p~~lic ~esc ...r~;s foregone in the process of building.ope~at1~9 and a~~;r.isteri~s :~e enhancement facilities.Fublic eapftal resources fro~the st~te ~rea­ SU~included in the 1962 ex-ante ecoMomic siT.~la~ions are :a~er ~ri~a;­ fly f~the Alaska Oepartmentcrr Fish !nd G~me Six-Yea~PlanS.Ccst estimates from_that repbrt have been adjustec to 1982 doilars.;r~~~: --8--!t-shou1d be noted that s1nce we are referr~Mg to 1c~S r~~c~s~s 41'ld for'tn,purpose of this ana1j'sis al1 lor.g run COStS a.re ~;ir.; t~ated as v!r1abie. ,There are some notao1e -exceptions to this. .::. I' '..... 2.Payroll 3.Pur~h4s f"9 Co~enents of Ad~in1strat1ve Costs in State 4$Whole 1.~e9hlation COIq)Oflents of AdJ:1nhtrat1ve Costs in F.R.E.O.01vis'on•. 1.Planning and Legislation infonution 2.PI4Yroll 3.F'tJrehas1 ng 4.SlJdgQting 5.Han119~nt, -fish r:u1turt -venetie! -p.athc1og)l -personno' As d1scu~sed 1"the ~reee~1n9 sectfon t ccnvent~on~1 ~!~ef;t eost a~alj. si~ISSu=eS that the price paid"for 'abort 1ncl~d1n;publ1c 'a~o~ inputs.~presQnts tnQ full socia'cost of that labor.that is,the amount 01 othll"produetion lost if hbo\'"is shif~ed fre~sc~,,·~p.r ;a~~:ful occupation to participate in ar.y part 01 the e""a~cer.'-en-:l",.,..~;!'"~~ lCrvteh11ald.198Z).Again,since some labor resources for ccnstruct'~; Ind operAting anhancement and reha~111tat10n facilities will clearly ecce fro=un~'cyed or underemployed r~nkst to~a1 '~bor costs ~sed for the.benef1t·cQ$i·framewor~1"this analysis are s1fghtTy oyeres!i~atea. ..... Recreation!'Values From the Enhancement Pr~cr!m: The estimates of consumer surplus from recre!ti~na"y harvested s~l-~~ us.~in the 1982 economic simulations are average cons~~er sur~!~s measures from studies 1n the U.S.Pacific Nor~~~est and eritis~ Columbia.The values have been compiled by the Ca~!dia~authors J~ ....asse and Pe'terson (1977).The ang~er day v~1ues frc::"l trat st:.:y ac~~.l separate rates to two cl!ss~of salmon and trout recreatic~al c:c:r- tun1ties.The general freshwater marine and re:re~tio~al angler ~ay value 1$$15.00 per aru;1!r day for!.non-trophy species such as CCI-:C salmon.The average vai~e of $25.00 per angler day was assig~ec :0 trophy recreation!l fishing op~~rtu~1t1es fer such s:ee1es as cr.~~c~~ s.l~n and steeihead.Tc express these resul:s in ~o'i~rs ac:~stec ~cr tnfl!t1on w1th ~he 1977 Canac1:n/U.S.exen!rg!r!~!cf (51.05 Carac'~~= $1.00 U.S.)and 1915 through 19S2 Ur.1ted St!~es eor,s~~er p~i:e ir~:xes hll'..e been used to adjust these resu1ts to 1982 c!o1hrs.ii~at a'::'~st":"e~': results in an IpprOx1m~te v41ue of respectively S25.00 =e~an;'e r ~3Y ". .:'.:'::. \. .- ! - &ftd ~.OO per _ngltr dlY fer th~qtnt~al f1$~~n;o~~ortvn1t~tS a~d t~~ffshfng opportun1ti!s. Use or In IVerig'rath,r than margfnal v41~tS for ~~~'~r days·v!lue~fo~ O\lr ll,'\lltc1s f~HQ'that sh~fts in tho dQrn-lnd curve from Ch!l'\g!s 1r. ~lteh ,x~tltton$~1ch resu't f~~nhlneement.!$well as such ~tn\ll'HS.shiftini v6rfa.!)les such IS 1ne0m2 gT"tl'Wth,l)op'Jiation gro'fot~", ~tc •••111 rasult 1ft &constAnt 'ong run value rather than a d1m~n1!nin9 long run ~rs1nal Vl'yt I'the enhanc!ment-prodvced harvest 1~trt!SQ$. OtM1'''1nvt$t1g~tors sueh as C1"\Ztch1ield (1982)have us!d averag_$1.l!'Clus valwf.s fn est1~tes 01 Alaskan salmon stock recreational values from such sites as Tal4m1na River. Subsistence Vaiuation Methods: Econl~~e v~hlltiQn tne"thods for subshtence uses o~s!imo",pofnr:.to a neg"I2~te-d-."i-of resource economics.Possible l'!'lethods for ....aiuati::"i o~ ennanc~nt-produe~d food fish eatc~es range frOM t~e use of 1a~~ec v~lu'$t retail.b'ac~market,or ~o'es!le prices (McKay,1977).Fo~~r.e p~~oses of the 1982 eeono~1c simu1ations where subsistence or persorai use ha"tsts ,~T"'I expected to be !s19nific!!'It part of tne overal ~ fntf:reeptfon (grtlltar than l~),the saimon are ass{;ned a value equivalent to tht ~rginal value of a co~r.c1a11y harvested fisn.~~·s apPr04eh is nothin9 new for Alaskan subsistence value projec,:1orls !r'lC WillS \lS~in the Tazam"ina River Study (see CnJ~enfieid.1982). Interest Rate Assumot1ons: Rea'1 1nter"est rates used for d1scounting of p:..bl ic irwest:"",e:'1~S a~;:ea"t':" va~y between 2 pareent and 10 percent.Recommendations from a few economists who hlv~been interviewed on the interest rate subiect ~urin; pr~plr!t1on of this text are surnr.~r1%ed below.. 1.Dave Reaume (1981),Economic Consu1tant,J~~eau.A1aska~ -nItre are n",=er,ous articles on the subject of choice o~discClJn~ra:; that wculd take pages to summarize.Let me sum up my view of the ~atter i n t~Q cavea,ts. A.Use I rea1 fnterest rate for dfscoun:ing if the d:~1ar r.~':=~5 a~"stated in constant base year tot!ls.Use a ro~~~al interest rate if the dollars are 9~ven in r.o~~nal te~s.Tn: real 1ntersst rate equals the no~~nal rate less the ~a~e o~ inflation.to a ftrst-orcer approx1~ation.. S.Let ye~r nominal (real)discount rate be the !verac~r:-i·~' {real expected)r~te of ~eturn on new AA cor~~rate¥t=~~s ~~ the same maturity as your hatchery fnvest~nt (cr as c10se ~~ years maturity as possible).In otrer words.use al"0::::"· tunity ~cst discount ~ate tMan a socia't1~~~~eferal":~ra::. U1e of 4 so~ia'tf~e preference r!te ~s a c~u~se'o~~e~· fection in the face of an tnabi1ft,Y to ag~ee 0"i~s :e\'e~." ------,--~-----------=ow .,,,",,",.'""'''''''' 'e - - - -,.......:i-:-~..~....,,;;w,;.-::.:======:!!!Il==---~~ 'Ib'....,--'- 2.,Jh,CM.ltchf1eld.1Jnfyers1~of WUM!'!~ton,Pl""'Ofe550r of Ece~~:lcs (plrtph~s~or.d1~tus$1on with Jeff H4rt~n 'n Haren 19aJ). -t would ldvocatt the use of an 1nte~st rat!wh~ch teprese~t!a ~~st 'f~~11 opportuntty eost of 1"ve,~nt for A'Qt~a.Pro~a~ly th;swo~1d f.l1 b.~n the rt"9Q of 3S to 51.WhQn eompartng an enha~ce~!rt rt"nv~stl;iQnt wfth an alternatha .us~of ~bHc funds it is ger.eraily ~copU~'e t:lraet1'et to \l'S!an 'dertttea1 interest rate for disec·l!n:ir.g.· 'So,if yoy',..e~4r1ng ,F.R.E.c project wfth a hydro ~l!nt1 for eX4~lt.or So.'N other ~roject wh1ch used ~31 rUe for d~sco~!"Iti"'9 i~ woul d;b~acceptable to co the same for the er.hance""ent project.I- 3.Or.John Klrpcf',Econo~1cs Professor,University o~A1as,a (~ar. aphrase of personal communication ~ith Jeff HartM!n,~arch 1983): t,c. IlThel/""t are thret·primary components of di scount rates ....hi I:h a re a:;::~ce- b1e to derhirlg &valid rate for your analysis.The ra~e you use shC:J:': "f'~t an of th~se components.The first is the norna1 rtsi:.less ro!~e of intorest wbich woyld be close to the long·te~e~pecte~rate of growth in the .eQno~.This is USU4"Y regarded ~s somewhere arc~~~3~. A second is thQ risk ~remi~m d~e to uncerta1nty about inflat1o~itself. This rata depends upon the nond1vers1f1a~h ~ort1on of ~he var1~oi ~i~j in the assets returned.A third is the risk premium assoc1ate~·wit~ fishing for the just the enhancement-pro~uced fish.C!~it!'~~rket theory SU99ost~thlt this is th~risk premium.which wo~1d resu1t ~rc-a d1fferencQ in the var{ance in that portion of the return for t~'s :y;e of inYGst==nt that can b!d1vers1fied away.Data reviewed fro~sc~e A1aska fishing fleets sugqasts that this rate 15 ~bo~t S.5~.Fe" efficiency e$t1~tQs in your p~ojeets,I.wculd suggest usir.g ao,rp~i­ Ir.ately 6~1ntlT"ast rate frt the-!rta1ysfs. H~~!Y.r,for l~plfclt1ons where the enh!"~errent 1nvest~ents a~e ~~;n; e~ared-w1th-s~alternative use of resources suen as a nycro plar.~ invest:ent,it is eonvent1ona1 to use the sa~1nterest rate i~eacr !na.lys1s.This would e$peehl1y hold true where the hypothet;::~1 .&lt~~t1ve is tn so~way mutually exclusfve to the e~hance~e~t ~~C=­ ect:(s).If thlt rat.is 3S,for example.then for ccm~arati",e ~ur~oses it is vl'id to ap~'y it.". Two yery large 1nYest~~nts which the State of Alaska is e~rre~t~j involved w1t~Ire the Permanent Fund program and the pro~os!d S~s~t-; Hyd~e1ectric power project.A resolution (B3-1)adcpted by t~e ~~~s~-. ees of the Permanent Fund identifies !~arget 10ng te~rea1 ~a:e Of return of 3.0S for (Jfm Rhoces Pers.COTom.wit~Jeff Har~~a~~ay.1?:;\ their 1nveH.ments..:. A eonsfaerable body of economic assumpticns has bee~co-;iled ~:~~~e 1962 eCQncm1c analysis of the proposed Sus1tr.a ~y~ro ~roj!ct.(S~~ at;tttnm;nt 11).An e~tensiye 11,terv1ew with vadolJs econo~ists CCI'l:'..::t- eel by A1!s~.a Power Authority resu1ted in an ~~~1ic!:ior!of a 3~i:1:e"es: ratQ for the 198Z Susitna ecc~cm1c !~a1~sfs (Yc~'c 1982).Th~s,fc~ purposes of comparison.an 1$82 ec:ono~ic sim'Jl!tio~s ha'"e cee'"ce;e 1 • oped at a "e~'re.te of 1nter-ast of 3:. - -, - -- - - = Infl~tton E~oectat1on$: Th'!b-t:nefH.cost f·ra~r~of'thh a",alt:1!1«'l~'ietly asSU1"lf!S"~h!':: inflation afflcts ~~"UQS and ec~ts ~roport1o~a'1y !~d,furtr.er.t~~: Cf\Y ct'ttnses 1n "al pr1cQs and co:t:~~e1ft~tt1"9 1!'t tt~S of to/"e;r' t~ct Gn t~ntt p~s~"'t vllut.A'l ,r1eQs and costs hlve thus beer r~f;"'''esStd in constant b~s!yetr don an. Hote on E~o"omfc and 8101ogica'Interact~o!"lS: 7he jn~ent of this p1"'eced1r.;doe!..~;nt~t~cn has 'e~e~~·~uant~fy ecc·;·-·" assu~t:ion$only for the F.R.E.O.Oivh1on 1982 t!'lt'l&net~n~,ir"unti:~L While it would b.worth~hfle for the Ofv1s1on to d!~elo~a site-scecific biolog1ea'rat10nal~for assumptions used 1~each of the 20eccr.::i:·~; sfmu1at1ons,th~SG d~e~~entations are not developed at this ~at!.Tre rea~ar may,h~tv~r,find a thorou;h discussicn of potentia1 bio1cgi:a 1 interactions and uncertainties in th~198,draft of the enhance:r:e n ,;ccs ~ benef1t aodel written by Hartman and Rawson (1982). Tho 1ff.-stage surviva1s in the 1982 s1~J1at1ons,are expect~~~eig~:ec average!of the futu~and represent the 01vfs1on's most like1y eS~iT!te of th~net in~rea$e ~n a given stock wh~ch co~ld be attributed to tre enha,nee"""7nt program.Furthermr::lre,!form!.'analysis of stoc~res:'J~ces fcre-gonQ IS I rQsul t of re~Yal of broodstock for deve 1op1 r.;/'I a tche 1"')" runt.has not been CQn~uct!d.~4nce the conventional benefit cost fra=ework dt=3n~s an accounting of a11 benefits end costs a~~ conversely,an glin1 and losses in the stream,lake,oce!n !~-j fisro!'"),. these hypothetical 'O$~~!h!ve been fm~'1c1t1y rather ~h~n exol1cl:1y del'lt with in thQ analysis.On'bahTlee,SON off-ta-the-side es.ti:"'la":~s of recru!t=Qnt ind preb!b1e harvests from this type stock loss ap~e!~to be somewhere bttwttn negligib1e (where stocks are bei~~~~~~~I~~-si~es wr"ch h&vG =t Or"txeeeded esc!pement goa 1s)to sma 11 ~fro~2 ..,~~~of the unlid~stock harvest).Similarly,the present value of the ~c~e­ gene stock in ~onQm1e terms appear to be extremeiy sma11 even wher calcll1atec using a pe~tua'd1scounting of the ineo~streaM.Fc!*t~e purpose af t,h1s <lna'Ysis,it is assumed that the va ll.ie of tlies~-F:reg:)'": resourees (should they be explicitly estimated)can cer~!irly ~e exc=c~­ ed to be 'tss t.han or equai to the nonp1"'ice benefHs earr'led f.,..::-f;sre'"· man p~eyiously dfscussed in the text and therefore cancel. _._--- ----_.-------~._----------~­......""""''''''......"'''''"'f\A' ~,.:....: ." REFERENCES---- 1.AlasKa OePirtment of F~sh and G~~.wA1aska 1979 etten ~"~ Productton:C~rcfal F1sh~r1~'St't1st1cs·.Ju~ea~{19/9." Cor:Mt!"'c1!1 ."-Alaska 19BO Catch Ind Product1on:··~i~s~hQ-r~i-es~S~tat1stfcsft.Juntau.19aO. ~A'lska 1981 Cateh and Prc~uctton~ ~lshtr{.s~at1stiesft.Juneau,1981. _.Barclay.J.L.and R.W.'Morley.E$t1mltio~01 co~!rei!l f1Sh!~j benefits and associated costs for th!national 1nccm-e aceowr.t, ~pend1x 2.Canadian Oepartment o~Fisheries an:Oceans.S~1~:~1: Enhanc~nt Fro9ram.1977.. 2. ( ~., 5.Crutchfield.J.A.and G.Pontecorvo.1969.Pacific sa1~on fisheries:A study of irrational conservatfon.Johns Ho;<ins Press,Ba1t1mo~t Md.220 p. 6.t S.Langdon,O.A.Math~sen and P.~.?oe.T~~ Siolog1cal.econom1~and socfa'values of a so:key~sal~~~S·~~~­ in Bristol Bay,A1aska.A cas!stud)'of Ta%imina River.Fisl.er"es Res.Inst.U.cf Washington.Circular No.82-2,1982. .7.Oeve'o~nt Planning and Kesearch Associates,Ire.AlaS¥.3 s~,~o~ projected 196Z market conditions.Manhattan,Kansas.1932. S.OeVoret:,O.An economet~ie deman~model for Canacia~S=1~C~. Canadian Journa'of A9ri~ltura'Econom~cs.30 (~a:~h 1982): 46-60. - -- ~.Ha~n,J.t ~.Rawson."F.R.£.O.Division Enr.ance~e~t Benefit-Cos.Moael-.Alaska Department of fish an:Ga~e. Unpublished.Ancho~age.1982 • ••10.'Kre1nheder,J.O.Teal."The Alaska Ffshing Indl.:stryll.A1 ask: House Research A;eney Report 81-4,Alaska State Legislat~re. Juneau,1982. 11.Lawson,C.M.Recent a~vances in reereationa1 v!luat;o~:,:. literature search.University of Alaska.Alaska Sea Grar.~.1;32 Unpub11shed. 12.McKay.W.Evaluation~f 1ncre~ental Indian foc~fis~t~r~ff:s ~~:­ salmonfd ~nhancemEnt.-Canadian Oepart~er.~of Fishe~ies ~~:C:!~~s. SA1mol"l1d Enhancemen~i'~cgra:n.Consu1ting eco!"!c~;st.A~;!"ci:(-. 1977.Unpublished.. 13.Masse.W.O ••K.Peterson."Eva'ua~~ol"l of ir.creiel"l':31 r~:"e;':~::~3. banef1ts 'from s~lmon1d enl'1ance~ent".A;:;,!n~~.'J:S.C~r:ac:ian Oe~~r'tment of Fisheries and Cce~~s.S!I~onfd ~nhan:~~;r~P~c~~~-. Unp~bi1sned.1977. .r.:... . :iE.RH\iIlQ,0.".COmntnts on Hartln!.T'l and R!wsonls ~at<:h!ry e:Ol"~~~e co~l.Alaska Eeon~1cs.Junea~t 1981.Unpublfsned. 17.Shaffer.~.The emp10yment impacts of salmon1d !~h!~eemeMt p?"Oi)osals and the sochl eost of labour,Preliminary Draft. CI~diln Ctpartmqnt of F1sheries and Oce!~s.S!1~on1c ~nh!~ce~e~~ P~rl~(SEP)1977. - r 14. 15. 'Orth.F~Ffnlnc~c1 and economic feAsibility C~.7.in Xra~t~CM(~ "Qf'lId ~$o10:::0n $0'0;:-.0"G'J1ch Sa1mon Hateh-~"'f Fen10T11ty Stu:)'. Vll-4-~l FhhQr1~s ~~'ol'me"t Ass".1"~•.lsaO. "'r1t.P.M.Con~11et and o~,ortuntty toward!new I'~iiey for ~n4dl"P4c1fic Fisheries C~~is:1on 0"P~:1fie F1she~i!s Policy. Vanecuv.,..1901. - ._.. lS.Yould.E.P.-The Sus1tna Hydro Stu~1es".A1aska Pe-...·er AI~:M:roi:J' Anchorago.1982. ., -:: cnCO"rIn s~~'!ro~'tRZ INaANC~3!N:1!!-eoS!~~tt JaIl R.~taAn a~~~1t ~av.o~ S·25·a~ '. J!' ...... - "---=--:-:......:::~"j-•.I,·•~I . KOlt PQblte 1uv ••~=.ut plann1nSJ~neiQd\nr~f~h.r1t.davelep:en:1~vest­ .e~t 1Delude t~&~nt ef beth efficilncy .n~'~Q1:1 111UII.E!f~cienc: 1 ••u ••tn chiD aauuscrlpt are d~f!n,d as ~hQSI which are ~~a~tifia~le i~ dollars tnrou:h an accounting of national ineom..In social te~,1:is "lUJtUN:a proc!uet1C1Q tt"o:soce given level 0I/inruts or cos:I:i:"ti:~utl:::::' for ..ct".n 11"'81 o!"output",Randall(l981)-.Eq.'Jity 1ss~e.s.O~.:!':e other haael,CQae.~the=selves })ricar11y ~th dis:t'ibuticn of i~9a::s batvelc :1"=;:111 and chi nfa!.rneastf of the gov.rn~nt at:io~ot'i~··..est- .-nt.Wb11.the aciluee of eeone=ies does net atte~~:eo make nc~;a:~ve jud~n~a ~1JIUCI of fairness.it dO~1 e~loy &nu:ber cE cee~=d~. theer10G and DO(f,ls to 1:*uu~e the ehan~el in efU,=1er.,=v·An"the i:lp!cts of .p.~1fic ~.oU1"e.1:ve.t2ents and pol~eies. OUtvid.ly u••~analytical tool vh1eh yields useful 1nro~:1o~O~ public ~~.==-nt &It.~&tiv••~.sad atrictly on :e&5UreS of eff1c1er.:y 1.~euet1t-c~.e a:alya1..!a fi8harr resou=~e a~~lie&~io~s'it has cri4~cue of 4 1041 to expend ~ublic fun~:to further a na~ion's O~ acaca'.ooci&l .~~.co~o=1c cbjtc:ivea in an effec:i...e :an~er v~c~an efficient .allQc.at:i~of rucu:,ce,4CO:J.S eo:o;:ee1ng g,:c~ps.!'ha atiGl ...~~5 ..thod dillan frCIQ tr&c!1tiOUlll fot":s of gover:t::ent ':ludget1r.g in chi.::': ccuc.ut~.te.0:the re.ule.or co~sequences o!govern:en:Actl~.~Y .adler ~hc d.=;tl,.0:tho couetary resources requi:'e~.!3ertef'it-.,:cst a:alyat.t.~h.-=ph••is of ~Division's curren:an~~eve!o~~n~ econaa1e ..cbods cad i~198L to 1982 t'esulted in the develop:en:c!a~ 1u-hou••-e~~ue.r .~l&tiQn codel desi~ed to evaluate p~,11c sal==n &Cd ~rout .nh&:~CD4~t alternatives.!ssentially,the me:ho~o:~gy c.: chi.fora of 1ncr...ntal analysis is identical to the :e:hoco:c~.0: a&n1 of the .ere ta:iliar a~pl1c4tiQ~3 of be~ef1t-co!t ar.&lys~s.s~c~3S the Sua1cna Rydr=1assibility Study.Yould (LS82). Aop11cat1ons of Enhancemen~Bene!1t-Cose Analvsis Tho~8h it 11 impossible to ~ntieipate all potencial uses of e~h~~:e~:~: and r~habilitation eco~o=ie eodel.s~nce it is in the relaeivelv &3~~Y .t~IGI of d.valQp:.ut~the pr~n:~~al capabilit1e!0:t~e prese~:=o~e: ara .a f¢llc,v~: 1)rh.economic model CAn ~.u,ed for icen~ifyi~g :he ~or~~~:~~ ax11t1ng prcsra=ana the v41~e of a p=cposed 1~ves:~e~:5~:~ a.a ca~1t4l or 0~ara:1on41 bu~ge:t'eq~e3:. ,~ ... ). t . , I ..•~• ,,•. I • ~)The ~.l cau be ul.d to produe,internal eO='lt1!O~!of a.lt.,""A~1,,"a to ate!in o~t:1=1:1n:the f!e/Ji;:'\and oi)eut1c~o~ ,h~tccl ~l~~t;and in Ide~tt!y!~:the ~o,t e!fi~ie~t ea~ae1­ tYl Q1&~l f~etLlty loeation:,tne~bAt1on and re~ri~g sehecel. ,3)The rout1n_.Y1th l.f\';I\lt trOll other econc:c1c studies ha!so:e Qtt11t1 tu 1c!Cltlti!11Q~the d1tttr1but1cn of us.r ber.eHl:Ito .,..e!.f1c a.etct'l of tht 1udultry AS v.ll I.,'i:l-r&ctl 0:'\"".oSe! auf!em.ploYUlut froa d1nc:t aed 1nduc.~.curCQs. - - ~r.l Stt'Uc:ture of Mo~.ll! Curl~utlT,the enhaftca.ent eeonoc1e feasibility codel is built cu~0: tvo ...parac:a ,,'ta~'of co:puter progra~"h1eh involve ir:put 0:be t ....ee:i 2CO to 300 yar1ab1.,·!o~&given siculation.The h&t~~e!y b=oo~scoc~ d.valopae:t (R!D)ay.:«=projeets future sal~onpro~uct~on fro~a fac:llity baled O'C it.e~rt'~n.t level of pro~·..ceio~,plans fo'!'ex~a~sior .• 11fe-sta,e ~r9ival .a,u=pt1cns.&n~f1sh.ry exploi~a:1on ex~ec~atio~s. nefac111ty be:af1tco.t (ne)5y~ee:1&th~!:o:':e~!.c s1=-Jla.tic~ p:'0lraa which ~I.'harvest pred1c.:ions frO'!:a given (H!~)sl:ulH t:::-.ar.:: comb~.a the.e v1~h ee~ymic as~e1ous to genera~e p'!'ed1c:~ons fer beu.f1t &nd caat .tr.~r~sultin1 free saleon &n~/o~:~Q~: e~="A~. Th.(F3C)rc~t1~.hal .110 evolvad into t~o separate ;c:?oner.:~.T~e fira:,il a pt'ie.index =Q~.l ~ich a~justs patt nc=in~l cos:s an~ batlef1t#ta b&~.,..ar c!ollara .for ex-eo!t ana1ysi5.r~e secot".c t'~s ar. ~·&ut.0:'f~t~r.cr1autod progra=v~ieh esti~ate!p~esent value;:or a ~u::.b.t'af be:.of1t and co.t sCt'UQ alternative,for co=e:cJ.i:liJ.j clr.~ ~.cr.&ti~11 h&~.tad sal=an ot'trout vhich are directly a~~r~o~:~~le to a :1geu .~~uct=GQt projec:. Tb ..sa:er&l .cructure for the pt'esent value of the enhance'sal~e~ product1o~caka;the follov1ng for:for both ~ec:ea:ionally an:c:~er­ c1&11,harY••cad t1.h. I' I B •pr1 Iccrc=eu:41 benefits Creven~e)fro:t~e pr1vate .ector attr1~ut&ble to the er.~anceeen~ pt'oc1uced f1s~. l:cre=e~e&l·coats ft'o:the privata sector at::1:~t-. a~le to the e~hanee~ent p:"cc:.1cec!.fish (e~g.c::s:c: harvesting anc!for processing He.). c upub'. ,~ Incre:ental ?ublie coses fro=~tocucing ar.~=~~ag~~3 onnancG9J:(lnt ,ro~uced:!~sh e.g.operat~o~al cosL C~?:.~:.: coat And p:ann~ni eo,t!o~ha~ehe:y:a~=:~~s:ra:~~~~~~ ----evAlu~tio1'\, ;-. ""'"! i ..... ( \. ~ ..- " • r t 1ptt -Cpr11/Cpu~•B/C. NB •Net beneflta ~I e~~re"c~aD a d1f!e~enee : Salmon ?lshery !.ntftts and As!oeiat~4 Cose! Evalua~io~of the .!fLc1en~y of a~1~V.Ae=en:for a .~.~if1~~roj'c~ re~~i:••the &~ly.t to e3t1:ate the grolt be~.t1t~And ~ro!1 eo!:!of 1a~r.a.1as ~h.available .aleon reseurce.In thQ (T!C):odel eMe b.:.f1ea to the ~r1vat••e~to~can be eseie&eed as either ehe ir.~r&- ..ntal val~.to t~.~c~ere1al fishery or as the ine~~=e~tal va:~e :c both the proc•••1T\1·1n~usen"and the cocereia!.fishery.In tr.e firs: c •••the lro ••beuef1t to the ecc:ercial fi5he~fro:the 1nc~e:~~ta: fteb p~o4~cc1oc ia =•••ured as the ex-vessel value o~the p~o~~ce.:te :ro••coat 1.m•••urad aa the reSQu~ce.fo~egone ftac the fleet eo ca:c~ the iacrelMt1tal 'Product1ctl..In the second ca.se the gross ~e!":!!f1:t:)tne })roc •••1%1:1:u!unry 1.the C4rket value'o!",,__1ne:'~4sed ea.t:eh ,,:-!if!': vhol ••ale value.The processing costs ate ta~!n to be th!value ~f :~~ foresoue r ••ourel.required to both procls!and harvest the ~~~an:e~e~: produced e&tch. MatrY of the projal:ts a:d !acilU1es :On n!:!)!Hvl,a1on are s:~e~ult.:';:;:~ ctJrrantly product I&l:ou and t.roue highly val!.:e~by sp~rt !i$l':e:~':ler.... fce:.same facil1t1e.are tarse:ed &l~.t e~t~rely at s~ote fishe~e~. Ju.c what t!:l •••tt.enat1on be:l.ef1t!are ant vill b\!!is a ~.;'."~';"-ca~.. ~_.i ••4 in the ~oc~.utat:!.Qfl fo,:,the ~:\h4neet:!~':!e.t:e!i:CO!t "':'~e:. ~rtm&n led l&v.ou L9SZ.The acalysis cet~od ~reseneed in the tex::s includad co enly ••~.the purpose of the enhanee:en,:?:,ograc ev~l­ uI:10:. Althoulb r.c~.at1oU&1 avaluat10n p~ccedure,ean enec=~ass be~efits c:~ prosr.a othar thla tho.a ~irectly receiYe~by Alaskan !isher:en (suc~as exi.teuca valu.at1oft .n~Q9tion valu&tion ee:hni~~e!).the p't'i:ll:"; purpo ••at tb.v£luation proces,is to identify the cha~ge i:'l CC:':!;I.:r:C' lur,lu.of •s1veu recreational fishing invese:ene.The ~e~s~~~r .urplua 11 a ....ura of the saeisfactien l'l!!:o~le.enj oy f:-e::r.e ir :C:'\- .~tioft of &co=codiey a=~is base~upon vhat th~y ve~ld be ~il~~~g :~ pay for it.te th~e ca ••of our enhance=e!\~1~"J'es:::e~e:s,1:is !..'~a~~....Cv YOuld be willing to pay fc:the opportuni:y to fis~~or the ~~:re=e~~~~ 1ucr••=_in the available stock. Ala8~an !=~&ct Ana!ysis U a c!aci.1on-lUker vere only i!"1u~e~cec 1:0:.1 si:":3le ::~j ecti':e,:".~~~_.. the c.LXr.u:J.~1on ot,f~!hins i:-lca=e.ehen e1-:!ee.e~:=~:·e'-·.3.1·..:at:-'~~~':"'::~ ~o:a ••d CQ sraw ~eyo~d ber.e:it ~o,t analys!s.Hcveve~.~f e~e -~... ~..... - deelw1on-..ker is alao 1nte~est.d in formally dealing w1t~ dl.t~1butlon41 Qffccta,th~~it 11 n~e.~~~~to o~pan~tht 5~o~e o~the .to~\to 1~ct .;~Q~~at,wh1ch ~It ba d~.lt vith ••~.r.~ely f~o~ .fftc1oney e~n::1~.r~ttanl.thQ purpo,.of 11C,?~et ll~al,.,1...1 15 to'r.':e&!'..lr. chan:t'and the ~-n1tude of ch&~CQ~1~lot~l or ~.sional .~?lc>~.~t. t.bor felt'ce p4ttlctt:'4tl~T\.'real tneo1tQ cUttr1blJUat\BOd.busir.eU &!'ld ,.1ftd~.tt'1al actt~1t1 by the ••ria.of a.etors.ThouSh ~.&sut.:.~ts of .t~.ct.f~OCI •project can.ta~e ~11C:.tven at the nat10nll level.WI! :-vtll extend aft,.a1\31y.1.5 only to aSUlcents rlltv~n:to Alulu.'r'he'.:~~ uct tht })d.sary funetlon of th.IlOdel,~h.facility btneHt c"os:~~~.-- rout1~.can account for these interActions vith~n tht Alacka!'l .e,~O=~• 1 -I.'•1nd1rec:tly by 1=.c:or'porattns val~e.frO':l ext&:.-nal 1~~1=::0:.I eap!';l a of I.C.t'&tl~1l'.J.lt1p11erl relevant eo ~h.lI&l:l~n fish!.n!and p~ecesg1r.i 1~du.try.Such DOdel.take o~e of tvo for,:Q.!he first type are k~~~~ ••inp\,lt-outJNt 1:0t!el~Yhich are bue~upon a detailed aeco~n:~:'\z ~::r.e flov of lood.and ~.t¥tces at &given point in e~~e. A a.coed forao!1:pacc .!se,s=e~ts are deal:~ith in se=e ~y~es ~~ econo:etric aodols which CAy also be ~sed for pre~ic~1ns c~anses ir. emplor=ant and 1nco~f~oc a change 1n ecot\o:1c activity fr~e sc~e pri=4ry ••ctor (1c OUt'case,thi3 vould be the harvescing a~;?~eccssi~; of 8.l:Ic-=). OUt operatics .c~om.tr1c =o~il·u~ed by the D~vi!1on of !~cget !er ere DeparcDaut o~llvlnua vas ~ae~to p~oduee 4 ~ae&8e:fo~the sal=~~ indu~trrba.ad en &hypetheel_&l increase in the lal:on ha~es:c:1J perceuc over the ~4tu~ally ~~oduc&d baSI lavel.:his 1ncre=e~~al 1n~~••e r-Iultad 1~aa ineoct eult1plie~for the !eafoe~incusety 0: approxi=&taly 1.84.'The esti:aee ind~c.:et that !e~ea~~o~e a~llar c: proc:ua1c.e 1tloCo~e producad.&:\adl!itict'lAl 'incre:et'.t 0:S,"cents·~s proCu~e4 ~th.fo~ot 1~duc.d vase~eo A14skans . •nae Cocle1tue ••an Effie1.nt Return on Inves~:.n:s for an E~~~~=~~~~: Projacd Secau••r ••ourc••are limited.the under~&king of any ~~blic :nves:~~~:. be 1:tra=..port~:1on,hydro-electric po~er generat1o:1,?er:anenr::.~~~. 01:'••all:lca ec.hancacent facility \1111 d1ve-r~resou~ces fro:4l". alter=a:1ve v.e.The b.n&f1~cost concept essential:,co:?ares the Iro••benGfi:.of the pro?csed project er re$c~rce al1::a:ion with ~:l of t~.ere,.~eu.ti:.forgone by its existence.Clearly,~f t~~v~l~a of the ban.fie.of the prgpo8ed p~~j.c::e~ceQd the va~ue of the ~=r.e:i:5 101:by the ~rojectfs existence,then the p~oje:t is in soc1e:y's ;es: iaceres:,baled en a =ea5u~e of ef£i~1e~cy. As &result,a dongle or-:'series ef benefiC ecse t>atics C~e9~:'::.a:as .• ~at\lrn en inve.tcent fo~Alaskan pu~lie h!.ecl'!er'!.es eay not ~:'="':c'::.!~ =~ch !a~:U1&.~infor"Q.aticn to the decision-cake:-as 4 oroa:e:-:o:"':'::::':~: CO=;&~1!on of tha rate of ~eturn fro~public hat~~eries versus =~:~~~ rlt...rn fro:IOC'selected A14!ka:2 investl:ent a::er:u.ti-..es.'.:~:'l~5'::"::'1 policy to c!aU c!.oe=,nQ~require I :Or:l.a:''ber:e!i:cost a\"lalysis :::a:~ pu~11c axponditures.~o!sibly since ehe value of so=e ~u'l:c gcc:s 3~= :.~hnicAlly difficult :0 expre~s in benefi:-ces:ar:a:ysis,c=~,~:~~~~ vith anticipated r~turn5 fo:.-&fev no:ao~e p~b~~: I- •-.: laftst1ttnta .,t11 help ,hed U,ht on eb.efUdeney of l typ i~.l .~,l-:a~':e· aect l~Te~~D~.Pou:1bt.c~~~1~ates for c~~n~i!on vcul~b.t~~~~e!e~t pe~ftQ~t fu~tft~.~t.or ~ropoD.d t~~'t~e~t.lu~h at l~rle ~ublic h1~t'04.lQctr!c proj.ct~11\Alub..'. Pr.l1alnary ••ttDet.1 free .~hl~c.aeftt tconosle ar.alys1s IUSS.':'& •'typ1eal b4teb~rr tnve.t~n~bon,f1t COlt ~&t10 ~uld fall bety ••~& .~~~of 2t1 aud 3rt with ~typtcal ~ot~rn en 1~v.~tmoct (!-C)of ·.pp~ztc&tell 10 ctl110D dollar;oyor tho a~t1~1pAted eccno:ic lit •. Vhl1e &~~ltc1t co~.t1son of ttee 1,.~1!!=cast.vith &r.~viehou: t~~pr'Opo~.d 1:..,el':~t\t would b.requirec!to 1<!ont1fy t1'lt &It.~I:.i'''. 1n~.eDout o~portunit1••forlon.fra:othor public projecta.1t can b. d~t\.tr&t.~th&t GO.t Ix1ltin:Inh&nc~ent project.co~ar.faVO~4Ql, with aoao Izlatin;end ~ro,o ••d ~ub11e ~~cj.ct •• 11 tb1a daf1u1t1on of efficieucy 1s ofcen referred to as P&r.to..ff1ci.n~y O~Pareto-opci:ality in the national ~ense. 2/I~chi.ca••&"sereaa"reflrs to a series c~~olla~a~ounes wdl .a &A ineo:&Or'co-r strea::exten:H.ng intQ the ",asc O~fut::.;t"e for &1~.c1f1c nUcOar of yea~s. 1.Kart1UD,Jaff;Kit Rawsou I1F.&..E.D.Division E:'l~a:'l:e~el'\:.. !.~.!1t-eott Model".-Alaska.Oepart:en~of F~sr.aru:!Ca:~. U~p~b11.h.d.Anchorage,1982. 2.Rartaa~f Jaft.uFi.hery and Ec:onorc1c:Assu,=?t1ons fc:'l,e:::;E.; nc Enh.a.nce=ent and RehabllitaCiQn Si::ulat:!.ons".Alas:";'.] Depart.one of Fish and Ga:e.unpublished.Ancho~age.19~~., 4.1t&l:ul.ll,Al.ft."ll.elcut<ce EelJno:ics".C:i~Po.:;lish1r.g Ir.:.• Colu=bu.,Ohio 1981. - - 3. 5. ltrd,uhedar,Jack;David Teal.tiThe Alaska Fishing !~~us::"y". Alalka Rou ••Research Agency Report 81·4,Alaska Stat~~~;~~. -----ljcura.Junl&u.-19827---- '!auld.!r1~,.'-the .Su!l1tua Hydro S Cue1e!"•A:'uka P;jve r: Authot<1ty.Ancharage.t982. ,.,.. "....'t ----- ••5.'.1.6 ~I~'d' ~~Wp.a'ra.,Z r ...-. te ..... :!i ;~~~i :;~:~::!:;;;~::;::!~.~:i ;:;:~>;::i ~:;,~ - .~ C'.. 5. .' TMre is ftO .y1fj.n~.that the cMnook sa1men fry ~,.od\leed fl'"or.'.n,!t~o strKaS which enter Oev"C!~on suffer any del !)'ed er,,1;N t ~M 0'" acartaltt1"in their downstr-el'"-pusage tl'U"'ou;h the 1ow!r sect i Cl"'·of De"n Can,yon. 5.1.1.7 To~'~1sso'ved Gas Supersaturation plge 59/~rl.2 There is no =-nt1on in the second or thfrd reference e~te~(~~rre:t. 1974;Fr1ts_.1975)pertafning to the prese~ee of adu1t salM~~at t~e Devil Canyon rapids. 6.5.1.3 Conc1usfon page 61/parl.3., A gr,vl1ng enhancement pioject does not necessarily eq'Jate Ioii ~l-;a h.tchery program.Habitat enhancement 1$on a1teina:fve "h~c~c:~1c be COft,i c!e red.Gily11ng haecherfes h~ve 1'10 record of pro·...en feas;.. b111ty or success.t~-hour rer:orrrnendati.on that tre rej:l:::: \ refaroncts to trcut and grayHng enhancement be deleted IlS ir,a~;r"'o" ~r1It..It is clearly outside the scope of the study. ," l - 7. 8. ", "eoUI flOt~tho t~"U INd!on plgtS !.~4 and !.35 of MF&u 's J4fWU'1 1S,1M3 rev'e,Of t!'lQ ~PA'I Dran Edlibft E for Susitna '.::HTdroel.-ctrfe project (lttlChtdj rt9!r-dtng 91"&1'1n9 tu1 tyre.TraTl ==anti wert prov1dtd by FRED staff in the courSt of t?'ltir review of' Ute Exhibit E. Enhancement T.chn'~e~(E.T.) " pave ,6S7ri1 r-a-;-2 The trail f"If'!l"'!f"C'ed wu not constructed by m~T'Iers or hunters but by tMa.u~au of Rec1a~t1Qn in the late H50's in u10ch~iol"l ""'~tl':Cie ...i' CI"Yon d&a 1nvestigat1ons. 5.2.3.5 Vertical Slot S4ff1e pige 81/plra.2 If the intent 1$to equate c:cnstnJ(:tion cost~of the Russian RiYe~u·:::..• Anan Creek ffshwl.,)'s with the ·Oevil Canyon t'i sh",ay costs t then it is essential to deffne total project costs not just cont~actor paJ~e~~s. 9.5.2.3.6 F1shway Construction Costs page SO/para.1 ~ .. It is Ippro~rfate to define stoe~select10n processes and a1ter~ati~es btfore defining a recommended ·stockfng program.ft t .~ ,.... - - - (... ..;: -.. - l'• )ihlt eyt l"lt ion processes ""~'o1\~d to Iseerta i n whether'it was feufbl,to ostlblhh wtf,"f&ctltt!es It Il'Iclhn Rhtr aM POr'tl;e CrMtl Whit txperhnee does FRED have in dufgnfnq fUl'lct1o~al wtirs on creeks w1th s1,,1H&,"watershed charaettr1 s ti c!as foul".d f"the tndtln ~1Y.r and Portlge Creek dr&1nages?B~th streams co~o~'Y flood in Itason.(ndfln River connonl)'undergoes channel changes.POl'"ta;e Creek uper1enc.s flood f10ws in season and $1 ~flt f1 cant bee:l!'atef"'i a 1 (~'61r .n~cobble)mcv~nt occurs.The po1nt is whether a weir is feisib1e or needld for either $t~am.On an average escapemel"t }!aT" there Irt not enough chinook salmon ut111z1ng Indfan River and Porta;e Creet coa:b1ned ttl provfde anywhere·r:ear the 2100 fish neeced foT"a kltche~.The h1;~st reeo~nded esca~ement in these strea~$ cc.bfned was 2305 fish.The sftuation is ne~T""Y the S~l'le foro c:~",,~. salacn.Thera are 01'1 the average probably r.lore than 200 adui t -=0":, sll.cn s~wn1ng in these stre~m~annual1y,but ~robably net ~c~e tha~.... 400.-It-would be unreasonabl.~_to r.emove 200 eoho sa 1mon and ~o t e~t a rather severe impact on nAtural stock PT"'oC:uctior:.eMu:- sallie"are IYailable from the Indian River in the numbers I'\eed!~for ~ hatch,,,,egg ta~e.However,there are several other syste~s in the Sus1tna Rtver drainage .~here chum salmon donol'"stOCKS c:ulc oe cbt!ined inc1udin9 the Taikeetna and tnd1a"rivers by si~~1y se{r.in~a f...,spawning areAS.In our opinion,we do consider it reaso:,,~~1e to COMstNct a weir on either strear.l; ------~-----..,...,--_..._- ·... 10.5.2.4.2 Brood Stce~1 ,.~lOVi"N.3 .- e.:-The tndhn Rhlr In4 Partagt Creek are not ap;rrc;Jrhte sc;"rces f,:;r chinook and coho Sll~n eggsbeeJuse based on aerial and foo~5ur~eyS I eM"Ire net enough ftsh to prov1 de the n\,/mbtrs r!q1J 1"e~(O!'a !'I annul'egg tlte. PI~103/plt"l.5 It is qutstfon&b1e whether adult eapture ~nd ho1di~9 (aeil~t1es ~o~1c SUCCIssfu111 bt operated at IndiAn River and Porta;!C"ee~due .... - \r-<. floodtng ;TOb'~.Further.the only area ava11~b'e at Portage C;ee~ suiUble for I holdi"g area 15 extensively used by sport tisher-:-ei.. .. There is no ether clq){ng or ffshfng area at the Porta;e Cre~k :01'1- fluence which would serve as a substitute s~te. The -st&tenlent that ·the G1,l1kana River.a tributary of the Cc;:;;:-~r RiveT'.is an appropriate source fof"'u1mon eggs·is a CC~CllJsio"a!'"J­ stater.ent preceding a presentatior.of fact.Standard rese3 rC!"1 e ....a 1..-.-attnn procedures d{ctate an analysh or presentation of fact ~;efc"': stating a conc1usion. t· . - • • • •,, . • J :;:;~:1 ::!;i :;:J ::::~i !.I :!'!~!:;;f ••!r •::;!: : .r:;;... page lOS/para.3 \~ ..::. - - ,.•...\ .., .~.. .... 11. ,Tht 'itt that the tHM virus f,present in Gul~a"a River stocks.a~~ .. thlt thlthe SptCif1c strafn-"hU caused mortality of Coo\:Inl!t sockeye s.l=on fry in tests,mak.es the GuH::an!R~ver natch!""stcc'( source fnapproprtate in our opinion.Wt would suggest that the !wtnor hlye the FREe P4~hO'O;Y sectfcn evaluate a'ternathe sto:lc.s .fT"C~ locations such u Larson Lake,Stephen l.ali:e,and Tahchu1itr.a River, page l06/paTI.4 Stephen Like is nat Iceessi~1e by boat from TaLkeetna nor by beat f~c~ any other location. 5.%.4.]Hatch.~C01tt page '1S/parl.2 . As 1nc1f~ated'earl ie,..there are inadequate pO;lulatior:s of coh~ar-c ~hinoolt Silmon at Indian River ana Portage Cree\l:to annua11y orC'·:e the number of ftsh needed for a hatchery o?eT"ation.Additicl"=11j,i~ is questionable whether ~!1rs could be successfu'ly o~erate:;~ej~~;~ stream ~rimartly due to flooding. If wefrs were constructed at Indian Ri ....er and Portage Cree~.,'"~,.:,:,-1: 11k!it explained how sockeye salr.toM would be ~ntercep~e~,~t.tr-cs: weirs inasmuch as there w111 be no sockeye sa'r::~n ret\:T"r.ing ':.c t.,~~-= .!.'.s ..,".'k ". :~: i •~i I •i -.i it;,'t :•I I ••:",j.),~;t I :0;.'~.:..t • . •~ ..... - f'iI"I'!'!'"I I "-,- 12 • 13. ,t~t~~Tht presence of soekeye sl1man in t.he Sus~tnl Rt~e~~ainst~~ 4Qet not ~l"thtse fish will ,nttr tndian ~tver nr Port!~e Cree~!~~ therefore be &V.~llble for &h.t~htry eg9 ta~e •.. .- It WO\Ih1 be enlightening to learn how the autnors of t~!r~co!"t prepase to of'erate tndian River and l'ortage Cree~we~l"'s.~"C ,..~"'~ thetr blse C4a\P for a t'f(flve to fourteen man crew seve~~~er,:':"~:e$ downstre~~at GoT~Creek at an annual cost of on1y S25,OOO. 5.3 Biological I~lct of Introduced Salmon nn Residen~Fish pAge 120/para.2 The grtltut length Oolly Varden cnar intercepted by Su Hydro bio'c- gists .bav.Oevil CA~on w!s.20S mm.A total of ,ixteer.were ir~er. cepted.It is doubtful that"the e~i$tin9 0011y Val"'~e~char pc~wl~ti:~ would have any r-ecogn1Ub1e impact on sa'!'l~n proc:.rc:tior.a':~....e OE\'~: Canyon..• 5.1.2 Economic Factors,Assumptions.and Caieulations. page l~6/items A,C !0 There is no va1ue pr~sented f,r sport cau~~t sccke~e 0;cr.~-S~1~~~. Both species are sport caught i~t~e Susftna River drainage. TM!nUl'T'~ers presented for the potential return of cnir.:o!':.c:-::·. sor:keye,and ehu:':'I salmon are too 10w as previous1y defiMd.!r:l1ne with ·this a reealcuht10n of p=tenthl 1'Iarvest 1e ....els is requ1 rec. ,..;. ;. i - t.'-'.'" ~/ - - .- V,lul of tht hArvt\t u ~r-eStr'\t,d is incOl'lt;'uSiv~"due 'to th~ h,~eC\l"ltt clltu1tt1on 0 f "CN1 ~"t.Add't fona11y,the!'"e i s ~o I' page 128/parl.2 Thtrt is no value estlbltshed for n!tural procuctioM 10sses assc:i!!ec with the taking of ~h1noOK,coho,chum.and sockeye sal~on frc~d:~~~ syst~during egg take years.The a,sumpt1on that the f1~h use:for hltcher,y brood stock would have ~roduced nothing in tMe ~!t~ra1 environment is 1naetu~ate. ~ge 131/para.3 The An&n Crt.~aMd Russian River projects h!::!cCl'Ibir'lpti cost 1:'~t"'e rang.of 1.0 million dollars.The Devil Canyon project is f~re:~s:~~ to cost 32.0 million dollars.It is pres~mptuovs.in O~r o~in'c~.~~•_.__,4 --_.._-~ assUft!that the experiences gained by the Russian River anc Ar.:!"l Cree-, projects can be closely correlated with cost estimates of the prcc:sec Susitna River fish",!y project. 14.6.2.1 aenefit/Cost Ratio T~e cost/benefit fig~res presented shou1d be recalculated in 1 i~="1:~ standard recn.zitrMnt numbers and value of natural prO~wctio:"\1;:sses from fish ~sed from egq takes. . t::,. -15. .- - f'., We btltlvt it WQuld be beneficial to present I dfst~$s1or,~n MO~t~e enhlncKlent study telft\established tint more than 90 pe,.e.~t Of tl'\~ hatchery cTWlted run can or wi"be harvested.!t i!our conten~1e~ " that it is not nu'htiC:to assume that any higher per-centage of. hatchery produced fish than that prod'Jced by the fi shway prc;Jos::' e~ld ~e taken wtthout overharvestin9 natural po~u'ations ccr.sid~rir.g the nlture of the existing.commercial and recreational fisner-fes . •• ,. .t::."" ," ~....•1<.. - p~;.tion of 91"&yl1"9 ....SlJfftc:',nt 9rtyHngwin be plant.ed $uc:li t~c,. '~~Ir (sic)of C.tchlble gray1 tng '«'"be similar to the nurr.~e"lost.".. The fRED Division of AOF&G has been experimenting wIth gray'1n9 cult~~e for seV~rl'yeArs.first at Fire lake,then Ft.R1chal"'ds'OI'l,anc n:;:101 at CleAr HAtchery_We aroe CClfttinuing to work ~dth grayiing and ;r.te:'1~t~ dev,lel)techniques that sOt:'leday wi1 \support a grayli rig pro~uct ;or; progr~.At this t1=e'And for the forseeable future.grayling produc- .tion in A'iSkl'DJst be considered exoerim.entai.Iii brief,se ..·era 1 facta't"'S.i~c::t hatc::hery g:-ayl ~n9 production: 1.It is diffiC\J1t tc find egg sources that are sufficient in n!.,:r-:~ei, .'. Wherels sllr:cn "99 takes in.the tens of mill ions are cornon,'!o::e milHon ;rI1f1n;egg tAke ~s a major underta'dng. z. 3. T~eggs and f,ry ar~extremely small and from a CU1tUiist's starj·• point.vel")'dffficult to worK with.Grayling fry ha'tct't at 3J,a:J per pound as compared with salmon which are ten ti~es that siZe J~ emergence.Marking and therefore evaluation of survivai af:e;- stocking are not possible wftn exi,stfn~te:hnology. SUN tval from green egg to fry have gene ra 11 y been 1c'..-5: percent 4S c:o~ared to SO to 9S percent for sal~or.production. ----------_.,---- .;~....~. t - - ~f.Atl~t'to ~a~fry in hltcherie,haye ~"'I~tll vnsuce!ss:~;. thoe ob.,i~\sunh.'Idvil\ltge that c\"Iuld ~9&ined 'by r!\eHil"l) ht"9~r Fhh c:annot ~obt.l\ned until UChf'l~qVt1 art dev~'Q:eO::: Which wttl pe~'t hO'~'"9 and feed'n9 or fry.Grayling hay!b!er. sucetlsfvl1y reared tn the lo~r 48.Howtvtr,those fish hat'~at. .;-a hrver-,{te (20,000 ptr pound)and behave di fftrent ly ;T"I We intend to OVlr-e:omt these prob1ems IS we lurn more about the perfor=ance of gr-lylfng in our hatcheries.However,the idea that ar 1M"'1voclble 10$s of grayling due to habitat inundation can be CO:':":;Jer,· Sited by hatchtl'")'propagation ftlJst be Judgtd s~ec\lhtive at tnh ~oint. The development Ind operoation of spawnfng channels and the modit'ica- tians of s'oughs,that has ~en proposed &$mitigation warrants furtr.e~ discuss 1on.--- tleference the fo"owing seven excerpts from Cha.pter 3.c~':~'=O:-a f: Exhibit E docum.nt: 1 "The s1oul'lh ~abl·t·t fo th •b t't b•~11 ..r e lneu a 109 sa Im~n er.:ryes r--ay 0; enha.need through increased intergravel flow associatec with 1ers~r flows.or it may be degraded if the higher f1o~s subscar:tiai ~J alter the intergravel teml-I!l'"!ture regir:-.e or ice eOl'lditl::,'1S,.. ~ (£-3-131) 8·35 ... Atr~,~.....~t 0 ~.MEMORANDUM ,",~.:,;,:,;"~"'~J~o;";;:lI~.A,:~;~·~'~~-i State of Alaska - 3eff Rartaan III taa=1A&t!.1:'n Eco~~=1c ~~k1D&Croup l.l.t.D.n1v1~1oft.Anchorage t)apllrt::ent of rich and C4~G S\l1./!C"; 267-2240 ~.v1e~e!teono~ie Na'l:'r&t1.."•• l 'tW'O n&:-rativ ••have bjt!n prov1~ed fer yeu.r rev1e,.in tr.is ?ad'..1~l:.7;;c: first 1&~h.e.orrocted draf!:of the F1shuy a~~Ec:o:"l;)::ic As 51,;:':,:>::i -:-.:::j ~:.-: the 1ge2/83 !eQaf1t eos:S1=ulations.An earlier versi~r.Qf ~~i=~~~~: "'••subQieted to 80me 1nd1vi~uals en this dis~r:1':l\Je~c~list i:-:A;!t'il. th~draft ,,111 ~Q'"b.41.~rtbuted for c:om:e.nt to a fl.1J:!l.bet'of eC';"-.__:-.i5:" ,,1:10 have coutr1b1.ltad.to the 1%\!o:'l:lat1otl use~in the tlar:usc:rip:. ( 0,.: ., ~.,~. The .ec:onc!carratlve is an executive su=arj'of the £:Cr.O=l~~~O:".~~ 4ocw:.entat1on.It ",.e IYggenec!by P'r'e.d Jo'r-.nsoC\tha:a sho:,":S'';=~C':' ~cb aa t~ba put toat~her far a qU1~k review of hov c~e ~~~~!~:~K~. A ~py of eh.cOQPlat.cQcuce~~~:1Qn for the econocic =~ca~=he~~~~e available 1n J'll,..,_.._~ Co=:Dect.' DUtr117utloc: P"" , [ - - !\JT'~.tt Daisy lLanac "Kepah1re It.:'aano,,,.k.1 Moceriy Prace P..a".cm~.plic vF/or~ .• -. - - F•.M r ... ~- • -_..-.~_._- •• .'.. •••'.'.;.•r. .• FISH£RY ~~O ECONO~IC ASS~~PTrONS FOR 1982/1983 FRED EN~~CEMEMT AHa REHAaI~ITATION S!HUL~T!ONS 8y Jeff Hartman Alaska Department of Fish and ~ame Division of Fisheries Rehabfl1~~tfcnt Enhancement,an(1 Oevelopment {FRED} Oon Collinsworth :""m1 s s 10ner Stan Moberly Cirector 333 Raspberry Road Anchorag!,Alaska 9950Z Mareh 1983 ORArT:Not for quotation without permission of author.. » ( ,(,.,. i I ~A"I - r- I Tho altho~~ld tfko to at~now'~~tho fo"OWin9 peop'e who eo~trio~~· "vll"t-blt 1nf'oraltton to th~dc~"t:Or.OIY'e R1!4ume.Eeol"lo!'llht, 't\lUt4 ECOftOQt.,..tc:\Cr.John ~~f".Eccncmist,tJnhersity of Ahs~ai ~.Jr~n Crutehf101d.Econeo'st.Un1vers1~of Wlsh1ngtcnj Or.FrQd Jonn:ott,~~t1c1~nt Rcnource Consuitants As!oehtts;M1'".Jim Rnodu, Ec~ttt,A'~ska Trustlos for the ?e~nent Fund;and a nY~or of rovfQWQrs-i~~tho Al~sk~Oeplr~~t of Fish and G~m=stiff. Furthermore,the luthor is soiely respons1b1e for any !rrors ~~tne Inalysis. ., d r- T~\.t OF cacTtNTS ••I ,. t'.IffrRfJD:tJCTIOH ~.............•1-"••••••••••••••••.••iI ..,•,•••:II 'I 1-... ."A~EDCEM£MTS •••••••••••'_.'••••••'••'•••••~'4'••••'.'~"""i """ (." ~~.. u.·DtSCUsst~••••••••••• • ••••••••••••••••••••••••••e ..'••••••,•••••• ." .1 -. .••i.'~:-~;."~;;.',;~;I : ;••!,=.'.'".',~I ,:".'.'""",:'.'." ":.:,;!'::,:.,'.',:'.,'•.i.,:.'.'",:.::',•.•.•.~•~,I:: i ~::::::~~::.:;:: . - - I.'INTRODUCTION 11'\tM fourth ~\I~~tftr of lsaZ,a~f1 rst q\l~rter c~1983.4-fed es of enht~nt prcJQct ~1e S1~~'lt1on~~re ~2vc'oped for t~e FRED 01vh ion b:t ~"t"~OJJSQ ~OrlO1'l1 C WO~1n-g O'r01Jp.t Th~prejoet COI'IS 1s te~ '0'20 ~~c..:::af\t ~M "h~b1ltt~ttol'l hen1t1es which wt?"'/!S1/ft'Jhtf':o~iM ~1t ffiltbtltty =d-Ql (!'4;l~n and Ra",son.19-52).fA.~tr.tra' f~t~tOft to tho ~hanfe:of th1s salmon anh~nc~nt OCOMom1: AN.ly:h h lva11~b'Q fl"'tlftt the !ecnom1c Phnl'dn':Pl"'e,:reH Reeol"'t , 3-21..;3 t Ma.f"'tt::1n (1~3).. Thfs docu=ont ts I fo~'exp1anat1on of a11 c~mmon a!!um~tfons in t~e 1982 h4tchlr,y and roh:b~'itat1cn projects wh1eh Ire either e~~'ic1t1y lfsted 1n tho d;tI fo~s for eaeh project or are fmp11ed in the analy- sis.ThQ 1nttnd~audience of this paper is an adm~nistrator or o~ner dee1s1on~kQr familiar with salmon enhancernen~in the Pacific North~est and with tho oquivalent of at least one university level course in a1cro-eccnocics.As ~ny of these of top1cs are pctenti~l su~jects fer •dfssert!tion.they wi"only be eovered in brief here. II .OISCUSSION [conocic Rent: General definitions an~equat~ons for e$t~~!t;";ecor.~~ic rer~are presented in Hart:r\al'l and Rawson '(198Z).The value from any g~ven enhane~nt project is estimated fro~~~e'n~~er two in that s~udJ' TI'I!privlte .eon~1c rent ~from enhance~T'It·produced sai~ol'l 1..te,.=~t:~!C in tho coc=t~111 fishar.y is estimated to be a sum of all of tre mar9i~- 11 rQV'nu~s f~direct prfce benefits less ~~r9ina'COlts to the . c~rc{-I'ffshormn.The lM.r;ins from the cOm:TIerchl 1ndus~ry c!r-e .<fer1;'td fT"CC lliiIr1:'ct prices of saTmn ~t the exve~sel le't'e1.EC01'10:""1C ~nt C~profitl fro=racreat1onat1l harvested salmon are esti~atec by theccnsu=r s\n·p'u~of the fishing experience. C~rc11'F~$~erx Re"t: WhiT.controv.rsy exists eve?"the use of wn01 esal e versus @x ...essei VAlues.IS I measure of wil1ingnes$to pay for the 1nterned~ate good (salcen in the round),the margins fer the ec~rc1al industry ir.this '-".... l,Thl work1ng group has inc1ude~Kit Raws::::n.Jeff Ha!""tr.'!an,J~'f': Hansen and Bry~~~e1 th.12..,I -C I iup"''''.''·pro ".~ 2.Ecanemic rent is defined here as ;'p1.e~:Ii{~_ll!ate w)oere ~he ftrent~or ~ro1it is me!surable ~n r.at~c~~1 ~r.::~e :e~s o!"":r.l"":~;~~ Pareto-optimiIet1on def1n1tat1on of eff~cie~cy. :T ..:. L· - lnalysh are ~",1v.d fT"OCl!marl{et p,.1ces cf ulcnen at tl'\!fll:veSH'1e .....~~. C,~~trict1"g Q$tt=at~~of ~rgina'~YQnue to only d1rtet ~r1ce bQnQftts ~t tht QxvessQ1 1ev!',~a~k"~f~911 undQro't1~tt1ng.the eeo1'lo:liC t"Qnt to thQ ~rc1i1 1 fUh'"9 f'hHZt,iP't~tTla91'\1ttJ~!o~tr'.~s~~re't1~tQ Qqu~ls the ~r~Qt vn1uQ c'tha nonpriee b!nefit$~.!~d produetr'I curp'uta:.to the f1sho~n.cf nQn~rtet ber.ef1ts~.Tnfse ,"11U'==1 IN not il'lcludtd fn ADF'~G ft sh t1cket daU t and:the,.~fere rtO~ ~1ncl~1ft ~tch a~d 'product1cn data used for lSSZ stltcwido e(o~emic It~'.tton,~. Prie;,ASS1JICt1ons: o...nd fvnctions for sIlmon have ~eMer!lly betn de~n$trated to be highly ,llstieS ,f~tht A'a$~a Salmon Proj!:ted 1992 Mar~!t Co~dit~:rs (DP'AA.lSU).Etastie1ty vallJQs 'ror cannQd pir:k sal~rt from tnat n:..dj'. in the vatid portion Qf the d~!nd.eurv~,are respect1ve1y 13 for car.,ed p1n~sl1ccn lnd 5 for canned sock~ye salmon, Demand functions for.Canadhn.BrHish Co'u~~1a s~'::':on prc~ucts !'l!'ic been dlveloped in an independent study by C.J.OeYortz (1952)~~ic~ hive been ustd to est1mate long term marginal revenue curves fo~the Canadian Sal:lCn1d En1iali,e~f't Progra!l'l (SEF').From that st:.;dy:"j!':e fact that the price e1ast1dt'fes for both sa1:"'1ol'l i1'l g!re~!1 !"d 1ndiv1dYal species 4r"far greater than unit beees ~e11 for C!~a~!'s enhane~nt pro~ram.As supply 1nerease$in the future,any d~~;i~ p~1ce will y1.id a growth in rever.ue M • While f1"e·tunfn~price pred~ctions for la~~e increases in t~e A1as~~-­ produc~d saimon supply WQula r~uife inputs frOM !~~;ket cc-3nd ~o~e: des1;ne<f for long-term price pred1ctfons,nany aut~ors r!ve devel=~EG e$t1~tes of .~on~ic rent for both the V~'U!of !Dote n t1a'1y elfminated stoe~(Crutchfield,1982)as well as projected increases l~ stock sizlS (Orth.1981)in constant base year ~ollars.Several reviewers 01 var1cus drafts of the F.R.E.D.enhancement mo~el have ~e~nded tht us.of constant base year l~nde~values for esti~at,n;., s A nonpr1ca benefit refers to payments or goc~s rece1ve::y fish'~"t such IS bonuses.lodgings.food storage or below market interest 'cans for bOlt,etc. ...Nonaartet benef1 ts refer to the va iue of sat1s fact 10:":g~i r,ej ,:,,:~ the e~rcf&l fishing ex~er1ence in the forn of a su~plus to t~e producer over and above the nonmafxet sU~Tuses that would be ;!~~~d in the next ~st likely empJqyme~t opportur.~ty,Tno~Sh wcrt~~r.t;o~;~s. it is assumed that this nonpecun~!ry value ~s small. 1 E1l$ticity of deNrtd ts tt:~~e!"'~a1"l":.:~~ri;:1~G'.H"~·~~j.~'....~~:: by percent Change in pr'tr:e.1=0:'"Imn:l gocds.eh:5t~<:H)'is tyt::~';J~:" ~losc to unlty.Ol'"1.0.Thus,a high el~st1c1ty res~1ts i,e re~~t ..:-'.... srr.al1 price change for a given char.;e in ClJ~P:.J:(cr ~n C;tiiCeSe S~'"":., ha rYes ted)• ------_......-...._...._--- -5 ".)'=r't .,. -- - ,.,.. •nnt"ce~nt pro9~l~.conomic rent.Th!y include Cr.Jo~~~I~e~'f, ~1st.~1v'r$1~of A'~'~d.19SJ;Or.Oa~Re!~~.tee~o~istt Al4~k~Eto~tr~t~,Juneau,1981;Or.Frod Joh"10n,1n eo~!y1tatio~ w1th Or.J1~CrutehftQ'd.ResoureQ Con~u'tt~t1 A5S~c1!tes~1982.T~e ~~UO'nS of thQ~q revit.,"';t'Q"h~Vil tl~tH"fra~by the followfr'g .O'QMr~l q\I~Hf1e~t~o":. r -::The 1ncr=atntl1 'nCrtl:t fn tota'rever.ue w1th the pro~Qsed sa'~~l'I ennancQCQ"t .n'.:~htJ .n~wJtho~t the enh!nee~~t i~v!!t~ents ~hfc~ wou14 ~prod~~~~~~~~at~o~of the entire salmOn ~~d~stry t~M:~g~ US4 of ·a-pybHcb~~.:su'J1t.~s~,mo!,der.-~nd mode'.wn,~rebtb'y P'let Ctsignif1~ntl1 d1frarent trom tOtal rtY~nue est~matt!of just t~! .n~n~nt-prodveed fish from exvess!'bas!year do"ar aver!geSt if, grc:.Jth in warl d supply of'u'~n f!"'01!\SOUrC!5 ot!':!r than A·'ask!wi 11 continuo to ba s~tJ.or on the order of l~to 2t pe~year and the contribution 0'Q~h:ncad stoek~to the Alaskan salmon catch co~ti~wes to be .$::.111 (not Qxc12td1ng 25:of the Alaskan harvest).C1ear1y,if t~es! ISI~t1ons do not prove to'be reai1st1e.overest1~ates in total reve;,~e Attributed to the enhancement program in the 1982 si~ul!t~er.s wi 1l OCe\lt"'. Similarly,ether lssumptfcns such as unanticipated cu~~a~c shilts i~t-e demand curves fer sa1mon prO~'Jcts in 1nternationa1 r.l!rke~s fro:':"s'J:," sources 4S cha~ge$in consumer tastes resu'ti~~from cur~ent a~c anticipated adver-t1sing eampa1c:ns eould leac to s1g::1fica nt underest1m.ates in total revenue from e1"lhance~ent·~~cduced sal-:"o. Fer the purposes of this analysis,proje:ted p~ices for the 1932 e~· haneement ey~1t.lat1on w111 be averages of the 1979 thro:.i~n 1981 .l:'C~ir.~l prices dOVQto~td from sfte·s~ec1fic information or frc~State o~A~~s~~ catch and proe;,:ct1on stat1st1c:s (AOF&G 1981,198'2.19~'3).to ",~;l!T" lSo~rcach WIS usod to deve'op ineome strea!'l'l estimates for A1!s~~sa1r"o~ f~(Crutchfi;ld,1982). Econ02ic Rent to Processing Sector: • •4 •Neoclassic.'.ccnOl'~c theory su;;ests that if Al~ska sai~on ~!ci:er's operata I:pr1~take~in a perfectly eo~etit1ve Market,the~ecor:~ic rent fro=fncrolsad harvests wi'l be largely dissipated in r.ew 1nvGst=Qnt in processing capacity. SC:Q long-time observers of the processing i~dus~ry (fran disc~ss·c~s c~ the Fish and Wildlife Econ~~ic Va1uat1on ~orksMo~198Z.J~~e!u.A~.) havQ sU9gested that ~roeess1n9 indijstry aet1or,$are ~ne result of o1fgo~olist1e price se~rc~~ng.Two conditior.s would be necessary jf 6 An outward shift in consumer de~ar.d fc~A'as(a s31~:r.~~~:~::s, which resulted from any given !dYert1s~~g ca-~a~;r"w~~:~;~:~~~ resulte:in an increase in tota'reve~ue fo~t~e e~~~~:a~e~:~~:.=~:e: fish,could only part1a1'y be attT~~ute~:0 ~~e e~~a~cg~en:e~'oT": =-="""'"".......;;w;,,;1~t:.:,;I"t.:.OlJ:,;t:;;;:::.::$~Q:me:.j.~r~~~s~k~Q~f~,~..~~O~Ub~'~'e~c~o~u n~t~i~n~;.:.__ -,.-.<-"'-~-- ~: - ~~..~.~.-9 pa I:00 (0'11'''1-\\-\ FILEO OFf'IC r f1:'"il:r.::tCRETAR~907'-'2226 T"'.35-409 t~···f ·.1 .......,..,..Jr,'".....~~to::;'.~i =~r.I::,••0,.':".'Ol.II$¢.IO'1..._.1Il t •'\,It,......I CQAL OPERATORS AND ALASKA LEASEHOLDERS J~ -July 5,198-4 '"; 1 I.• J Dear Mr.Plumb: ~..ffi :'.-;,.'.1 :f '.1"...~~..~8~::. tf\.'-.:.q ..S=1 $.., This letter is written on behalf of the Coal operat.o;'s:;an; Alaskan Leaseholders (C.Q.A.L.),an or;anization of cotnpa~es interested in the common problems and.opportunities'a.sociated with the·development of Alaskan coal resOurces.As an associa- tion we have followed the activities ••sociated with the Susitna Hydroelectric Project with eletached interest. Mr.Kenneth Plumb,Secretary Federal Energy Re9ulatory Commission 825 North eapit~l Street,N.E I washin9ton,D.C.20426 - In 1984,with the p~lishin9 of the Kentco study and the Alasxa Power authority update,we felt it:.nec.ssary to take a more act i ve role.O\lr pos i tion chAnged beca~..of our perception that theae reports dealt unfairly with coal-baaed alternatives to the Susitna Hy~ro.lectric Project.The decision to build or not to build the Susitna project is obviously an important lonq range decisi.on for Alaska.We feel the decision should be made based on the best,mOlt objective info~mation-'-vailaDle.The draft EIS prepared by the rederal Ener9Y Requlatory Commission represents,in our opinion,one of the better evaluations we have .een. C.O.A.t..;..s pleased with the thorou9hness and objectivity of the Commi ••ion'.analysis.No one can predict the future,but our analylis of previous work leaves UI concerned that decision makers will be forced to make tough decisions b ••ed on very optimistic ••sumptions,with little knowledse of what these decisions might mean if key asaumpt:.ions turned out to have been incorrect.We fe.l the range of possible outcomes the FERC considered provide a sound baae for deciaion makin9. Perhaps our bigqest concern with the Alaska Power Authority update are the twin assumptions t.hat coal prices are directly tied to oil prices,and that eoal prices will escalate signifl- c:antly in real terms over the next SO years.C.0 .A.L.believes ----~=====~.,--- ji" ','ttt.Kenneth Plumb July 5,It'" pac;e TwO ... both of t.hese assertions to be abaolut.ely incorrect..We.w4lre encouraged t.h.~FERC also believes "there is no persuasive reason to anticipat.e that.the real costl of supplying the coal will escalat.••It (Draft EIS,paie 1-33)We feel strongly that.prices will not escalate in real terms,and that there will be suffi- cient competition for local markets wit.hin Alaska to keep prices down indefinitely,reflecting production COltS. C.O.A.L.has no specific quarrel with the rZRC 4.c18ion to base its coal alternative analysis on the costo.and environmental effects of production from the Nenena field ant!electric power generation in the Nenena area.However,members of C.O.A.L. have stated pUblicly that they would open a mine in the Beluga field solely to serve an on-site power plant..Such &deeision would and could be made with no specific t.ie-i.n to the develop- m.n~cfan expert market. Discussion.bave also been held concern.ing II.power plant fueled by reaerves from the Matanulka coal field -the one other coal field in Alaska that.hal historically produced siqnificant quan- tities of coal.In our view,plants analyzed.at those sites would have result.ed in similar impacts to those analyzed in the DEIS. As an association C.O.A.L.ha.not taken a position on the Susit- na Hydroelectric Project.:however,our analysis lupport.s the conclusion reache4 by PERC'"That.a mixed thermal-based genera- tion scenario,lupplemented with ••lec~ed non-Susitna Basin hyclropower facilitie.,would be the most effective approach to meetine;the project.ed g-eneration requirements of·the ilailbelt area."(DEIS,Paqe 5-7)The flexibility provided by this approach,coupled with it.apparent economic reasonableness, strongly recommends it.-We appreciate this opportunity to comment on the DEIS and,once again,would like to eOmllend PERC on t.he thorough and cO,mplete anlay8ia in the DEIS. Very truly yours, ,.... f ..\. OIAMONO~Al.SIIA~",.1': ~A~ R.•Stile. Pre.ident COMPANY